Clery Compliance for College Sponsored Student Travel, Study Abroad and Field Study Programs

Under the Clery Act, the college is required to collect and publish statistics on crimes occurring on campus, and on “non-campus property.”

Clery Trip Form

 Non-Campus Property is defined in the Act as: 

• Property outside the contiguous border of the campus “owned or controlled” by the college Written Agreements

 • For the purposes of non-campus property, the determining factor is an agreement, defined as a rental or lease document or other written form of agreement covering the colleges use of academic and/or residential space. The agreement need not be a formal one; something in writing agreeing to the utilization of space being utilized by this college suffices

. • If there is an agreement between the university and the host, the Clery requirements kick in only for those areas for which the college has the agreement as well as public areas leading to those spaces (such as hallways, entryways, etc.). This makes providing as much detail when you notify Campus Police about your program. 

• Clery requirements also only apply to those dates and times covered by the agreement. If a property manager agrees to provide a block of rooms to our students for 8 weeks during the summer, statistics only need to be collected for those locations during that time, not for the entire year.

 • Clery requirements may also kick in when the college rents a specific block of hotel rooms or a specific hostel, especially if students return to that location regularly (annually, each semester, etc.). 

Students Educated Overseas Taught and Housed by a Third Party or Local Institution 

• If the agreement is with another institution or third party, you may not have Clery requirements. For example, you have an agreement with a university to allow our students to enroll at their institution, but not to provide specific rooms, etc., the college does not have Clery requirements. (Title IX requirements may, however, apply.)

 Private Home Stays

 • Normally home stays do not invoke Clery requirements.

 • Similar to other academic and residential space, Clery requirements would kick in if the college has some kind of agreement directly with the provider of the homestay (such as agreement to provide certain services for our student). 

• Arrangements with another institution or company would not necessarily cause Clery to click for the homestays that may be arranged by that third party. 

Side Trips 

• Side trips organized by the attending students or by host families which are not covered by an agreement by the college and are not officially organized by the college do not have Clery reporting requirements.

 • However, as in other areas, there could potentially be Title IX implications.

 • Best practice would also suggest that if the college becomes aware of a crime that occurred during such a trip, it may be beneficial to advise students involved in the particular program when possible. 

Field Trips 

Not all student trips need be reported. For trips to be reportable, student trips must meet certain requirements. The College must have control over the trip or program accommodation and any related academic space used in conjunction with the trip. Control, as defined by the Clery Act, means that there is a written agreement (no matter how informal) directly between the college and the end provider for use of the space. 

In addition, the controlled space must be used in direct support of, or in relation to, the institution’s educational purposes and frequented by students. Some examples of a written agreement include renting hotel rooms, leasing apartments, leasing space in a student housing facility or academic space on another campus and even an e-mail agreement for use of space free of charge. Hostels are not normally reportable unless the written agreement gives the College control over the space within the accommodation. This definition would cover trips such as those below, provided the college has an agreement for academic/residential space and the trip is part of the college educational purpose:

 • Athletics long-term travel

 • Performing & visual arts long-term travel

 Non-Campus Property Matrix 

To determine if your site is Clery reportable, please check the Non-Campus Property Matrix table located below. 

Research Vessels 

Similar to other study abroad or field study, the college must disclose statistics for the ship or the areas controlled by the college while students are on board. 

Other Field Study Locations

 If the college owns or controls property overseas or at a distance, that does not meet the definition of a separate campus but that is frequently used by students, crimes that occur there must be reported. 

Note that some crimes may be relevant based on Title IX requirements but may not initiate Clery requirements. Refer to the college information on Title IX for abroad and field study programs. 

Timely Notifications

 Study abroad and field study coordinators should note that in addition to obtaining crime statistics, the college is responsible for providing timely notification of incidents made known to the college which threaten the safety of students studying at an abroad or field location. This notification need not be issued to the entire community, but can be issued only to students studying in that same program. 

The role of study abroad and field study coordinators: 

• notify Public Safety of the exact location and addresses for abroad and field study programs; be prepared to provide sufficient details about the colleges control over those spaces that will determine if the space is covered by Clery Act requirements. 

• assure students report any crimes occurring on non-campus property (residential and academic areas controlled by the college)

 • obtain sufficient information on what happened, where, and when • report the crime to Public Safety who will review it for potential inclusion in Clery crime statistics (the most significant factor is where the crime occurred) 

• assure that students studying at an abroad or field study location are made aware of crimes that are reported to you or location coordinators

 Documentation and Maintenance of Files 

The college is required to maintain documentation of Clery records for a period of seven (7) years. This includes correspondence with Campus Security Authorities relating to incidents occurring in non-campus property. 

Campus Security Authorities should maintain a copy of all records shared with Public Safety, including any criminal incidents determined ultimately not to meet Clery definitions. Questions? If you have any questions relating to study abroad or field study, please contact Demitria Kirby or Fawn Torrey.