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Evaluating Safety Protocols: The Value of Completing Internal & External Security Assessments Jennifer Engel, Ph.D., Loyola University Chicago Courtney Greene, Academic Programs International Craig Rinker, Georgetown University Luis Reyes, Ashcroft Law Firm

Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

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Page 1: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

Evaluating Safety Protocols: The Value of Completing Internal & External Security Assessments

Jennifer Engel, Ph.D., Loyola University Chicago

Courtney Greene, Academic Programs International Craig Rinker, Georgetown University

Luis Reyes, Ashcroft Law Firm

Page 2: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

PRESENTER BIOS

•  Jennifer Engel, Ph.D: Executive Director of International Programs at Loyola University Chicago   Jennifer earned a Ph.D. in educational leadership and policy from the University of South Carolina, with an emphasis in international higher education.  Prior to her appointment at Loyola, Jennifer was the Executive Director of Global Learning at the University of South Carolina.  •  Courtney Greene: Senior Vice President of Organizational Operations at API ( a third party provider) Courtney has worked in international education since 2002 and holds a master's degree in international development studies with a concentration in international education from The George Washington University, and holds professional certification through the Forum.

•  Luis Reyes: Health and Safety Officer at API and a partner at the Ashcroft Law Firm Luis has over a decade of experience holding senior positions in the federal government. While serving under President George W. Bush, he was responsible for a legal, national security, and international affairs portfolio that included the DOJ, the DOD, the DOS, the DHS, the CIA, USAID, the Peace Corps, the FTC and the EEOC. •  Craig Rinker: Director of Global Education at Georgetown University Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20 years as a higher education professional for organizations and institutions in the U.S. and United Kingdom. Craig holds a master’s degree in higher education administration from the University of Georgia and was recently appointed to the Forum Council.

Page 3: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

BACKGROUND ON API

•  Founded in 1997

•  Operates study abroad, intern abroad, teach abroad and volunteer programs

•  Sends approximately 4,000 participants abroad each year

•  Programs designed with the intention of providing high-quality and safe

experiences facilitated by well-trained on-site directors

Page 4: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

TIMELINE OF API’S SECURITY REVIEW

April 2015: API initiates external security review through Ashcroft Law Firm

May - July 2016: Document gathering

August 2016: Completed RFI returned to Ashcroft Law Firm by API

September – October 2016: Documents review by law firm

November 2016: Process delayed by Paris attacks and aftermath

December 2015 - January 2016: Interviews with key API representatives

March 2016: Formal findings presented to API Advisory Board by Luis Reyes

April 2016 and onwards: API incorporates recommendations

Page 5: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

Project Mission and Scope

•  In 2015, at the direction of President and Executive Director, Jennifer Allen, API requested an independent assessment of the organization’s ability to protect the physical and electronic security of program participants, personnel and the organization itself.

•  API engaged The Ashcroft Law Firm to deliver analysis, findings and recommendations as to the composition and effectiveness of the organization’s overall security program.

Page 6: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

GOAL OF EXTERNAL REVIEW

Conduct a profound review of API’s existing security practices

and protocols with the intent of:

•  revealing areas for improvement;

•  obtaining formal recognition of the quality of most existing

security practices.

Page 7: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

WHO NEEDED TO BE INVOLVED

Representatives of each division, including:

Financial Services

IT Services

Student Services

Regional management team abroad

Page 8: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

PHASES OF THE ASSESSMENT

(Pre-assessment) Framing the industry: ensuring that the entity conducting the assessment has a full picture of expectations and best practices within the field of

international education

Defining the scope of the assessment (approximately 1 month): helping security

consultants get a strong feel for work and security framework of the organization through

interviews with key employees

Document gathering (approximately 3 months): compiling all necessary documents for

review by the security review team

Document review (2 months): allowing the security consultants to carefully review materials provided and formulate follow-up questions for interviews

Interviews (1 month): conducting personal meetings with key employees to fill in any

holes from the document review

Page 9: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

PHASE I: THE SCOPE OF THE ASSESSMENT

Tone at the Top & Organizational Structure  

Review of Emergency Action Plans, Policies, & Procedures

  Physical Safety of the Participants

  Physical Safety of Personnel

Review of IT and Data Security

Page 10: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

PHASE II: DOCUMENT GATHERING

Page 11: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

PHASE II (CONTINUED)

Page 12: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

PHASES OF THE ASSESSMENT

(Pre-assessment) Framing the industry: ensuring that the entity conducting the assessment has a full picture of expectations and best practices within the field of

international education

Determining the scope of the assessment (approximately 1 month): helping security

consultants get a strong feel for work and security framework of the organization through

interviews with key employees

Document gathering (approximately 3 months): compiling all necessary documents for

review by the security review team

Document review (2 months): allowing the security consultants to carefully review materials provided and formulate follow-up questions for interviews

Interviews (1 month): conducting personal meetings with key employees to fill in any

holes from the document review

Page 13: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

PHASES OF THE REVIEW (CONTINUED)

Report creation (2 months): security consultants used documents and interview

information to compile a report

Report review (1 month): API reviewed the first draft of the security report and

provided feedback to correct errors

Final report

Incorporating recommendations (ongoing)

Note: ”True” crises may intervene and affect the timeline

Page 14: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

INCORPORATING FEEDBACK

SO…You thought you were done, didn’t you?

•  Must be committed to getting right to work onincorporating recommendations.

•  If you don’t incorporate all recommendations, you should document a very persuasive rationale as to why not.

•  If you are not prepared to focus on responding to critiques, you can actually be more exposed to legal challengesthan you were prior to the assessment.

Page 15: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

CONDUCTING AN EXTERNAL/INTERNAL AUDIT

What is an external-internal audit? ●  Audit conducted by an entity within the institution but outside of your

office/unit. Why conduct an external-internal audit? ●  As a new Director/AVP/VP/SIO, provides opportunities to:

○  Get a sense of the unit(s) you will be leading: their purpose, scope of activities, liabilities and risks;

○  Identify liabilities/gaps in policies, practices, procedures and address them proactively;

○  Use outcomes to advocate for changes to policies/procedures/practices and solicit necessary resources.

●  As current/long term leader:

○  Get a fresh perspective on the work your unit(s) is doing; ○  Use outcomes to (hopefully) advocate for changes you already know

need to be made.

Page 16: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

PROFILE: THE UNIVERSITY OF SOUTH CAROLINA ●  Founded in 1801 - Comprehensive Research University ○  25,500 undergraduate students ○  8500 graduate students

●  1250 undergraduate students going abroad to study, intern, volunteer & conduct research - for credit and not-for credit (2013-14 data). ○  50+ faculty led programs ○  80+ undergraduate exchanges ○  Multiple program provider programs ○  Various graduate student programs abroad, including medical

school groups, with no way of tracking those students

●  Increasing centralization of student mobility abroad beginning in 2004-05.

Page 17: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

STRUCTURING AN EXTERNAL/INTERNAL AUDIT: THE U. OF S. CAROLINA CASE Phases similar to those followed by API.

Determining the Scope: all aspects of SAO operations; initial meetings helped teach auditors what we did as a unit; identified key areas to evaluate in more depth. Initial Information Gathering: team of auditors working with SAO staff at all levels, document review, interviews. Follow-up Meetings with Auditors: go more in depth on specific functions of the office: advising processes, program evaluation, financial processes, risk management, insurance coverage. Provide Documentation: copies of agreement templates, policies, waivers, applications, insurance policies, evaluation forms. Final Meetings: clarify discrepancies, address questions, review draft report for accuracy. Timeframe: nine months to complete the work.

Page 18: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

SAMPLE OF SA POLICY REVIEW & SELF-IDENTIFIED RECOMMENDATIONS

Page 19: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

FINAL REPORTING & RECOMMENDATIONS

Financial: ●  Recommendations for how to reconcile exchange student balances and

revenue account activity; ●  Identified improvements to cash handling procedures. Resource Support (personnel, financial): ●  Should be monitored as EA participation grew, in order to sustain services to

students. Risk Management: ●  Routine site visits to exchange and third-party programs should be

performed and documented; ●  Faculty-led study abroad programs should be reviewed and approved

similar to other EA programs; ●  Mandatory enrollment of faculty, staff and graduate students as well as

undergrads in overseas insurance; ●  Expanded waiver and disclaimer requirements.

Page 20: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

VALUE OF AN AUDITAdvocacy: ●  Scope of SAO Work: Executive Director of Audit Services able to communicate

to the institutional leadership the functions of the SAO in a way others could relate to, and in a way we could not without sounding self-serving:

“Operating the study abroad office is like operating a multi-national corporation in 65 different countries.”

●  Increased Resources: Connecting resources to risk management functions in a way that I could not without sounding self-serving; recommended funding to conduct site visits as a risk management function/due diligence.

●  Policy Creation: University had concrete rationale to implement polices that codified SAO practices and aligned university actors (Policies SAO had been wanting to implement but had faced resistance).

Documented what the SAO was doing right! ●  Found very few recommendations for change in day-to-day operations. ●  Recommendations aligned with SAO’s prior concerns ( e.g. due diligence on

program vetting, tracking and insuring all university students-- not just undergraduate, for-credit students).

Page 21: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

Emergency Management and Response at Georgetown University Craig Rinker Director, Office of Global Education

Page 22: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

Profile: Georgetown University

•  Approximately 4,000 university-related international travelers each year

•  No centralized institutional international risk manager or SIO

•  Many units sponsoring international programs - therefore, many different approaches to monitoring, assessment, communication, and response

•  Different reporting structures for emergency response and international academic programming

Page 23: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

Internal Assessment: Office of Global Education

•  OGE- over 1,000 university-related travelers each year (over 25% of all university-related travel)

•  Completion of internal assessment - identification of liabilities, gaps •  Reorganization based on expertise, staffing, structure utilizing internal resources

only •  Ongoing advocacy for centralized international risk manager and coordinated

policies and resources

Page 24: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

Changing Landscape: External Consulting and Assessment Firm

•  Acknowledgement of liabilities/gaps by senior university leadership (compliance, monitoring, etc.)

•  Announcement of hiring of RFP for external firm to deliver support and services to address Georgetown’s requirements for monitoring, support, and response services, and security consulting

•  Three firms considered •  Short time frame between announcement of RFP to decision to hire

Page 25: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

Changing Landscape: Challenges Working with External Consulting and Assessment Firm

•  Firms familiar with international and domestic security environment but not international education

•  Lack of understanding of institutional culture, commitment to safety, and structure •  Unbalanced landscape - without central strategic leadership and coordination,

significant inconsistencies in standards

Page 26: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

Changing Landscape: Assimilation of External and Internal

•  Understand roles and responsibilities (including scope of contracted deliverables) •  Compare and contrast to needs as identified by internal assessments •  Identify opportunities for utilization •  Be realistic given internal and external limitations •  Always think first about your unit’s commitment to safety

Page 27: Evaluating Safety Protocols: The Value of Completing ... · Craig oversees the Office of Global Education at GU– sending over 1,000 students abroad annually. He has spent over 20

Thank you!

Jennifer Engel [email protected]

Courtney Greene

[email protected]

Luis Reyes [email protected]

Craig Rinker

[email protected]