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Defining Clery Act Geography and Campus Security Authority

Campus safety is a federal requirement, not just a moral one. Every year, U.S. colleges and universities must disclose detailed reports about crimes that occur on campus and in surrounding areas connected to student life. These disclosures are mandated by the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act, known simply as the Clery Act. Born from tragedy, this legislation compels federally funded institutions to uphold transparency about campus crimes, creating safer environments and building public trust. But complying with the Clery Act isn’t always straightforward. One of the most frequently misunderstood aspects is Clery geography: how institutions define and report incidents based on location. This piece breaks down the critical rules around where crimes must be reported and why getting it right can make all the difference in protecting students and the institution itself.

Understanding Clery Geography: The Boundaries That Matter

One of the most overlooked challenges in Clery Act compliance is knowing where a reportable crime occurs. That’s a geographic as well as legal question. The Department of Education outlines three categories of Clery geography: on-campus, non-campus and public property. Each designation comes with specific reporting obligations. Getting them wrong can lead to serious consequences for institutions.

On-Campus Areas: Under 34 CFR 668.46(a), “campus” includes:

  • Buildings or property owned or controlled by the institution within the same reasonably contiguous area and used to support educational purposes (think classrooms and dorms).
  • Structures within or near that area which are owned by the institution but controlled by another party, regularly used by students and support institutional goals (like a campus-run coffee shop or bookstore).

Though “reasonably contiguous” isn’t explicitly defined, many institutions interpret this to include locations listed on campus maps or marked with campus signage.

Non-Campus Buildings or Property: This category broadens the reporting landscape to include:

  • Any location owned or controlled by officially recognized student organizations such as fraternities, sororities or club housing.
  • Buildings or property owned by the institution, used for educational purposes, frequently accessed by students, but not located in the contiguous campus area (like off-site learning centers or sports venues).

The term “officially recognized” isn’t firmly defined either but typically refers to student groups that receive funding or administrative support from the institution.

Public Property:

  • Public streets, sidewalks, parking lots and other thoroughfares that run through or border campus areas.
  • Must be publicly owned, adjacent to campus and easily accessible from the institution.

Institutions aren’t responsible for private properties nearby, but they should clearly demarcate these areas with signage like “Private Property” or “No Trespassing” to avoid confusion. Transparency here protects both the school and students.

Who Must Report? Clarifying Campus Security Authority

The Clery Act places reporting responsibility not only on campus police, but on a wide range of staff and faculty known collectively as Campus Security Authorities (CSAs). These are people with major responsibility for student and campus activities, such as:

  • Residence hall directors or advisors
  • Athletic directors and coaches
  • Faculty or staff advisors to student groups
  • Greek Life coordinators

These individuals must be trained to recognize and report incidents — especially sensitive cases like sexual harassment — accurately and promptly. When they don’t, institutions risk fines, reputational damage or legal action from victims. Underreporting is a regulatory failure.

Why It Matters

The Clery Act exists to empower students, parents and communities with reliable information about campus safety. But that only works if institutions take their obligations seriously. Misunderstanding geography or failing to train CSAs can lead to errors, leaving students vulnerable. Compliance is much more than just a checkbox.

This publication contains general information only and Sikich is not, by means of this publication, rendering accounting, business, financial, investment, legal, tax, or any other professional advice or services. This publication is not a substitute for such professional advice or services, nor should you use it as a basis for any decision, action or omission that may affect you or your business. Before making any decision, taking any action or omitting an action that may affect you or your business, you should consult a qualified professional advisor. In addition, this publication may contain certain content generated by an artificial intelligence (AI) language model. You acknowledge that Sikich shall not be responsible for any loss sustained by you or any person who relies on this publication.

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