Clery Act Compliance Committee Charter

Swarthmore College Clery Compliance Committee Charter

Purpose

The Clery Compliance Committee serves as the institutional oversight body responsible for supporting Swarthmore College's ongoing compliance with the federal Jeanne Clery Campus Security Policy and Campus Safety Act (Clery Act), as amended, including applicable provisions of the Violence Against Women Reauthorization Act (VAWA), the Campus SaVE Act, the Stop Campus Hazing Act, and related federal regulations.

The Committee provides cross-functional leadership and institutional coordination to ensure the College maintains effective policies, reporting processes, educational programs, and compliance practices that promote transparency, accountability, and campus safety.

The Committee supports Swarthmore College's commitment to fostering a safe learning, living, and working environment through collaboration, continuous improvement, and compliance with all applicable regulatory requirements.

Guiding Principles

The Clery Compliance Program is founded on the following guiding principles:

  • Shared Responsibility: Compliance is an institutional obligation requiring collaboration across administrative and academic units. 
  • Central Accountability: The Clery Compliance Officer serves as the institutional coordinator responsible for managing the College's Clery compliance program. 
  • Timeliness: Offices shall provide required information promptly to support regulatory deadlines. 
  • Accuracy: Crime statistics, policy statements, and required disclosures shall be reviewed for completeness and accuracy before publication. 
  • Continuous Improvement: The Committee shall routinely evaluate institutional practices and recommend enhancements to strengthen compliance and campus safety. 

Responsibilities and Duties

The Clery Compliance Committee shall provide institutional oversight by:

  • Reviewing departmental and institutional policies and procedures related to Clery Act compliance; recommending revisions as federal regulations or institutional practices evolve or are amended. 
  • Monitoring institutional compliance with federal crime reporting, statistical reporting, emergency notification, timely warning, annual security reporting, fire safety reporting, and campus security authority (CSA) training and reporting requirements. 
  • Serve as an advisory group to the Clery Compliance Officer regarding strategic compliance initiatives, emerging regulatory requirements, and institutional risk. 
  • Review institutional processes for collecting, classifying, and validating Clery reportable crime statistics and disciplinary referrals.
  • Support the development and coordination of campus-wide education, awareness, and training programs related to Clery compliance, Campus Security Authorities, and campus safety obligations. 
  • Review and recommend changes to communication and collaboration among departments with Clery reporting responsibilities to ensure timely information sharing and coordinated (non-duplicative) compliance efforts. 
  • Review the Annual Fire Safety and Security Report (AFSSR) prior to publication and providing recommendations regarding content and policy statements to ensure accuracy. 

Composition

Membership

The Committee shall consist of representatives from offices with significant responsibilities under the Clery Act. Membership should include, at a minimum, representatives from:

  • Department of Public Safety 
  • Division of Student Affairs 
    • Student Conduct 
    • Residential Communities 
  • Human Resources 
  • Environmental Health and Safety 
  • Athletics
  • Office of General Counsel (advisory capacity, as needed) 
  • Communications
  • Admissions 
  • Provosts Office
  • Office of Diversity, Equity, and Inclusion
  • Title IX Office 
  • Additional subject matter experts designated by the Chair as necessary. 

Members should possess sufficient authority within their respective divisions/departments to facilitate compliance activities, coordinate information sharing, and be active change agents to implement committee recommendations.

Leadership

The Committee shall be chaired by the Clery Compliance Officer, who will:

  • Establish meeting agendas; 
  • Coordinate committee activities; 
  • Maintain committee records; 
  • Monitor institutional compliance initiatives; 
  • Report significant compliance matters to senior leadership as appropriate. 

(The Chair may designate a Vice Chair or alternate to serve in the Chair's absence.)

Meetings and Quorum

The Committee shall meet no fewer than four (4) times annually, typically during:

  • September 
  • February 
  • June 
  • August 

Additional meetings may be convened by the Chair as necessary to address regulatory changes, significant incidents, audit findings, Annual Fire Safety and Security Report preparation, or other compliance matters that arise.

Meeting agendas should align with the annual Clery compliance cycle, including:

  • Regulatory updates; 
  • Policy review; 
  • Crime statistic validation; 
  • CSA identification and training; 
  • Annual Fire Safety and Security Report preparation; 
  • Campus Safety and Security Survey submission; 
  • Compliance planning for the upcoming reporting cycle. 

Quorum

A quorum shall consist of a simple majority of appointed members. Whenever possible, committee decisions shall be reached by consensus. If consensus cannot be achieved, recommendations may be adopted by a simple majority vote of members present.

Authority

The Clery Compliance Committee functions in an advisory and oversight capacity. The Committee is authorized to:

  • Recommend revisions to institutional Clery related policies and procedures. 
  • Recommend improvements to compliance processes, reporting practices, training programs, and internal controls. 
  • Establish working groups to address specific compliance initiatives. 
  • Request information from participating departments necessary to fulfill its responsibilities. 

The Committee does not possess independent authority to:

  • Approve College-wide policies; 
  • Commit institutional financial resources; 
  • Interpret federal law on behalf of the College; 
  • Make personnel decisions; or 
  • Override institutional leadership. 

Recommendations involving institutional policy changes, allocation of resources, or significant operational impacts shall be forwarded to the appropriate College leadership for review and approval in accordance with established governance processes.

Operational responsibility for the collection, classification, publication, and submission of Clery-related data remains with the Clery Compliance Officer and the Department of Public Safety, in collaboration with designated campus partners.

The President's Staff approves Clery-related data based on the committee's recommendations. They may also provide input on any changes before giving final sign-off. 

Review of Charter

This Charter shall be reviewed annually by the Clery Compliance Committee to ensure continued alignment with:

  • Federal statutes and regulations; 
  • U.S. Department of Education guidance; 
  • Institutional governance practices; and 
  • Swarthmore College's operational needs. 

Committee Administration

The Chair shall maintain official committee records, including:

  • Membership roster; 
  • Meeting agendas; 
  • Attendance records; 
  • Meeting minutes; 
  • Action items; 
  • Compliance work plans; and 
  • Documentation supporting Annual Fire Safety and Security Report development. 

Committee records shall be retained in accordance with federal Clery Act records retention schedule.

Committee Administration

This Charter is adopted to establish the governance framework for the Swarthmore College Clery Compliance Committee and shall remain in effect until amended or rescinded.