Framework

Clery Act

Requires institutions participating in federal student aid to collect, classify, and publish campus crime information, warn the community about threats, and maintain the records behind all of it. It is the most procedurally exacting framework we practice in, and the one most often run by someone doing it alongside another job.

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At a glance

Campus crime reporting and warnings

Statute20 U.S.C. § 1092(f)
Regulation34 CFR § 668.46
Applies toInstitutions in Title IV aid programs
Report dueThe annual security report, by October 1

Scope

What it covers

What the framework reaches.

The annual security reportPublished each year by October 1, carrying three years of statistics, policy statements, and required disclosures. Beginning with the 2026 report, that includes hazing statistics.
Timely warnings and emergency notificationTwo distinct obligations with different triggers, different audiences, and different timing.
The daily crime logMaintained by institutions with a campus police or security department, open for public inspection.
VAWA provisionsStatistics and procedures for dating violence, domestic violence, sexual assault, and stalking, including required prevention programming.

Reach

Who it applies to

Who answers to it, who enforces it, and where it stops.

InstitutionsPostsecondary institutions participating in Title IV federal student aid programs.
EnforcementThe Department of Education, through program reviews, civil penalties per violation, and in serious cases limits on Title IV participation.
GeographyClery geography is a defined concept covering on-campus, non-campus, and public property, and misclassifying it is one of the most common findings.
Campus security authoritiesA defined group across the institution that must be identified, notified of the role, and trained on reporting.

The checklist

What has to be in place

The structural obligations, stated plainly. Specifics vary by institution and by state.

01An identified CSA populationReviewed annually rather than inherited, with notification and training documented.
02Defined geographyMapped, dated, and revisited when property changes hands or a program runs somewhere new.
03Classification practiceConsistent counting and classification, with decisions recorded so the numbers can be reconstructed later.
04Warning protocolsWritten criteria for who decides, on what basis, and how fast, so the decision is not being invented during an emergency.
05Policy statementsEvery disclosure the regulation requires, kept current rather than rolled forward.
06RetentionRecords supporting the statistics, retained for the required period and organized for a program review.

Where files fail

Where it usually goes wrong

Clery findings are almost never about hiding crime. They are about classification, geography, and missing documentation: a location never mapped, a CSA population that was never identified, statistics that cannot be reconstructed from the underlying records. The obligation is annual, but the work is continuous, and institutions that do it once a year in September are the ones that get findings.

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Where we come in

The work we do under Clery Act

Casework, coverage, and training, each scoped to this framework.

Scoping

Not sure which framework governs?

Most matters touch more than one. A scoping call settles which apply before anything else is decided.

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