The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (“Clery Act”) is a federal consumer protection law that provides campus members and the public with information about campus safety. Every educational institution that participates in federal student financial aid programs under Title IV of the Higher Education Act must comply with the Clery Act and also certify such compliance as part of its Program Participation Agreement with the United States Department of Education (“Department”). Included among schools’ Clery Act obligations is the designation of campus security authorities (“CSAs”). CSAs include institutional officials who have significant responsibilities for student life or activities. CSAs are obligated to report alleged crimes that occur in college-owned or controlled buildings or on campus grounds and adjacent public property to campus police or security. In accordance with the Clery Act, crimes reported by CSAs are included in institutions’ daily crime logs that are available for public inspection and also used by campus safety to issue timely warnings and emergency notifications about ongoing threats impacting the campus community.
 
Educational institutions’ summer youth camps are no exception to these requirements. In its Campus Crime Final Program Review Determination involving Baylor University, the Department noted that the institution hosted dozens of summer camps comprised of hundreds of high school-aged students who lived in residential student housing during their programs. Though the university required camp employees to complete minor safety training that explained how to report and respond to student incidents, the Department indicated that the training failed to meet fundamental CSA requirements for reporting of crime statistics and the issuance of timely warnings. Specifically, the Department found that the university failed to ensure its camps’ directors and staff, who were entrusted with campers’ safety, were aware of relevant CSA policies and processes and prepared to handle CSA duties and responsibilities.
 
Separately, in its Campus Crime Final Program Review Determination involving Pennsylvania State University, the Department stated that the required recipients of Clery Act timely warnings are not limited to university students and employees and specifically include campers. Consequently, covered institutions also must be prepared to extend their emergency notification systems to reach summer camp attendees as well.
 
As a result of these determinations, minor safety training alone for summer camp staff will not suffice in a Clery Act compliance audit; summer camp directors and staff should be formally identified as CSAs, notified of this designation, and trained accordingly; and colleges must be prepared to issue timely warnings under the Clery Act to summer camp attendees and staff. For many colleges, summer camp compliance with the Clery Act may be achieved by simply expanding the use of existing systems, such as Clery Act training modules and emergency notification platforms, to include camp staff and campers.
 
Elliot Cox reminds us in their article “Summer is Coming: Are Youth Camps Part of Your Clery Compliance Program?” for Campus Safety, “youth camp staff are a particularly tricky group of CSAs to manage” and “highly transitory.” Cox adds, “They are often students or employees whose normal campus function 363 days out of the year would not make them CSAs, but because they happen to work a two-day youth camp, now are.” In addressing this conundrum, Cox recommends that schools consider their existing Clery Act infrastructure to accomplish compliance with summer camp staff and attendees.
 
The bottom line: Clery Act compliance is not unattainable, but planning is key. Including colleges’ youth camp organizers in institutions’ Clery Act compliance meetings or committee service, formally identifying camp staff as CSAs in summer camp policies, mandating camp staff complete CSA and minor safety training, and developing a system for enrolling campers and their parents in the colleges’ timely warning notification system are a few measures that schools can deploy to ensure their summer camps comply with the Clery Act and support campers’ safety.