Report 2012-032 All Recommendation Responses

Report 2012-032: California's Postsecondary Educational Institutions: Some Institutions Have Not Fully Complied With Federal Crime Reporting Requirements (Release Date: October 2012)

Recommendation #1 To: Academy of Art University

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should review and adhere to applicable guidance related to the Clery Act, including Education's Office of Postsecondary Education's (OPE) Handbook for Campus Safety and Security Reporting (OPE handbook) and the Federal Bureau of Investigation's Uniform Crime Reporting Handbook.

60-Day Agency Response

According to the Academy, the annual security report will be updated each year. To ensure that the report includes only Clery reportable crimes as well as the campus security procedures and disclosures required by Education, reportable crimes will be based on the OPE handbook and Academy staff will stay current on new disclosure requirements by attending Clery conferences and monitoring Clery updates. (See 2013-406, p. 103)

California State Auditor's Assessment of 60-Day Status: Fully Implemented

Recommendation #2 To: Northridge, California State University

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should review and adhere to applicable guidance related to the Clery Act, including Education's Office of Postsecondary Education's (OPE) Handbook for Campus Safety and Security Reporting (OPE handbook) and the Federal Bureau of Investigation's Uniform Crime Reporting Handbook.

60-Day Agency Response

According to the police department at Northridge, it has reviewed and will adhere to the applicable guidelines related to the Clery Act. Specifically, Northridge records unit personnel will continue to use the OPE handbook as its primary resource for meeting Clery Act requirements. (See 2013-406, p. 103)

California State Auditor's Assessment of 60-Day Status: Fully Implemented

Recommendation #3 To: Laney College

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should review and adhere to applicable guidance related to the Clery Act, including Education's Office of Postsecondary Education's (OPE) Handbook for Campus Safety and Security Reporting (OPE handbook) and the Federal Bureau of Investigation's Uniform Crime Reporting Handbook.

Annual Follow-Up Agency Response From October 2015

The Peralta District Vice Chancellor of General Services has responsibility for the Peralta Police and district wide oversight of compliance for the Clery Act. Under the Vice Chancellor's authority, the Alameda County Sheriffs provide Peralta Community College District Police Services and serve as the campus security authority on the Laney College campus. Designated police staff and other district staff completed the following activities on or before October, 2015:

1. The Annual Crime Statistics for Laney College were filed on October 12, 2015 with the Department of Education and the data can be found on their website and at the following Peralta District web address: http://web.peralta.edu/police-services/crime-statistics/.

2. The Office of the Chancellor is responsible for all district wide policies and procedures while the Vice Chancellor of General Services informs all security policies in consultation with college representatives. Security policies and procedures were updated and compliant with Clery Act requirements as of September 2015 and can be found at the following web address: http://web.peralta.edu/police-services/policies-procedure/.

3. Peralta Police completed periodic reviews of the Clery Act updates prior to maintaining daily log of crimes, creating the annual crime statistics and submitting the Annual Crime Statistics Report to the Department of Education website in October 2015.

4. Peralta Police assigned staff completed attendance at the annual training on the proper implementation of the Clery Act and related changes or updates.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2014

The Alameda County Sheriffs are assigned to provide Peralta Community College District Police Services and serve as the campus security authority on the Laney College campus. Peralta Police have responsibility for compliance with the Clery Act and designated police staff will:

1.Review on a periodic basis and adhere to the Clery Act updates on the Department of Education website.

2.Use the OPE Handbook and Federal Bureau of Investigation's Uniform Crime Reporting Handbook as its primary source for annually updating the Annual Security Report, maintaining the daily log of crimes and annually updating Safety policies and procedures in accordance with the Clery Act Requirements.

3.Attend annual trainings on the proper implementation of Clery Act additions and changes.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

60-Day Agency Response

Laney did not provide a response to the state auditor as requested in time to include it in this report. (See 2013-406, p. 103)

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #4 To: San Bernardino Community College District

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should review and adhere to applicable guidance related to the Clery Act, including Education's Office of Postsecondary Education's (OPE) Handbook for Campus Safety and Security Reporting (OPE handbook) and the Federal Bureau of Investigation's Uniform Crime Reporting Handbook.

6-Month Agency Response

San Bernardino indicated in its response that it has updated its policies and procedures to implement this recommendation. Specifically, according to San Bernardino Community College District Police Department policy 11.02.04, those responsible for crime statistic entry into the department's crime log will review the U.S. Department of Education's Office of Postsecondary Education's Handbook for campus safety reporting as well as the Federal Bureau of Investigation's Uniform Crime handbook to ensure Clery compliance.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

60-Day Agency Response

According to San Bernardino's police department, it is updating its annual security report's policies and procedures for both crime statistics and campus security policy disclosures to include a review of the OPE handbook and the Federal Bureau of Investigation's Uniform Crime Reporting Handbook to ensure Clery Act compliance. (See 2013-406, p. 104)

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #5 To: San Diego Community College District

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should review and adhere to applicable guidance related to the Clery Act, including Education's Office of Postsecondary Education's (OPE) Handbook for Campus Safety and Security Reporting (OPE handbook) and the Federal Bureau of Investigation's Uniform Crime Reporting Handbook.

1-Year Agency Response

The SDCCD Emergency Communications Policy and Procedure (AP 7415.2) was approved and implemented February 25, 2013. The SDCCD Emergency Communications Policy and Procedure statement was included in the 2012 Annual Security Report. The policy can also be viewed on the SDCCD Board Policies website at http://www.sdccd.edu/public/district/policies/.

SDCCD provides students with information and guidance, education and/or treatment through Alcoholics Anonymous and Narcotics Anonymous. The District provides assistance to employees through the Employee Assistance Program. Information on these programs was included in the 2011 and the 2012 Annual Security Report; as well as the Student Rights, Responsibilities and Privacy of Student Records Policy 3100, which includes Student Code of Conduct and Student Grievance Procedure, and the Smoking Policy (BP 0505).

To ensure compliance with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, all SDCCD PD personnel that contribute to the annual security report have been directed to review and adhere to applicable guidance related to the Clery Act, including the U.S. Department of Education's Office of Postsecondary Education's Handbook for Campus Safety and Security Reporting and the Federal Bureau of Investigation's Uniform Crime Reporting Handbook.

California State Auditor's Assessment of 1-Year Status: Fully Implemented

60-Day Agency Response

According to the San Diego Community College District (district), its Clery Act Compliance Committee is assessing compliance concerns, including district policies and procedures. All policies and procedures determined to be out of compliance with the Clery Act will be revised and/or included in future annual security reports. Also, the district's Emergency Communications Policy and Procedure is currently under administrative review. Once approved, this policy and procedure will be added to the 2012 annual security report. Lastly, the district is developing additional information to include in future annual security reports regarding illegal drug and alcohol policies. (See 2013-406, p. 104)

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #6 To: University of the Pacific

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should review and adhere to applicable guidance related to the Clery Act, including Education's Office of Postsecondary Education's (OPE) Handbook for Campus Safety and Security Reporting (OPE handbook) and the Federal Bureau of Investigation's Uniform Crime Reporting Handbook.

Annual Follow-Up Agency Response From October 2014

The Annual Clery Report is in compliance and all crimes are accurate and applicable crimes and disclosing all required campus security policies, institutions should review and adhere to applicable guidance related to the Clery Act. These can be viewed at the URL listed below.

http://www.pacific.edu/Documents/student-life/publicsafety/Annual%20Report%20090714c.pdf

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

6-Month Agency Response

Pacific determined that a portion of the policy had inadvertently been left out of the Annual Safety and Security Report. According to Pacific, the text was added to the report.

California State Auditor's Assessment of 6-Month Status: Pending

Pacific's response does not indicate when or how it will review and adhere to applicable guidance related to the Clery Act. Thus, it does not specifically address the recommendation.

60-Day Agency Response

Pacific did not provide a response to the state auditor as requested in time to include it in this report. (See 2013-406, p. 104)

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #7 To: Academy of Art University

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should thoroughly review the Clery Act crime statistics and security policy disclosures in their annual security reports for accuracy before publication.

6-Month Agency Response

The following procedures are now in place to ensure that any new disclosures required by the U.S. Department of Education are reflected in the Academy of Art University Annual Security Report.

1. The Executive Vice President of Financial Aid and Compliance will review any new disclosure requirement by the Department of Education. This information will be obtained by attendance at Clery conferences, annual attendance at the National Association of Financial Aid Administrators conference, updates on the Department of Education Federal Student Aid website and updates contained in the Department of Education Federal Student Aid Handbook.

2. At the request of the Executive Vice President of Financial Aid and Compliance, a meeting will take place with the Executive Vice President of Financial Aid and Compliance, Director of Campus Safety and the Communication Center Dispatcher to review the new requirements. The location of the requirements in the Annual Security Report will also be determined at this meeting.

3. A draft Annual Security Report will be generated containing the new requirements for a final review by the Executive Vice President of Financial Aid and Compliance.

4. The final Annual Security Report will contain the new disclosure requirements on or before the Department of Education effective date.

The school is already aware of new requirements signed into law on March 7, 2013. The Violence Against Women Reauthorization Act of 2013 goes into effect in 2014. This update is currently in step #1 above.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

60-Day Agency Response

According to the Academy, the annual security report will be updated each year. To ensure that the report includes only Clery reportable crimes, the report will be reviewed for accuracy by the Academy's Clery officer and director of security. These reviews will occur throughout the year as well as at year end before the report is released for publication. Also, as mentioned under recommendation 1.1.a, Academy staff will stay current on new disclosure requirements by attending Clery conferences and monitoring Clery updates. However, although the Academy indicated that it will be taking steps to stay informed of the disclosures required by Education, it did not mention the steps it would take to ensure that any changes to its campus security procedures related to those disclosures are reflected in its annual security report. (See 2013-406, p. 104)

California State Auditor's Assessment of 60-Day Status: Partially Implemented

Recommendation #8 To: Northridge, California State University

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should thoroughly review the Clery Act crime statistics and security policy disclosures in their annual security reports for accuracy before publication.

60-Day Agency Response

According to Northridge, in 2012, it established a two-step process to ensure that the annual security report includes all the required policy statements and disclosures as well as accurate statistics. This process includes a review by the records supervisor who writes the report. Next, the report is reviewed by the records administrator to verify its completeness. The review is completed by using a checklist of the procedures, policies, disclosures, practices, and programs as required by Education to be included in the report. (See 2013-406, p. 104)

California State Auditor's Assessment of 60-Day Status: Fully Implemented

Recommendation #9 To: Laney College

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should thoroughly review the Clery Act crime statistics and security policy disclosures in their annual security reports for accuracy before publication.

Annual Follow-Up Agency Response From October 2015

Under supervision by the Peralta District Vice Chancellor of General Services and in coordination with assigned representatives from each Peralta College, the Annual Security Report is reviewed in compliance with the Clery Act before it is distributed to students and staff. Under the supervision of the Vice Chancellor of General Services, Peralta Police services completed implementation of the following steps to ensure correct reporting of crime statistics in the Annual Security Report and in compliance with the Clery Act.

1. The Annual Crime Statistics for Laney College were filed on October 12, 2015 with the Department of Education and the data can be found on their website and at the following Peralta District web address: http://web.peralta.edu/police-services/crime-statistics/.

2. The Office of the Chancellor is responsible for all district wide policies and procedures while the Vice Chancellor of General Services informs all security policies in consultation with college representatives. Security policies and procedures were updated and compliant with Clery Act requirements as of September 2015 and can be found at the following web address: http://web.peralta.edu/police-services/policies-procedure/.

3. The Annual Security Report is produced by District General Services on behalf of all Peralta District Colleges. The report contains both college specific crime statistics and district wide policies, and administrative procedures, practices, programs and referral services required by the Department of Education in accordance with the Clery Act. The Annual Security Report can be found on the Peralta District website at the following web address: http://web.peralta.edu/police-services/college-annual-security-reports-ars/.

4. The Annual Security Report was distributed to Peralta District registered students and active employees on September 9, 2015 and September 4, 2015, respectively.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2014

Under the supervision of the Vice Chancellor of General Services, the Peralta Police Services currently publishes and distributes the Annual Security Report in compliance with the Clery Act. The Peralta police will implement the following steps to ensure correctly reporting all applicable crimes and security policies are documented in the report in compliance with the Clery Act. Peralta Police unit will create:

1.A Checklist to identify all procedures, policies, disclosures, practices and programs required by the Department of Education to be included in the report.

2.The Vice Chancellor of General Services Office staff and Peralta Police Services staff who will review a draft of the report for accuracy and completeness before it is published and distributed.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

60-Day Agency Response

Laney did not provide a response to the state auditor as requested in time to include it in this report. (See 2013-406, p. 104)

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #10 To: San Bernardino Community College District

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should thoroughly review the Clery Act crime statistics and security policy disclosures in their annual security reports for accuracy before publication.

6-Month Agency Response

San Bernardino indicated in its response that it has updated its policies and procedures to implement this recommendation. Specifically, according to San Bernardino Community College District Police Department policy 11.02.04, a secondary review, by management and staff of the Clery Act crime statistics and disclosures policy will be completed to ensure accuracy prior to publishing the annual security report.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

60-Day Agency Response

According to San Bernardino, it is updating its annual security report's policies and procedures to include a secondary review of the Clery Act crime statistics and security policy disclosures in its annual security report to ensure this information is accurate before the report is published. (See 2013-406, p. 105)

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #11 To: San Diego Community College District

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should thoroughly review the Clery Act crime statistics and security policy disclosures in their annual security reports for accuracy before publication.

1-Year Agency Response

Shannon Nasca, the Clerical Supervisor and main Clery Act Compliance Officer for the SDCCD Police Department, has attended Clery Act Training to ensure compliance in correctly reporting all applicable crimes and disclosing all required campus security policies. Shannon attended Clery Act Training classes in 2010, 2012, 2013 and is attending training in January 2014. She has utilized the Checklist for Campus Safety and Security Compliance provided in the Handbook for Campus Safety and Security Reporting. Additional SDCCD PD personnel have attended Clery Act Training to provide Shannon with assistance and backup in ensuring compliance.

As online training and webinars are available Shannon and SDCCD PD personnel will participate as necessary. Shannon will ask the Department of Education for guidance regarding reports that may be complex to ensure accurate crimes statistics.

To ensure compliance with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, all SDCCDPD personnel that contribute to the production of the annual security report will thoroughly review the Clery Act crime statistics and security policy disclosures in the annual security report for accuracy before it is published.

California State Auditor's Assessment of 1-Year Status: Fully Implemented

60-Day Agency Response

According to the district, it is continuing to take the necessary steps to ensure that the crime reporting review process is in compliance with the federal definition of all Clery reportable crimes. However, these steps were not explained. In addition, the district did not mention the steps it would take to stay current on new disclosure requirements or the steps it would take to ensure that any changes to campus security procedures related to new disclosures are reflected in the annual security report. (See 2013-406, p. 105)

California State Auditor's Assessment of 60-Day Status: Partially Implemented

Recommendation #12 To: University of the Pacific

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should thoroughly review the Clery Act crime statistics and security policy disclosures in their annual security reports for accuracy before publication.

Annual Follow-Up Agency Response From October 2014

The Annual Clery Report is in compliance and all crimes are accurate and applicable crimes and disclosing all required campus security policies, institutions should review and adhere to applicable guidance related to the Clery Act. These can be viewed at the URL listed below.

http://www.pacific.edu/Documents/student-life/publicsafety/Annual%20Report%20090714c.pdf

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

6-Month Agency Response

In order to prevent a repeat of the software error that led to the inadvertent failure to report one burglary in the 2010 Clery statistics, a review was conducted of the location codes to make sure that every active location code has a site name as well.

Pacific's Annual Campus Safety and Security Report was updated (along with an explanatory caveat) to show the correct number of burglaries in 2010.

Pacific's Clery statistics for 2010 were also updated on the United States Department of Education web site.

California State Auditor's Assessment of 6-Month Status: Pending

The review described by Pacific is not of the crime statistics and disclosures as they appear in their annual security report. Although the review described is a helpful step towards ensuring all applicable crimes and disclosures are included in the report, the response does not specifically address our recommendation.

60-Day Agency Response

Pacific did not provide a response to the state auditor as requested in time to include it in this report. (See 2013-406, p. 105)

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #13 To: Laney College

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should ensure that they have a complete, accessible daily crime log, as required by the Clery Act.

Annual Follow-Up Agency Response From October 2014

Peralta Police has responsibility for reporting and maintaining daily crime logs in compliance with the Clery Act. Every crime on the Laney Campus is reported to the Peralta Police services and entered into the Dispatch System(CAD) maintained in the Peralta Police Services Offices at Peralta District General Services. A report number is assigned to each crime entered into the system along with the nature of the crime, date reported, date crime occurred and general location of the crime. Designated Peralta Police staff review the crimes in accordance with Clery Act requirements using the OPE Handbook and Federal Bureau of Investigation's Uniform Crime Reporting Handbook. According to Peralta Police Services, crime logs are open for public viewing at the patrol station.

In response to an audit issue, Laney College now excludes vehicle burglaries from the burglary category. The 2014-15 Annual Safety Report and crime statistics for 2010, 2011 and 2012 reflect this correction.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

60-Day Agency Response

Laney did not provide a response to the state auditor as requested in time to include it in this report. (See 2013-406, p. 105)

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #14 To: San Bernardino Community College District

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should ensure that they have a complete, accessible daily crime log, as required by the Clery Act.

6-Month Agency Response

San Bernardino indicated in its response that it has updated its policies and procedures to implement this recommendation. Specifically, according to San Bernardino Police Department (department) policy 11.02.04, the daily crime log is reviewed by the Chief of Police or a supervisor on a daily basis. Also, a hard copy of the daily crime log is located in the front office, emailed to the departmental list server, and posted on the department's Web site.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

60-Day Agency Response

According to San Bernardino, it is planning to ensure that the daily crime log is reviewed by a supervisor on a daily basis and forwarded to the chief of police for verification of accuracy. (See 2013-406, p. 105)

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #15 To: San Diego Community College District

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should ensure that they have a complete, accessible daily crime log, as required by the Clery Act.

60-Day Agency Response

According to the district, it will now spot check the daily crime log for accuracy for a period of at least six-months to ensure that all required information is being reported correctly. (See 2013-406, p. 105)

California State Auditor's Assessment of 60-Day Status: Fully Implemented

Recommendation #16 To: University of the Pacific

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should ensure that they have a complete, accessible daily crime log, as required by the Clery Act.

6-Month Agency Response

According to Pacific, every crime reported to Public Safety is now entered via CAD (the dispatch screen) and then assigned a case number. This ensures that all crimes reported to Public Safety appear in the Daily Crime Log. An example of how this works can be demonstrated by describing how Public Safety reported in 2012 a crime that occurred years earlier. Public Safety was informed on 7-19-12 of a sexual assault of a student that occurred between Jan 1, 1997 and Dec 31, 1998 (14-15 years earlier). Following Clery requirements, the crime was noted in the Daily Crime Log on Jul 19, 2012. The Daily Crime Log shows the nature of the crime, as well as the date reported and date range in which it occurred. In accordance with the Clery Act, this crime will be listed in Pacific's 2012 Clery statistics (with a caveat as to the date of the crime).

California State Auditor's Assessment of 6-Month Status: Fully Implemented

60-Day Agency Response

Pacific did not provide a response to the state auditor as requested in time to include it in this report. (See 2013-406, p. 105)

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #17 To: Laney College

Institutions should ensure that they properly notify both current and prospective students and employees of the availability of their annual security reports in the manner prescribed by the Clery Act.

Annual Follow-Up Agency Response From October 2014

Peralta Police has responsibility for notifying both current and prospective students and employees when the annual security reports are available. For current students and employees, access to the digital copy of the report is located on the Peralta Community College District website and the Laney College website at the following web addresses. For prospective students, language exists in the Laney College 2013-2015 catalog on page 119 under the Clery Act Section. The disclosure in the Laney College catalog provides a web address for accessing the Annual Security Report on the Peralta Community College District website.

Peralta web page for Handbook

http://web.peralta.edu/police-services/personal-safety-handbooks/

Peralta web Page for Crime Statistics for All four colleges

http://web.peralta.edu/police-services/

Laney College web page for Handbook and Crime Statistics

http://www.laney.edu/wp/security/

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

60-Day Agency Response

Laney did not provide a response to the state auditor as requested in time to include it in this report. (See 2013-406, p. 105)

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #18 To: San Bernardino Community College District

Institutions should ensure that they properly notify both current and prospective students and employees of the availability of their annual security reports in the manner prescribed by the Clery Act.

1-Year Agency Response

The San Bernardino Community College District has posted notice on the home page of the District's web-site. It reads, For prospective students and employees and current students and employees please click on the link below to view the Annual Security Report. Currently they are three links available to view the ASR for each campus.'

California State Auditor's Assessment of 1-Year Status: Fully Implemented

6-Month Agency Response

San Bernardino provided the State Auditor screen prints for current and prospective students. However, the Valley college site would not print the security report information. As a result, San Bernardino requested that the State Auditor go to www.valleycollege.edu where the link to the security report can be found. San Bernardino also provided the State Auditor Crafton Hills screen print which shows where the security report link is located. New and prospective employees can view the security report on each job announcement posted.

California State Auditor's Assessment of 6-Month Status: Partially Implemented

Based on a review of the screen prints and the Web site San Bernardino refers to in its response, San Bernardino implemented the portion of this recommendation concerning prospective students and employees. However, it did not provide documentation to support its assertion that current students and new employees are made aware of its annual security report and did not address how San Bernardino informs current employees of the availability of the annual security report. While San Bernardino provided support for a link on its Web site to its security report, it did not indicate how it communicates the presence of this link to its current students and employees. As we stated in our report, if an institution chooses to distribute its security report by posting it on its Web site, it must provide a notice of the availability of the information to all students and employees. This notice must include the exact electronic address (link) at which the information is posted, a description of the report's contents, and a statement that the institution will provide a paper copy of the information upon request.

60-Day Agency Response

According to San Bernardino, it is in the process of updating its policies and procedures for notifying current and perspective students as well as current and perspective employees of its annual security report to ensure the notification is done properly. (See 2013-406, p. 106)

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #19 To: San Diego Community College District

Institutions should ensure that they properly notify both current and prospective students and employees of the availability of their annual security reports in the manner prescribed by the Clery Act.

1-Year Agency Response

All applicants for employment with SDCCD receive a Certification Page that they must electronically sign acknowledging their statements are truthful and complete. Below this statement is the link to the annual security report that states the following:

"The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act requires colleges and universities to disclose information about crime on and around their campuses. Click here for Campus Crime Statistics information."

The applicant can return to the Certification Page, even after submission, to view the link and read the annual security report.

California State Auditor's Assessment of 1-Year Status: Fully Implemented

60-Day Agency Response

According to the district, it has added a link to the annual security report on the district's Employment Opportunities Web site. Also, its Clery Act Compliance Committee is working with the district's Human Resources to establish any additional guidelines necessary for compliance with the notification requirement. (See 2013-406, p. 106)

California State Auditor's Assessment of 60-Day Status: Partially Implemented

Recommendation #20 To: University of the Pacific

Institutions should ensure that they properly notify both current and prospective students and employees of the availability of their annual security reports in the manner prescribed by the Clery Act.

Annual Follow-Up Agency Response From October 2014

The University has properly notify both current and prospective students and employees of the availability of their annual security reports in the manner prescribed by the Clery Act.

The Annual Clery Report is in compliance and all crimes are accurate and applicable crimes and disclosing all required campus security policies, institutions should review and adhere to applicable guidance related to the Clery Act. These can be viewed at the URL listed below.

http://www.pacific.edu/Documents/student-life/publicsafety/Annual%20Report%20090714c.pdf

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

6-Month Agency Response

Pacific indicated in its response that for prospective employees Human Resources has added a link to the front page of its web site to inform them of the annual Safety and Security Report. This link is near the link that prospective employees will use to search for open positions (Employment Opportunities). For prospective undergraduate students a paragraph was added to the online Pacific catalog, informing the students about the Annual Safety and Security Report.

California State Auditor's Assessment of 6-Month Status: Partially Implemented

Pacific's response does not include the actions it has or will take with regards to properly notifying "current" students and employees.

60-Day Agency Response

Pacific did not provide a response to the state auditor as requested in time to include it in this report. (See 2013-406, p. 106)

California State Auditor's Assessment of 60-Day Status: Pending

All Recommendations in 2012-032

Agency responses received after June 2013 are posted verbatim.