Here are several tips on CSAs, timely warnings, and mass notifications that will help your youth summer camps comply with the Clery law.
It’s winter, and I live in Idaho, which turns into a pretty cold place during those months. Since I’m not a fan of feeling like I’m constantly on the verge of hypothermia, I spend quite a bit of time thinking about the warmer summer months ahead – and I’m not the only one. Do you know who else starts spending a lot of time thinking about summer? People who organize summer camps for young people at your college or university.
The first semester of spring is often the time when the planning of summer camps for young people kicks into high gear at higher education institutions. This is when camps navigate the maze of curriculum, logistics, compliance, and safety precautions that come with hosting a youth camp on campus.
When it comes to compliance and safety, many institutions have child protection policies that camps must follow. These policies generally require camp staff to pass a background check and undergo training related to recognizing and reporting signs of minor abuse before beginning to work at a camp. However, as the U.S. Department of Education (ED) audit of Baylor University Loi Cléry program reveals, this alone is insufficient.
Youth camp staff are Campus Safety Authority (CSA)
In the Final Program Review Determination (FPRD) ED released regarding its audit of Baylor, youth camp staff are specifically referred to as CSA. Helpfully, ED explained why this designation was appropriate, writing that “responsibility for the safety of young campers has been given” to camp staff. In Clery parlance, ED says youth camp staff meet the second criteria listed in the regulations to be a CSA:
Any person or persons who have responsibility for campus security but who are not a campus police department or a campus security department
In the FPRD, ED noted that Baylor did what most institutions do: they provided their youth camp staff with training on miner safety. Importantly, ED took issue with the fact that Baylor youth camp staff were not “officially identified as CSAs or trained to perform CSA duties.” In other words, providing youth camp staff with only minor safety training, while important, will not be enough to pass an ED Clery audit.
This finding has clear implications for all US higher education institutions that host on-campus youth camps: your youth camp staff are CSAs and should be identified as such and trained accordingly.
Considerations for Clery Compliance
As the head of youth protection and Clery compliance efforts for a university, I recognize that youth camp staff are a particularly difficult group of CSAs to manage. This is because these CSAs are very transient. These are often students or employees whose normal campus operation 363 days a year would not make them CSAs, but because they work at a two-day youth camp, they now are.
Ensuring that your camp’s staff training program complies with best practices and the Clery Law doesn’t have to be an insurmountable feat and can be accomplished using your facility’s existing infrastructure.
Consider the following strategies:
- Include anyone who oversees child protection or camps at your facility as a member of your Clery Law Compliance Committee. These people will be needed for advocacy and technical assistance if changes are made to existing youth camp policies, procedures or training.
- Formally identify youth camp staff as CHWs in your facility’s youth protection policy.
- Mandate that all youth camp staff complete both CSA training and minor safety training before beginning to work for a camp. Generate and maintain documentation of trainings and who has been trained. Many camps hold an all-staff meeting just before camp begins to train staff and discuss logistics. This is a great time to deliver tailored CSA training to youth camp staff, discuss available security resources, and talk about the downstream effects of what happens after a CSA reports a crime.
How do campers receive timely warnings?
Speaking of crime reports, this brings us to another camp-related issue to consider: if a CSA reports a crime that triggers a timely warning, how does your institution convey this message to your campers?
Now you might be thinking, “Wait a minute. I thought timely warnings should only be issued to students and employees. Who says they also have to be issued to campers? Excellent question. ED says so.
Clery Law regulations state that when a Clery Law crime is reported to a CSA or local police and the institution determines that it poses a threat to students and employees, the institution must issue a timely warning to its campus community. Who is considered part of your campus community? Enter another illuminating ED FPRD. In the Pennsylvania State University FPRD, ED outlined the composition of a campus community to include, in particular, campers. In this FPRD, ED wrote that institutions “shall issue timely warnings whenever a reportable crime in Clery is reported to a CSA or the police that may pose an ongoing threat to students, employees or other members of the campus community, including guests such as campers or people attending concerts or sporting events.
Considerations for Clery Compliance
Since the ED expects timely warnings to be delivered to campers, a logical starting point to consider is whether your institution even has a process in place to be able to accomplish this. Typically, when an institution issues a timely warning, it does so using emails or text messages. These methods typically capture college or university students and employees, but not their impermanent campers. For institutions that do not yet have a process in place to issue timely warnings to campers, consider the following strategies:
- Contact the person who oversees child protection or camps at your facility to see if there is already a system for camps that can be used or expanded to enable timely warnings to campers.
- If not, consider alternatives. This could be things like developing a process to enroll campers and/or their parents in a messaging group for the purpose of issuing timely warnings; put up signs displaying timely warnings in places frequented by campers (food court, dormitories, sports fields); display timely warnings using electronic reading cards; develop a process where camp staff provide timely warning information to campers and/or their parents; post timely warnings on institutional public-facing social media channels, etc.
- Whatever delivery method your institution uses to issue timely warnings to campers, ensure that it complies with your institutional policies and that documentation is kept of the policies and their execution.
Youth camps can be a challenging component of an institution’s Clery Law compliance program. Building relationships and having discussions with key stakeholders now – during the initial planning stages and before the summer camp season pandemonium – will position your facility well to develop the policies and procedures needed for a camp season. safe and compliant. A season, might I add, which I hope will arrive sooner rather than later.
Elliot Cox is a School Safety Analyst for the Idaho Schools Safety and Security Program and can be reached at [email protected]