UConn Private Clery Audit Report

D. Stafford & Associates

University of Connecticut Clery Audit Draft Report 1

University of Connecticut Clery Act/HEOA Review

September 21, 2012

Submitted by: Dolores A. Stafford

Table of Contents

Overview

Section I: Geography/Campus Map

Section II: Local/State Police Department Statistics

Section III: Timely Warning Notice

Section IV: Distribution of Compliance Document to Current Students/Employees

Section V: Distribution of Compliance Document to Prospective Students/ Employees

Section VI. Gathering Statistics from Campus Security Authorities

Section VII: Separate Campuses

Section VIII: Daily Crime Log

Section IX: Education Programs: Security Awareness/Crime Prevention

Section X: Emergency Response/Communication

Section XI. Emergency Test (Exercise and Drill)

Section XII: Fire Safety Report and Fire Log

Section XIII: Missing Persons

Section XIV: Records Retention

Section XV: Reported Statistics (Charts)

Section XVI Audit of UCONN PD Criminal Incident Reports

Section XVII: Audit of the Office of Community Standards Records and Processes

Section XVIII: Overall Recommendations



Overview

Overall, the institution has tried to comply with many of the requirements of the Clery

Act. It is obvious that Captain Averna spends a considerable amount of time compiling

the information that needs to be published in the Annual Security and Fire Safety Report.

She was very much engaged in the audit process and was extremely helpful throughout

our time on campus. We believe that she benefited from the one-on-one training that she

received during the audit process. We were impressed with the willingness of Chief

O'Connor and her staff to implement all of the suggested recommendations that we made

throughout our time on campus. If all of the recommendations are implemented, there is

no doubt that the University of Connecticut will be a model agency in terms of

compliance with the Clery Act.

The institution has some areas of non compliance, as identified within this report. Some

are more significant issues than others, but the Department of Education focuses on the

details of compliance when they conduct Clery Act audits, so the areas of non

compliance that may appear to be minor issues are treated the same as the more serious

issues. All of the issues of non compliance can result in a fine of $27,500 per violation

and as such, all of them need to be rectified.

When we arrived, we would estimate that the institution was in the 60-70% range in

terms of being in total compliance with all of the requirements of the Clery Act. In

comparison to other institutions that we have audited, the institution made a strong good

faith effort to comply with the requirements of the Clery Act. There were some errors and

omissions, as described within this report and the report previously submitted to the

institution regarding the Annual Security and Fire Safety Report, but most of them were

caused by a lack of understanding of some of the nuances of this complex law.

We made 75 recommendations in this report to improve your process and methodology

for complying with the Clery Act/HEOA security and safety requirements. All

recommendations contained in this report are underlined.

Section I: Geography/Campus Map

The University of Connecticut Police Department (UCPD) did not have an official Clery

Map of the campus, which caused some significant errors in counting crimes as having

occurred on public property instead of correctly counting them in the on campus

geographic section of the crime statistics chart. We identified the boundaries of the core

campus and created an initial Clery map based on the information provided to me by

Captain Averna and Lt. Vargas about the ownership, control and property lines of the

institution. The current map needs to be enhanced to reflect all roads, for example

Hunting Lodge Rd. and Separatist Rd. are missing from the map. UCONN has a written

agreement with CT DOT to maintain and control the North Eagleville Rd. from Rte. 195



to Hunting Lodge Rd. They have designated that UCONN manages that road. This

written agreement needs to be filed in the Clery Administrative file.

The UCPD has a list of campus buildings that provides an specific information about

whether each building is being counted as on campus property or non campus property.

This list is helpful, as it explains the map in narrative terms. UCPD needs to obtain a new

list of campus buildings and their usage from the Real Estate Office to allow the PD to

verify the accuracy of their current list.

We reviewed the Comprehensive Sign Plan for the Control of Traffic document that

clarifies the agreement between the University of Connecticut and Connecticut State

Traffic Commission. The agreement indicates that the institution controls the majority of

streets that are immediately adjacent to or run through the campus. The three streets that

were identified (for purposes of this audit) as public streets are Storrs Road (Rt 195),

South Eagleville Road, and Gurlyville Road from Storrs to campus boundary.

The campus representatives indicated that:

the institution has non-campus properties associated with the main campus.

the campus has public streets running through or immediately adjacent to the

campus boundaries and they have been identified on the new Clery map.

the campus does not have any public parking facilities within the core campus

boundaries or immediately adjacent to campus. NOTE: The new building on Dog

Lane is scheduled to have a municipal parking facility so the institution will need

to request crime statistics for that facility and report them under the public

property statistics once the facility is operational.

the campus does not have any public parks within the core campus boundaries or

immediately adjacent to campus.

the campus does not have any public transit stations or stops within the core

campus boundaries or immediately adjacent to campus.

the campus does not any public waterways within the core campus boundaries or

immediately adjacent to campus.

The Daily campus building and the sororities in Husky Village are currently owned or

controlled by UCONN and these properties are within the core campus boundaries.

Crimes reported for those locations have been correctly captured under the on campus

and residential facilities locations in the crime statistics. There are also two student

organizations that own or control property outside of the core campus (Sigma Alpha

Epsilon and Alpha Gamma Rho) and the crime statistics for those locations were

correctly being reported under the non-campus location in the crime statistics.

UCONN does not currently have a procedure in place to automatically notify the UCPD

when the institution buys, sells or leases property.



Recommendation 1.1: Develop an approved Clery map for internal use that identifies

and clarifies the boundaries of the campus or the “core campus” for Clery purposes. The

map should clearly identify the public streets that are immediately adjacent to or running

through the campus, that are required to be captured under the Public Property category.

Recommendation 1.2: Review the final draft of the map with the General Counsel’s

Office and the UCONN Real Estate Office to ensure that all three offices are in

agreement about the accuracy of the map. In a Department of Education Audit, the

auditors have been known to interview people in those offices about the accuracy of the

map.

Recommendation 1.3: As property is bought, sold or the use changes, the UCPD should

be automatically notified by the UCONN Real Estate Office to allow that office to update

their Clery map and building list.

Recommendation 1.4: Provide the Clery Map and completed building list to the Office of

Community Standards when it is approved and anytime it is updated.

Recommendation 1.5: Compare the list of campus buildings with the newly developed

Clery map to ensure that all of the "Clery Designations" are accurate and consistent with

the map.

Section II: Local/State Police Department Statistics

The UCONN Police Department currently sends a written request for crime statistics to

the Connecticut State Police (they run the Mansfield Police Department). They receive

statistics from the State Police on an annual basis, but they have only been counting the

statistics that they receive for the two non campus sororities. They have not been

counting what is provided to them for other areas in the core campus, such as Storrs Road

(Rt 195) and South Eagleville Road.

Recommendation 2.1: Count all crimes that are reported by the State Police for all

property within the core campus that is owned or controlled by UCONN, the public

property that runs through or immediately adjacent to the core campus and any non-

campus properties associated with the institution.

Recommendation 2.2: Send a written request for crime statistics to each police

department with jurisdiction for each separate/branch campus. Each written request

should include a list the specific addresses of the locations that institution owns, leases or

controls; any public property running through or immediately adjacent to the campus

facilities (list the specific hundred blocks); and any non-campus properties associated

with each separate/branch campus.



Recommendation 2.3: Send a letter annually and/or any time there is a change in the

leadership of any of the law enforcement agencies that you request statistics from,

informing them about the timely warning notice requirement, and make a formal request

that they notify UCPD immediately if a crime is reported to them that could pose a

serious, ongoing threat to the campus community.

Recommendation 2.4: Letters/emails sent to local law enforcement and their written

responses should be maintained on file for seven years (the standard records retention

period for all Clery Act related documents). If they call you to respond verbally to the

request, obtain a written response via letter or email for your file.

Recommendation 2.5: Enhance the letter being sent to local law enforcement to clarify

the Clery crimes and the geography for the requested crime statistics. See appendix #1 for

sample language to enhance the letter.

Appendix #1—Local Law Enforcement Letter

Section III: Timely Warning Notice

The timely warning notice statement that was published in the Annual Security/Fire

Safety Report (ASR) was insufficient and recommendations for enhancing the description

of the process were included in the ASR Review that was previously submitted to UCPD.

The ASR was missing two key components, which included the circumstances for which

a warning will be issued and the individual or office responsible for issuing the warning

(who writes it and who initiates it). The timely warning email messages that we reviewed

provided the facts about the crimes that were reported, but the institution needs to make

sure that each timely warning notice contains information that would assist in the

prevention of similar crimes, thus the message should include at least one crime

prevention tip--either something you want the reader to do or not to do--in terms of

potentially preventing a similar occurrence.

In the interviews with UCONN Police staff, they indicated that the department is in the

process of developing a standard operating procedure that will govern the distribution of

timely warning notices.

Recommendation 3.1: Develop a timely warning notice protocol/standard operating

procedure. The procedure needs to start at the point of a serious crime being reported to

the UCPD. The protocol needs to address the circumstances that will trigger a warning,

who is responsible for developing the warning, who is responsible for disseminating the

warning, and the method of disseminating warnings.

Recommendation 3.2: File a copy of each timely warning notice with each incident

report that prompts an alert. This will be beneficial in the event of a future audit.

Recommendation 3.3: Maintain timely warning notices on file for seven years (the

standard records retention period for all Clery Act related documents).



Recommendation 3.4: Each timely warning notice must contain information that would

assist the community in the prevention of similar crimes. Make sure each email message

includes at least one crime prevention tip or tell them what they should or should not do.

Appendix #2—Timely Warning SOP Sample

Appendix #3—Timely Warning Publication Determination Form

Section IV: Distribution of Compliance Document to Current Students/Employees

All faculty, staff and students are required to have a University of Connecticut email

address. The campus sends a blast email each year to all students and employees to notify

the campus community of the availability of the Annual Security and Fire Safety Report.

I requested a copy of the notice that was sent to the UCONN community in the Fall of

2011 and Fall 2010. The notice included a statement of the report's availability and a

brief description of the contents. The notice did not include the exact electronic address

of the report or a statement that a paper copy will be provided upon request, as required.

Recommendation 4.1: Revise the notice to include a direct URL to the Annual Security

and Fire Safety Report (the PDF of the complete report).

Recommendation 4.2: Revise the notice to include a statement that a paper copy will be

provided upon request.

Section V: Distribution of Compliance Document to Prospective Students/Employees

I reviewed the following admissions applications/materials on the UCONN website:

Undergraduate Admissions, Freshmen

Undergraduate Admissions, Transfer

Center of Continuing Studies

Graduate Admissions

International Students

MBA and EMBA

School of Dental Medicine

School of Law

School of Medicine

School of Social Work

I did not see the required notice on any of these sites where individuals apply for

admission to various programs. The notice of availability must be provided to all

prospective students.



The notice must include a statement of the report's availability; a statement that a paper

copy will be provided upon request and how to obtain a hard copy; a brief description of

the contents; and the exact electronic address of the report.

The Clery compliance officer has not routinely reviewed the admissions materials for the

various undergraduate and graduate programs to ensure that the required notice is being

provided to prospective students. One of the hard copy admissions applications

(undergraduate) that I was provided contained a notice for prospective students, which

included a statement of the report's availability and a statement that a paper copy will be

provided upon request. It did not include a list and brief description of the contents and

the exact electronic address of the report.

Recommendation 5.1: Gather all admissions application materials to determine (verify)

whether or not the required notice is contained within those materials (in hard copy or in

the on line versions).

Recommendation 5.2: Provide the required language for the notice of availability to the

appropriate office(s) to be put on the website application for admission to each program

that has a separate and distinct application process. Request that the statement

immediately be added to any admissions materials on their websites and request that the

statement be added to the hard copy documents the next time they are printed.

Recommendation 5.3: Add a statement that provides a list and brief description of the

contents and the exact electronic address of the report to the notice of availability in the

hard copy of the Undergraduate Admissions Application.

Recommendation 5.4: Provide the required language for the notice of availability to the

Human Resources Department. Request that the statement immediately be added to the

employment application on their website and request that the statement be added to the

hard copy application, if applicable.

Recommendation 5.5: Conduct an annual audit of the admissions and employment

applications. Request all admissions materials in January of each year or print them from

the websites and review them thoroughly to verify that the required notice is included in

each application package or prospectus. I recommend the same course of action regarding

the employment application. You should flag the notice contained in each application and

maintain all of those documents in your annual administrative file in the event of a future

audit.

The required statement must include:

Notice of the report's availability

Description of the content of the report

Opportunity to request a copy.

Exact URL where report is posted



SAMPLE STATEMENT

University of Connecticut is committed to assisting all members of the community in providing for their

own safety and security. The annual security and fire safety report is available on the UCONN PD website

at (PUT DIRECT LINK TO ASR HERE).

If you would like to receive a hard copy of the Annual Security and Fire Safety Report which contains this

information, you can stop by the UCONN Police Department AT ????? or you can request that a copy be

mailed to you by calling ????.

The website and report contains information regarding campus security and personal safety including topics

such as: crime prevention, university police law enforcement authority, crime reporting policies, fire safety,

disciplinary procedures and other matters of importance related to security on campus. They also contain

information about fire statistics in UCONN Residence Halls and crime statistics for the three previous

calendar years concerning reported crimes that occurred on campus; in certain off-campus buildings or

property owned or controlled by UCONN; and on public property within, or immediately adjacent to and

accessible from the campus.

This information is required by law and is provided by The University of Connecticut Police Department.

Section VI. Gathering Statistics from Campus Security Authorities

The institution has not been gathering crime statistics from Campus Security Authorities.

The institution needs to come into compliance with this requirement as soon as possible.

This is a significant issue of non-compliance.

When determining the list of Campus Security Authorities, the institution must include

all individuals who have responsibility for student and campus activities. Include the

people in the following positions and those people who have as one of their functions the

responsibility of building relationships with students under the auspices of student and

campus activities:

Resident Assistants, Resident Directors, and Community Directors

Dean of Students Office (Leaders in Student Affairs and Housing)

Athletic Directors and Coaches (including Assistant ADs and Assistant Coaches)

Faculty or Staff Advisors to Student Organizations on Campus

Access Monitors (any professional or student staff members who monitor access

into campus buildings, including residential facilities, academic/administrative

facilities or parking facilities)

Contract Security Officers

Event Security Officers

Staff who provide safety escorts on campus (professional and student staff)

Staff in the Student Center or Student Union Building

Staff in the Student Activities Office (handling extracurricular activities)

Coordinator of Greek Affairs (or related positions)

Administrators at Branch/Satellite/Separate Campuses

Title IX Coordinator(s)



Study Abroad Administrators

A physician in a campus health center, a counselor in a campus counseling center,

or a victim advocate in a campus rape crisis center if they are identified by your

school as someone to whom crimes should be reported or if they have significant

responsibility for student and campus activities.

Recommendation 6.1: Develop a list of all campus security authorities for the institution.

Include all individuals who have responsibility for student and campus activities. Include

the people in the positions identified above or those with functions of building

relationships with students under the auspices of student and campus activities.

Recommendation 6.2: Send a letter/email in January of each year to all CSAs to request

information about crime statistics for the previous calendar year (if you wait until

October of each year, ten months will have passed since the end of the previous calendar

year). The letter/email should include information about the obligations of CSAs to

immediately report a crime so it can be assessed to determine if a timely warning notice

should be distributed to the community and include a statistics chart for them to fill out

with the letter/email that includes the Clery crime definitions

Recommendation 6.3: Send the letter/email annually (in December) to all Campus

Leaders (Deans, Directors, and Department Heads) to notify them of the definition of

Campus Security Authority and to request their assistance in identifying staff members

within their areas of responsibility who may fit the definition.

Recommendation 6.4: Train all Campus Security Authorities in their responsibilities as a

CSA. NOTE: There is an on line training system available for purchase on the D.

Stafford & Associates website. The campus can buy a training center and manage the

training and records through this system. For more information go to

www.dstaffordandassociates.com

Recommendation 6.5: Add language to the agreements governing the Contract Security

Companies used by the institution on an on-going basis or for event security (when they

come up for renewal). In the interim, add language in the renewal letter to educate the

company about the fact that their employees, when working at University of Connecticut

or UCONN events, are campus security authorities and require them to put language into

their Standard Operating Procedures that are read by the contract officers or event

security officers working at the campus.

Suggested Language for Contract Security

When XXX Contract Security Company personnel are working at the University of

Connecticut (UCONN), they are considered Campus Security Authorities by a Federal

Law, the Jeanne Clery Disclosure of Campus Security Policy and Crime Statistics Act. As

such, any employee of the company who works at any location that is owned, leased or

controlled by UCONN is required to immediately report any crime reported to him/her to

the reporting structure of the institution, which is the UCONN Police Department. The

http://www.dstaffordandassociates.com/



XXX Contract Security Company must add this requirement to the Standard Operating

Procedures that are read by the officers and supervisors who work on site on UCONN

owned, leased or controlled properties.

Recommendation 6.6: As a best practice, the Residence Hall staff (such as the Resident

Assistants) should also receive the email in the summer during their training period, so

that they are aware of their reporting responsibilities as they start their position for the

new academic year.

Appendix #4—Letter to Campus Security Authorities

Appendix #5—Crime Statistics Reporting Form that should be distributed with Appendix

#4

Section VII: Separate Campuses

The institution has been complying with the requirements for separate campuses for the

six branch campuses, which includes, Avery Point, Hartford Law, West Hartford,

Stamford, Waterbury, Torrington for which they have a separate Annual Security Report.

We conducted an assessment of the other off campus sites to determine if each of them

fits the revised definition of a separate campus, as defined in the 2011 Department of

Education Handbook. The campus has been complying with the Depot Campus

as part of the main campus in Storrs. We would recommend that the institution comply

with the Depot Campus as a separate campus, as it is not immediately contiguous to the

main campus, some classes are held there leading to a degree or other educational

credential and there are administrators on site at that location. It is clear that in the

marketing of the location, including the signage at the entrance to the campus, that the

institution considers this a "campus" and as such, at a minimum, the institution should

report separate crime statistics for that campus. The Annual Security and Fire Safety

Report (ASR) for the main campus could be identified (in an introduction) as complying

with the Main Campus and the Depot Campus. This would be the easiest way to comply

with the requirements of a separate campus for that location, as we were told all of that

the policy statements for both campuses are the same. That being said, the institution

would simply need to report the crime statistics for that location in a separate crime

statistics chart in the ASR.

Recommendation 7.1: Treat the Depot Campus as a separate campus for Clery reporting

purposes. The revised criteria of a “Separate Campus” as defined in the 2011 Clery

Act Handbook, includes locations offering a “organized program of study” and

having at minimum of one “administrator on site” working at that location. (The

Handbook states: “Administrative personnel encompass a variety of individuals who may

have some responsibility for the activities that take place at the location, for example, a

director, a building coordinator, a registrar, or a secretary”).



Recommendation 7.2: Conduct an assessment of all University of Connecticut non

campus properties to determine if any of those locations meets the definition of separate

campus under the Clery Act.

Recommendation 7.3: Include a statement in the Annual Security and Fire Safety Report

that notifies the consumer that: all policy statements included in the report pertain to both

campus locations unless otherwise stated.

Recommendation 7.4: Send a request to the administrator at each campus/site to request

that they inform everyone at their location who fits the definition of campus security

authority about their responsibility to notify UCONN Police Department if they are

notified about any crimes that occur at the site. Notify the administrator about his/her

responsibility to notify UCPD in the event that they are notified of a serious crime so

UCPD can post a timely warning notice.

Recommendation 7.5: Develop Clery map for each separate campus and a narrative list

of all UCONN buildings and property at each campus. Keep this on file and update it

annually.

Section VIII: Daily Crime Log

The UCONN Police Department maintains a daily crime log with all of the required

categories. The specific information reported to UCPD by the Office of Community

Standards and the local police agencies has not previously been added to the daily crime

log. Once the incidents are reported to UCPD, the personnel there have two business days

to add that information into the daily crime log.

We were told that the officers investigate most crimes and they are responsible for

changing the dispositions in the LEAS system when they close a case or the disposition

changes. The process that was described causes some level of concern, as this important

requirement is currently the responsibility of one of many officers who may be assigned

the responsibility to investigate a crime. This system leaves significant room for error and

the administration should test the system to see if the officers are actually updating the

dispositions within two business days as required. If not, there may be a need to

streamline the process to ensure full compliance.

Four of the six separate campuses security/police officers working on site and thus, the

institution must maintain a daily crime log at those locations. These campuses include

Avery Point, Hartford Law (West Hartford is a satellite location of Hartford Law),

Stamford, Waterbury (Torrington is a satellite location of Waterbury). There is a hand

written daily crime log maintained at each of the four police sub-stations, as required by

the law.

The UCONN police officers technically have jurisdiction in the town of Mansfield. It is

our understanding that the officers may be periodically called upon to provide mutual aid

for the local/state police agencies, but that generally the police officers do not patrol



beyond the campus borders and do not respond to calls for service outside the campus

boundaries. The UCONN Police Department should develop a standard operating

procedure or policy describing the technical jurisdiction of the officers and how they

come by that jurisdiction. The SOP should also address the institution's expectations and

limitations placed on the officers, i.e. to patrol the campus and respond to calls on the

campus property. Otherwise, any incident that the officers respond to outside the campus

boundaries (which we understand does not occur on a regular basis) must be addressed in

the daily crime log. (NOTE: This issue was raised in the ED audit of Yale University

because they "technically" have jurisdiction in the city of New Haven).

Recommendation 8.1: Develop a process to include the incidents reported directly to

Office of Community Standards in the daily crime log within two days of being received

by UCONN Police Department.

Recommendation 8.2: Develop a process to include the incidents reported directly to the

local police agencies in the daily crime log within two days of the information being

received by UCONN Police Department.

Recommendation 8.3: Develop a standard operating procedure or policy describing the

technical jurisdiction of the officers and how they come by that jurisdiction. The SOP

should also address the institution's expectations and limitations placed on the officers,

i.e. to patrol the campus and respond to calls on the campus property.

Recommendation 8.4: Develop a standard list of dispositions, define them for the

consumer and publish those on the website and place a copy in the front of the hard copy

book as part of the instructions for the crime log. If a disposition changes within 60 days

of the crime log entry, someone must be assigned to update it within 2 business days.

Recommendation 8.5: Do not use the term "Police Information" "Agency Assist" or other

generic terms under the "Nature" column in the crime log. The department must indicate

the specific criminal violation for all crime log entries.

Appendix #6: Crime Log Instruction Sample

Section IX: Education Programs: Security Awareness/Crime Prevention

The annual security report included a solid description of the crime prevention and

education programs that are presented to the campus community. The description also

provided information about the frequency of the programs, as required by law.

Section X: Emergency Response/Communication

UCONN did not address any of the other required policy statements regarding emergency

response, evacuation or immediate notification in the Annual Security and Fire Safety

Report published in 2011.



The following policy statements were missing (as outlined in the previously submitted

Report that assessed the contents of the Annual Security and Fire Safety Report):

A statement of current campus policies regarding immediate emergency response

and evacuation procedures.

A statement that the campus will immediately notify the campus community upon

the confirmation of a significant emergency or dangerous situation involving an

immediate threat to the health or safety of students or staff occurring on the

campus.

Include a list of the titles of the person(s) or organization(s) responsible for

providing a description of the process the institution will use to confirm that there

is a significant emergency or dangerous situation.


providing a description of the process the institution will use to determine the

appropriate segment or segments of the campus community to receive a

notification.


providing a description of the process the institution will use to determine the

content of the notification.


providing a description of the process the institution will use to initiate the

notification system.

If there is an immediate threat to the health or safety of students or employees

occurring on campus, describe how the institution will provide follow-up

information to the university community.

A statement that the institution will, without delay, and taking into account the

safety of the community, determine the content of the notification and initiate the

notification system, unless issuing a notification will, in the professional judgment

of responsible authorities, compromise efforts to assist a victim or to contain,

respond to, or otherwise mitigate the emergency.

Indicate procedures for disseminating emergency information to the larger

community, i.e. neighbors who live near the campus, parents, etc.

Publicize the procedures to test emergency response and evacuation procedures in

conjunction with at least one test on an annual basis.

The UCONN Police Department is in the process of developing a Standard Operating

Procedure for Emergency (Immediate) Notification of the community in the event of an



incident that poses an immediate threat to the health and safety of the UCONN

community.

Recommendation 10.1: Address all of the required policy statements identified above in

the 2012 version of the Annual Security and Fire Safety Report.

Recommendation 10.2: Develop a Emergency (Immediate) Notification protocol/standard

operating procedure. The procedure needs to start at the point of an immediate threat

being reported to UCPD and needs to include the circumstances that will trigger a

message being sent to the community, who is responsible for developing the message,

and who is responsible for sending the message. The protocol should also include a

process about follow-up messages and how follow-up information will be distributed to

the community.

Recommendation 10.3: Add all of the required policy statements to the Emergency

(Immediate) Notification Standard Operating Procedure that were added to the Annual

Security and Fire Safety Report to get the institution into compliance with the

requirements of the law.

Section XI: Emergency Test (Exercise and Drill)

The University of Connecticut is not in compliance with the requirement to conduct at

least one test of the emergency response and evacuation procedures each year. I found no

evidence that the institution has conducted a test that would meet the HEOA guidelines,

since the requirement went into effect in 2008. A required objective for the annual

exercise portion of the test must include addressing emergency response and evacuation

on a campus-wide scale. This means the institution must discuss how they would

evacuate the campus if that course of action was deemed necessary (you are not required

to actually evacuate the campus).

NOTE: A Test is defined by the HEOA as regularly scheduled drills, exercises, and

appropriate follow-through activities, designed for assessment and evaluation of

emergency plans and capabilities. A “drill” is defined as an activity that tests a single

procedural operation (e.g., a test of initiating a cell phone alert system or a test of campus

security personnel conducting a campus lockdown). An “exercise” is defined as a test

involving coordination of efforts (e.g., a test of the coordination of campus administrators

who oversee key units and first responders including police, firefighters, and emergency

medical technicians). Exercises are defined as tabletop, functional or full scale (live)

exercises designed to evaluate the emergency response plans of the institution. The

institution must complete a drill and exercise on an annual basis to meet the requirements

of completing a "test" per HEOA.

UCONN has not met the requirement of publicizing the emergency response and

evacuation procedures in conjunction with at least one test per year (a test is defined as an

exercise and a drill-which must be conducted in close proximity to each other at least

once a year to meet this requirement). This publication must be distributed to the



UCONN community at least once each calendar year immediately following the

completion of all components of the test.

Recommendation11.1: Conduct a test of the emergency response and evacuation

procedures on an annual basis. As part of the test, the institution must conduct an exercise

and drill). (NOTE: A Test is defined as regularly scheduled drills, exercises, and

appropriate follow-through activities, designed for assessment and evaluation of

emergency plans and capabilities. “Drill” is defined as an activity that tests a single

procedural operation (e.g., a test of initiating a cell phone alert system or a test of

campus security personnel conducting a campus lockdown). “Exercise” is defined as a

test involving coordination of efforts (e.g., a test of the coordination of campus

administrators who oversee key units and first responders, including police, firefighters,

and emergency medical technicians). They must complete both as part of the

requirement to conduct a test.

Recommendation 11.2: Conduct an exercise (tabletop, functional or full scale/live

exercise) including at least one representative from each of the key units on campus to

test the UCONN emergency response and evacuation procedures on an annual basis.

The key units include, but are not limited to: UCPD, Housing, Dean of Students, External

Relations, Facilities Management, Risk Management, Environmental Health & Safety,

Information Technology, Human Resources, and Academic Affairs.

Recommendation 11.3: Invite the local police department, fire department and emergency

medical services department to participate in the exercise (required). If any of these

departments do not attend the exercise, document your efforts to invite them to

participate in the after action report.

Recommendation 11.4: Conduct a drill in conjunction with the annual exercise.

Recommendation 11.5: Develop a plan to publicize the emergency response and

evacuation procedures in conjunction with at least one test per calendar year. The

institution is required to publicize the date, time, whether the test was announced or

unannounced and a summary of the UCONN emergency response and evacuation

procedures. This information must be publicized throughout the UCONN community.

Recommendation 11.6: Maintain a list of all “tests” conducted by the institution starting

in 2009. This should include all drills and exercises. Minimally, the list should

include, date, time, location, whether it was announced or unannounced, and a brief

description of the drill or exercise. The list should be maintained by the Clery

Compliance Officer and should be filed in the annual compliance file.

Recommendation 11.7: Address emergency response and evacuation on a campus-wide

scale following both portions of the annual “Clery” test. “Campus-wide” scale means

that exercise must address your plan for evacuating all of your campus buildings.



Section XII: Fire Safety Report and Fire Log

The institution has published the Annual Security Report and the Fire Safety Report as

one document, which is an acceptable practice. If they are published together, the

institution is required to call the document the Annual Security and Fire Safety Report,

but it was called the "United States Crime Awareness and Security Act" which is not in

compliance with this requirement.

UCONN provided a general description of the fire safety systems in the Report, but that

general description does not meet the requirements of the law. The institution is required

to list each residential facility and to provide a description of each fire safety system. The

fire safety systems in the Celerone Apartments were not included and need to be added to

the 2012 report.

UCONN provided some general fire statistics for the 2011 Annual Security and Fire

Safety Report, but those general statistics do not meet the requirements of the law. The

institution is required to list each residential facility (include the Celerone Apartments)

and publish specific fire statistics for each facility.

Currently, UCONN is maintaining a fire log that includes all fires. The fire log contains

four categories, including Date, Nature of Fire, Time and Location. The log needs to be

revised to include: Date Reported, Nature of Fire, Date and Time Occurred and Location.

There were several other missing policy statements in the Fire Safety Report and they

were outlined in the previously submitted Report that assessed the contents of the Annual

Security and Fire Safety Report.

Recommendation12.1: Change the name of the report to the Annual Security and Fire

Safety Report.

Recommendation 12.2: Develop a Fire Statistics chart that meets all of the requirements

of the law. List each residential facility by name and address.

Recommendation 12.3: The Annual Security and Fire Safety Report should describe the

fire safety system in each of your on-campus student housing facilities.

Recommendation 12.4: Revise the Fire Log to include the categories of date reported

and the date and time occurred.

Section XIII: Missing Persons

The missing person section of the Annual Security Report was missing only one "missing

person" policy statement, which involves notifying local law enforcement within 24

hours when the institution determines that a student is missing. The institution is

obligated to actively offer an opportunity for all students living in residential facilities to

provide a missing person contact to the institution at least once a year.



Recommendation 13.1: Notify the residential students of the option to provide the

institution with a Missing Person Contact on an annual basis regardless of whether they

chose to register a contact the previous year, as required by law.

Section XIV: Records Retention

It appears that most records relating to the Clery Act/HEOA compliance were being

maintained for seven years, but the institution needs to ensure that all records are being

maintained as required.

Recommendation 14.1: Maintain all records pertaining to the Clery Act/HEOA

security/safety provisions for seven (7) years. Develop an institutional records retention

policy regarding all of the documents that should be maintained on file for all offices

managing/ maintaining Clery Act records.

Section XV: Reported Statistics (Charts)

The Forcible Sexual Assault category in the crime statistics chart should be changed to

Forcible Sex Offenses.

The Non Forcible Sexual Assault category in the crime statistics chart should be changed

to Non Forcible Sex Offenses.

The Hate Crime statistics documentation from 2010 showed that Captain Averna had

eight hate crimes documented, but only six were reported in the annual security report

statistics. The Clery Act requires the institution to conduct an investigation regarding any

incidents that could be bias related. The UCPD did not complete an investigation

regarding the eight incidents that were originally identified by Captain Averna.

Recommendation 15.1: Conduct an investigation and document the results of the

investigation for any incident that is potentially bias related.

Section XVI: Audit of UCONN PD Criminal Incident Reports

Captain Rhoda Averna, Lieutenant Magdalena Vargas and D. Stafford & Associates staff

Lindi Swope and Deb Pettit reviewed all of the University of Connecticut Police

Department (UCONN PD) incident reports involving reported Clery reportable criminal

incidents and all larceny and simple assault reports for 2010. This review involved

reading between 300-400 reports to verify the facts and properly classify and count the

incidents using Uniformed Crime Reporting (UCR) definitions and guidelines.

Kim Hill (Assistant Director of Community Standards), Cathy Cocks (Director of

Community Standards), Elsie Gonzalez (Assistant Director of Residence Education), and

D. Stafford & Associates staff Lindi Swope and Dolores Stafford also reviewed more

than 700 judicial referral records for all violations, including liquor, drug and weapons.



The records regarding referrals were reviewed in the Community Standards Office and

recommendations regarding those records will be listed in Section XVII of this report.

This information about the crime statistics assumes that all of the required reports were

pulled for us to complete the review.

The original statistics for 2010 were reported as:

On Campus Non Campus Public Residential

Property

Murder/Non-Negligent

Manslaughter 0 0 1 0

Negligent Manslaughter 0 0 0 0

Forcible Sex Offenses 9 0 1 8

Non Forcible Sex Off 0 0 0 0

Robbery 0 0 3 0

Aggravated Assault 0 0 2 0

Burglary 23 0 0 16

Motor Vehicle Theft 0 0 1 0

Arson 4 0 0 4

Larceny 0 0 0 0

Liquor Law Arrests 0 0 57 0

Drug Law Arrests 47 0 107 42

Illegal Weapons Arrests 0 0 9 0

Liquor Law Referrals 714 0 75 686

Drug Law Referrals 3 0 0 2

Illegal Weapons Referrals 0 0 1 0



The statistics for 2010 should have been reported as:


Property

Murder/Non-Negligent

Manslaughter 0 0 0 (-1) 0

Negligent Manslaughter 0 0 0 0

Forcible Sex Offenses 12 (+3) 0 0 (-1) 11 (+3)

Non Forcible Sex Off 0 0 0 0

Robbery 2 (+2) 0 0 (-3) 0

Aggravated Assault 3 (+3) 0 0 (-2) 0

Burglary 26 (+3) 0 0 15 (-1)

Motor Vehicle Theft 1 (+1) 0 0 (-1) 0

Arson 5 (+1) 0 0 4

Liquor Law Arrests 47 (+47) 0 3 (-54) 0

Drug Law Arrests 135 (+88) 0 17 (-90) 40 (-2)

Illegal Weapons Arrests 7 (+7) 0 0 (-9) 0

Liquor Law Referrals 575 (-139) 1 (+1) 0 (-75) 574 (-112)

Drug Law Referrals 88 (+85) 0 0 63 (+61)

Illegal Weapons Referrals 0 0 0 (-1) 0

** Number with a plus (+) or minus (-) sign is the difference between the statistics that were originally

reported and the statistics as they should have been reported based on the what was found during the audit.



The current process for reviewing reports and collecting information for the crime

statistics is as follows: Captain Averna goes through the records system and conducts a

search on all Clery reportable categories. She reviews the arrest log for drug, liquor and

weapons. The LEAS system does not consider a citation as an arrest, so Captain Averna

looks up the citations to count them as arrests.

For drug, liquor and weapons violations--the officer can write a report and refer the

report to the Office of Community Standards. They also have a system they call the

"buck slip" where an officer can document an incident and refer it to the Office of

Community Standards without writing an incident report in the LEAS system. They

recently developed a new buck slip form that captures additional information including

the CAD number. If an officer completes an agency referral, the officer may not write a

report for several days or the report may not get approved in a timely manner. Lt. Vargas

periodically (at least once a month) runs a report that captures all of the disposition codes

under "agency referrals" and she sends that report to the Office of Community Standards.

The current system of UCPD staff sending referrals to OCS "at least once a month" is

causing significant challenges in the student conduct process. there are times where

students are being charged with violations of the code of conduct weeks after the incident

occurred because of the delay in OCS receiving the reports from UCPD. There are times

that OCS receives an initial report within a day or so from the residence hall staff and

they move forward and process the case. They then receive a report about the same case

from OCPD weeks later, and the PD report often has additional important details that

were not known immediately to OCS and sometimes, the conduct process has already

been concluded and the sanctions have been issued to the student.

Recommendation 16.1: Develop a more timely system for distribution of reports

involving student violations of the law or violations of the code of conduct to the Office

of Community Standards to allow them to process cases in a more timely and thorough

manner.

There are some common practices that are delaying the completion of reports and the

forwarding of that information to the Office of Community Standards. Officers do not

always write all of their reports before leaving the shift for the day. Sometimes there is a

delay in the reports being approved. The chain of command for approving a report is:

Sergeant, Lieutenant, Captain. The disposition codes are not always being entered

correctly--for example, the narrative of the report indicates that the incident was referred

to the Office of Community Standards but the disposition says that case is closed. The

department should educate the officers and supervisors who review reports on the correct

usage of the disposition codes.

Recommendation 16.2: Review the current practices for writing reports for liquor, drug

and weapons violations. There are questions the UCPD administration needs to ask to

assess whether changes need to be made in the practice of documenting incidents. Is the

buck slip process effective? Failing to put all incidents in LEAS, even the incidents that

result in a referral to the Office of Community Standards, then means that information is



not searchable like the rest of the reports. Why does a different standards exist? Is there a

good reason?

The University of Connecticut Police Department currently uses LEAS (Law Enforcement

Administrative System) report management system. This system is difficult to query

report information to collect data for Clery compliance work. Listed below are some of

the specific drawbacks of this system.

Report Module

The report functions are not flexible to:

Create reports to track Clery crime

Create a comprehensive audit trail

Search by different values other than date and time

Citation Module

It doesn’t allow searches by the charges

Citation Search function doesn’t work

There isn’t an area to search by incident number

There is no link between the citation module CAD remarks and incident modules,

the user must go to each area independently.

The system is not currently capable of counting the Clery statistics. The current system of

counting Clery statistics is a combination of the system and the user.

We found various errors in what was originally reported in the 2010 statistics such as:

LARCENY- Ex. Case #10-3786: A CAD entry was completed, no report was

done to collect all of the elements of the crime to ascertain whether or not the

report may meet the criteria of a burglary. The CAD entry only states that the

victim reported their cell phone stolen, however no details of the nature of the

theft (location).

LARCENY- Ex. Case #10-7529: The theft of an instrument from a locker within

a storage closet. The report does not state whether or not the storage room is

locked or unlocked which is necessary information to properly classify the

incident from a UCR perspective.

BURGLARY- Ex. Case 10-9736: This incident should have been counted as two

burglary offenses since it occurred in a residential suite where there was unlawful

entry of the suite area AND the bedroom, thus both need to be counted.

LIQUOR LAW ARRESTS--Challenges:

o Liquor law infractions do not get police reports generated in LEAS, but do

get a CAD entry.

o Liquor Arrests (Infractions) (Administrative Disposition 03)-- An

infraction is issued to the subject(s). The officer types a brief summary of

events on the back of the infraction. In LEAS, a CAD entry is generated.



The infraction is entered into the Citation module and other involved

parties are entered into the Name Field of the CAD entry. No LEAS police

report is generated, the information captured on the back of the infraction

is considered the report. *The process for any other arrests in combination

with Liquor would result in a LEAS report.

o Liquor Referral (Administrative Disposition 02)--A CAD Entry is

generated, no LEAS police report generated when no enforcement needs

exist. (These are potential judicial referrals).

o Ex 10-18919: This CAD entry only includes names and has no typed

information regarding the circumstances. Lt. Vargas stated this case is

most likely involving students over 21 and therefore no further

information was provided. It is recommended that information is typed

into the CAD entry so an auditor would understand this entry.

o Referrals & Arrests (Infractions) (Administrative Disposition 01)-- A

written report is generated based on the complexity of the incident. It is

possible that infractions and referrals may exist in these reports.

o Assessment process by PD for Liquor Referrals: There is a Case

Disposition box which must be checked on every report before they are

fully reviewed. Sergeants, Lieutenants & Captains are all a part of this

review process. The Case Disposition is a part of the decision making

process to forward reports to the Office of Community Standards as well

as assessing the “Call type” aka crime classification and if it is Clery

reportable, it is referred. The Case Management Module is what alerts the

assessment process for the review and when is finished, it is marked

“Checked” in the system. The “Agency Referral” box is checked which

triggers UCPD to send the reports to Office of Community Standards.

LOCAL LAW ENFORCEMENT STATISTICS - Connecticut State police

statistics were originally not counted due to a misunderstanding of Clery

Geographic requirements. There were two countable burglary incidents reported

to CSP which should have been counted. 10609190 & 1074828.

ASSAULT- Generally, injuries suffered from assaults were not usually described

and when persons went to the hospital, no one followed up on the extent of the

injuries.

o Ex. Case 10-25689: A victim was punched by several people. He was

found bleeding from face and head and went to hospital. No follow up on

the injuries. The follow-up is necessary in these cases to determine

whether a case should be counted as aggravated assault or simple assault.

o Ex. Case 10-9449: A victim was attacked by 10 people hit in head with

beer bottle and found with deep laceration to leg. No follow up on leg

injury. We changed this from simple to aggravated assault.

o Ex. Case 10- 9183: An incident was classified as a simple assault that

involved a knife being used to cut victim. We changed this from simple to

aggravated assault.

UNFOUNDED CASES- The PD does not currently have a way to check for

unfounded cases. They manually looked up the sexual assault cases and they



found that Case 10-13054 was unfounded. They did not look up any of the other

cases so there may be other incidents that we reviewed that were unfounded.

DATE OF REPORT- The date reported is sometimes the date the officer puts

the report into the computer or date the incident occurred rather than the day the

police take the report. Ex. SA 10-4481 had 3/2/10 and is 3/1/10 and SA10-9492

has 4/24/10 and is actually 4/30/10. A motor vehicle theft was reported with a

date of 11/10/2010, which is the date it occurred when it was reported to police on

11/11/2010.

ARSON-Ex. Case 10-10261. Fire occurred on 5/5/10 outside of the Celeron

dumpster. The Mansfield Fire Department responded. CUPD did not get the

investigative report to determine whether or not the incident should be counted as

arson. UCPD needs to verify that the fire department investigates any fire that is

not immediately known to be accidental or the UCPD needs to conduct the

investigation. The institution is required by the Clery Act to conduct an

investigation, so if the fire department does not do it, the institution must have a

process in place to conduct the investigation.

Recommendation 16.3: UCPD needs to be able to assess whether or not subjects

involved are current students. There needs to be a system in place to confirm

involved parties status especially for liquor, drug and weapon law offenses.

Currently, LEAS does not capture this information.

Combining Cases: There is a pattern regarding officers combining cases that should not

be combined and separating cases that should be considered one case.

Ex. Case 10-4351: Male in a residence hall at 0513 hours yelling on phone told to

quiet down or be arrested. Police left and at 0614 hours encounter same subject

outside residence hall yelling so they arrest him for breach of peace and

possession of drugs. This should have been written as two separate cases due to

the separation in time and place. Ex Cases 10-9025 and 10-9027: There was no

separation in time or place. The officer arrested one person for drugs in 10-9025

and one person for alcohol and one for drugs in 10-9027. These two cases could

have been written as the same report.

Ex. Case 10-26813: In a traffic stop for drugs, officers found a UCONN ID card

not belonging to anyone in the car. The officer later goes to room of the person

the ID belongs to, searches the room and finds roach and wooden box with

Marijuana residue. This should have been written as two cases due to separation

in time and place.

Recommendation 16.4: Train the officers in when to complete a separate report and when

to combine reports. They need to understand that the UCR concept regarding counting

crimes revolves around a separation in time and place.

Errors in the reported location of the incident (which causes inaccuracies in reporting the

statistics in one of the 4 required geographical locations):



Officers often times use the Police Department's building address when taking

reports in the office instead of using the location where the incident occurred.

This creates incorrect geographic statistics for Clery reporting requirements.

Incident reports need to reflect the specific building location of an incident. For

example, North Campus is sometimes used on reports as the location, but North

Campus contains approximately 12 different dorms each with a specific dorm

name (EX. 10-21702).

All non campus locations are not currently being captured (ex. Lee Farm in

Coventry, CT) and off site facility usage assessments need to be made to know if

these locations may or may not be Clery reportable.

Incident locations need to be specified, often times incidents occurred outside a

building but the location was listed having occurred in the building.

All weapons violations were counted as public property and they were all on

campus.

In general, the location of incidents the officers use is a street address near an

incident or address of an entire residential housing unit. These locations need to

have building names and more specific locations so the on-campus, off campus,

and residential areas can be accurately recorded. Often times the officers will

record an incident as a building or residential address when the offense is really

occurring outside of the building.

Recommendation 16.5: Do not use the Police Department address as the location of an

incident unless the crime occurs in the Police Department (not likely).

Recommendation 16.6: Do not use a general location of North Campus when the incident

occurs in a specific building. The building name and/or address should be used whenever

possible.

Recommendation 16.7: Do not use the name or address of the closest building as the

location for an incident report for incidents that occur outside. If an incident occurs on a

street, use the street name. If the incident occurs in an outside area that has a name, use

that name. If an incident occurs in an outside area that does not have a name, indicate that

it happened outside and pick a landmark to provide a sense of where it occurred.

The UCPD did not have an audit trial that was adequate and that meets all of the

requirements outlined by the Department of Education Auditors (as currently being

requested when the Department of Education notifies institutions of a scheduled audit)

for maintaining detailed information about the crime statistics being counted for Clery

Act purposes. We created a 2010 audit trail that identifies all of the required information

for each crime that needs to be reported. That system was used when we conducted the

audit of 2010 Incident Reports.

Recommendation 16.8: This system should be continued in the future to assist with

auditing of records and verifying the crime statistics at the end of each year.



An excel spreadsheet exists from the Registrar’s Office and is often times inaccurate

which makes it challenging for the UCPD to determine whether or not they are dealing

with students or non students. The UCPD officers need to verify and document the ages

of the students who are listed in the incident reports, this is particularly important in cases

involving liquor violations, as Captain Averna needs to determine whether or not those

incidents should be documented as potential liquor law referrals.

Recommendation 16.9: Require the officers to list the date of birth of any subject

involved in an incident report involving alcohol (at a minimum).

Recommendation 16.10: There are several issues that need to be addressed through

additional training and education of the officers and supervisors in the department:

-The officers need to gather more information for incident reports classified under

the larceny and burglary categories. They need to ask questions such as: Was the

room/facility locked? Who secured the room/building, and when (date and time)?

When is the last time the victim saw the property? When did victim notice the

property missing?

-The officers need to describe any injuries that a person received during an assault

and if there were any weapons used during the assault.

-The officers need to clearly indicate if a weapon is used in an assault. If a

weapon was not used, they should indicate any and all injuries in the incident

report.

-In incident reports that involve an arrest, the officers need to summarize in the

narrative who was arrested and for what specific offenses.

-The officers need to identify the specific hundred block or landmark when

reporting incidents that occur on public streets that run through or border the

campus.

The institution should develop a consistent practice and document that practice in the

Clery Compliance SOP regarding generally, how Clery crimes are counted.

Recommendation (for SOP language) 16.11: Clery crimes are typically counted where

the crime or violation occurred or was witnessed by the officer, except in stances of

traffic stops, as described below.

The institution should develop a consistent practice and document that practice in the

Clery Compliance SOP regarding how Clery crimes are counted involving traffic stops

(Ex. Case 10-3657). If the officer observes a traffic violation, and a subsequent Clery

violation is identified once the vehicle is stopped, is the crime being counted where the

traffic violation occurred or where the traffic stop was made by the officer?

Recommendation (for SOP language) 16.12: If the officer observes traffic violation on a

public street within the core campus (i.e. “on campus” property) and follows the person

outside the core campus (i.e. off campus) and he/she then identifies a drug law violation,

the incident should be counted where the car was stopped and the Clery violation was



observed. Therefore, this incident would be an off campus drug law violation, which

would not be counted in your Clery statistics. In the converse, if the officer observes a

traffic violation outside the core campus, (i.e. off campus) and follows the person on

campus to make the traffic stop (i.e. within the core campus) and identifies a drug law

violation, the Clery crime should be counted as an on campus or public property crime

(depending on whether it is a public street or a University owned street).

Recommendation 16.13: If the officer observes a liquor violation on a public street within

the core campus (i.e. “on campus” property) and follows the person outside the core

campus (i.e. off campus) the incident should be counted where it occurred. In the

converse, if the officer observes the crime outside the core campus, i.e. off campus and

follows the person to an on campus location i.e. within the core campus, the incident

should be counted as having occurred at the off campus location where it occurred.

Appendix #7--Excel spreadsheet with a ‘sheet’ for each crime category that includes the

incidents that were verified in each category during the audit. (Saved as: Clery Chart

UCONN 2009-FINAL)

Appendix #8--Cover sheet for Part 1 Crimes

Appendix #9--Cover sheet for Liquor, Drug and Weapons Violations

Section XVI: Audit of the Office of Community Standards Records and Processes

Kim Hill (Assistant Director of Community Standards), Cathy Cocks (Director of

Community Standards), Elsie Gonzalez (Assistant Director of Residence Education), and

D. Stafford & Associates staff Lindi Swope and Dolores Stafford also reviewed more

than 700 judicial referral records for all violations, including liquor, drug and weapons.

The statistics for referrals for liquor violations and drug law violations were inaccurately

reported.

UCPD used the information provided by the Office of Community Standards (OCS) to

report the "referral" statistics for the institution. The original statistics provided by OCS

and reported by UCPD were:




Property

Liquor Law Referrals 714 0 75 686

Drug Law Referrals 3 0 0 2

Illegal Weapons Referrals 0 0 1 0

In reviewing the 700+ judicial referral records for all violations, including liquor, drug

and weapons, we found that there were a significant number of referrals for liquor and

drug violations that were not reported correctly. The statistics should have been counted

as follows (these numbers are also listed in the crime statistics chart in Section XVI):


Property

Liquor Law Referrals 575 (-139) 1 (+1) 0 (-75) 574 (-112)

Drug Law Referrals 88 (+85) 0 0 63 (+61)

Illegal Weapons Referrals 0 0 0 (-1) 0

There were several practices that were in place in 2010 that affected the errors in the

referrals statistics that were reported to UCPD by OCS. These practices included:

OCS reported all incidents of intoxication (174 cases) to UCPD because they

believed that those incidents were violations of the law and countable under the

Clery Act. This is the reason for the majority of cases that were over-reported by

OCS.

OCS was told by UCPD that if UCPD officers responded to an incident and sent a

report to OCS, OCS should not report those referrals back to UCPD. The

assumption was that if UCPD was present on the scene, they were counting that

incident as a referral. This appears to be the reason for OCS under-reporting the

drug referrals to the UCPD.

Currently (as of 2011), the system between the two departments is as follows: UCPD is

counting the arrests for drug, weapon and liquor law violations from the police

department records. For the referrals, the Office of Community Standards is

automatically counting and reporting back to UCPD all non arrests (all referrals for

current students) for liquor, drug and weapon offenses where the student was charged

with a violation of the law, as well as any other Clery crime that is reported to OCS by

anyone other than UCPD. OCS also sends data regarding the arrests that was reported to

them back to UCPD for verification purposes.



As we were completing the audit of the disciplinary records, we identified various

problems with the current systems and processes. Listed below are some general

problems that were identified and recommendations to improve and enhance the current

systems that are in place:

We assisted the UCPD in conducting as assessment of the UCR definitions of

drug law violations, liquor law violations, and weapons law violations. Lt Vargas

completed an assessment of the state laws and local ordinances that fall under

those three UCR definitions. The final assessment should be shared with the

Office of Community Standards to educate them about the specific violations of

state and local law that are Clery countable so they can conduct a similar

assessment involving the drug, liquor and weapons violations in the Student Code

of Conduct.

In 2010, in general, the incident categories that are being used by OCS do not

allow for the staff in that office to determine if the incident should have been

counted as a Clery Reportable offense. For example, they used categories like

Liquor Violation, but the types of incidents they put into these categories include

violations of law and violations of policy (that are not violations of law).

Currently, OCS has a means to identify an incident as a Clery reportable

violation using a dropdown menu in the PAVE.

In cases where a student is referred for multiple violations as part of the same incident,

specifically in the areas of drugs, alcohol, and weapons violations, the incident should be

entered into PAVE using the most serious offense. For example, if the individual violates

a liquor law (by possessing a six pack of beer) and a drug law (by possessing 16 oz of

marijuana)—it should be captured in the database as the most serious offense, i.e. the

drug violation. Ex. Case 10-28681--this case should have been counted as a referral for

(Virgilio) drugs and (Blackman) for liquor.

Recommendation 17.1: Use the UCR hierarchy in capturing incidents in PAVE to allow

the highest violation (crime) to be captured for Clery reporting purposes.

In addition, there are incidents where the student was referred for two violations and one

is a Clery countable violation and the other isn’t. For example, a person who is under 21

is referred for DUI and Possession of Alcohol. List this in the system as a possession

violations, because that violation should be counted in the Clery Act statistics and DUI is

not a reportable category.

Recommendation 17.2: The Clery countable category should be the one entered into the

database, so the statistic can be identified and counted.

There were instances of liquor law reports being classified by UCPD as non Clery

reportable offenses (Disorderly Conduct (10-24906), Vandalism (10-23682) which

involved the presence of alcohol, but were not captured by UCPD as potential referrals



due to the classification and the process of running reports in LEAS to review only Clery

crime code call types.

Cases 10-28675, 10-29972 and 10-24160 are in LEAS as a Narcotics offenses but do not

appear on the LEAS Case Incident Report based on Call Type which Captain Varga uses

as her audit trail. We are not sure why they did not show up on the report that generated

that was supposed to identify all of the narcotics cases. This type of problem in the

system could impact the Clery statistics, if she is running a report to try to identify all

narcotics cases, and some of them do not show up on the report. This potential system

error should be investigated.

The UCPD staff is often times responding to calls involving liquor, drug or other

violations in the residence halls, and they are not consistently writing a report about the

incident or they have documented some of the people involved, but not all of them. Ex.

Case 10-2976-- this case involved 9 students and OCS adjudicated all 9 students. The

UCPD incident report only named 3 students ( Benn, Woodruff & Seiwertsen). The other

6 names were given to the RA to be documented in their reporting process. It is

recommended that UCPD document all involved parties in their incident report.

Currently, officers only CAD entries are being generated for liquor law offenses

involving arrests and referrals combined. Only CAD entries are generated for single

incidents of arrests or single incidents of referrals. Using the current LEAS system this

makes it highly probable that potential arrests and referrals are not being counted due to

LEAS reporting deficiencies.

Recommendation 17.3: The officers need to be encouraged to write a thorough report any

time they respond to an incident involving a crime or incident that could be a referral to

OCS.

OCS staff should review the current locations that are available in PAVE to ensure that

they can properly identify incidents that occur on campus (within the core campus map),

in non-campus locations, and on public property--which are all Clery reportable

geographic locations. They also need to be able to log those cases that occur off campus

and thus, are not Clery reportable.

Overall, in some cases, OCS originally over counted the statistics, because they counted

some crimes that are not Clery reportable, such as DUI or Intoxication. In some cases,

they under-reported because of guidance they were given by the previous administration

of UCPD about what to report back to UCPD and what they would count using their own

records. Some mistakes were caused by inadvertent human error, and some were due to a

lack of complete understanding of the requirements of the Clery Act reporting guidelines.

The staff in the Student Conduct Office was actively engaged in the audit process and

they were helpful and receptive throughout our visit. We were impressed with their desire

to learn how to improve the reporting process for the future.



Recommendation 17.4: The Office of Community Standards needs to send all records

regarding reported crimes to UCPD each month, to allow UCPD staff to compare that

information to their records and capture the statistics for any criminal incidents that were

not reported directly to the PD. This will assist the staff at UCPD in keeping the crime

log updated on a regular basis, rather than adding all of that information to the log at the

end of the year.

Recommendation 17.5: The Office of Community Standards should continue to send a

spreadsheet to UCPD at the end of the year to allow them to cross-reference the

information on their audit trail to the information provided by OCS, to ensure that all

cases UCPD sent to OCS are accounted for and that there are no errors in counting the

arrests versus the referrals. The spreadsheet should contain, at a minimum: the violation,

the UCPD case number, the student's name, the location of the incident, and the date of

the incident.

XVIII. Overall Recommendations:

Recommendation 18.1: The institution should initiate a Clery/HEOA Committee that

includes, at a minimum (if you have these units/departments): UCPD, Compliance and

Internal Audit, Office of Community Standards, Student Activities, Residence Life and

Housing, Environmental Health and Safety, and the Office of the General Counsel.

Recommendation 18.2: The following offices, at a minimum, should be responsible for

reviewing and signing off on the accuracy of the policy statements and other information

contained in the Annual Security/Fire Safety Report prior to publication each year:

a. UC Police Department

b. Compliance and Internal Audit

c. Office of Community Standards

d. Risk Management

e. The Women’s Center/Sexual Assault Advocate

f. The Office of the General Counsel

g. UCONN Fire Department

Recommendation 18.3: Maintain an annual compliance file with all records pertaining to

each compliance cycle.

Documents

UConn Private Clery Audit Report