Clery Act
Six California Colleges and Universities
We Visited Struggled to Report Accurate
Campus Safety Information
July 2024
REPORT
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Mike Tilden Chief Deputy
Grant Parks State Auditor
July ,
2024‑032
e Governor of California
President pro Tempore of the Senate
Speaker of the Assembly
State Capitol
Sacramento, California
Dear Governor and Legislative Leaders:
As required by section of the Education Code, my oce conducted an audit of sixinstitutions
of higher education (institutions) to determine their compliance with the federal Jeanne
Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act).
Wedetermined that in general the six institutions we reviewed did not fully comply with the
Clery Act’s requirements for safety policies or the accurate reporting of crime statistics.
e six institutions we reviewed reported crime statistics in their annual security reports,
but ve of them did not do so accurately. We also found omissions in four of these institutions’
crime logs—public records that are intended to provide timely information about all criminal
activity on campus. Because of these errors and omissions, current and prospective students,
sta, and other stakeholders may have an inaccurate understanding of campus safety.
Finally, we found that none of the six institutions we reviewed had fully complied with the
Clery Act, federal regulations, and certain state law provisions that require institutions to have
in place specic security policies and disclose these policies in their annual security reports. If
institutions do not disclose all required policies, students and other stakeholders may not have
the information necessary to make informed decisions about their personal security, or they
may not be aware of resources available to help ensure their safety.
Respectfully submitted,
GRANT PARKS
California State Auditor
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Selected Abbreviations Used in This Report
Chico California State University, Chico
Clery Act Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act
CSU California State University
ED U.S. Department of Education
Imperial Valley Imperial Valley College
Mount Saint Mary’s Mount Saint Mary’s University, Los Angeles
Orange Coast Orange Coast College
San Diego University of San Diego
Santa Cruz University of California, Santa Cruz
Title IV Title IV of the Higher Education Act of 1965
UC University of California
VAWA Violence Against Women Reauthorization Act of 2013
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Contents
Summary 1
Introduction 3
Most of the Institutions We Reviewed Reported Erroneous Crime
Statistics and Had Incomplete Crime Logs 11
Institutions Did Not Disclose All Required Campus Safety Information
to Stakeholders and Lacked Some Required Policies 21
Recommendations 31
Appendix A
Crimes and Violations That Institutions Must Report Under
Federal Crime Disclosure Requirements 35
Appendix B
Crime Statistics in the 2023 Annual Security Reports of Six Institutions 37
Appendix C
Six Institutions’ Compliance With Federal Law Regarding the
Disclosure of Security Policies 45
Appendix D
Six Institutions’ Compliance With State Law and Best Practices
Regarding Campus Safety Policies, Procedures, and Programs 53
Appendix E
Scope and Methodology 59
Responses to the Audit
California State University, Chico 61
Imperial Valley College 63
Mount Saint Mary’s University, Los Angeles 67
Orange Coast College 69
University of San Diego 71
University of California, Santa Cruz 73
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Summary
KEY FINDINGS AND RECOMMENDATIONS
To help inform students, employees, applicants, and their parents about campussafety,
the federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics
Act (Clery Act) requires all eligible institutions of higher education (institutions) to
prepare, publish, and distribute annual security reports disclosing specied campus
crime statistics and campus security policies. As required by California state law, we have
reviewed the compliance with these requirements for a selection of six institutions—
California State University, Chico (Chico); Imperial Valley College (Imperial Valley);
Mount Saint Mary’s University, LosAngeles (Mount Saint Mary’s); Orange Coast College
(Orange Coast); University of SanDiego (SanDiego); and University of California,
SantaCruz (SantaCruz)—from across the State. Our review found the following:
• Chico, Imperial Valley, Mount Saint Mary’s, Orange Coast, and SantaCruz reported
statistics that were inaccurate or incomplete to varying degrees. For example,
SantaCruz did not include in its Clery statistics seven of crimes we reviewed,
and Mount Saint Mary’s reported more crimes than it was required to report in
its Clery statistics. Additionally, despite the importance of daily crime logs in
providing accurate, transparent reporting on campus safety, we found incomplete daily
crime logs at Chico, Mount Saint Mary’s, Orange Coast, and SantaCruz.
• e six institutions we reviewed did not disclose to stakeholders all campus safety
policies, procedures, and programs that the Clery Act requires. For example, none
of the institutions fully disclosed campus emergency response and evacuation
procedures. In some cases, institutions disclosed in their annual security reports
information that is required to come from policies, but the institutions did not have
the underlying campus policies that would have included that information. Moreover,
veof the sixinstitutions that are required to comply with specic state requirements,
such as having campus-specic safety plans and memorandums of understanding
with local police departments, did not always fully comply with therequirements.
• ese institutions did not comply with the Clery Act and with state law requirements
because they lack adequate procedures, such as desktop manuals, for sta to follow
when preparing Clery Act reports and because sta have not received sucient
training on the Clery Act and its requirements.
To address these ndings and the fact that over the past years, the State Auditor has
found noncompliance with Clery Act requirements at institutions, we recommend
that the Legislature consider requiring all institutions subject to the Clery Act to undergo
regular, periodic reviews of their compliance with the Clery Act and to publish the
results online. We also make numerous recommendations to the campuses, including
that they establish procedures for sta to follow when compiling Clery Act statistics,
develop guidance for sta preparing annual security reports, and provide training to
these sta to ensure they are aware of all of the Clery Act’s requirements and of all
campus policies and protocols for complying with the CleryAct.
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Agency Perspective
All six institutions agreed with our conclusions and indicated that they will implement
our recommendations to improve their practices and processes for complying with
Clery Act requirements.
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Introduction
Background
To ensure the availability of accurate information for students, employees, applicants,
and parents making decisions about institutions of higher education (institutions),
the federal government enacted the Student Right-to-Know and Campus Security
Act—later renamed the Jeanne Clery Disclosure of Campus Security Policy and
Campus Crime Statistics Act (Clery Act)—to provide transparency around campus
crime policy and statistics. e Clery Act requires institutions that participate in
federal student aid programs under TitleIV of the Higher Education Act of
(TitleIV) to prepare, publish, and distribute annual security reports disclosing
specied campus crime statistics and campus security policies. ese institutions
include both public and private nonprot educational institutions of higher
education and postsecondary vocational institutions.
Among other activities, each institution must publish and distribute an annual
security report each year by October that contains specied crime statistics for
the three previous calendar years and specic statements of existing campus safety
policies and procedures. In addition to federal requirements, state law requires
institutions in California to implement certain types of campus safety policies and
protocols that are more extensive than the Clery Act requires. For example, state law
requires institutions to prepare and prominently post campus safety plans and to
provide educational and preventive information about sex oenses.
is audit focused on six institutions, some public and some private, from across the
State: California State University, Chico (Chico); Imperial Valley College (Imperial
Valley); Mount Saint Mary’s University, LosAngeles (Mount Saint Mary’s); Orange
Coast College (Orange Coast); University of SanDiego (SanDiego); and University of
California, SantaCruz (SantaCruz). We based our selection on a number of factors,
including the number of crimes each institution reported to the U.S.Department
of Education (ED), the institution’s geographic location, the type of institution, and
whether we had previously audited the institution.
Clery Act Requirements
e Clery Act requires institutions to publish an annual security report containing
statistics related to specic crimes, such as murders, robberies, and aggravated
assaults. ese oenses, which we refer to in this report as Clery reportable crimes,
are listed in detail in AppendixA and are grouped into four categories: criminal
oenses; oenses that violate the Violence Against Women Reauthorization Act
of (VAWA), such as domestic violence, dating violence, and stalking; hate
crimes; and arrests and referrals for disciplinary action.
Each institution must distribute its annual security report by October to all enrolled
students and current employees. e institution can fulll that requirement by
posting the report to its website and notifying students and employees of its
availability. Each institution must also notify prospective students and employees of
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the report’s availability and may use methods that include direct mail, campus mail,
or electronic mail; must provide a description of the report’s contents; and must
establish a means of requesting a copy. Additionally, each institution is required to
submit its campus crime statistics annually to ED, which then makes the crime
statistics available on its website so that interested persons can review data for a
specic institution or compare the data for multiple schools.
e Clery Act requires institutions to report
statistics related to crimes that occurred
within specic Clery reporting locations
(Clery geography), described in the textbox.
e institutions must annually report these
statistics for the most recent and twopreceding
calendar years for which data are available.
Federal regulations also require institutions to
make a reasonable, good-faith eort to obtain
and disclose reportable crime statistics from
local law enforcement agencies about crimes
that occur within Clery geography but that
may not have been reported directly to campus
securityauthorities.
Additionally, the Clery Act requires institutions to maintain certain campus policies
and procedures and to include statements of those policies and procedures in
their annual security reports. Table provides a summary of the types of policies,
procedures, and information that institutions must maintain and disclose in their
reports. For example, institutions must include their procedures for students and
others to report criminal actions or other emergencies that occur on campus.
Institutions that provide on-campus student housing must also include statements
describing certain policies and procedures that the institution will follow in the event
of a missing student.
State Law Requirements
State law requires certain institutions in California to implement campus safety
policies and protocols in addition to the federal requirements. State law identies
those institutions it requires to comply with each separate provision. For example,
some requirements pertain only to California State University (CSU) and California
Community College (community college) institutions, whereas other requirements
also apply to private institutions. Further, although many of these provisions appear
to require the University of California (UC) to comply with the requirements, a
separate provision in state law exempts UC’s institutions from these requirements
unless the Board of Regents of the University of California (Regents) adopts a
resolution making each requirement applicable to its institutions. According to UC’s
legal counsel, the Regents have not yet adopted such a resolution. In AppendixD, we
identify each of the provisions in state law and specify whether the institutions we
reviewed complied with each provision as required or as a matter of best practice.
Clery Reporting Locations
Institutions must report statistics related to crimes that occur
in the following locations:
• On campus, including residence halls.
• In or on noncampus buildings or property that an
institution owns or controls.
• On public property that is within a campus or is
immediately adjacent to and accessible from a campus.
Source: Federal law.
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Table 1
Clery Act Requirements
REQUIREMENT CATEGORY*
NUMBER OF
REQUIREMENTS
SUMMARY OF REQUIREMENTS
INSTITUTIONS MUST:
Annual Reports and General CampusSafety
CRIME
REPORT A
9 Disclose policies regarding collecting and reporting crime statistics by types
and location; policies regarding the security and maintenance of campus
facilities; and policies encouraging counselors to inform victims of voluntary
reportingprocedures.
Daily Crime Log and CrimeReporting 7 Maintain, update, and make crime logs available to the public within
certain time frames; make timely warnings to the campus community of
Clery Act crimes; and disclose procedures for individuals to report crimes
andemergencies.
Campus Law Enforcement and
CrimePrevention
4 Disclose policies describing the authority of campus security personnel, the
institution’s relationship with law enforcement, and programs related to
campus security procedures and crime prevention.
Illegal Drugs and Alcohol 3 Disclose policies regarding possession, use, and sale of alcohol and illegal
drugs, including enforcement of underage drinking laws and drug laws,
and describe its programs for alcohol and drug abuse education.
Campus Sex Oense Mitigation Programs 3 Disclose policies that describe programs informing all incoming students
and new employees of domestic violence, dating violence, sexual assault,
and stalking prevention programs and of the institution’s procedures for
addressing such crimes.
Campus Sex Oense Response Procedures 8 Disclose policies that require the institution to provide information to
victims in writing regarding their rights, their options for notifying law
enforcement, and the services available to them.
Disciplinary Action Processes in the Event
of an Alleged Sex Oense
5 Disclose policies that address the procedures for institutional disciplinary
action that may result from alleged sex oenses, including the types of
proceedings and the steps, timelines, and the decision-making process.
Emergency Response and
EvacuationProcedures
11 Disclose policies that explain the institution’s process for conrming and
notifying students, employees, and the larger community of situations
that involve an immediate threat to their health and safety.
Processes in the Event of a Missing
StudentReport
MISSING
9 Disclose policies, including time frames, for notifying local law
enforcement and designated contacts of reported missing persons who
reside in on-campushousing.
Total: 59
Source: Federal law.
* We identied numerous Clery Act requirements and compiled the requirements into 59 items, grouping similar items into ninecategories. For a full list
of the requirements and our assessment of each institution’s compliance with the requirements, see Appendix C starting on page 45.
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Among these provisions, state law requires certain institutions to implement additional
policies related to sexual assault and to provide additional educational and preventive
information about sex oenses, as well as other requirements. State law also requires
most California institutions that receive public funds for student nancial assistance
to implement and prominently post Campus Safety Plans and to enter into
memorandums of understanding with their local law enforcement agencies to clarify
each agency’s responsibilities. ese institutions must adopt certain campus safety
policies in order to receive state funds for student nancial assistance. Moreover, to
receive such state funds, these institutions are also required to enter into agreements
or partnerships to the extent feasible with existing on-campus and community-based
organizations or to otherwise make available to students a variety of assistance
services, such as counseling, mental health services, and victim advocacy.
Institutions We Reviewed and the Processes They Used to Compile and Report Clery
ActStatistics
Institutions we reviewed use dierent processes for compiling and reporting their
Clery crime statistics. Crimes are generally reported by campus security authorities,
which can include campus police; by individuals who are responsible for campus
security, such as monitors at entrances to institutional property; by ocials who have
signicant responsibility for student and campus activities, including student housing
and student discipline; by individuals or organizations that campus security policies
have identied as campus security authorities to which students and employees
should report criminal oenses; and by victims. e Clery coordinator at each
institution compiles the Clery statistics and reports the data to ED and in the annual
security report. Figure shows examples of processes that institutions use to compile
their Clery statistics.
For example, four dierent entities at SantaCruz contribute to reporting Clery
statistics: Risk and Safety Services, the TitleIX oce, the student conduct oce,
and the university police department. SantaCruz’s Clery coordinator, who is housed
within Risk and Safety Services, obtains Clery-reportable statistics from each of the
other three departments, prepares the institution’s annual security report, and sends
the institution’s Clery statistics to ED. Chico and Mount Saint Mary’s also compile
their Clery statistics using multiple data sources.
ree dierent entities at SanDiego—the Department of Public Safety, the TitleIX
oce, and the student conduct oce—also separately record and store their
incident reports, but SanDiego’s Clery coordinator, housed within the Department
of Public Safety, keeps a master spreadsheet of all incidents. She uses that master
spreadsheet to compile the Clery statistics. Imperial Valley has a more streamlined
process—its Campus Public Safety oce uses a single database to record all incidents
that occur on campus. en the oce uses that database to generate the institution’s
Clery statistics. Finally, although Orange Coast’s dierent departments use their
own incident-recording databases, Orange Coast used a new database to track its
Clery-reportable crimes for by pulling data from incident reports located in its
other internal databases.
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Figure 1
Institutions Use Dierent Processes for Compiling and Reporting Clery Statistics
Clery Coordinator
» Generates Clery statistics
based on all records in
Omnigo database.
» Publishes crime statistics in
the annual security report
and reports to ED.
Campus
Public Safety
Oce
(Omnigo
database)
Publishes daily crime logs
Victims and campus security authorities
submit incident reports
EXAMPLE 3—IMPERIAL VALLEY
Clery Coordinator
» Generates Clery statistics
based on an internal master
tracking spreadsheet.
» Publishes crime statistics in
the annual security report
and reports to ED.
Department of
Public Safety
[Automated Records
Management
System (ARMS)
database]
Publishes daily crime logs
Division of
Student
Aairs
(Maxient
database)
Resident
Assistants
and
Community
Directors
Title IX Oce
(emails)
Victims or
campus
security
authorities
submit
incident
reports
EXAMPLE 2—SAN DIEGO
Clery Coordinator
» Obtains data from the Title IX oce,
the student conduct oce, the
university police department, and
from local police departments to
generate Clery statistics.
» Publishes crime statistics in the
annual security report and reports
to ED.
Risk and
Safety
Services
(No central
database)
Publishes daily crime logs
University Police Department
(RIMS database)
Student Conduct Oce
(Advocate database)
Title IX Oce
(iSight database)
Victims and
campus
security
authorities
submit
incident
reports
EXAMPLE 1—SANTA CRUZ
Source: Analysis of institutions’ practices of compiling Clery statistics.
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Government Oversight and Guidance
Both the state and federal governments conduct oversight activities that evaluate
institutions’ compliance with the Clery Act. State law requires the California State
Auditor (State Auditor) to report to the Legislature the results of an audit every
threeyears of not fewer than sixinstitutions that receive federal student aid to
determine those institutions’ compliance with the requirements of the Clery Act and
related state laws. As part of these audits, the law requires the State Auditor to
evaluate the accuracy of the crime statistics the institutions report and the
eectiveness of the procedures the institutions use to identify, gather, and
disseminate these data, as well as the institutions’ compliance with state law
governing crime reporting and the institutions’ development and implementation of
related policies and procedures.
e State Auditor has previously issued
sevenaudit reports related to the Clery Act, as the
textbox shows. ese reports have consistently
found that the institutions reviewed were not
fully complying with Clery Act requirements.
For instance, the report found that of the
sixinstitutions we reviewed, the four institutions
that reported crimes had errors in their reported
crime statistics, and veinstitutions did not
provide complete information about important
campus safety policies to current and prospective
students andemployees.
At the federal level, ED also conducts reviews to
evaluate institutions’ compliance with Clery Act
requirements. ese reviews can be initiated in a
variety of ways, including through complaints ED
receives from students, employees, or the public.
e ndings from its reviews can lead ED to issue nes of up to approximately
, for each violation, an amount that ED adjusts annually for ination. In
March, ED ned Liberty University of Virginia million for serious and
persistent violations of the Clery Act, such as inaccurate crime statistics and an
inability to conduct competent investigations and to ensure that the needs of sexual
assault survivors were met.
In ED ned the University of California, Berkeley (Berkeley) .million for
Clery Act violations and for a lack of sucient administrative capability to oversee
itsClery Act reporting. According to ED’s published review, Berkeley did not develop
and implement an adequate system of policies, procedures, programs, training,and
internal controls to reasonably assure compliance with the requirements of the
Clery Act. ED’s review found that among other violations, Berkeley did not report
hate crimes in twoannual security reports and did not disclose security policies in
multiple annual security reports.
The State Auditor issued seven previous audit
reports on the Clery Act on the following dates:
• December 2003
• January 2007
• January 2010
• October 2012
• July 2015
• May 2018
• May 2021
Source: State Auditor’s Clery Act audit report numbers 2002-032,
2006-032, 2009-032, 2012-032, 2015-032, 2017-032, and 2020-032.
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To assist institutions in meeting Clery Act requirements, ED published guidance
in in a -page document called e Handbook for Campus Safety and Security
Reporting. However, ED rescinded that guidance in October because it was
outside of the scope of the relevant statutory and regulatory authority, although it is
still archived on the department’s website. Instead, institutions may nd information
in federal student aid handbooks about Clery Act requirements. For example, oneof
the now-rescinded changes was ED’s guidance about which buildings and
properties institutions must report as part of their Clery geography. Specically,
the handbook recommended that institutions include any public property
that is within a one-mile radius from a campus property in their Clery-reportable
geography. However, the Clery Act and federal law and regulations do not prescribe
a specic distance from campus when dening Clery-reportable public property,
instead describing such public properties as thoroughfares, streets, sidewalks, and
parking facilities that are within, immediately adjacent to, or accessible from the
campus. According to ED, the handbook improperly dened public property in
a way that was not compliant with federal law.
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Most of the Institutions We Reviewed Reported
Erroneous Crime Statistics and Had Incomplete
Crime Logs
Key Points
• Chico, SantaCruz, and Mount Saint Mary’s did not track their Clery-reportable
incidents in a central location, which has led to SantaCruz underreporting
crimes and Mount Saint Mary’s overreporting crimes in their Clery
statistics compared to what each institution marked as Clery-reportable.
Further, although SanDiego maintained a central database, it also overreported
one incident. ese reporting errors can mislead interested parties, such as
prospective students, about campus safety.
• Five of the six institutions we reviewed—Chico, Imperial Valley, Mount
Saint Mary’s, Orange Coast, and SantaCruz—reported statistics that were
inaccurate or incomplete to varying degrees, which may be misleading
students, sta, and faculty about safety risks on or around the campus. For
example, SantaCruz underreported seven of crimes we reviewed in its
Clery statistics, with an overall error rate of percent, whereas Mount Saint
Mary’s overreported of crimes we reviewed, with an overall error rate of
percent.
• Four of the six institutions—Chico, Mount Saint Mary’s, Orange Coast,
and SantaCruz—had incomplete daily crime logs, which could obscure
stakeholders’ ability to understand campus safety on an incremental,
day-to-day basis. ese four institutions were missing between and
crimes from their daily crime logs out of about crimes we reviewed for
each institution.
The Lack of Written Procedures or the Absence of a Central Clery Database Led
FiveInstitutions to Report Erroneous Crime Statistics
As we describe in the Introduction, the institutions we reviewed use dierent
processes for compiling their Clery statistics. However, none of the six institutions
we reviewed had documented procedures for their sta to follow for compiling Clery
statistics. In addition, when compiling the Clery statistics, Chico, Mount Saint
Mary’s, and SantaCruz did not track Clery crimes in a central database. As Table
shows, institutions that maintained Clery data centrally were less likely to make
signicant systemic reporting errors.
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Table 2
Institutions That Maintained Clery Data Centrally Were Less Likely to Make Signicant ReportingErrors
CAMPUS
MAINTAINED
CENTRAL CLERY
DATABASE
NUMBER OF CLERY CRIMES
REPORTED TO ED
NUMBER OF CRIMES INSTITUTIONS
MARKED AS CLERY CRIMES IN
THEIR INTERNAL DATABASES
DIFFERENCE
Chico No 62 61 1
(2%)
Imperial Valley Yes 2 2 0
Mount Saint Mary’s No 27 12 15
(56%)
Orange Coast Yes 159 159 0
San Diego Yes 216 215 1
(0.5%)
Santa Cruz No 672 705 33
(5%)
Source: Review of each institution’s reported Clery crimes and internal Clery tracking documents.
Note: This table is based on our review of total Clery statistics each institution reported to ED in 2022 and the number of Clery crimes that
each institution marked as Clery-reportable in their internal databases. These data may include crimes that institutions inaccurately marked
as Clery-reportable. The results of our sample testing of accuracy of the data reported to ED are presented in Table 3.
We reviewed the total number of Clery crimes that institutions reported to ED to
determine whether those numbers aligned with the total number of crimes each
institution marked as Clery-reportable in their internal documents. We observed
that the number of Clery crimes that Mount Saint Mary’s and SantaCruz reported
to ED for calendar year were signicantly dierent from the number these
institutions had identied as Clery-reportable in their internal databases. Specically,
SantaCruz reported crimes to ED, but we identied Clery-reportable
incidents in the institution’s internal databases—a dierence of cases. Mount Saint
Mary’s reported incidents, but we identied only Clery incidents in its internal
databases—a dierence of cases.
e reason these two institutions reported inaccurate crime statistics involves the
way they tracked the Clery-reportable crimes. Although SantaCruz stated that its
previous Clery coordinator generally tracked in a central location all Clery-reportable
crimes, that Clery coordinator left her position before compiling the Clery
statistics, and SantaCruz relied on other sta in its Risk and Safety Services oce to
compile those statistics. In the absence of written guidance, the sta in the Risk and
Safety Services oce did not use the les that the previous Clery coordinator used,
and they did not have access to the databases that the university police department,
the TitleIX oce, or the Student Conduct oce use. As a result, the sta at the Risk
and Safety Services oce compiled the statistics that each of the departments gave
them but did not check the accuracy of those numbers. e university explained
that the Risk and Safety Services oce mistakenly thought the data had been
cross-checked by the former Clery coordinator.
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Similarly, Mount Saint Mary’s did not use a central Clery repository to track incidents
for calendar year , which led to its overreporting a signicant number of crimes
in its Clery statistics. e institution generally uses two dierent databases to
record incidents—the Campus Safety and Emergency Management oce maintains
incident records in a shared drive, and the Division of Student Aairs maintains incident
records in a dierent database to which the Clery coordinator does not have access.
e former Clery coordinator explained that to compile the Clery statistics
she identied the Clery-reportable crimes from the records that the Public Safety
oce maintained and she requested the number of Clery crimes that the Division of
Student Aairs maintained in its database. e Division of Student Aairs provided
her with aggregate Clery numbers that did not allow the former Clery coordinator to
readily check the accuracy of those data. e sta at the Division of Student Aairs
explained that they mistakenly provided her with Clery-reportable crimes for the
academic year instead of the calendar year, as Clery Act requires. As a result,
the institution reported more Clery crimes than it should have. e institution
became aware of these errors after we started this audit, and it plans to correct the
reporting for with ED and to issue a revised annual security report for.
In its annual Clery statistics, Chico also reported one more crime than we
identied to be Clery-reportable. We highlight this single error because it resulted
from Chico’s not maintaining in a central location the data related to all Clery
crimes. Instead, the institution relied on the university police department to provide
the Clery coordinator with the police department’s Clery-reportable statistics in an
aggregate format, which did not include case numbers and therefore made it dicult
for the Clery coordinator to check the accuracy of the statistics. However, the
university police department has since changed this process, and currently the Clery
coordinator receives additional details on cases that come from the university police
department’s database, allowing her to check the accuracy of the statistics.
In contrast, the other three institutions—Imperial Valley, Orange Coast, and
SanDiego—tracked Clery-reportable crimes in a central location, which allowed
the institutions to cross-check incidents reported by dierent departments and
thereby reduce the risk of including duplicate crime reports or of not including
Clery-reportable crimes. For example, SanDiego’s Department of Public Safety
collected all crime data across the institution’s departments, including the TitleIX
oce and the Division of Student Aairs, and cross-checked it all within its internal
tracking system before generating the annual security report. SanDiego’s Clery
coordinator maintained a master spreadsheet in which she documented all incidents
that met the criteria for Clery reporting. She then identied and documented the
origin of each incident and cross-checked all databases to ensure that duplicates were
not included. is process ensured accurate reporting of SanDiego’s Clery statistics.
We found that SanDiego also reported to ED onemore Clery incident than we found
in its database, as we discuss later. However, our review of a sample of crimes did
not identify any reporting errors for SanDiego.
In addition to verifying the total number of Clery crimes each institution reported
to ED, we also reviewed a selection of crimes at each institution to evaluate the
accuracy and completeness of their reported Clery statistics. To determine whether
the institutions reported their Clery crimes in the appropriate categories, wereviewed
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a selection of up to incidents that each of the
sixinstitutions reported as Clery crimes for calendar
year .
1
We also reviewed a separate selection of
at least crimes at each institution—those identied
by the institution as both Clery-reportable and as
non-Clery-reportable—to assess whether the
institutions appropriately included or excluded
incidents from their Clery statistics. Our review
revealed threetypes of errors: overreporting,
underreporting, and misreporting, as the textbox
describes. We found that Chico, Imperial Valley,
Mount Saint Mary’s, Orange Coast, and SantaCruz
reported erroneous Clery crime statistics, as
Tableshows.
Table 3
Five of the Six Institutions We Reviewed Reported Inaccurate Crime Statistics
REPORTING ERRORS WE FOUND
CAMPUS
NUMBER OF CLERY
AND NONCLERY
CRIMES REVIEWED
UNDERREPORTED
OVERREPORTED MISREPORTED ERROR RATE
Chico 65* 4 8 0 18%
Imperial Valley 32
†
1 1 0 6
Mount Saint Mary’s 57
†
1 16 0 30
Orange Coast 60 1 7 2 17
San Diego 69
‡
0 0 0 0
Santa Cruz 60 7 2 0 15
Source: Analysis of crime statistics each institution reported to ED.
* Chico provided an additional pool of cases after we created our initial sample of 60. As a result, we selected an additional ve
crimes for a total of65.
†
Imperial Valley reported only two Clery crimes, and Mount Saint Mary’s reported only 27 Clery crimes for 2022. Therefore,
our review included all of their reported Clery crimes and 30 non-Clery crimes for each institution.
‡
Because we identied higher risk for certain crimes not being included in the Clery statistics, we tested a total of 69crimes
for San Diego, including 30 Clery and 39 non-Clery crimes.
Underreporting
Chico, Imperial Valley, Mount Saint Mary’s, Orange Coast, and SantaCruz
underreported crimes to varying degrees, as Table shows. Underreporting may
occur when an institution improperly records a crime as not Clery-reportable or
when a department does not disclose a Clery-reportable crime to the university’s
1
If an institution reported fewer than Clery-reportable crimes, we reviewed all crimes.
Types of Reporting Errors
Underreported: A Clery-reportable crime was not
reported as required.
Misreported: A Clery-reportable crime was reported in
the wrong category.
Overreported: An incident was erroneously reported as
a Clery crime or was erroneously counted in more than
onecategory.
Source: California State Auditor’s interpretation of federal
regulations and review of crime reports.
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Clery coordinator. When an institution does not accurately report crimes occurring
on or near its campus, interested parties—such as current and prospective employees
and students—may be unaware of serious incidents that have taken place on campus.
SantaCruz did not report in its Clery statistics multiple instances of serious
crimes, including dating violence, domestic battery, and rape. Our review of
crimes at SantaCruz for that year found that the institution did not include
sevenreportable crimes in its Clery statistics. ese included vereports from the
TitleIX oce that involved stalking, sexual violence and sexual harassment, rape,
and dating violence; onealcohol-related disciplinary referral from the Student
Conduct oce; and onecase from the local police department, involving burglary.
SantaCruz did not report these seven crimes because it lacked written procedures
for compiling Clery statistics. e signicance of this deciency became more
evident when the person who normally compiled Clery statistics left the institution.
SantaCruz’s previous Clery coordinator had sent requests to individual departments
within the institution, including the university police department, the TitleIX oce,
and the Student Conduct oce, and to outside local law enforcement agencies when
she was compiling Clery statistics, asking them to provide her with Clery-reportable
crimes. However, she left her position in June, and the Risk and Safety Services
oce assigned an interim project coordinator to compile the Clery statistics.
SantaCruz explained that it did not report any TitleIX incidents or incidents from
local law enforcement agencies in because the interim coordinator was not aware
of the need to request Clery statistics from the TitleIX oce nor aware of the need to
separately request statistics from the local law enforcement agencies; she thought they
were already included in statistics provided by the university policedepartment.
By not including these serious crimes in its Clery statistics as required, SantaCruz
presented its campus as safer than it was. e institution became aware of its
underreporting after we began our audit, and it agreed that it should implement
procedures, such as written guidance for its sta to follow when compiling the Clery
statistics, to ensure that it reports all Clery crimes. Additionally, SantaCruz sta
indicated that they are working on revising their Clery statistics to resubmit
them to ED.
Similarly, other campuses underreported serious crimes in their Clery statistics
because, as we noted, they lacked written procedures that would ensure accurate
reporting, such as guidance for sta to follow when making determinations about
whether a crime is Clery-reportable. Chico did not report an arrest for illegal weapon
possession related to an aggravated assault case. In this case, Chico should have
reported the incident as twoseparate crimes—one for the act of aggravated assault
and another for the act of possessing an illegal weapon—as the Clery Act requires.
Imperial Valley improperly determined that it should not report an intimidation hate
crime because the case was under investigation by local law enforcement. However,
law enforcement had not determined that this case was unfounded; therefore, it
was inappropriate for Imperial Valley to omit this reported crime from its statistics.
Mount Saint Mary’s did not report one case of a drug law violation in its Clery
statistics although the institution had correctly categorized it as such in its internal
database. Orange Coast did not report a referral for disciplinary action for a drug law
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violation that occurred at student housing because the institution ultimately did not
initiate a disciplinary action against the student, and sta erroneously determined that
the referral was therefore not reportable. However, federal law requires institutions to
report all referrals for disciplinary actions, regardless of whether disciplinary actions
were taken.
Misreporting
We found that Orange Coast misreported crimes in its Clery statistics. Misreporting
occurs when an institution correctly identies a crime as Clery-reportable but does
not report the crime under the correct Clery category or does not correctly document
the location of the crime. Reporting crimes in the wrong category or location deprives
interested parties of accurate information about the nature of thosecrimes.
Our review of Clery crimes at Orange Coast revealed that the institution
reported two crimes in the wrong Clery category, including an incident of hate crime
intimidation that the institution reported as domestic violence.
2
In that incident,
a student physically intimidated another student and used derogatory language
aimed at the victim’s sexuality while the two were living together in student housing.
Orange Coast reported the incident to ED as domestic violence. However, our review
of the case narrative suggests that the institution should have reported the incident
as a hate crime of intimidation based on sexual orientation.
Like the other institutions we reviewed, Orange Coast did not have written
procedures to guide its compilation of Clery statistics. e institution had hired
an outside consulting rm to compile the crime statistics for its annual
security report. e consultant categorized as domestic violence certain incidents
that occurred in the institution’s student housing and that involved violence between
roommates. When asked why, the consultant claimed that she used the state
denition of domestic violence, as directed in the Clery law. She further explained
that California law denes acts of violence between roommates, even those not in a
romantic relationship, as domestic violence.
However, we disagree with Orange Coast’s consultant’s interpretation of state law.
Domestic violence was added as a reportable category to the Clery Act as a result
of VAWA. Federal law denes domestic violence for purposes of the Clery Act as
violence committed by a spouse, an intimate partner, a person with whom the
victim shares a child, and other similar relationships. Federal law further extends the
denition of domestic violence to include violence against an adult or youth victim
protected under the domestic or family violence laws of the jurisdiction in which
the crime of violence occurred. In this regard, although state law denes domestic
violence for certain purposes to include abuse perpetrated against a cohabitant, state
case law limits the denition of cohabitants for these purposes to individuals who
live together as a group with a common goal or a social unit living together with
some permanency in their living arrangement. erefore, in California, violence that
2
Clery categories are dened in Appendix A.
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occurred between student roommates who neither live together with a common goal
nor in a permanent arrangement should not be classied as domestic violence for
Clery purposes.
Overreporting
Finally, we found that Chico, Imperial Valley, Mount Saint Mary’s, Orange Coast,
and SantaCruz overreported their Clery statistics, potentially leading interested
parties to conclude that campuses were more dangerous than they actually were. As
we noted earlier, all veinstitutions also underreported crimes, which potentially
presents conditions as safer than they are. Underreporting is therefore a more
egregious error than overreporting. However, overreporting also presents inaccurate
data and could lead people to erroneously avoid a campus that may be a good t.
Overreporting also results from institutions’ lacking procedures, such as guidance
with clear denitions of crimes that are Clery-reportable, that would help ensure
accurate reporting. An institution overreports when it reports more crimes in
its annual security report than the number of crimes that actually qualify as
Clery-reportable. is may occur when an institution reports an incident that does
not fall under the denition of a Clery-reportable crime or when an institution
improperly reports multiple crimes during a single incident.
An institution can also overreport when it mistakenly reports crimes that took
place outside its Clery-reporting geography, as Chico did when it reported multiple
such crimes. e patrol jurisdiction of Chico’s university police department extends
beyond the campus and beyond its Clery geography. As a result, Chico reported
crimes that occurred within the university police department’s patrol jurisdiction
but not within the institution’s Clery geography. We found that of the crimes
that we reviewed for Chico, the institution overreported eight. Of these eight crimes,
sevenoccurred inside Chico’s patrol jurisdiction but not in the institution’s Clery
geography and should therefore not have been included in Chico’s Clery statistics.
Another reason institutions overreport Clery crimes is that sta at institutions
do not always know how to classify incidents and sometimes mark incidents as
Clery-reportable when they are not sure of the correct classication. A lieutenant at
Chico’s university police department explained that when university police ocers
are not sure whether an incident is Clery-reportable, they mark it as such to avoid
the risk of underreporting. Chico’s Clery coordinator said that she does not have
access to the university police department’s electronic records and that she relies on
the statistics that the department provides to her. As a result, she reported all crimes
that the university police department provided and did not verify whether they were
within the institution’s Clery geography.
For similar reasons, Imperial Valley, Orange Coast, and SantaCruz overreported
certain crimes in their Clery statistics. Both Imperial Valley and SantaCruz
overreported incidents of liquor law violations. e Clery act requires that institutions
report arrests or referrals for disciplinary actions for liquor law violations. For the
purposes of Clery Act reporting, liquor law violations include underage alcohol
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possession but do not include cases of intoxication or violations of campus drinking
policies. Imperial Valley inappropriately reported an incident of intoxication as a liquor
law violation, and SantaCruz inappropriately reported a disciplinary action for campus
policy violation as a liquor law violation.
Orange Coast overreported seven incidents, including incidents that it mischaracterized as
domestic violence, stalking, and aggravated assault. For example, Orange Coast inappropriately
marked an incident of simple assault as aggravated assault. Except for incidents involving
hate crimes, simple assault is not reportable under the Clery Act, but aggravated assault
is. By improperly reporting a simple assault as an aggravated assault, Orange Coast may
be portraying that its campus is more dangerous than it may be.
Four of the Six Institutions Did Not Maintain Complete, Up-to-Date Daily Crime Logs and
May Misinform Interested Parties About Campus Safety
e Clery Act requires that institutions report in their annual Clery statistics some of the
most serious crimes occurring during the prior three calendar years. To provide more
immediate information, the Clery Act also requires institutions with campus police or
security departments to maintain daily logs of all crimes reported to them, including
crimes that are not reportable in the annual Clery statistics, such as simple assault and
theft when not related to a hate crime and driving under the inuence. Daily crime logs
provide current information and contain crimes and incidents not covered by the reporting
requirements of the annual Clery statistics, providing a potentially more comprehensive
overview of campus safety when paired with the annual Clery reports.
Institutions must enter all reported crimes into their crime logs within twobusiness days
of the report being made to campus police or security departments, unless disclosureof
such information is prohibited by law or would jeopardize the condentiality of thevictims.
Federal law requires institutions to make these daily crime logs available to the public for
the most recent -day period. State law requires institutions to compile and provide to
current and prospective students and sta within twobusiness days of their request all
reported incidents that happened on campus.
Despite the importance of daily crime logs in providing accurate information about
campus safety, we found incomplete daily crime logs at fourof the sixinstitutions we
reviewed. All sixinstitutions reported Clery crimes in and maintained daily crime
logs. As part of our review for the accuracy and completeness of crimes the institutions
reported to ED, we determined whether each institution had recorded those crimes in its
daily crime log by reviewing the underlying support, such as incident reports. As Figure
shows, four institutions—Chico, Mount Saint Mary’s, Orange Coast, and SantaCruz—
were missing a signicant number of crimes from their daily crime logs, ranging from
to crimes out of about crimes we reviewed for each institution. We did not identify
any missing crimes from Imperial Valley’s or SanDiego’s daily crime logs.
Students, sta, and faculty may report to institutions’ TitleIX or Student Aairs oces
incidents of serious crimes, such as rape, aggravated assault, or domestic violence. In many
instances, the victims of crimes decide not to pursue further investigation, and therefore
these incidents do not get reported to the campus police or campus security departments.
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Figure 2
Four of the Six Institutions We Reviewed Did Not Include All Crimes in Their Daily Crime Logs
1
13
1
3
3
1
Burglary
Drug or Liquor Law Violation
Attempted Rape
Sexual Harassment
Assault
Disorderly Conduct
Santa Cruz
1
1
1
10
1
3
1
1
3
2
1
Fondling
Robbery
Burglary
Drug Law Violation
Liquor Law Violation
Hate Crime—Intimidation
Dating Violence
Domestic Violence
Stalking
Harassment
Vandalism
Orange Coast
1
5
5
2
1
2
1
Robbery
Drug Law Violation
Liquor Law Violation
Dating Violence
Intimidation
Theft
Forgery
Mount
Saint Mary’s
1
1
7
1
2
2
2
1
Robbery
Aggravated Assault
Liquor Law Violation
Domestic Violence
Stalking
Sexual Assault
Sexual Misconduct
Harassment
Chico
Source: 2022 crime reports and daily crime logs from Chico, Mount Saint Mary’s, Orange Coast, and Santa Cruz.
Note: We reviewed the same crimes we reviewed for determining the accuracy and completeness of institutions’ Clery statistics.
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Although federal law requires institutions to maintain daily crime logs on only
crimes reported to campus police and security departments, institutions may mislead
interested parties about the safety of their campuses when they do not include in
their crime logs serious crimes that were reported to their other departments.
We found that the primary reason institutions did not include certain types of incidents
in the daily crime logs is that dierent departments, such as the TitleIX and student
conduct oces, did not report to the campus security oce the incidents that were
reported to them. e campus security oce or the campus police department at
each institution maintains the daily crime logs according to the incidents reported to
it. For example, Orange Coast’s campus Public Safety oce generates its daily crime
log from incidents that populate its reporting software system. Other departments,
such as the housing department, the TitleIX oce, and the Student Conduct oce,
use dierent reporting software to record incidents that occurred on campus; these
departments did not report those incidents to the Public Safety oce. As a result,
Orange Coast did not include in its daily crime log crimes—about percent
ofcrimes we reviewed—that it could have included. Some of the most serious of
the crimes that Orange Coast did not include in the daily crime log were robbery,
stalking, domestic violence, and dating violence. Orange Coast’s campus safety
oce sta agreed with our conclusions that certain crimes were missing from its
daily crime logs. e sta explained that they changed their process in
for maintaining daily crime logs to ensure that the institution includes all crimes in
the daily crime logs by directing its dierent departments to forward to the campus
safety oce all the crimes reported to them.
Similarly, Chico’s university police department generates the institution’s daily crime
log using its internal system, but the rest of the campus uses a separate system to
log incidents and therefore must forward the incidents to the university police
department for the campus police to include the incidents in the daily crime logs.
When victims or campus security authorities do not directly report incidents to the
university police department, Chico’s Clery director communicates those incidents to
the university police department to ensure they are recorded in the daily crime log.
However, we observed that Chico’s daily crime log did not include cases of liquor and
drug law violations in which an arrest did not occur. ese incidents involved cases in
which the institution responded to the incident and the university police department
was not involved. Chico’s Clery director did not communicate these crimes to the
university police department, and as a result, the university police department
did not include in its daily crime logs the drug and liquor law violations related to
referrals for such violations. Chico explained that it has since implemented additional
administrative controls to ensure that the university police department evaluates
reports of crimes originating outside the department for inclusion in its daily crime log.
Similar to Chico, sta at the TitleIX and Student Conduct oces at Mount Saint
Mary’s and SantaCruz also did not communicate the crimes that were recorded in
their other databases to the sta in charge of producing the institutions’ daily crime
logs. Consequently, the campus public safety or campus police departments that
maintain the daily crime logs did not include those incidents in the logs. As a result,
incidents of theft were missing from Mount Saint Mary’s log and incidents of sexual
harassment and attempted rape were missing from SantaCruz’s daily crimelog.
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Institutions Did Not Disclose All Required
Campus Safety Information to Stakeholders and
Lacked Some Required Policies
Key Points
• e six institutions we reviewed did not have or did not disclose all policies,
procedures, or programs required by the federal Clery Act to inform the
public of how these institutions ensure campus safety.
• None of the six institutions we reviewed fully complied with additional state
requirements and best practices to maintain certain crime reporting, tracking,
and safety policies and protocols.
The Six Institutions Did Not Fully Disclose Policies, Procedures, or Programs That the
Clery Act Requires
None of the institutions fully disclosed all statements of policies involving campus
emergency response and evacuation procedures, and none of the institutions fully
complied with specic reporting requirements pertaining to alleged sex oenses. All
sixinstitutions also disclosed in their annual security reports statements of policies
for which no such policies exist.
We identied and consolidated the numerous requirements of federal law into
policies, procedures, and programs that the law requires institutions to have and,
in most instances, to disclose in their annual
security reports. We organized these requirements
into nine categories, as the textbox shows. Our
review consisted of a two-part test. First, we
determined whether each institution had the
necessary policies, procedures, or programs that
fully complied, partially complied, or did not
comply with the Clery Act requirements. For
example, if an institution had a policy, procedure,
or program that did not include some or all of the
specic information the Clery Act requires, we
assessed the institution’s documentation as
partially compliant or noncompliant, respectively.
Second, we determined whether each institution
disclosed the specied information in its annual
security report and whether the disclosure was
consistent with its policies, procedures, and
programs. If a disclosure did not fully match the
institution’s policies or did not exist in policy, we
assessed the disclosure as partial or
unsupported,respectively.
Nine Categories of Policies, Procedures, and
Programs Institutions Must Develop or Disclose
• Annual reports and general campus safety
• Daily crime log and crime reporting
• Campus law enforcement and crime prevention
• Illegal drugs and alcohol
• Campus sex oense mitigation programs
• Campus sex oense response procedures
• Disciplinary action processes in the event of an alleged
sexoense
• Emergency response and evacuation procedures
• Processes in the event of a missing student report
Source: Review of federal laws related to Clery Act requirements.
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Appendix C lists all federal requirements we reviewed, and it identies whether
the institutions fully disclosed required information. Although Chico and SantaCruz
largely complied with the federal requirements and disclosed a vast majority of the
required policy statements or descriptions of processes and programs in their annual
security report, none of the sixinstitutions we reviewed fully disclosed all required
policies, procedures, and programs, as Figureshows.
Figure 3
The Six Institutions Did Not Fully Comply With or Disclose All 59 Clery Act Campus SafetyRequirements
We found noncompliance with the
largest number of requirements in
the following categories:
1. Emergency response and
evacuation procedures
2. Processes in the event of a
missing student report
3. Campus sex oense
response procedures
4. Disciplinary action processes in
the event of an alleged sex oense
Not Applicable—The institution
is not required to disclose this
security policy because it does
not have student housing.
The institution has not enacted
a campus policy to support
its disclosure.
Partially Disclosed*
Not Disclosed
Fully Disclosed
Santa Cruz
San Diego
Orange Coast
Mount
Saint Mary’s
Imperial
Valley
Chico
Source: Analysis of federal law and institutional policies, procedures, and programs and each institution’s annual security report.
Note: Refer to Appendix C in this report for additional detail on each institution’s results for each of the 59 requirements.
* An institution only partially satised the Clery Act when the requirement included multiple components and the institution did not disclose each
required component or when the institution’s policy, procedure, or program did not address each component.
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Missing Disclosures
According to ED, the Clery Act is rst and foremost a consumer information
initiative based on the premise that students and employees should have the
information they need to take steps for their own safety and security. Accurate and
complete disclosure of policies and a clear articulation of the institution’s programs
are essential to that goal and allow the members of the campus community to be
more fully informed and actively provide for their own safety. Any failure in this area
deprives the campus community of vital campus safety information and eectively
negates the intent of the Clery Act.
In one of the nine categories—emergency response and evacuation procedures—none
of the institutions fully disclosed all statements of policies, as TableC.2 in AppendixC
shows. Specically, for oneto of the requirements in this category, each of the
sixinstitutions did not comply with or only partially complied with the requirement
or it disclosed information that was not supported by its policies. Chico fully disclosed
all required procedures in this category except one. Mount Saint Mary’s did not fully
comply with or disclose nineof the requirements. Similarly, SanDiego did not
fully comply with or disclose of the required procedures in this category. For
example, neither institution disclosed in its annual security report a policy stating that
emergency response and evacuation tests may be announced or unannounced and that
the testing procedures include documenting specic information related to each test.
As ED noted in a recent review of an institution in another state, by not including this
information and other disclosures, institutions do not allow the campus community to
be more fully informed and actively provide for their own safety.
None of the institutions we reviewed fully complied with all requirements in the
threecategories related to alleged sex oenses. Federal law requires institutions
to disclose policy statements or other disclosures; we compiled these into the
threecategories.
However, the sixinstitutions individually did not fully disclose from
oneto of these requirements. Imperial Valley, Mount Saint Mary’s, and Orange
Coast fully disclosed veor fewer of the requirements. For example, federal law
requires each institution to disclose in its annual security report a statement of policy
asserting that it will provide written notication and assistance to victims about
options for reasonable accommodations, regardless of whether the victim chooses
to report the crime to campus police or to law enforcement. However, Imperial
Valley did not have such a disclosure in its report. Although Mount Saint Mary’s
included a statement of the related policy in its annual security report, the statement
indicates only that a sta member from the institution will discuss the availability
of such accommodations with students who are victims. e statement did not
assert that the institution will provide victims with written notication of their
options for such measures, as the Clery Act requires. We provide in AppendixC
the complete results of our review of all six institutions’ compliance with each of the
federalrequirements.
3
The three categories are Campus Sex Oense Mitigation Programs, Campus Sex Oense Response Procedures, and
Disciplinary Action Processes in the Event of an Alleged Sex Oense.
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Lacking Policies
We found that the six institutions also did not have all underlying policies for the
required statements, as Table shows. Further, each institution disclosed in its annual
security report statements for which it did not actually have policies. For example,
although Chico disclosed eight of the ninerequired statements in the category related
to missing students, the institution did not have underlying policies or procedures
for any of the nine required statements, including a policy that requires any report of
a missing student be referred immediately to its campus police or campus security
department. Similarly, SantaCruz disclosed eight of the ninerequired statements
in the same category, but we found that, in addition to the requirement it did not
disclose, the institution did not actually have underlying policies to support threeof
these statements. For example, SantaCruz did not havepolicies that included the
requirement that it notify local law enforcement withinhours of a missing student
report. By not having these policies, institutions might delay law enforcement’s ability
to locate a missing person.
ED has also found such instances to be concerning. In a recent compliance review of
an institution in another state, ED expressed concerns about the institution’s missing
certain policies and procedures completely or not accurately or fully developingthem.
However, of even greater concern to ED was the fact that the institution included
statements of policy and procedure that did not accurately describe actual institutional
practices. ED reported that in most of these cases, the institution published disclosures
that appeared to meet federal requirements but simply did not align with the
institutional operations. Without having the underlying documented, written policies
that align with the disclosures they make in their annual security reports, institutions
increase the risk that they may not follow the statements they disclose to the campus
community and to prospective students and sta.
Sta at four of the six institutions generally explained that sta turnover and overall
inexperience and a lack of understanding of the Clery Act’s requirements may have
resulted in their not including certain statements in their annual security reports and
in the institutions’ not having all required policies. For example, Imperial Valley’s
associate vice president of human resources said she believes that management
turnover is the primary cause of Imperial Valley’s diculties complying with
the Clery Act because that turnover has led to a loss of institutional knowledge,
disruption in trainings, and delays in policy updates. She also explained that prior to
our audit, she was not familiar with all Clery Act requirements.
SanDiego’s Clery Act compliance manager said she strongly believes that additional
specialized Clery-specic training would be useful for sta campus wide, particularly
for sta involved in preparing crime reports and serving on the institution’s Clery
committee. e compliance manager indicated that she shares some training
opportunities, such as webinars, with other Clery committee members and relevant
campus partners, but the university does not require its sta to take any specic
Clery Act training. Ocials at the other four institutions also agreed that regular
training on Clery Act requirements and updates would help ensure that sta in
campus safety and student aairs departments—which generally are involved with
Clery Act reporting—would be able to better meet Clery Act requirements.
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Table 4
All Six Institutions Had More Than 10 Policies, Procedures, or Programs That Did Not Fully Comply With Clery Act
Requirements or Did Not Exist
SUMMARY OF POLICIES, PROCEDURES, AND
PROGRAMS THE CLERY ACT REQUIRES
NUMBER OF POLICIES, PROCEDURES, AND PROGRAMS THAT
DID NOT FULLY COMPLY WITH CLERY ACT REQUIREMENTS
REQUIREMENT CATEGORY
TOTAL
REQUIREMENTS
CHICO
IMPERIAL
VALLEY
MOUNT SAINT
MARY’S
ORANGE
COAST
SAN DIEGO SANTA CRUZ
Annual Reports and General
Campus Safety
9 0 0 1 1 1 0
Daily Crime Log and
CrimeReporting
7 0 0 1 1 3 2
Campus Law Enforcement
and Crime Prevention
4 0 3 2 1 1 1
Illegal Drugs and Alcohol 3 0 1 0 0 0 0
Campus Sex Oense
Mitigation Programs
3 0 3 3 1 3 1
Campus Sex Oense
Response Procedures
8 2 5 3 6 2 0
Disciplinary Action Processes
in the Event of an Alleged
Sex Oense
5 1 4 3 4 1 0
Emergency Response and
Evacuation Procedures
11 0 5 2 3 10 3
Processes in the Event of a
Missing Student Report
9 9 N/A* 3 6 2 4
Total Not Fully Complied 12 21 18 23 23 11
Total Fully Complied 47 29 41 36 36 48
Compliance Rate 80% 58% 69% 61% 61% 81%
Legend: Fully Compliant Not Compliant
Source: Analysis of federal law and institutional policies, procedures, and programs and each institution’s annual security report.
* These requirements pertain only to institutions with on-campus housing, and Imperial Valley does not have on-campus housing. We calculated its
compliance rate accordingly.
Given the lack of compliance we identied, institutions can likely benet by
developing written procedures and tools to guide sta in preparing annual security
reports that include all required disclosures. Five of the six institutions generally
attributed the omissions in their annual security reports to a lack of clear and
centralized procedures for complying with the Clery Act. A set of procedures or
a desk manual for complying with the Clery Act might include a checklist that
describes each requirement, lists which of the institution’s policies apply, species
which campus departments need to be consulted, and identies the language that
must be disclosed. Figure shows an example of such a checklist that institutions
could develop to improve their compliance with the Clery Act.
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Figure 4
Sample Portion of a Checklist That Institutions Could Develop to Improve Their Compliance With Clery ActRequirements
NOT FULLY DISCLOSED OR UNSUPPORTED DISCLOSURE
FULLY DISCLOSED
Clery Act Requirement Required Campus Policy Disclosed in Annual
Security Report (ASR)
Notes / Instructions
List policy/procedure name/number,
along with relevant subsection or page,
that addresses the requirement.
List which section or page
of the ASR includes the
required disclosure.
List any related documents as
indicated for each requirement.
Use attachments as needed.
#24
Included within its annual security
report a statement of policy
regarding its programs to prevent
• domestic violence,
• dating violence,
• sexual assault,
• and stalking;
and the procedures it will follow
once such an incident has
been reported,
including a statement of the standard
of evidence that will be used during
any institutional conduct proceeding
arising from such a report.
20 USC §1092(f)(8)(A)
34 CFR §668.46 (b)(11)
Not all elements included in policy. Not all policy elements
disclosed in annual
security report.
Institution lacks policy;
its disclosure is not
supported.
Institution lacks necessary policy.
Review sample of program
materials to ensure they cover
all the required topics.
Document procedures and how
campus ensures that all relevant
sta are trained and aware of them.
Example:
no mention of dating violence
no mention of stalking
Example:
no policy
Missing disclosure in
annual security report.
#23
Included within its annual security
report a description of programs for
drug or alcohol abuse education.
20 USC § 1092 (f)(1)(H)
34 CFR § 668.46 (b)(10)aa
Ensure that policy includes all elements. Ensure that disclosure
includes all elements.
Document all programs
covered by the campus policy.
Example:
Example:
Source: Auditor generated from review of federal law.
Five of the six institutions we reviewed agreed that having a set of procedures, such as
a desktop manual and a checklist, would help them to accurately compile Clery crime
data needed to prepare their annual security reports. After we shared our ndings
with ocials at Mount Saint Mary’s and showed them the type of detailed information
that such procedures might contain, the university updated a number of its policies to
address the deciencies we identied and better comply with the CleryAct.
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Regular periodic reviews by either an internal or external auditor also would provide
institutions with feedback on the quality of their Clery Act compliance over time.
e majority of the institutions in California have never had a state or federal
Clery Act compliance audit to provide independent feedback on the quality of
their performance over time. e six institutions we reviewed also currently do not
perform formal internal audits of their compliance with the Clery Act but generally
agreed that having regular periodic audits or other similar reviews of their Clery Act
processes would improve their compliance with the Clery Act. In fact, SantaCruz’s
associate chancellor stated that the university plans to audit its Clery Act processes,
including crime reporting and preparation of the annual security report, during the
next year.
Institutions Lacked Additional Campus Safety Policies, Protocols, and Information That
State Law Requires
In addition to not fully complying with federal Clery Act requirements, institutions
we reviewed did not fully comply with additional state requirements. State law
requires certain institutions to implement in specic areas additional campus safety
policies and protocols that are more extensive than Clery Act requirements. e
Legislature found in that women on U.S.college campuses are at greater risk
of becoming victims of sexual assault, domestic violence, and stalking than women
in the general population. e Legislature further recognized that men; individuals
with disabilities; members of cultural and religious minority groups; and lesbian, gay,
and transgender individuals also experience sexual assault. erefore, the Legislature
enacted a law requiring community college and CSU campuses and requesting
UCcampuses to establish policies to encourage the reporting of sex oenses, and to
include in their student orientations and on their websites education and preventive
information about sex oenses. We identied state requirements that expand
upon the federalrequirements.
Although some institutions are exempt from all or some of these requirements, we
determined whether they had implemented these requirements as best practices.
As we discussed in the Introduction, UC institutions are specically exempt
from the state law requirements unless the Regents adopt a resolution to make
each requirement applicable. Further, some requirements do not apply to private
institutions. In other cases, state law only requests that certain institutions comply
with a specic requirement. However, we believe that these requirements represent
best practices. erefore, we determined whether SantaCruz had implemented all
requirements as a matter of best practice. We also determined whether institutions
that are only requested to comply with certain requirements had implemented those
requirements as a matter of best practice. As Table shows, the sixinstitutions did
not always comply with these requirements or best practices.
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Table 5
The Six Institutions Did Not Fully Comply With Eight or More State Requirements or Best Practices
STATE REQUIREMENTS
NUMBER OF REQUIREMENTS OR BEST PRACTICES
WITH WHICH INSTITUTIONS DID NOT FULLY COMPLY*
REQUIREMENT CATEGORY
TOTAL
REQUIREMENTS
CHICO
IMPERIAL
VALLEY
MOUNT SAINT
MARY’S
ORANGE
COAST
SAN DIEGO SANTA CRUZ*
Crime Reporting, Tracking,
and General Campus Safety
6 1 1 2 2 2 1
Agreements With Local
LawEnforcement
3 3 1 0 0 1 1
Education and Prevention
Information
9 3 9 2 5 0 2
Safety Policies and
Procedures
22 6 17 11 16 12 4
Services Available for
Victims of Sexual Violence
2 0 0 0 0 0 0
Total Not Fully Complied 13 28 15 23 15 8
Total Fully Complied 29 13 24 18 26 34
N/A 0 1 3 1 1 0
Compliance Rate 69% 32% 62% 44% 63% 81%
Legend: Fully Compliant Not Compliant
Source: Analysis of state law and each institution’s policies, procedures, and programs.
* Some requirements pertain only to certain types of institutions, such as the CSU or community colleges. For these items, state law often suggests
or requests, but does not require, that other institutions comply. Refer to Appendix D for additional detail on each institution’s results for the
42 requirements, and which institions were required to, requested to, or exempt from complying. For Santa Cruz only, we evaluated all state
requirements as best practices.
For example, we found that Imperial Valley did not prepare, post, or distribute a
campus safety plan as state law requires and that SantaCruz did not implement
this provision as a matter of best practice. To promote overall campus safety,
state law requires ocials from each community college and the CSU to prepare
and prominently post a campus safety plan each year. is plan must include the
availability and location of security personnel, methods for summoning security
personnel, and any actions the institution took in the preceding months or
anticipates making during the next months to increase safety.
According to Imperial Valley’s vice president of administrative services, the
institution identied the need for a campus safety plan in April. It subsequently
developed a plan, but nalization and approval of the plan has been delayed
because of a vacancy in the campus safety manager position since December.
SantaCruz stated that the individual responsible for posting its safety plan left the
university and that after SantaCruz updated its website, sta neglected to post
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the plan. By not preparing and posting a campus safety plan to inform faculty and
students about how to respond or seek assistance in the event of an emergency
or crime, these institutions have increased the risks to campus communities.
SantaCruz’s associate vice chancellor explained that SantaCruz intends to complete
its safety plan regardless of whether the Regents have adopted a resolution requiring
it to do so.
State law also requires certain institutions to have written agreements with local law
enforcement agencies that clarify operational responsibilities for investigating certain
crimes, and it requires those institutions to review and update those agreements
every ve years. Fourof the sixinstitutions that we reviewed do not have sworn
police ocers with full authority to arrest and investigate crimes, so such agreements
are critical to maintaining the safety of the campus community. However, we found
that twoof the sixinstitutions we reviewed—SantaCruz and Chico—had not
updated their written agreements with local law enforcement agencies within the
past veyears.
Chico’s executive director explained that although the institution’s written agreement
with local law enforcement was not signed or dated by all parties, Chico has operated
with the understanding that the agreement was valid and enforceable. However, he
recognized the need to update the agreement and said that the institution is currently
working with the city of Chico to correct the deciency.
As a matter of best practice, SantaCruz campus police department’s records and
communication manager explained that its written agreement was due to be renewed
in. However, because the institution was dealing with several crises, including
the pandemic, the institution was not able to renew the agreement before its former
police chief retired. e manager also stated that SantaCruz’s current campus police
chief plans to enter into a newly signed agreement during the summer of.
Without having valid and binding legal agreements with local law enforcement
agencies, institutions may be unable to obtain full cooperation from local law
enforcement to compile, report, and respond promptly to crimes that occur on or
near the campus.
e lack of comprehensive policies and procedures to meet state requirements or
best practices, in addition to the gaps related to federal Clery Act disclosures and
a lack of underlying policies, is particularly concerning because these policies and
procedures are necessary to help institutions respond consistently and adequately to
campus emergencies and crimes. Given the risks of the crimes that the Legislature
identied in enacting these requirements, and the unpredictable nature of
emergencies, it is imperative that each institution conduct a comprehensive review
and revision of its policies, procedures, programs, and website in order to comply
with the Clery Act, state law, and best practices.
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Recommendations
Legislature
Over the past years, the State Auditor has found noncompliance with federal Clery
Act requirements at institutions. If the Legislature desires greater campus focus on
and awareness of Clery Act requirements, it could consider requiring all institutions
that are subject to the Clery Act to conduct periodic reviews of their compliance
with the Clery Act and with state law requirements. e Legislature should require
these institutions to post the results of their campus safety reviews publicly and
conspicuously on their websites, near the institutions’ annual security reports. At a
minimum, the reviews should include the following:
• A review of all campus crimes, to ensure the accuracy and completeness of the
institution’s disclosure of all relevant crimes.
• A review of all institutional policies, procedures, and programs, to ensure that
they include all required components set forth in the Clery Act and in state law.
• A review of the institution’s annual security reports, to ensure that the institution
disclosed all required items in a manner consistent with the institution’s
underlying policies, procedures, and programs.
Chico, Imperial Valley, Mount Saint Mary’s, Orange Coast, and SantaCruz
To ensure the accuracy and completeness of campus crime statistics that each
institution reports to ED and includes in its annual security report, these institutions
should establish procedures by January for compiling the Clery Act statistics.
ese procedures should include the following:
• Listing all campus departments that maintain crime and incident data and protocols
for obtaining data from those departments. Identifying all law enforcement agencies
and obtaining all crime and incident data from thoseagencies.
• Procedures for the specic tests that certain sta should use to determine whether
to include a crime or incident in the Clery Act statistics.
Chico, Mount Saint Mary’s, Orange Coast, and SantaCruz
To ensure that all crimes are recorded in the institution’s daily crime log, these
institutions should develop procedures by January for their campus security
oce or campus police department sta to follow. ese procedures should include
the list of all institutional departments and law enforcement agencies from which the
campus security oce or campus police department obtain crime data to include
in the institution’s daily crime logs. ese procedures should also dene who is
responsible for obtaining data for inclusion in the daily crime log.
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Chico, Imperial Valley, Mount Saint Mary’s, Orange Coast, SanDiego, and SantaCruz
To ensure that they fully and adequately disclose all required policies in their annual
security reports, these institutions should develop guidance by January for sta
preparing the annual security reports. is guidance should identify all required
disclosures for the reports and should include a comprehensive checklist that lists
each of the required disclosures and their necessary supporting policies, as we
illustrate in Figure on page.
To ensure that the disclosures in their annual security reports accurately represent
campus policies and institutional practices and that they are reporting reliable
information to the public and to ED, these institutions should develop, adopt, or
update by October, , campus policies, procedures, and programs to ensure that
the institution meets all requirements of the Clery Act.
To ensure that sta responsible for compiling Clery crime statistics and preparing
the annual security reports—as well as sta who provide crime data and policy
information to those individuals—are aware of all the Clery Act’s requirements and
are aware of all campus policies and protocols for complying with the Clery Act,
these institutions should provide to their sta regular trainings by January
on CleryAct requirements and on specic campus procedures for complying
with theClery Act. e institutions should then require and ensure that all sta
responsible for compiling the crime data and the annual security reports regularly
participate in those trainings.
To ensure that they fully comply with state law and best practices related to campus
safety, these institutions should develop, adopt, or update by January their
campus policies, procedures, and programs to ensure that they comply with all
requirements of state law shown in AppendixD. Institutions should comply with
these requirements as a matter of best practice even if the law does not explicitly
require them to do so.
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We conducted this performance audit in accordance with generally accepted
government auditing standards and under the authority vested in the California State
Auditor by Government Code section et seq. ose standards require that we
plan and perform the audit to obtain sucient, appropriate evidence to provide a
reasonable basis for our ndings and conclusions based on the audit objectives. We
believe that the evidence obtained provides a reasonable basis for our ndings and
conclusions based on our audit objectives.
Respectfully submitted,
GRANT PARKS
California State Auditor
July ,
Sta: Kris Patel, Principal Auditor
Ani Apyan, MPP, Senior Auditor
David DeNuzzo, CIA, CFE, Senior Auditor
Salma Healy
Rachel Hibbard
Arseniy A. Sotnikov
Karen Wells
Legal Counsel: JudyAnne Alanis
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Appendix A
Crimes and Violations That Institutions Must Report Under Federal Crime
DisclosureRequirements
e Clery Act and its implementing regulations require all institutions that participate
in federal student aid programs under TitleIV to report statistics for the categories of
criminal oenses and violations shown in Table A.
Table A
Crimes and Violations Reportable Under the Clery Act
CRIME / VIOLATION APPLICABLE DEFINITION
Criminal Oenses
Aggravated assault An unlawful attack by one person upon another for the purpose of inicting severe or
aggravated bodily injury. This type of assault is usually accompanied by the use of a weapon
or by means likely to produce death or great bodily harm. It is not necessary that injury
result from an aggravated assault when a gun, knife, or other weapon is used that could and
probably would result in serious personal injury if the crime were successfully completed.
Arson Any willful or malicious burning or attempt to burn, with or without intent to defraud, a
dwelling house, public building, motor vehicle, aircraft, personal property of another, etc.
Burglary The unlawful entry of a structure to commit a felony or a theft. For reporting purposes, this
denition includes unlawful entry with intent to commit a larceny or felony; breaking and
entering with intent to commit a larceny; housebreaking; safecracking; and all attempts to
commit any of the aforementioned.
Fondling The touching of the private body parts of another person for the purpose of sexual
gratication, without the consent of the victim, including instances where the victim is
incapable of giving consent because of his/her age or because of his/her temporary or
permanent mental incapacity.
Incest Sexual intercourse between persons who are related to each other within the degrees wherein
marriage is prohibited by law.
Motor vehicle theft The theft or attempted theft of a motor vehicle. Classify as motor vehicle theft all cases where
automobiles are taken by persons not having lawful access, even though the vehicles are later
abandoned—including joyriding.
Murder and nonnegligent manslaughter The willful (nonnegligent) killing of one human being by another.
Manslaughter by negligence The killing of another person through gross negligence.
Rape The penetration, no matter how slight, of the vagina or anus with any body part or object, or
oral penetration by a sex organ of another person without the consent of the victim.
Robbery Taking or attempting to take anything of value from the care, custody, or control of a person or
persons by force or threat of force or violence and/or by putting the victim in fear.
Statutory rape Sexual intercourse with a person who is under the statutory age of consent.
continued on next page . . .
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CRIME / VIOLATION APPLICABLE DEFINITION
Violence Against Women Reauthorization Act of 2013 Oenses
Dating violence Violence committed by a person who is or has been in a social relationship of a romantic or
intimate nature with the victim, where the existence of such a relationship shall be determined
based on a consideration of the length of the relationship, the type of relationship, and the
frequency of interaction between the persons involved in the relationship. Dating violence
includes but is not limited to sexual or physical abuse or the threat of such abuse. Dating
violence does not include acts covered under the denition of domestic violence.
Domestic violence Includes felony or misdemeanor crimes of violence committed by a current or former spouse
or intimate partner of the victim, by a person with whom the victim shares a child in common,
by a person who is cohabitating with or has cohabitated with the victim as a spouse or
intimate partner, by a person similarly situated to a spouse of the victim under the domestic or
family violence laws of the jurisdiction in which the crime of violence occurred, or by any other
person against an individual who is protected from that person’s acts under the domestic or
family violence laws of the jurisdiction in which the crime occurred.
Stalking Engaging in a course of conduct directed at a specic person that would cause a reasonable
person to fear for her, his, or others’ safety or to suer substantial emotional distress.
Hate Crimes
Hate crimes Crimes reported to local police agencies or to a campus security authority regarding any of the
criminal oenses described above, as well as larceny-theft, simple assault, and intimidation;
destruction damage or vandalism of property; and any other crimes involving bodily injury
in which the victim was intentionally selected because of the perpetrator’s bias against the
victim’s actual or perceived race, religion, gender, gender identity, sexual orientation, ethnicity,
national origin, or disability.
Arrests and Referrals for Disciplinary Actions
Drug abuse violations The violation of laws prohibiting the production, distribution, and/or use of certain controlled
substances and the equipment or devices utilized in their preparation and/or use. The
unlawful cultivation, manufacture, distribution, sale, purchase, use, possession, transportation,
or importation of any controlled drug or narcotic substance. Arrests for violations of state
and local laws, specically those relating to the unlawful possession, sale, use, growing,
manufacturing, and making of narcotic drugs.
Liquor law violations The violation of state or local laws or ordinances prohibiting the manufacture, sale, purchase,
transportation, possession, or use of alcoholic beverages, not including driving under the
inuence and drunkenness.
Weapons law violations The violation of laws or ordinances prohibiting the manufacture, sale, purchase, transportation,
possession, concealment, or use of rearms, cutting instruments, explosives, incendiary
devices, or other deadly weapons.
Unfounded Crimes
Unfounded crimes An institution may withhold, or subsequently remove, a reported crime from its crime
statistics in the rare situation where sworn or commissioned law enforcement personnel
have fully investigated the reported crime and, based on the results of this full investigation
and evidence, have made a formal determination that the crime report is false or baseless
and therefore “unfounded.” Only sworn or commissioned law enforcement personnel may
determine a crime is unfounded for purposes of reporting under this section.
Source: Federal law.
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Appendix B
Crime Statistics in the 2023 Annual Security Reports of Six Institutions
e Clery Act and its implementing regulations require all institutions that
participate in federal student aid programs under TitleIV to report statistics
for the categories of criminal oenses and violations described in AppendixA.
TablesB. throughB. summarize the criminal oenses, Violence Against Women
Reauthorization Act of oenses, hate crimes, arrests, disciplinary actions, and
unfounded crimes that the sixinstitutions we reviewed reported for , ,
and.
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Table B.1
Chico’s Crime Statistics Reported Under the Clery Act
CRIME REPORTED UNDER THE CLERY ACT 2020 2021 2022
Criminal Oenses
Aggravated assault 1 0 3
Arson 5 0 0
Burglary 6 5 6
Motor vehicle theft 2 1 2
Murder and nonnegligent manslaughter 0 0 0
Manslaughter by negligence 0 0 0
Robbery 0 0 3
Rape 2 3 1
Fondling 3 3 2
Incest 0 0 0
Statutory rape 0 1 0
Subtotals 19 13 17
VAWA Oenses
Domestic violence 3 0 2
Dating violence 0 0 0
Stalking 0 0 9
Subtotals 3 0 11
Hate Crimes
Hate crimes 0 0 2
Arrests
Drug law arrests 8 2 14
Liquor law arrests 0 0 3
Weapons law arrests 8 2 1
Subtotals 16 4 18
Disciplinary Actions
Drug law disciplinary actions 13 3 2
Liquor law disciplinary actions 2 1 10
Weapons law disciplinary actions 0 1 1
Subtotals 15 5 13
Unfounded Crimes
Unfounded crimes 0 1 1
Totals 53 23 62
Source: Crime statistics in Chico’s 2023 annual security report and fall 2020 through 2022 student enrollment information.
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Table B.2
Imperial Valley’s Crime Statistics Reported Under the Clery Act
CRIME REPORTED UNDER THE CLERY ACT 2020 2021 2022
Criminal Oenses
Aggravated assault 0 0 0
Arson 0 0 0
Burglary 0 0 0
Motor vehicle theft 0 0 0
Murder and nonnegligent manslaughter 0 0 0
Manslaughter by negligence 0 0 0
Robbery 0 0 0
Rape 0 0 0
Fondling 0 0 0
Incest 0 0 0
Statutory rape 0 0 0
Subtotals 0 0 0
VAWA Oenses
Domestic violence 0 0 0
Dating violence 0 0 0
Stalking 0 0 0
Subtotals 0 0 0
Hate Crimes
Hate crimes 0 0 1
Arrests
Drug law arrests 0 0 0
Liquor law arrests 0 0 0
Weapons law arrests 0 0 0
Subtotals 0 0 0
Disciplinary Actions
Drug law disciplinary actions 3 0 0
Liquor law disciplinary actions 0 0 1
Weapons law disciplinary actions 0 0 0
Subtotals 3 0 1
Unfounded Crimes
Unfounded crimes 0 0 0
Totals 3 0 2
Source: Crime statistics in Imperial Valley’s 2023 annual security report and fall 2020 through 2022 student enrollment information.
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Table B.3
Mount Saint Mary’s Crime Statistics Reported Under the Clery Act
CRIME REPORTED UNDER THE CLERY ACT 2020 2021 2022
Criminal Oenses
Aggravated assault 0 0 0
Arson 0 0 0
Burglary 4 1 0
Motor vehicle theft 0 0 0
Murder and nonnegligent manslaughter 0 0 0
Manslaughter by negligence 0 0 0
Robbery 0 0 1
Rape 0 0 0
Fondling 0 0 0
Incest 0 0 0
Statutory rape 0 0 0
Subtotals 4 1 1
VAWA Oenses
Domestic violence 0 0 0
Dating violence 0 0 2
Stalking 0 0 0
Subtotals 0 0 2
Hate Crimes
Hate crimes 0 0 0
Arrests
Drug law arrests 0 0 16
Liquor law arrests 0 0 7
Weapons law arrests 0 0 0
Subtotals 0 0 23
Disciplinary Actions
Drug law disciplinary actions 0 0 0
Liquor law disciplinary actions 0 0 1
Weapons law disciplinary actions 0 0 0
Subtotals 0 0 1
Unfounded Crimes
Unfounded crimes 0 0 0
Totals 4 1 27
Source: Crime statistics in Mount Saint Mary’s 2023 annual security report and fall 2020 through 2022 student
enrollmentinformation.
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Table B.4
Orange Coast’s Crime Statistics Reported Under the Clery Act
CRIME REPORTED UNDER THE CLERY ACT 2020 2021 2022
Criminal Oenses
Aggravated assault 1 1 9
Arson 1 0 1
Burglary 4 3 12
Motor vehicle theft 3 6 15
Murder and nonnegligent manslaughter 0 0 0
Manslaughter by negligence 0 2 0
Robbery 1 1 3
Rape 0 0 6
Fondling 1 0 6
Incest 0 0 0
Statutory rape 0 0 0
Subtotals 11 13 52
VAWA Oenses
Domestic violence 1 1 27
Dating violence 0 8 0
Stalking 0 4 17
Subtotals 1 13 44
Hate Crimes
Hate crimes 1 0 4
Arrests
Drug law arrests 1 1 2
Liquor law arrests 0 0 0
Weapons law arrests 0 1 3
Subtotals 1 2 5
Disciplinary Actions
Drug law disciplinary actions 14 32 46
Liquor law disciplinary actions 44 56 5
Weapons law disciplinary actions 1 2 3
Subtotals 59 90 54
Unfounded Crimes
Unfounded crimes 0 0 0
Totals 73 118 159
Source: Crime statistics in Orange Coast’s 2023 annual security report and fall 2020 through 2022 student enrollmentinformation.
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Table B.5
University of San Diego’s Crime Statistics Reported Under the Clery Act
CRIME REPORTED UNDER THE CLERY ACT 2020 2021 2022
Criminal Oenses
Aggravated assault 0 4 4
Arson 0 0 0
Burglary 5 8 13
Motor vehicle theft 0 3 14
Murder and nonnegligent manslaughter 0 0 0
Manslaughter by negligence 0 0 0
Robbery 0 0 0
Rape 0 7 8
Fondling 0 5 2
Incest 0 0 0
Statutory rape 0 0 0
Subtotals 5 27 41
VAWA Oenses
Domestic violence 2 0 0
Dating violence 0 6 4
Stalking 2 5 4
Subtotals 4 11 8
Hate Crimes
Hate crimes 0 0 0
Arrests
Drug law arrests 0 0 0
Liquor law arrests 1 0 0
Weapons law arrests 0 1 1
Subtotals 1 1 1
Disciplinary Actions
Drug law disciplinary actions 0 26 31
Liquor law disciplinary actions 70 275 134
Weapons law disciplinary actions 0 6 1
Subtotals 70 307 166
Unfounded Crimes
Unfounded crimes 0 0 0
Totals 80 346 216
Source: Crime statistics in San Diego’s 2023 annual security report and fall 2020 through 2022 student enrollment information.
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Table B.6
Santa Cruz’s Crime Statistics Reported Under the Clery Act
CRIME REPORTED UNDER THE CLERY ACT 2020 2021 2022
Criminal Oenses
Aggravated assault 2 1 9
Arson 4 0 2
Burglary 22 13 13
Motor vehicle theft 4 4 8
Murder and nonnegligent manslaughter 0 0 0
Manslaughter by negligence 0 0 0
Robbery 1 0 2
Rape 11 16 17
Fondling 6 7 4
Incest 0 0 0
Statutory rape 0 0 0
Subtotals 50 41 55
VAWA Oenses
Domestic violence 7 6 6
Dating violence 4 4 0
Stalking 3 6 15
Subtotals 14 16 21
Hate Crimes
Hate crimes 1 1 5
Arrests
Drug law arrests 7 5 2
Liquor law arrests 0 0 0
Weapons law arrests 0 1 6
Subtotals 7 6 8
Disciplinary Actions
Drug law disciplinary actions 111 125 256
Liquor law disciplinary actions 152 268 323
Weapons law disciplinary actions 2 3 3
Subtotals 265 396 582
Unfounded Crimes
Unfounded crimes 3 0 1
Totals 340 460 672
Source: Crime statistics in Santa Cruz’s 2023 annual security report and fall 2020 through 2022 student enrollment information.
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Appendix C
Six Institutions’ Compliance With Federal Law Regarding the Disclosure of SecurityPolicies
e Clery Act and its implementing regulations require all institutions that participate
in federal student aid programs under TitleIV to prepare annual security reports that
disclose certain campus security policies, procedures, and programs. ese policies
include procedures for students and others to report criminal actions, programs
pertaining to domestic violence, dating violence, sexual assault, and stalking, as well
as the procedures the institutions will follow if such conduct occurs. We identied
numerous policies, procedures, and programs, which we compiled into items, that
federal law requires institutions to have and, in most instances, to disclose in their
annual security reports. Table C. shows whether the sixinstitutions we reviewed fully
disclosed each of the required policies in their most recent annual security reports.
As shown in Table C.1, which summarizes Table C.2, we found noncompliance with
the largest number of requirements in the following categories: campus sex oense
response procedures, disciplinary action processes in the event of an alleged sex
oense, emergency response and evacuation procedures, and processes in the event
of a missing student report. We discuss the institutions’ noncompliance in these
threeareas starting on page of our report.
Table C.1
Summary of the Six Institutions’ Compliance With and Disclosure of Campus Safety Policies, Procedures, and
Programs Set Forth in Federal Law
SUMMARY
NUMBER OF
REQUIREMENTS
TOTAL NOT
COMPLIED WITH*
NUMBER OF THE
SIXINSTITUTIONS NOT
FULLY COMPLIANT
†
NUMBER OF DIFFERENT
REQUIREMENTS NOT
COMPLIED WITH
Annual Reports and General Campus Safety 9 5 4 3
Daily Crime Log and Crime Reporting 7 7 4 3
Campus Law Enforcement and
CrimePrevention
4 7 4 4
Illegal Drugs and Alcohol 3 1 1 1
Campus Sex Oense Mitigation Programs 3 11 5 3
Campus Sex Oense Response Procedures 8 20 5 7
Disciplinary Action Processes in the Event of
an Alleged Sex Oense
5 15 5 5
Emergency Response and
EvacuationProcedures
11 34 6 10
Processes in the Event of a Missing
StudentReport
9 23 5 9
Totals 59 123 45
Source: Analysis of federal law and each institution’s policies, procedures, programs, and annual security report.
* Total number of requirements not complied with is the sum of the number of requirements that each institution did not comply with for all
sixinstitutions.
†
All six institutions did not fully comply with all requirements in at least one of the nine categories.
46
CALIFORNIA STATE AUDITOR
July 2024
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Report 2024-032
Table C.2
The Six Institutions’ Compliance With and Disclosure of Campus Safety Policies, Procedures, and Programs Set
Forth in Federal Law
DESCRIPTION OF POLICIES, PROCEDURES, AND PROGRAMS CHICO
IMPERIAL
VALLEY
MOUNT
SAINTMARY'S
ORANGE
COAST
SAN
DIEGO
SANTA
CRUZ
Annual Reports and General Campus Safety
1 Submitted Clery crime statistics to ED annually.
2 Prepared, published, and distributed an annual security
report (ASR).
3 Disclosed in its ASR its Clery crime statistics for the most
recent three years.
4 Included in the ASR its current policies for preparing the
annual disclosure of crime statistics.
5 Included statistics for hate crimes and VAWA crimes in
its ASR.
6 Categorized its crimes statistics by location as
either on campus, noncampus, public property, or
campus-residential.
7 Included in its ASR a list of the titles of each person or
organization to whom students and employees should
report crimes.
8 Included in its ASR a statement of policies concerning
security of, maintenance of, and access to campus
facilities, including campus residences.
9 Included in its ASR a description of procedures, if any,
that encourage pastoral counselors and professional
counselors, if they deem it appropriate, to inform
persons they are counseling of procedures to voluntarily
report crimes for inclusion in its crime statistics.
Daily Crime Log and Crime Reporting
10 Maintained a daily log of all crimes reported to its police,
security department, or campus security authority.
11 Included in its ASR a statement of policy concerning the
monitoring and recording of criminal activity by students
at noncampus locations of student organizations
recognized by the institution, including student
organizations with noncampus housing facilities.
12 Made its crime log for the most recent 60-day period
open to public inspection during normal business hours
and made any portion of the log older than 60days
available within two business days of a request for
public inspection.
13 Made open to the public all required entries in its crime
log within two business days of the initial report being
made to the police or campus security department.
14 Included in its ASR a statement of policies regarding
procedures for individuals to report crimes or other
emergencies occurring on campus, as well as the
institution’s response to such reports.
15 Included in its ASR a statement of policies for making
timely warning reports to members of the campus
community regarding the occurrence of the crimes
listed in the Clery Act.
47
CALIFORNIA STATE AUDITOR
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DESCRIPTION OF POLICIES, PROCEDURES, AND PROGRAMS CHICO
IMPERIAL
VALLEY
MOUNT
SAINTMARY'S
ORANGE
COAST
SAN
DIEGO
SANTA
CRUZ
16 Included in its ASR a statement of policies or procedures
for victims or witnesses to report crimes on a voluntary,
condential basis for inclusion in the annual disclosure
of crime statistics.
Campus Law Enforcement and Crime Prevention
17 Included in its ASR a statement of policies concerning
campus law enforcement, including the authority
of campus security personnel, whether they have
authority to make arrests, and the working relationship
of campus security personnel with state and local
law enforcement agencies, including whether
the institution has agreements, such as written
memorandums of understanding, with such agencies
for the investigation of alleged crimes.
18 Included in its ASR a statement of policies that
encourage accurate and prompt reporting of all crimes
to campus police and appropriate law enforcement
agencies when the victim of such crime elects or is
unable to make such a report.
19 Included in its ASR a description of the type and
frequency of programs designed to inform students
and employees about campus security procedures and
practices and to encourage students and employees to
be responsible for their own security and the security
of others.
20 Included in its ASR a description of programs designed
to inform students and employees about the prevention
of crimes.
Illegal Drugs and Alcohol
21 Included in its ASR a statement of policy regarding the
possession, use, and sale of alcoholic beverages and
theenforcement of state underage drinking laws.
22 Included in its ASR a statement of policy regarding
the possession, use, and sale of illegal drugs and the
enforcement of federal and state druglaws.
23 Included in its ASR a description of programs for drug or
alcohol abuseeducation.
Campus Sex Oense Mitigation Programs
24 Included in its ASR a statement of policy regarding its
programs to prevent domestic violence, dating violence,
sexual assault, and stalking, as well as the procedures
it will follow once an incident has been reported,
including the standard of evidence it will use during any
related institutional conduct proceeding.
25 Included in its ASR a statement of policy that describes
its education programs that promote the awareness
of rape, acquaintance rape, domestic violence, dating
violence, sexual assault, and stalking, including primary
prevention and awareness programs for all incoming
students and new employees.
continued on next page . . .
48
CALIFORNIA STATE AUDITOR
July 2024
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DESCRIPTION OF POLICIES, PROCEDURES, AND PROGRAMS CHICO
IMPERIAL
VALLEY
MOUNT
SAINTMARY'S
ORANGE
COAST
SAN
DIEGO
SANTA
CRUZ
26 Included in its ASR a statement of policy that describes
its educational programs, which shall include primary
prevention and awareness programs for all incoming
students and new employees that address the following:
• A statement that the institution prohibits domestic
violence, dating violence, sexual assault, and stalking.
• The denition of domestic violence, dating violence,
sexual assault, and stalking in the applicable jurisdiction.
• The denition of consent, in reference to sexual
activity, in the applicable jurisdiction.
• Safe and positive options for bystander intervention
that may be carried out by an individual to prevent
harm or to intervene when there is a risk of domestic
violence, dating violence, sexual assault, or stalking
against another person.
• Information on risk reduction to recognize warning
signs of abusive behavior and how to avoid potential
attacks and on ongoing prevention and awareness
campaigns for students and faculty, including the
information above.
Campus Sex Oense Response Procedures
27 Included in its ASR a statement of policy describing
the procedures victims should follow if a sex oense,
domestic violence, dating violence, sexual assault, or
stalking has occurred, including written information,
where applicable, to the victim about their rights and
the institution’s responsibilities regarding orders of
protection, no contact orders, restraining orders, or
similar lawful orders.
28 Included in its ASR a statement of policy describing
the procedures victims should follow if a sex oense,
domestic violence, dating violence, sexual assault, or
stalking has occurred, including written information to
the victim about the importance of preserving evidence
and options regarding notifying law enforcement and
campus authorities.
29 Included in its ASR a statement of policy describing
that the institution will provide written notication to
students and employees about existing counseling,
health, mental health, victim advocacy, legal assistance
and other services available for victims both within the
institution and in the community.
30 Included in its ASR a statement of policy that the
institution will provide written notication to victims
about options for available reasonable accommodations
or protective measures, regardless of whether the victim
chooses to report the crime to campus police or local
law enforcement.
31 Included in its ASR a statement of policy that the
institution will provide a student or employee a written
explanation of his or her rights and options, including
the sanctions that the institution may impose following
a nal determination of an institutional disciplinary
procedure, when the student or employee reports he
or she has been a victim of domestic violence, dating
violence, sexual assault, or stalking, whether the oense
occurred on or o campus.
49
CALIFORNIA STATE AUDITOR
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DESCRIPTION OF POLICIES, PROCEDURES, AND PROGRAMS CHICO
IMPERIAL
VALLEY
MOUNT
SAINTMARY'S
ORANGE
COAST
SAN
DIEGO
SANTA
CRUZ
32 Included in its ASR a statement of policy with
information about how the institution will protect the
condentiality of victims and other necessary parties,
including how the institution will complete publicly
available recordkeeping, such as Clery Act reporting
and disclosures, without the inclusion of personally
identifying information about the victim.
33 Included in its ASR a statement of policy with
information about how the institution will generally
maintain as condential any accommodations or
protective measures provided to the victim.
34 Included in its ASR a statement advising the campus
community where law enforcement agency information
provided by a state concerning registered sex oenders
may be obtained.
Disciplinary Action Processes in the Event of an Alleged Sex Oense
35 Included in its ASR a statement of policy that describes
the procedures for each type of disciplinary proceeding
used by the institution in alleged sex oense cases,
including the steps, timelines, and decision-making
process for each type of proceeding; how to le
a disciplinary complaint; and how the institution
determines which type of proceeding to use.
36 Included in its ASR a statement of policy that includes
a statement that its procedures for institutional
disciplinary actions shall provide a prompt, fair, and
impartial investigation and resolution conducted by
trained ocials who receive annual training related
to domestic violence, dating violence, sexual assault,
and stalking and to conducting an investigation and
hearingprocess.
37 Included in its ASR a statement of policy that includes
that the accuser and accused are entitled to the same
opportunities to have an advisor of their choice present
during an institutional disciplinary proceeding and any
related meeting.
38 Included in its ASR a statement of policy that includes
that both the accuser and accused in alleged sex oense
cases shall be simultaneously informed in writing of
the results of any institutional disciplinary proceeding
arising from the case, the appeal process, any change to
the results that occurs before the results become nal,
and when the results become nal.
39 Included in its ASR a statement of policy listing all
possible sanctions that the institution may impose
following a nal determination of an institutional
disciplinary procedure regarding sex oenses and the
range of protective measures that the institution may
oer to the victim following an allegation of sex oenses.
Emergency Response and Evacuation Procedures
40 Included in its ASR a statement of policy regarding
emergency response and evacuation procedures that
the institution will use to immediately notify the campus
community of a signicant emergency or dangerous
situation involving an immediate threat to the health or
safety of students or employees on campus.
continued on next page . . .
50
CALIFORNIA STATE AUDITOR
July 2024
|
Report 2024-032
DESCRIPTION OF POLICIES, PROCEDURES, AND PROGRAMS CHICO
IMPERIAL
VALLEY
MOUNT
SAINTMARY'S
ORANGE
COAST
SAN
DIEGO
SANTA
CRUZ
41 Included in its ASR a statement of policy describing the
process the institution will use to conrm that there is a
signicant emergency or dangerous situation involving
an immediate threat to the students or employees
occurring on campus.
42 Included in its ASR a statement of policy describing
the process the institution will use to determine the
appropriate segment or segments of the campus
community to receive a notication.
43 Included in its ASR a statement of policy describing the
process the institution will use to determine the content
of the notication.
44 Included in its ASR a statement of policy describing
the process the institution will use to initiate the
notication system.
45 Included in its ASR a statement of policy listing the titles
of the persons or organizations responsible for carrying
out its emergency notication plan.
46 Included in its ASR a statement of policy that includes
that the institution will without delay, and taking into
account the safety of the community, determine the
content of the notication and initiate the notication
system, unless issuing a notication will compromise
eorts to assist a victim or to contain, respond to, or
otherwise mitigate the emergency.
47 Included in its ASR a statement of policy that includes
the institution’s procedures for disseminating
emergency information to the larger community.
48 Included in its ASR a statement of policy that includes
the institution’s procedures to test the emergency
response and evacuation procedures at least annually
in a manner designed to reach students and sta and
to publicize its emergency response and evacuation
procedures in conjunction with at least onetest per
calendar year.
49 Included in its ASR a statement of policy of the
emergency response and evacuation testing procedures
for tests that may be announced or unannounced.
50 Included in its ASR a statement of policy that the
emergency response and evacuation testing procedures
include documenting for each test a description of the
exercise, the date, time, and whether it was announced
or unannounced.
Processes in the Event of a Missing Student Report
51 Included in its ASR a statement of policy regarding
missing student notication procedures for students
who reside in on-campus student housing facilities,
indicating the list of titles of persons or organizations
to which individuals should report that a student who
resides in on-campus student housing has been missing
for 24 hours.
N/A
51
CALIFORNIA STATE AUDITOR
Report 2024-032
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DESCRIPTION OF POLICIES, PROCEDURES, AND PROGRAMS CHICO
IMPERIAL
VALLEY
MOUNT
SAINTMARY'S
ORANGE
COAST
SAN
DIEGO
SANTA
CRUZ
52 Included in its ASR a statement of policy requiring
that any missing student report must be referred
immediately to the institution’s police or campus
security department, or if no police or campus security
department, to the local law enforcement agency that
has jurisdiction in the area.
N/A
53 Included in its ASR a statement of policy containing an
option for each student to identify a contact person or
persons whom the institution shall notify within 24hours
of the determination that the student is missing.
N/A
54 Included in its ASR a statement of policy advising
students that their missing person emergency contact
information will be registered condentially and
accessible only to authorized ocials and that it may
not be disclosed except to law enforcement personnel
as part of a missing person investigation.
N/A
55 Included in its ASR a statement of policy advising
students that if they are under 18 years of age and not
emancipated, the institution must notify a custodial
parent or guardian within 24 hours of the determination
that the student is missing, in addition to notifying any
additional contact person designated by the student.
N/A
56 Included in its ASR a statement of policy advising
students that the institution will notify the local
law enforcement agency within 24 hours of the
determination that the student is missing.
N/A
57 The missing student notication procedures disclosed
in the statement of policy within its annual security
report shall include notifying the contact person within
24 hours that the student is missing If the student has
designated a contact person.
N/A
58 The missing student notication procedures disclosed
in the statement of policy within its annual security
report, which the institution must follow when a
student who resides in an on-campus student housing
facility is determined to have been missing for 24 hours
and is under 18 years of age and not emancipated,
shall include notifying the student’s custodial parent
or guardian and any other designated contact person
within 24 hours that the student is missing.
N/A
59 The missing student notication procedures disclosed in
the statement of policy within its annual security report,
which the institution must follow when a student who
resides in an on-campus student housing facility is
determined to have been missing for 24 hours, shall
include informing the local law enforcement agency
that has jurisdiction in the area within 24 hours that the
student is missing, regardless of the student’s age and
designated contact information.
N/A
Source: Analysis of federal law and each institution’s policies, procedures, programs, and annual security report.
= Fully Disclosed
= Not Disclosed
= Partially Disclosed*
= Unsupported—The institution has not enacted a campus policy to support its disclosure.
N/A = Not Applicable—The institution is not required to disclose this security policy because it does not have student housing.
* An institution only partially satised the Clery Act when the requirement included multiple components and the institution did not disclose each
required component or the institution’s policy, procedure, or program did not address each component.
52
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Blank page inserted for reproduction purposes only.
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CALIFORNIA STATE AUDITOR
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Appendix D
Six Institutions’ Compliance With State Law and Best Practices Regarding Campus
Safety Policies, Procedures, and Programs
State law generally requires institutions that receive public funds for student nancial
assistance to implement campus safety measures, including policies, procedures,
and programs, that are in addition to the Clery Act’s requirements. ese additional
measures include crime tracking and reporting, agreements with local law enforcement,
education and prevention information, and specic policies, procedures, and services
related to sexual harassment and sexual violence incidents. We compiled these
requirements under state law into items, which we list in TableD. Each provision
of state law identies the specic types of institutions that must comply, such as
community colleges, private institutions, and those in the CSU system. Although
these provisions of state law require or request that UC comply, another provision
of state law provides that none of these provisions apply to UC except to the extent
that the Regents, by appropriate resolution, make that provision applicable. Although
the sixinstitutions we reviewed were not required to comply with every provision,
we generally assessed the extent to which they complied with the requirements as
a matter of best practice. TableD summarizes the state requirements and whether
the six institutions we reviewed complied as required or as a matter of best practice.
Starting on page of our report, we discuss some of the institutions’ noncompliance
with the state law requirements.
Table D
The Six Institutions’ Compliance With State Law and Best Practices Regarding Campus Safety
Policies, Procedures, and Programs
STATE REQUIREMENTS CHICO
IMPERIAL
VALLEY
MOUNT
SAINTMARY'S
ORANGE
COAST
SAN
DIEGO
SANTA
CRUZ *
Crime Reporting, Tracking, and General Campus Safety
1 Ocials at each campus must compile records of all
occurrences reported to campus police, security personnel,
or safety authorities, and arrests for violence, hate violence,
theft, destruction of property, illegal drugs, or alcohol
intoxication, and noncriminal acts of hate violence.
2 Institutions must include in crime records for all
noncriminal acts of hate violence that are reported to
and for which a written report is prepared by campus
authorities a description of the act of hate violence,
victim characteristics, and oender characteristics,
ifknown.
3 Institutions must make crime records concerning
violence, hate violence, theft, destruction of property,
illegal drugs or alcohol intoxication, and noncriminal
acts of hate violence available within two business days
after a report.
continued on next page . . .
54
CALIFORNIA STATE AUDITOR
July 2024
|
Report 2024-032
STATE REQUIREMENTS CHICO
IMPERIAL
VALLEY
MOUNT
SAINTMARY'S
ORANGE
COAST
SAN
DIEGO
SANTA
CRUZ *
4 Institution ocials must prepare, prominently post,
and copy for distribution a campus safety plan that sets
forth the availability and location of security personnel;
methods for summoning assistance of security
personnel; any special safeguards that it has established
for particular facilities or activities; any actions the
institution took in the preceding 18 months to increase
safety; and any changes in safety precautions it expects
to make during the next 24 months.
5 Institution ocials must report the compiled crime
records relating to hate violence to its governing body,
which must then make a compiled report of all of
those records available to the general public on the
institution’s internet website.
6 The institution must immediately or as soon as practicably
possible disclose to the local law enforcement agency
with which the institution has a written agreement a
report of a criminal homicide, rape, robbery, aggravated
assault, burglary, larceny, motor vehicle theft, arson,
human tracking, sexual assault, or hate crime.
Agreements With Local Law Enforcement
7 The institution must enter into written agreements with
local law enforcement agencies that clarify operational
responsibilities for investigating the crimes noted above.
8 The written agreement with law enforcement must
include the geography boundaries of the institution’s and
the law enforcement agency’s operational responsibility.
9 The institution must review and update its written
agreement with law enforcement by July 1, 2016, and
every ve years thereafter.
Education and Prevention Information
10 In collaboration with campus-based and community-based
victim advocacy organizations, the institution must
provide, as part of established campus orientations
for incoming students, educational and preventive
information about sexual violence and sexual harassment.
N/A
†
11 The institution shall post educational and preventive
information on sexual violence and sexual harassment
on its campus internet website.
* *
12 The institution’s student orientation and internet
website must include common facts and myths about
the causes of sexual violence and sexual harassment.
* *
13 The institution’s student orientation and internet
website must include what constitutes sexual violence
and sexual harassment, including information on how
to le internal administrative complaints with the
institution of higher education and how to le criminal
charges with local law enforcement ocials.
* *
14 The institution’s student orientation and internet website
must include the availability of, and contact information
for, campus and community resources for students who
are victims of sexual violence and sexual harassment.
* *
15 The institution’s student orientation and internet website
must include methods of encouraging peer support for
victims and the imposition of sanctions on oenders.
*
*
55
CALIFORNIA STATE AUDITOR
Report 2024-032
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STATE REQUIREMENTS CHICO
IMPERIAL
VALLEY
MOUNT
SAINTMARY'S
ORANGE
COAST
SAN
DIEGO
SANTA
CRUZ *
16 The institution’s student orientation and internet
website must include information regarding campus,
criminal, and civil consequences of committing acts of
sexual violence and sexual harassment.
*
*
17 The institution must implement comprehensive
prevention and outreach programs addressing sexual
violence, domestic violence, dating violence, and
stalking, with a range of prevention strategies. At a
minimum, shall include the institution’s policy for such
oenses, a process for contacting and informing certain
student groups and organizations about the institution’s
overall sexual assault policy, the practical implications
of an armative consent standard, and the rights and
responsibilities of students under the policy.
18 The institution must include outreach programming in
every incoming student’s orientation, including informing
students about the warning signs of intimate partner and
dating violence, campus policies and resources relating
to intimate partner and dating violence, o-campus
resources and centers relating to intimate partner and
dating violence, and bystander intervention training as it
relates to intimate partner and dating violence.
Safety Policies and Procedures
19 The institution must adopt and implement policies and
procedures to ensure that it immediately, or as soon as
practicably possible, noties law enforcement of reports
of criminal homicide, rape, robbery, aggravated assault,
burglary, larceny, motor vehicle theft, arson, human
tracking, sexual assault, or hate crimes that occur on
or o campus.
20 The institution must adopt and implement written
procedures or protocols to ensure that students, faculty,
and sta who are victims of sexual assault [or domestic
violence]
§
committed at or on campus grounds or
facilities maintained by the institution or its aliated
student organizations receive treatment information.
[...]
§
does not apply to private colleges
continued on next page . . .
56
CALIFORNIA STATE AUDITOR
July 2024
|
Report 2024-032
STATE REQUIREMENTS CHICO
IMPERIAL
VALLEY
MOUNT
SAINTMARY'S
ORANGE
COAST
SAN
DIEGO
SANTA
CRUZ *
21 The above written procedures or protocols shall include:
1. The institution’s policy regarding sexual assault
oncampus.
2. Personnel on campus who should be notied and
procedures for notication with the consent of
thevictim.
3. Legal reporting requirements and procedures for
fullling them.
4. Services available to victims and personnel
responsible for providing these services.
5. A description of campus resources and o-campus
services available to victims.
6. Procedures for ongoing case management, including
procedures for keeping the victim informed of
the status and results of any student disciplinary
proceedings in connection to sexual assault [or
domestic violence]
§
and for helping the victim deal
with academic diculties that may arise because of
the victimization and its impact.
7. Procedures for guaranteeing condentiality and
appropriately handling requests for information from
the press, concerned students, and parents.
[...]
§
does not apply to private colleges
22 Procedures ensuring that the institution provides
each victim of sexual assault [or domestic violence]§
with information about the availability of all of the
followingoptions:
[a. Counselors and support services for victims.]
§
b. Criminal prosecutions.
c. Civil prosecutions.
d. The disciplinary process through the institution.
e. Alternative dispute resolution or other
accountability processes.
f. Alternative housing assignments.
g. Academic assistance alternatives.
[...]
§
does not apply to private colleges
23 The institution shall review the above written procedure
or protocols annually and update as necessary in
collaboration with sexual assault and domestic violence
counselors and student, faculty, and starepresentatives.
N/A N/A
24 The institution must develop policies to encourage
students to report campus crimes involving sexual
violence to the appropriate campus authorities.
† †
25 The institution must adopt a policy concerning sexual
assault, domestic violence, dating violence, and
stalking. This policy must include an armative consent
standard in the determination of whether consent was
given by both parties to sexual activity.
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CALIFORNIA STATE AUDITOR
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STATE REQUIREMENTS CHICO
IMPERIAL
VALLEY
MOUNT
SAINTMARY'S
ORANGE
COAST
SAN
DIEGO
SANTA
CRUZ *
26 The above policy must include that in the evaluation of
complaints in any disciplinary process, it shall not be a
valid excuse to alleged lack of armative consent that
the accused believed that the complainant consented
to the sexual activity because:
a. The accused’s belief in armative consent arose from
the intoxication or recklessness of the accused.
b. The accused did not take reasonable steps, based
on the circumstances known to the accused at
the time, to ascertain whether the complainant
armativelyconsented.
27 The above policy shall include that the standard used
in determining whether the elements of the complaint
against the accused have been demonstrated is the
preponderance of the evidence.
28 The above policy must include that in the evaluation
of complaints in the disciplinary process, it shall not
be a valid excuse that the accused believed that the
complainant armatively consented to the sexual
activity if the accused knew or reasonably should have
known that the complainant was unable to consent to
the sexual activity in specied circumstances.
29 The institution must adopt detailed and victim-centered
policies and protocols regarding sexual assault,
domestic violence, dating violence, and stalking
involving a student that comport with best practices
and current professional standards and that, at
minimum, include how the institution will protect the
privacy of individuals involved.
30 The above policies and protocols shall cover the initial
response by the institution’s personnel to a report
of an incident, including requirements specic to
assisting the victim, providing information in writing
about the importance of preserving evidence, and the
identication and location of witnesses.
31 The above policies and protocols shall cover the
response to stranger and nonstranger sexual assault.
32 The above policies and protocols shall cover the
preliminary victim interview, including the development
of a victim interview protocol and a comprehensive
follow-up victim interview as appropriate.
33 The above policies and protocols shall cover contacting
and interviewing the accused.
34 The above policies and protocols shall cover seeking the
identication and location of witnesses.
35 The above policies and protocols shall cover providing
written notication to the victim about the availability
of, and contact information for, on- and o-campus
resources and services, and coordination with law
enforcement, as appropriate.
36 The above policies and protocols shall cover participation
of victim advocates and other supporting people.
37 The above policies and protocols shall cover
investigating allegations that alcohol or drugs were
involved in the incident.
continued on next page . . .
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STATE REQUIREMENTS CHICO
IMPERIAL
VALLEY
MOUNT
SAINTMARY'S
ORANGE
COAST
SAN
DIEGO
SANTA
CRUZ *
38 The above policies and protocols shall cover providing
that an individual who participates as a complainant or
witness in an investigation of sexual assault, domestic
violence, dating violence, or stalking will not be
subject to disciplinary sanctions for a violation of the
institution’s student conduct policy at or near the time
of the incident unless the institution determines that
the violation was egregious, including but not limited
to an action that places the health or safety of any
other person at risk or involves plagiarism, cheating, or
academic dishonesty.
39 The above policies and protocols shall cover a
comprehensive, trauma-informed training program
for campus ocials involved in investigating and
adjudicating sexual assault, domestic violence, dating
violence, and stalking cases.
40 The above policies and protocols shall cover procedures
for condential reporting by victims and third parties.
Services Available for Victims of Sexual Violence
41 To the extent feasible, the institution must enter into
agreements or partnerships with on-campus and
community-based organizations, including rape crisis
and domestic violence centers, to refer students for
assistance or make available to students such services
as counseling, health, mental health, victim advocacy,
legal assistance, and resources for the accused.
42 To the extent feasible, the institution must ensure that
when a student who experiences sexual violence seeks
support services, the student receives information
about their right to obtain a sexual assault forensic
medical examination, their right to be accompanied to
the examination by a certied sexual assault counselor
and support person of the student’s choosing, and how
to access transportation to an examination site.
N/A N/A N/A
†
Source: Analysis of state law and each institution’s policies, procedures, and programs.
= Fully Compliant
= Not Compliant
= Partially Compliant
‡
N/A = Not Applicable—State law does not require the institution to comply with this requirement.
* State law only requests that the institution comply with this requirement. For Santa Cruz, we evaluated all state requirements and requests as
matters of best practice.
† State law does not require the institution to comply with this requirement. However, the institution implemented the requirement as a matter of
best practice.
‡ A policy, procedure, or program only partially satised the state requirement: the requirement included multiple components, and the policy,
procedure, or program did not address each component.
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Appendix E
Scope and Methodology
Section of the Education Code requires the State Auditor to report to the
Legislature every three years the results of an audit of not fewer than six institutions
that receive federal student aid. is law requires the State Auditor to determine the
institutions’ compliance with the requirements of the Clery Act by evaluating the
accuracy of the crime statistics they report and the procedures they use to identify,
gather, and track these data for publishing, disseminating, and reporting. e State
Auditor previously issued audit reports on this subject in , , , ,
, , and . Table E lists the audit objectives the State Auditor developed
and the methods we used to address them. Unless otherwise stated in the table or
elsewhere in the report, statements and conclusions about items selected for review
should not be projected to the population.
Table E
Audit Objectives and the Methods Used to Address Them
AUDIT OBJECTIVE METHOD
1
Review and evaluate the laws, rules,
and regulations signicant to the
auditobjectives.
Reviewed laws, rules, and regulations signicant to the audit objectives.
2
Evaluate the accuracy of the 2022crime
statistics reported by educational institutions.
• Selected six institutions to review according to the type of institution, its geographic
location, its enrollment, the number of crimes it reported to ED in 2022, and whether we
had previously audited the institution.
• Interviewed campus sta at each institution to understand the process used to compile
crime statistics, including how they acquired local police statistics and whether electronic
data was used. Interviewed local police ocials to obtain their understanding of the
crime situation on campuses.
• Obtained a copy of the 2022 statistics provided to ED by each institution and reviewed
underlying support for those crime statistics.
• Performed accuracy and completeness testing of each institution’s reported crime statistics.
For each of the sixinstitutions, reviewed a selection of up to 30incidents that the
institutions reported as Clery crimes for calendar year 2022, to determine whether
the institutions accurately categorized them as Clery. Reviewed a separate selection
of at least 30crimes at each institution—those identied by the institution as both
Clery-reportable and as non-Clery-reportable—to assess whether the institutions
appropriately included or excluded incidents from their Clery statistics.
• Reviewed supporting documentation in institutions’ electronic databases and daily
crime logs to determine whether cases were appropriately classied as Clery-reportable,
reported in the correct Clery category, appropriately included in the institution’s daily
crime log, and occurred within the correct reporting period of calendar year 2022.
continued on next page . . .
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AUDIT OBJECTIVE METHOD
3
Evaluate the institutions’ process for
compiling their annual security reports
and compliance with state and federal
requirements related to Clery Act policies
and procedures.
• Interviewed sta and reviewed supporting documentation regarding the process each
institution used to create its required annual security report. Determined whether each
institution had a written description of the steps needed to ensure that its disclosures
comply with federal and state law.
• Reviewed each institution’s 2023 annual security report and required disclosures.
Determined whether each institution is providing students and employees with all
disclosures required by the Clery Act and providing selected disclosures required by
state law.
• Reviewed the institutions’ underlying support to determine whether each institution
has all relevant policies, procedures, and programs as disclosed in its annual
securityreports.
• Reviewed the institutions' policies, procedures, and programs to determine whether
each institution complied with the requirements in state law, or implemented those
requirements as a matter of best practice.
Source: Audit workpapers.
Assessment of Data Reliability
In performing this audit, we relied on electronic les from Chico, Imperial Valley,
Mount Saint Mary’s, Orange Coast, SanDiego, and SantaCruz that these institutions
use to track and report on campus crimes. e U.S. Government Accountability
Oce, whose standards we are statutorily required to follow, requires us to assess
the suciency and appropriateness of computer-processed information that we
use to support our ndings and conclusions. We assessed the institutions’ data by
comparing them to corroborating documentation from actual incident reports
created by the campus and local law enforcement. We determined the data to be
suciently reliable for the purpose of determining the accuracy and completeness of
each institution’s Clery-reportable crime statistics.
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July 11, 2024
Grant Parks
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Dear Mr. Parks:
This letter is in response to your draft audit report, 2024-032 - Clery Act. We thank you and
your staff for their hard work in completing this important audit report.
We have received and reviewed the draft audit report and appreciate the opportunity to review
the recommendations and respond. Upon review, the university concurs with the listed
recommendations and looks forward to sharing our implementation progress in the upcoming
review.
Chico State recognizes the importance of complying with the Clery Act and other laws relating
to campus safety and crime reporting covered in this audit, and in ensuring a safe and
supportive environment for our campus community.
Thank you again for the opportunity to respond to this audit.
Sincerely,
Steve Perez
President
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Grant Parks
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Dear Mr. Parks,
Thank you for your letter dated July 8, 2024, and for the opportunity to respond to the draft Clery Audit report.
Mount Saint Mary’s University (MSMU) is committed to providing a safe environment for all our students and community. Using the
recommendations from the report, as well as reporting and policy changes we have already started to enact, MSMU will continue to
fulfill this commitment.
The good news is that MSMU is a safer campus than reported in its 2023 ASR. Also, even if the precise language of the regulation was
not used in its policies which informed its Annual Security Report (ASR), MSMU complied with the spirit and intent of the regulation.
Some inaccuracies were due to a time of staff transition.
In response to the recommendations made on pages 50-52 of the redacted report, MSMU will improve and develop centralized policies
and procedures to ensure the accuracy of its process for reporting Clery statistics and completing its ASR and associated disclosures.
Regular training will be provided for staff across various departments who contribute to the process. MSMU is committed to improving
its tracking and reporting to comply with the requirements of the Clery regulation as well as state law and best practices. We have
already changed our incident reporting tool and will adopt a standardized checklist to improve consistency. A focused Clery Committee
will be created to monitor these improvements.
MSMU’s mission is to offer a dynamic learning experience in the liberal arts and sciences to a diverse student body. As a Catholic
university primarily for women, we are dedicated to providing a superior educaon enhanced by an emphasis on building leadership
skills and fostering a spirit to serve others. Our measure of success is graduates who are commied to using their knowledge and skills
to beer themselves, their environments, and the world.
We appreciate your team’s responsiveness to inquiries and the guidance they provided. The audit provided meaningful feedback that
will help us as continue to make our campuses a safe environment for our students’ success. If you have any questions, please contact
me at jbrathwaite@msmu.edu, or 213.477. 2905.
Sincerely,
Joy E. Brathwaite, MBA MSA
Vice President for Administration and Finance
cc Ann McElaney-Johnson, PhD, President of Mount Saint Mary’s University
Chalon Campus, 1 2001 Chalon Road, Los Angeles, CA 90049 Phone: 310.954.4000
Doheny Campus, 10 Chester Place, Los Angeles, CA 90007 Phone: 213.477. 2500
www.msmu.edu
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2701 Fairview Rd., Costa Mesa, CA 92626 • www.orangecoastcollege.edu • President: Angelica L. Suarez, Ph.D.
Coast Community College District Board of Trustees: Mary L. Hornbuckle, Jim Moreno, Elizabeth Parker, Ed.D, Jerry Patterson, Lorraine Prinsky, Ph.D., Student Trustee • Chancellor: Whitney Yamamura, Ed.D.
July 11, 2024
Grant Parks
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Reference: Orange Coast College – Response to the Draft Clery Audit Report
Dear Mr. Parks:
Please accept this letter as the Orange Coast College’s official response to the redacted draft of the Clery Audit
Report dated July 8, 2024. First, we would like to express our appreciation to the State Audit Team who
participated in the process. Their thorough review and collaborative approach contributed to the valuable
experience we had going through this audit.
Orange Coast College is fully committed to ensuring that we not only meet the Clery Act requirements, but also
continue to review and incorporate best practices and protocols that support a safe college community for all
constituencies.
We have reviewed the redacted Draft Report and appreciate the opportunity to respond to the findings. The
College agrees with the findings and the recommendations provided. The outlined recommendations are
reasonable and beneficial to the College and provide us with an opportunity for continuous improvement. To
that end, appropriate team members have already begun to meet, discuss, and create a roadmap to address the
recommendations noted in the Draft Audit Report.
The College, therefore, will work towards meeting all the recommendations by the timeline specified in the
Draft Audit Report. However, we would like to note that while the College will make every effort in meeting
the recommendation which has a timeline of October 1, 2024 (To ensure that the disclosures in their annual
security reports accurately represent campus policies and institutional practices and that they are reporting
reliable information to the public and ED, Orange Coast should develop, adopt, or update by October 1, 2024,
campus policies, procedures, and programs to ensure that the institution meets all requirements of the Clery
Act),
due to our internal governance structures, the College may require additional time to accomplish this task.
We will provide you with an update in our status report document.
Please know that Orange Coast College is fully committed to promoting and maintaining a safe campus
community and has established policies, procedures, practices, and protocols that support that commitment. We
appreciate the critical recommendations provided through this audit process as we continue to enhance our
efforts towards that commitment.
Sincerely,
Angelica L. Suarez, Ph.D.
President
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Grant Parks
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Dear Auditor Parks:
The University of San Diego is committed to providing a safe environment for all students, faculty, staff, and campus
community members. Thank you for the opportunity to review and respond to the 2024-032 Clery Act audit report findings
and recommendations. USD, as described below, will comply with the findings outlined in the auditor’s report. Below you
will find our response to all four recommendations.
Recommendation 1: To ensure that they fully and adequately disclose all required policies in their annual security
report, San Diego should, by January 2025, develop guidance for staff preparing the annual security report. This
guidance should identify all required disclosures for the reports and should include a comprehensive checklist
that lists each of the required disclosures and their necessary supporting policies.
USD will comply with the recommendation made by the State Audit Team. While the Clery Act Compliance Manager does
utilize a checklist provided by ED in the 2016 handbook to fully and adequately disclose all required information in the
annual security report, this checklist can be improved to include information about necessary supporting policies and state
disclosures. By January 2025, USD will implement a checklist that includes the additional information illustrated in Figure 4
of this report.
Recommendation 2: To ensure that the disclosures in their annual security report accurately represent campus
policies and institutional practices and that they are reporting reliable information to the public and to ED, San
Diego should, by October 1, 2024, develop, adopt, or update campus policies, procedures, and programs to ensure
that the institution meets all requirements of the Clery Act.
USD will comply with the recommendation made by the State Audit Team and will identify, develop, adopt or update
policies, procedures, and/or programs that were identified as inadequate by the Audit Team. The university has already
begun the process of reviewing and updating missing or inadequate policies, including finalizing the Department of Public
Safety Timely Warning, Emergency Notifications, and Other Alerts policy which was in draft form during the audit process. We
have also made updates to the Missing Student Notification Policy and Access to University Buildings, Facilities and Grounds policy
based on recommendations identified by the State Audit Team. USD will update or implement the remaining policies that
were identified by the State Audit Team by October 1, 2024.
Recommendation 3: To ensure that staff responsible for compiling Clery crime statistics and preparing the annual
security report—as well as staff who provide crime data and policy information to those individuals—are aware
of all the Clery Act’s requirements and are aware of all campus policies and protocols for complying with the
Clery Act, San Diego should, by January 2025, provide to these staff regular trainings on Clery Act requirements,
and on specific campus procedures for complying with the Clery Act. The institution should then require and
ensure that all staff responsible for compiling the crime data and the annual security report regularly participate
in those trainings.
USD will comply with the recommendation made by the State Audit Team. Prior to our participation in this review, members
of our Clery Act Compliance Committee, which includes relevant stakeholders across the university, have participated in
Clery Act training and had opportunities to join relevant webinars focused on Clery Act compliance. The Clery Act
Compliance Manager will develop a training schedule for the committee and other staff involved in providing crime data
University Operations
Office of the Vice President
5998 Alcalá Park
San Diego, CA 92110-2492
P: (619) 260-2930
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and policy information. We will also work to identify more training opportunities for other Campus Security Authorities
across campus.
Recommendation 4: To ensure that they fully comply with state law and best practices related to campus safety,
San Diego should, by January 2025, develop, adopt, or update their campus policies, procedures, and programs to
ensure that they comply with all requirements of state law. Institutions should comply with these requirements
as a matter of best practice, even if the law does not explicitly require them to do so.
USD has reviewed and understands the recommendation made by the State Audit Team. USD is committed to complying
with all applicable laws and best practices and will identify, develop, adopt or update policies, procedures, and/or programs
wherever possible and necessary.
Thank you and your staff for your thorough and professional efforts in conducting this audit.
Sincerely,
Ky Snyder
Vice President Operations/COO
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Our voices will define the century.
The real change is us.
Chancellor Cynthia K. Larive
1156 High Street, Santa Cruz, CA 95064 | ucsc.edu
Grant Parks, State Auditor
State of California
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Dear Mr. Parks:
The University of California, Santa Cruz (UCSC) would like to thank the audit team and the
Auditor of the State of California for their work and engagement throughout the process of
conducting this audit. We are always working to improve safety in our community and
appreciate the opportunity to review our policies and processes and implement positive change.
UCSC takes compliance responsibilities seriously and agrees with each of the
recommendations outlined in the draft audit report.
Recommendation 1:
Establish procedures by January 2025 for compiling the Clery Act statistics. These procedures
should include the following:
● Listing all campus departments that maintain crime and incident data and
protocols for obtaining data from those departments. Identifying all law
enforcement agencies and obtaining all crime and incident data from those
agencies.
● Procedures for the specific tests certain staff should use to determine whether to
include a crime or incident in the Clery Act statistics.
UCSC response:
UCSC will establish, by January 2025, procedures for compiling the Clery Act statistics
including a list of all campus departments that maintain crime and incident data and
protocols for obtaining data from those departments, identification of law enforcement
agencies and protocols for obtaining data from those agencies, and procedures for the
specific test UCSC staff should use to determine whether to include a crime or incident
in the Clery Act statistics.
Recommendation 2:
Develop procedures by January 2025 for their Campus Police Department to follow to ensure
that all crimes are recorded in the institution’s daily crime log. These procedures should include
the list of all institutional departments and law enforcement agencies from which the Campus
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Police Department obtains crime data to include in the institution's daily crime logs. These
procedures should also define who is responsible for obtaining data for inclusion in the daily
crime log.
UCSC response:
UCSC will develop, by January 2025, procedures for the UC Santa Cruz Campus Police
to ensure that all crimes are recorded in the daily crime log. These procedures will
include a list of all institutional departments from which the UC Santa Cruz Campus
Police obtain crime data to include in the daily crime logs, a list of all law enforcement
agencies from which the UC Santa Cruz Campus Police obtain crime data to include in
the daily crime logs, and clear definitions of responsibility for obtaining data for inclusion
in the daily crime log.
Recommendation 3:
Develop guidance by January 2025 for staff preparing the annual security reports. This
guidance should identify all required disclosures for the reports and should include a
comprehensive checklist that lists each of the required disclosures and their necessary
supporting policies.
UCSC response:
UCSC will develop, by January 2025, guidance for staff preparing the annual security
reports to ensure that we fully and adequately disclose all required policies. This
guidance will include all required disclosures for the reports and a comprehensive
checklist that lists each required disclosure and their supporting policy.
Recommendation 4:
Develop, adopt or update by October 1, 2024 campus policies, procedures, and programs to
ensure that the institution meets all requirements of the Clery Act.
UCSC response:
UCSC will develop, adopt, or update, by October 1, 2024, the campus policies,
procedures and programs identified as insufficient in this report to ensure compliance
with the Clery Act.
Recommendation 5:
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Provide staff regular trainings by January 2025 on Clery Act requirements, and on specific
campus procedures for complying with the Clery Act. Require and ensure that all staff
responsible for compiling the crime data and the annual security reports regularly participate in
these trainings.
UCSC response:
UCSC will provide, by January 2025, regular training on Clery Act requirements and
specific campus procedures for complying with the Clery Act. All staff responsible for
compiling the crime data and annual security report will regularly participate in these
trainings.
Recommendation 6:
Develop, adopt, or update by January 2025 campus policies, procedures, and programs to
ensure that they comply with all requirements of state law.
UCSC response:
UCSC will develop, adopt, or update, by January 2025, the campus policies, procedures
and programs identified as insufficient in this report to ensure compliance with the
requirements of state law.
UCSC is eager to implement these recommendations and is already working to improve the
transparency of our public safety information and compliance with the Clery Act based on the
productive engagement we have had with your team. We are committed to continuous
improvement and creating a campus environment that promotes safety for all.
Sincerely,
Cynthia K. Larive
Chancellor
University of California, Santa Cruz
200 Kerr Hall | 831.459.4291
