Jill Creighton:	Welcome to season two of the ASCA Viewpoints Podcast, the podcast where we talk about the student conduct profession in higher education. I'm Jill Creighton, your Viewpoints host.

Jill Creighton:	Today's episode features Laura Egan. Laura serves as the Senior Director of Programs at the Clery Center. At the Clery Center, she oversees the development and execution of training and technical assistance projects, programs and resources, including Clery Act Training Seminars, webinars, and National Campus Safety Awareness Month. She presents nationally and provides individualized support on compliance and implementation of Clery Act requirements, campus safety, compliance, and gender based violence and discrimination. Prior to joining the Clery Center, Laura worked at Saint Joseph's University in Philadelphia, Pennsylvania for five years, serving both in residence life and student conduct roles. Laura earned a Bachelor of Arts in Psychology from Villanova University and a Master of Arts in Education and Human Development from The George 
Washington University.

Jill Creighton:	Welcome to the podcast, Laura Egan. Laura serves as the Senior Director of Programs for the Clery Center. How's it going, Laura?

Laura Egan:	Hi, Jill. It's going great. How are you doing? 

Jill Creighton:	Great, thanks. I'm glad to be speaking to you today, so close to the release of our Annual Security Reports. Think that's always a bit of a trying time in every conduct officer's life.

Laura Egan:	Yes.

Jill Creighton:	But before we dig into your technical expertise and all about Clery and the Clery Center, we always like to start off our episodes by getting to know our guest a little bit. Can you tell us about your journey to this position with the Clery Center?

Laura Egan:	Sure, absolutely. Yeah, I started my professional work as a school counselor, actually. I was at a K to 8 school in Philadelphia for about three years when I was looking for a change, but still wanting to stay in the field of education. A friend of mine, who was working in residence life in higher ed, recommended that I look into that field, just because of the transferable skills between being a counselor and working in res life. I had been an RA in college, so she thought it would be a really great fit, and it was. I had an awesome position in both residence life and student conduct at a higher education institution right in Philadelphia. 

Laura Egan:	Then during my time there, I was really starting to get interested in other roles that I could take on that would intersect still with higher education work, but would be a little bit more focused in a topic area. I, actually, reached out to Clery Center to ask if they would be down for an informational interview essentially, because I knew the work was distinctly coming from a non-profit lens, but intersecting with a lot of higher education pieces. When I reached out to them, that was when they shared that they were about to post for a position that was connected to working with institutions and learning a lot more about the Clery Act, and helping institutions gain some of that knowledge and awareness. 

Laura Egan:	Ultimately, I applied for that position and got that position, and was really excited to gain a little bit more perspective on higher education and compliance in general. I had been on a campus, or one school, for those five years, so getting to work at Clery gives me the opportunity to intersect with a bunch of different campuses and learn about how each campus' unique culture is impacted by these laws, Clery being one of them, and how that creates specific challenges for each campus. Being somebody that enjoys problem-solving, enjoys bridging different groups of people together to solve a problem or to organize around an idea or a goal, it just felt like a really perfect fit. I've been at Clery for just over three years now and have really enjoyed my experience being able to train on Clery, meet a bunch of different professionals from all walks of life, but also, create some things that are uniquely Clery Center in terms of educational tools, as well.

Laura Egan:	That's just a little bit about how I got to where I am. 

Jill Creighton:	Can you tell us a little bit about what the Clery Center is and what it actually does?

Laura Egan:	Yeah, absolutely. Clery Center is a national non-profit founded by Connie and Howard Clery, who are the parents of Jeanne Clery, who was a woman attending Lehigh University in the '80s when she, actually, was brutally raped and murdered in her dorm room back in 1986, when she was first-year student there. Connie and Howard were really upset by their loss and looked into asking a lot of questions around how did this happen and could this have been prevented, and in doing that work discovered some pieces around how campuses weren't really required to share information about crimes that occurred on their campus, or in the surrounding community with campus community members at all. They thought that that would've been a really helpful piece of information for them to know when choosing colleges for their child. Not even to say that they would've made a different decision, necessarily, but it just would've helped them be a more informed consumer. 

Laura Egan:	In addition to working to develop legislation on the state and local level that ultimately became the federal law of the Clery Act, they also founded an organization, originally called Security on Campus, but now known today as Clery Center. It's been around for 30 years. We just had our 30-year celebration this past spring, and they really were connected to the idea of having institutions be supported by people that knew the law and understood the law better. It's actually no secret either, that security on campus, when it was originally founded, functioned more as a watchdog organization and reported campuses to the Department of Education that were not complying with the Clery Act once the law was passed. They would even file complaints on behalf of victims of sexual assault. Their rights weren't being met accurately, and that was the role that we kinda felt was needed and wanted at one time. But it didn't really serve everyone in the best way it could, because it caused us to have sort of fractured relationships with institutions of higher ed and was, actually, possibly, re-victimizing these victims, because we were acting on their behalf, taking away their agency and making choices. So we no longer serve in that watchdog capacity. We probably, actually, haven't filed a complaint in about 10 years.

Laura Egan:	But as recently as 2015, we made a concerted effort to change our mission and vision to align more with the work we want to do today, which is working in partnership with colleges and universities to help them understand what the Clery Act requires and how they can best meet those goals with their own unique campus in mind. So that's really a lot of the work that I do today. It's focused on that mission.

Jill Creighton:	Excellent, so how does a campus actually work with you? Do they contact you, do you contact them? What is that partnership and what actually happens when you all link up?

Laura Egan:	No, that's a great question. Campuses can intersect with us in a variety of ways. One, is they could just call us up at any time with any question they might have about how to comply with a certain aspect of Clery. We would call the answer to that sort of question, technical assistance. It's a more specialized term around following the guidance of laws or federal regulations, so that's a function that we provide to anybody that would call. We are very clear in stating that we are not the enforcement authority of the Clery Act. Sometimes we would refer questions like that out to the help desk that works on behalf of the Department of Education to provide those answers. That's one thing that we would do. 

Laura Egan:	We also do in-person training. We do about six to eight of those a year, all across the country where anybody can sign up to attend. They range from one-day trainings to three-day trainings, where we touch on all different aspects of the Clery Act. Our one-day trainings are a little bit more high-level. Our three-days are more hands-on, a lot of activities thinking through how to apply the concepts that we're teaching. Then, also, campuses could be just a user of one of our products, so we have multiple training videos and resources. We have online trainings and webinars that we offer all the time. Every September is National Campus Safety Awareness Month, so all month long we've been holding free webinars and providing free resources connected to our theme of "What's your message" this year. So that's another way that campuses can interact with us.

Laura Egan:	Then, our favorite way to talk about, honestly, is our membership program. A campus can join as a team of individuals to be a Clery Center member, which means that they get free and discounted resources or registrations for our trainings or our webinars. Then they gain access to the network of other Clery Center members, so if they need to ask questions and learn answers from peer institutions, they have a member portal that they can do stuff like that. 

Laura Egan:	I know it's a really long answer, but there's a lot of different ways that they could intersect with us and figure out how to get answers to the questions that they might have.

Jill Creighton:	How would a conduct officer's role fit into that?
Laura Egan:	Yeah, so another great point. I think Clery became more relevant, perhaps, for conduct officers with the recent passage of the Violence Against Women Act amendments to the Clery Act, where guidelines for elements of disciplinary proceedings and procedures for sexual assault, dating violence, domestic violence, and stalking incidents were outlined in those amendments. Prior to that, student conduct officers might have only thought of Clery in relation to counting drug and alcohol referrals in an institution's Clery statistics for the Annual Security Report. While that still is extremely important, as are the dating violence, domestic violence, stalking and sexual assault statistics, I would think the area where there is more of an opportunity to have a conversation or to learn from each other, is around these disciplinary procedures requirements.

Laura Egan:	The law was originally signed in 2013, and then the regulations went into effect as of 2015. There are certain elements that need to be in place in an institution's disciplinary proceedings, for both students and employees, when it comes to those sorts of cases. Those pieces need to be, not only part of your procedures, but they need to be grounded in policy, they need to be accurately described in your institution's Annual Security Report policy statements. And an area that I think is often, maybe, a little bit overlooked is, the student conduct part is there, but maybe an employee conduct process is not described as well. So a student conduct officer might be a really helpful resource for an HR department, or an EEO office on a campus, that is supporting all of that work for employees. Modeling or aligning procedures to mirror each other would be a really helpful thing to have happen, but that's how I would see student conduct officer today really connecting with Clery or understanding more about the Clery Act.

Jill Creighton:	I think most of our campuses have a dedicated Clery professional who are either based in public safety or maybe in compliance, or potentially even in a local campus law enforcement office, that are really compiling all of that. But we're often the ones providing the statistics, so what advice would you have for conduct officers who are, maybe, new to working with Clery, or maybe aren't aware of some of the funkier updates that have happened in the last couple of years?

Laura Egan:	You know, I think the first thing I would recommend, is for them to become familiar with a lovely light read called the Handbook for Campus Safety and Security Reporting. It is about a 200 plus page document, published by the Department of Education, that's designed to help individuals understand the regulations of the Clery Act. It technically is sub-regulatory guidance, meaning it is not the law itself, but it is something that the Department of Education says it uses when they're conducting a program review, say, of determining whether or not a campus is fully in compliance with the Clery Act.

Laura Egan:	There are some chapters in that handbook that might not be as relevant for student conduct officers, but when it comes to understanding how statistics are counted or classified, there's a whole chapter dedicated to walking through that. Then when it comes to thinking through, maybe, systems for organizing that information, that's where I really think the peer pieces are such helpful resources. Connecting with others either at your campus, or at similar institutions, to understand what their record-keeping systems are. I think that's one of the biggest areas that is yet to be fully answered under Clery, is what is the best way to store your information. There is never gonna be, probably, one fix-all solution through a CRM or something like that, so there's always gonna be a need to do some manual reconciliation with numbers and information or reports. 

Laura Egan:	If you were new to Clery on a campus, I would really recommend just having a partnership with your Title IX coordinator, with your public safety office, with your Clery coordinator, if that exists, at your school, to make sure that you all have open lines of communication at a minimum with talking through reports that come through, and how you're coding them, recording them, documenting them, classifying them, because that element of manual reconciliation will always need to be an element, I think, of proper record-keeping under Clery. 

Jill Creighton:	Clery is really the law, but I think the spirit of the law is really allowing our campus communities to know about what happens in terms of crimes of violence or other concerns. But I think that the report, the ASR, is something that scares the life into a lot of us every October, in terms of compliance, because the fines are so heavy. Can you speak a little bit to how we can help conduct officers dispel the myth that this is one of the scariest things that we do?

Laura Egan:	Yeah, sure. No, I think that's a really great point. I think a couple of things are often heard or said about ASRs. One is, no one ever reads this. I spent so much time making sure it looks great, and I don't think anybody's caring or taking the time to read it or pay attention. Then, yeah, the other half of it is, I'm just so scared that I'm not doing the right thing.

Laura Egan:	My response to the first part would be really connected to thinking through how you might not think anybody is reading your ASR now, but God forbid, something were to happen at your institution, a lot of people would be looking at that ASR, because it is one commonly referred to outward-facing document that has a lot of information about what your campus says it's going to do when a certain incident takes place. A lot of my work right now is been answering questions from students, or student reporters, that call wanting to know if their institution was quote-unquote "Out of compliance", because they did or didn't issue a warning or include a statistic in this column. So providing a lot of awareness for them about what campuses are required to do or not is critical, but it tells me that they are reading, at a minimum, your Annual Security Report, and at a maximum, the law itself and what the law is requiring. So I would say, know that it might be being read more than you think it is. It just might not be that relevant to you.

Laura Egan:	In terms of the scary factor, I try to use the metaphor, like if you reflect on your time in high school algebra class when you had to maybe fold the paper in half and show the work on the right-hand side of the page, like how you got that answer, that's what your ASR is for your campus. It is just the proof of the work that you're already doing. At the end of the day, everything in that ASR should be a complete accurate reflection of the things that are happening on your campus, which are hopefully aligned with what Clery requires. So in terms of it being scary, be it the burden or the onus of the scary part, should not necessarily be just on you, as much as it should be on the institution if there's a fear that something that's in that is either not accurate or not aligned with Clery. But the spirit there is about transparency and accountability. Clery is written as a consumer protection law to promote that spirit of open communication between the institution and the campus community members. The ASR is one concrete way that that is actualized. 

Laura Egan:	Think of it as an opportunity to be really helpful and clear with your students and parents, or staff, about all the things that your campus is doing to create a safe environment or a welcoming environment. All the things that you're doing to create prevention and response actions for violence prevention at your institution. 

Laura Egan:	So I would hope that if there are concerns about anything in that ASR being inaccurate or being not aligned with Clery, my recommendation would be to go to the people at your institution that are connected to Clery compliance, that are maybe not just you in student conduct, to let them know of your concerns and to see if there is anything that could be done to bridge in a gap of understanding between the people that are putting that information in there and those that are saying, "It's good to go from my perspective".

Jill Creighton:	A lot of us are writing that section where we talked about what are institutions will do or those resolution sections, available sanctions, I guess that's statistics. Do you have any good writing tips for what you've seen in terms of what makes a strong ASR?

Laura Egan:	Yeah, A large part of my time is spend reviewing ASRs. I think one area that I see people falling into a lot is wanting to just lift completely a policy and put it in the ASR for exactly what you were talking about earlier, Jill, a fear of missing something or if not including an element that they think they should have. What I see happening there is creating more confusion for folks, because then we are not summarizing that information. We're just giving a full-on policy that might have a lot of superfluous information beyond what's required. I would really recommend thinking through, if we as professionals cannot summarize this policy, how is a 19 or 20-year-old, that's possibly the victim of a traumatic event, expected to, really? I would say, my tip would be to try to simplify and remove any terminology that's very jargon-y form those explanations, and try to make the summaries, or the elements that you're including read as clearly and plainly to the general public as possible. Because the ASR is designed to be something that a parent could read, that a student could read, that another staff member at your institution that doesn't live in the work all the time can read.

Laura Egan:	Sometimes I think the best activity to do for that, is once you've written something, ask somebody else that completely is not connected to the work to review it for you. So a peer review on the professional level, a peer review from students even could be really helpful, to just give you that feedback on whether or not this sounds good, this looks clear, or sorry looks good, sounds clear to the average reader. I think to a certain extent any sort of structural help there, so headings, breaking out the paragraphs, a visual image, anything that breaks up just a bunch of text is always helpful at any part of the ASR.

Jill Creighton:	I want to take kind of a giant step back, because I'm having this realization in our conversation, a good chunk of our audience that listens to our podcasts are not United States based professionals. Probably about 10 to 15% of our audience are listening from all over the world. We have listeners from Canada, from Germany, from South Africa, it's a pretty broad cross-section of listeners, so can we back up even further and just first off identify ... I understand, listeners, this episode is pretty ethnocentric to our U.S. professionals, so I appreciate you bearing with us through that. But also, we've used a couple of abbreviations, you and I have said ASR like 100 times now. Go back and clarify what some of these abbreviations are. 

Laura Egan:	Yeah, sure absolutely. You know, Jill might already specify this in another way as well in advertising the podcast, but Clery is really specific just to U.S. based institutions that receive Title IV funding, in terms of federal financial aid. Foreign institutions are not required to adhere to it, except many campuses that are based in the U.S. might have a separate campus abroad, so those institutions would be required to fully comply with all aspects of Clery. 

Laura Egan:	But yes, when we say things like ASR, we are talking about an Annual Security Report, which is a document that the Clery Act requires institutions publish each year by October 1st. That Annual Security Report contains two major elements. One is a set of crime statistics, Clery crime statistic, which are crimes that meet the definition of a Clery crime, that were reported to a campus security authority. That's another acronym for you, a CSA, which is a reporting party defined in the law, as well, that occurred within Clery geography. So, certain defined parts of an institutions property, or buildings, that, again, the Clery Act specifies and defines. So those statistic, again, one part of the ASR, Clery crimes reported to a CSA that occurred within Clery geography. 

Laura Egan:	Then the other part of an Annual Security Report are what we call policy statements. Those are, essentially, summaries of existing policies at the institution in various aspects of campus safety. That ranges from talking through how one can report a crime, to fire safety if you have on-campus residence halls, to response prevention and disciplinary procedures for cases of dating violence, domestic violence, sexual assault and stalking. Those are the two major content areas of an Annual Security Report, and yes, due by October 1st each year.

Jill Creighton:	When we say "due" we actually also mean to our whole campus community. We're turning it in to everybody that might have a stake in our institutions, so they're very, very public. 

Laura Egan:	Yes, yes absolutely.

Jill Creighton:	You mentioned something that I think is really an interesting component of Clery, which is if you have a campus that is U.S. based but located abroad. I think that is one of the most difficult, technically, aspects of reporting that we do have under our Clery obligations. Can you talk a little bit about how you've seen institutions be most successful in reporting, when you have a campus that's not in U.S. territory?

Laura Egan:	Sure, yeah. I think that it's really important to note the type of ownership, or control, you have of that physical space abroad, because the way that that agreement or ownership, like the way it's written out, determines your obligations under Clery. Clery, in terms of space, is really concerned with what a written agreement for use of space says. 

Laura Egan:	As a United States based institution, you might have some properties abroad that would fall under a category that's called non-campus property, which mean that you own, or control, space there that is used for an educational purpose, like a class that is frequently used by students, but you don't really have anything going on there beyond that element. On top of that, you might have something that rises to the level of what we would call a separate campus under Clery. A separate campus would be one that has a formal organized program of study and an administrative presence at a building or property that is owned or control by the institution for educational purposes.

Jill Creighton:	You sound like you've said that before. 

Laura Egan:	Yeah, just a couple of times. Yeah, so the distinction there is just that non-campus is a little bit less formalized in terms of the institution there. It literally could just be that you're using that space to teach a class and that's it. The separate campus would be a little bit higher in terms of administrative structure. You would have your own budget, your own hiring authority, possibly, for a separate campus. 

Laura Egan:	When it comes to reporting what you would want to be most concerned about is who, if anyone, at either of those locations would fall under this category of a campus security authority, so somebody that either works for public safety or security, or has been given duties that are likened to being an access monitor, that even if they don't fall under a campus public safety or campus security office, or anyone to whom the institution has directed folks to report crimes to. Then that ever popular fourth category, CSAs, an official with significant responsibility for student and campus activities. 

Laura Egan:	If you have anybody that would fall under one those four categories at either a non-campus location or a separate campus abroad, they would be responsible for reporting to whatever crime collection body is designated at that location, or at that institution, crimes reported to them. That can be really challenging, particularly, when you're talking about, as a CSA, that your role probably goes a little bit beyond just taking the report. While Clery might not require more of you in operationalizing that role, you're going to be talking to the reporting part, you're going to be connecting them with resources. If you're abroad, that might mean getting immediate physical help in that moment, in terms of local resources, and it might also be sharing with them institutional resources, like this is what happens next in terms of a discipline process or a conduct process, or the types of accommodation you could receive, either here or when you return to the U.S. based campus.

Laura Egan:	So that's a lot of different components to take into account, for sure. I think the best thing to make sure that you're doing is identifying who your CSAs are in those abroad locations, and making sure that they are trained and aware of their role and any referrals that they would need to make for individuals. 

Laura Egan:	Another thing that I know campuses really are doing well, currently, is training students that are going to study abroad about all the resources available to them in the local community and at the campus abroad, should they be the victim of any sort of crime. Some campuses even go so far as to educating students on the local laws of the country or region that they're going to be studying in, so that they know, should they find themselves in a situation, this is how that area would handle this type of an incident. 

Laura Egan:	It's a lot of collaboration that would need to happen with your study abroad offices, with your Clery coordinator to make sure that reports are getting accurately counted and reported and shared with the institution. Then it really comes down to knowing what that space is classified as abroad, because that would help determine where those reports, ultimately, would fall for the campus, in terms of which set of statistic they would go under. 

Jill Creighton:	What would you say to campuses who have locations abroad that are identified as those second campuses, essentially? I'm thinking about my prior institutions, like NYU Shanghai or NYU Abu Dhabi. I'm thinking about places like George Mason in Seoul or Yale Singapore, American University just opened two campuses in Malta and Armenia. For these locations where when we try to go to local law enforcement to get the statistics to make reports and we're either shut down or ignored, what advice do you give to those campuses?

Laura Egan:	That's a great element, too, Jill. I wasn't sure if I should bring it up because I didn't want to confuse folks, but I'm glad that you did because that means that it's okay to talk about it. So the other level too with your campuses abroad is, depending on if you have a non-campus property or a separate campus, an obligation under Clery is to request local statistics from those areas. You would do that for your campus locations in the United States as well, so every time you're publishing your statistic, you would do a request for your local law enforcement to say, "Have you received any reports of Clery crimes that have occurred in Clery geography?" This answer applies to the requests you would make domestically, as well as internationally. 

Laura Egan:	It is not a requirement for local law enforcement anywhere to give that information to campuses. It is a requirement for campuses to request it, so if you can document that you have made that request, even if you don't receive an answer back, that is okay as long as you would be able to demonstrate that you've made the good faith effort to request that information. 

Laura Egan:	I would say, you might be surprised at the responses that you do get. I think it helps if you send the request in the native language of the country that you're requesting it from. But sometimes what happens is a little bit of misunderstanding, especially when it comes to the geography. If there are campuses with separate campuses abroad, then you have to think about non-campus public property and on-campus property, so some campuses have a difficult time translating the non-campus part of things or public property part of things. 

Laura Egan:	Regardless, all you're required to do is request for that information. If you get a response, you want to do the best you can to verify that that information falls in line with what Clery is requiring. You don't need to necessarily verify that that actual incident took place or was reported. You're taking it on the word of the law enforcement entity that's sharing that information with you. 

Laura Egan:	But yeah, if you're getting no response, that is okay as long as you can demonstrate that you made the request in the first place. 

Jill Creighton:	What about online institutions, institutions that maybe, like Argosy, or something like that, run their entire operation without physical property except for an administration building?

Laura Egan:	Yeah, so if you have completely online classes and you have no physical footprint, you would not be required to comply with Clery in terms of providing statistics or an ASR, or anything like that. No physical footprint, you are not required to comply with Clery. 

Laura Egan:	If there is an administration building, I actually don't fully know the answer to that question, Jill. I know that the way it's described in the handbook is that if there is no physical footprint at all, you don't have any obligation. I'm not sure how the Department of Ed would view just the administrative building. I could see them arguing that that part is your campus, maybe, your core campus, but if no students are actually physically present there, I could actually see the converse argument. That one, I would [inaudible 00:31:34] as a question to direct to the Department of Education, for sure, but I know that if you have a completely online facility, well not facility, but the online setup situation for your institution, then you are not required to comply with Clery. 

Jill Creighton:	I got to say, I feel a little bit fancy that I asked a question that you maybe hadn't got before. I'm sure that never happens for you.
Jill Creighton:	Laura, I really appreciate all of this technical guidance that you've given on Clery itself. What about when Clery has intersections with other laws? I know, for example, the Violence Against Women Act has some very interesting specifications around campus based reporting that sometimes intersect and overlap with our Clery CSA requirement but are not the same, so how do you all help campuses navigate those intersections?

Laura Egan:	Yeah, sure. That's a great question. When the VAWA amendments to Clery were passed back in 2013, there was a lot of conversation around whether or not that act, in and of itself, prohibited institutions from fully complying with other laws, like Title IX or FERPA. We had to do a lot of myth-busting around that, because the truth is, they really don't prevent institutions from complying with those other laws at all. 

Laura Egan:	There are some areas where both Clery and Title IX say the same thing, or call for the same thing but use different terms to do that. Even that is kind of, sort of in limbo right now, considering the rescinded guidance from the Dear Colleague Letter in the 2014 Q&A Doc that were rescinded last year by the Department of Education. 

Laura Egan:	Still, even putting that aside, there are still aspects to Title IX and Clery that speak to the same concept. They both identify a reporting authority. Under Title IX, we have responsible employees, under the Clery Act, we have CSAs. They both talk about the requirement for those individuals to share information that is reported to them. For Clery it's a very specific set of individuals that is required to share information across the broad range of crime categories, whereas Title IX, it's a broader category of reporting party with a much narrower focus in terms of what they need to report. That is, of course, anything related to sex or gender based discrimination of which sexual violence is a part. We always like to highlight here that your Title IX Coordinator is a really important person at your institution, because they are a bridge between these two systems, or these two laws, in that they are a CSA themself.

Laura Egan:	If you are in student conduct, I would really suggest having a great relationship with your Title IX Coordinator, or at least one where you feel like you could ask them questions and talk across reports or concerns that you would have around collecting information or sharing information. A big distinction, too, is under the Clery Act, technically, you are not required to share any personally identifiable information in reports, whereas under Title IX you are required to share all information that you are aware of in connection to an incident or a report of sex or gender based discrimination or violence.

Laura Egan:	This comes up more when you have individuals that fall under the category of both CSA and responsible employee, because while under Clery they might not be required to share personally identifiable information, if they are also a responsible employee, themselves, then they would need to share all the information that they are aware of in terms of a report. 

Laura Egan:	So it's really helpful to be clear with your campuses as to what roles they have, and what their obligations are under those roles. Sometimes when it comes to reporting, also, there's a little bit of a misunderstanding that reporting in general is breaking trust, or is divulging information that was supposed to be kept in a certain way. I always try to preach the message of flipping the script on reporting or sharing information is breaking trust, as opposed to ... Like, it is the most helpful and trusting thing you could do for that individual, because to not do that sells the false narrative that you are the only person that can help that individual, and you're going to take that burden on as a person. That, actually, isn't accurate because of all of the varying needs that somebody has when they experience any sort of crime. No one person could satisfy all the needs of another person when they are the victim of some sort of traumatic event, whether that be a motor vehicle theft, an agg assault, sexual assault, or stalking. So, in not sharing information or not reporting information, you could be doing more harm than good, possibly. 

Laura Egan:	I know that's a little bit off of what the exact question was, but I do see some importance in just making sure that folks understand that there is really nothing with those VAWA amendments to Clery that prohibit or precludes individuals from fully complying with other aspects of Title IX or FERPA.

Jill Creighton:	Just to clarify, you mentioned agg assault, are you referring to aggravated assault in that context?

Laura Egan:	Oh gosh, yes. So sorry, yes. Aggravated assault. There, I did the thing that I said you shouldn't do with ASR. So, that is what you should not do. 

Jill Creighton:	I think that sometimes in higher education, we get so lost in the technical aspects and compliance aspects of what we do, especially on the conduct side, that we can, in these contexts, sometimes forget that the whole point of this is to protect our humans. The whole point of this is to let our human beings know that we are caring about their safety, we're caring about their campus environment, and making sure that they can come to school and focus on learning and engagement. I think that's a really important component to kind of just throw in there for this, because this has been an amazingly helpful technical episode, but we do this because we want our students to have good experiences at the end of the day. 

Laura Egan:	Absolutely. 

Jill Creighton:	Laura, do you have any other tips or tricks or hot takes for the conduct officer lens on Clery?

Laura Egan:	I just think I would really want to thank all the conduct officers that are listening, because I do think they are sometimes the unsung heroes of Clery compliance. When we talk about compliance, too, I'm glad you brought this up Jill about the spirit part of things, because I think the unique thing about, particularly, the VAWA amendments to Clery, is if you actually read through it and ask what it's fully requiring institutions to do, granted it can seem really challenging because it is a lot and it's an unfunded mandate by the federal government, but it fought through a lot of the pieces that are what we would think of as spirit pieces. It doesn't just say "Make sure you have a prevention program." It talks about what your prevention program should look like and sound like and who they should be for, and that all students and employees are entitled to this, and that employees are important from not just a lens of supporting students, but as potential victims themselves. 

Laura Egan:	With all of that, I think it's often the people that are on the ground that see where there might be some gaps between what an institution says it does and what it actually is doing, in terms of procedures, or how policies are written, or how those policies are communicated to students or how decision are made, in terms of conduct cases, you're often in a tough position. Because you might be considered entry or mid-level positions that don't necessarily have access to bringing voice to those concerns but do anyway, because you do care about students and you do care about the community at your institution. 

Laura Egan:	So Clery Center thanks you, and I know all folks that work around violence prevention work would thank you because that type of advocacy benefits all students, potential victims, potential accused students or respondents. It would really be beneficial for anybody to draw attention to any sort of inequity or gaps that you're noticing. I just know from firsthand experience that when you're doing the work in and out, you're the ones that would be the first to notice. So thank you for even tuning in to this podcast today to learn more about an area that might not be something you intersect with all the time, but that intersects with your work enough that it's important to pay attention to. 

Jill Creighton:	Then, just kind of a final thought for you or question, I know that Howard Clery has since passed, but in thinking about Jeanne Clery's parents and your work with them specifically, what is their take, and I'm not asking you to speak for them but just your experience with them, what is your take on how they view the evolution of all of this today?

Laura Egan:	Yeah. No, that's a great question. Connie is an incredible force to witness. That is Jeanne's mom, who has really just made her whole life about working to ensure, to the extent that she can, that there are as few Jeannes, in terms of victims, as possible. I would think that, again, not to speak for her, I know that she has never perceived that the battle is over. She really wants to continue to work and to support works that create safer campuses for, truly, all students. She has often acknowledged, and I actually believe it's a quote in one of our videos, that there are a lot of Jeanne Clerys out there, and what she doesn't say, but what I think she is referring to is that we might not even know about. We want to know about those stories, and we want to make sure that we support all individuals that could be the victim of any sort of crime on a campus. Half of that support is making sure that folks are informed about what violence looks like in and around your campus, and what efforts are put in place by your institution to prevent and respond to them.

Laura Egan:	I know from Connie's perspective, she's really proud of all the work we've accomplished, but there is still so much more to do. And we really want to be a part of the conversation.

Jill Creighton:	Well, we like to close out all of our episodes by asking our guests what you are currently reading. 

Laura Egan:	Oh, yes. Totally not planned, but I did just finish reading the memoir, Educated, a couple of weeks ago. That was, actually, a really interesting read. For those of you that don't know, it's about this child, she's actually a woman reflecting back on her life growing up in Idaho, and by parents that may or may not have had mental health concerns, maybe influenced by some religiosity pieces. She basically talks about the idea that, she had no idea the context of the world that she was living in, because she didn't attend formal school and she was only being fed messages from parents that were a little bit eccentric to put it lightly. So she exposes herself to formal education for the first time at college. It's fascinating for her to talk about the support that she did receive from administrators and professors at prestigious universities, both here and abroad ironically, and how that helped to reframe the way she approaches her life and her family and the world. 

Laura Egan:	Again, totally not planned, but I thought it was a really interesting read, especially at the start of a new academic year, for our traditional two semester campuses, to just think about the influence that higher education really could have on a life and on a community and on a family, and how all the roles that we play are really powerful and cool in that way, to be a part of somebody's life in a transformative way. I highly recommend it, although, I would say, like a huge disclaimer, that there is a lot of violent pieces that are described, some physical abuse, some emotional abuse, so just as a warning that that is a part of the content of the book.

Jill Creighton:	Can you repeat the title and author again?

Laura Egan:	Sure. It is Educated, and it's a memoir by Tara Westover. 

Jill Creighton:	If we'd like to reach you after the podcast ends, how can listeners get a hold of you?

Laura Egan:	Yeah. No, I would say my email address would be the best way to reach me. That's just legan@clerycenter.org.

Jill Creighton:	If you'd like to reach the podcast, you can find us on Twitter at ASCAPodcast. That's A-S-C-A-P-O-D-C-A-S-T, or you can email us at ASCAPodcast@gmail.com. Thank you so much, Laura, for sharing your viewpoint today.

Laura Egan:	Thank you so much, Jill. I had a great experience.

Jill Creighton:	In two weeks on the ASCA Viewpoints Podcast, we welcome Dr. Chris Linder. Dr. Linder currently serves as an Associate Professor in Higher Education Prog at the University of Georgia, where she focuses her research on intersectional and power-conscious ways for universities to address sexual violence on college campuses. She also has a new book out, which we'll discuss, that might be a great read for all of our conduct professionals. We hope you come back and join us. 

Jill Creighton:	This episode was produced and hosted by Jill Creighton, that's me. Produced, edited, and mixed by Colleen Mater. Special thanks to New York University's Office of Student Conduct and Community Standards and to the University of Oregon's Dean of Students Team for allowing us the time and space to create this project. 

Jill Creighton:	If you're enjoying the podcast, we ask that you please like, rate, and review us on Apple Podcasts, or wherever you get your podcasts. It really helps others discover us and helps us become more visible in the general podcasting community. If you have suggestions for future guests or would like to be featured on the podcast yourself, please feel free to reach out to us on Twitter at ASCAPodcast or by email at ASCAPodcast@gmail.com.




0dafa60f-a9e4-431c-9c36-5852ae69f97c (Completed  09/25/18)
Transcript by Rev.com
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