The College is undergoing an audit of campus compliance to the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics. One of the Act’s mandates is that colleges receiving federal funding must publicly share information and collect data about crime in and around campus.
The Clery Act requires colleges to take specific actions like publicly releasing an annual security report, issuing “timely warnings” and “emergency notifications” if there is a threat to campus safety and providing sufficient support to survivors and respondents of sexual misconduct. Federal penalties for non-compliance begin at $35,000 per violation.
The audit was not prompted by any specific concerns about noncompliance, according to President Sean Decatur, but by a motivation to be one step ahead of the Clery Act’s evolving expectations. The College revised its Clery report in 2014 after failing to include some incidents of sexual misconduct due to a miscommunication.
Decatur anticipated the College will need to add staffing in the future specifically dedicated to Clery-related responsibilities.
To conduct the audit, the College is working with the firm Margolis Healy, based in Burlington, V.T., which specializes in campus safety, security and regulatory compliance. Kenyon previously hired the company in 2015 to assist in data collection for Clery reports. Administrators cited Michael N. Webster, the firm’s Director for Regulatory Compliance, as a prominent figure in Kenyon’s auditing process.
Webster could not be immediatly reached for comment.
The audit began at the time of the April 2015 hiring of Andrea Goldblum, Kenyon’s former Civil Rights and Title IX coordinator, according to Vice President of Student Affairs Meredith Harper Bonham ’94. Goldblum worked on the College’s compliance to the Clery Act and brought in Webster to help in the process. (Goldblum formerly worked as Manager of Regulatory Compliance at Margolis Healy, and has served as an Associate at the company since spring 2015, according to her LinkedIn page.)
Goldblum resigned her position at Kenyon last spring, citing her wish to continue her work at a larger institution.
As the College’s current Civil Rights and Title IX coordinator, Samantha Hughes is also involved in the process of evaluating Clery Act compliance.
“We don’t have anything solidified,” Hughes said when asked about plans to create a campus committee to discuss Clery Act compliance. “I know we definitely talked about trying to utilize elected student positions that might make sense.”
The federal act was named after Jeanne Clery, a female student who was sexually assaulted and murdered at Lehigh University in 1986. In the wake of her death, her family successfully won a lawsuit against Lehigh. The family claimed they would not have sent their daughter to the university had they known the levels of crime on campus. The Clery Act became law in 1990.
The audit of the College’s compliance to the Clery Act is separate from the Title IX audit currently being conducted by lawyer and consultant Rebecca Veidlinger.