2023-2024 Undergraduate Catalog > Student Rights and Responsibilities (Policies and Procedures) > Clery Compliance Policy

Clery Compliance Policy

Policy approved by Mercy College Board of Trustees, September 2021

Institutions of higher education participating in federal financial aid programs are required to comply with the Jeanne Clery Disclosure of Campus Security Policy and the Campus Crime Statistics Act (20 USC § 1092(f)) (the “Clery Act"). The Clery Act is enforced by the United States Department of Education (“ED”).

In order to comply with the Clery Act, Mercy College of Ohio (“the College”) takes the following steps.

• Tracks crime statistics for incidents reported to have occurred on campus, on public property immediately adjacent to, or running through the campus, and at certain non-campus buildings or property.
• By October 1 each year or other deadline established by ED, publishes an Annual Security Report (“ASR”) for each campus or location, providing security-related statements of policy, procedure and programming, as well as crime statistics for the past three calendar years.
• Submits crime statistics to ED via its online survey each fall.
• Issues timely warnings when a reported crime presents an ongoing danger to the College community.
• Devises an emergency response, notification, and testing policy.
• Retains documentation of the College’s Clery compliance efforts.

Because the College’s campuses have security departments (as that term is defined by the Clery Act and related guidance published by ED), the College also has and maintains a daily crime log that is available to members of the College community and the public upon request.

Preparing the Annual Security Reports

Separate ASRs are prepared for the Toledo campus and Youngstown location. The reports are prepared by the Vice-President of Students Affairs or his/her designee, along with the Director of Compliance and Risk Management. The reports are prepared in cooperation with campus security/police officials including Mercy Public Safety-Toledo Campus and Mercy Health Youngstown Police Department. The Clery Act Appendix for FSA Handbook is ED’s key guidance document related to the Clery Act, and the current version is available at: https://www2.ed.gov/admins/lead/safety/cleryappendixfinal.pdf.   This document is reviewed and utilized in preparing the ASRs.

Availability of The Annual Security Reports (ASR)

ASRs are updated annually and published on the College website on or before October 1 (or other deadline established by ED) each year. The campus community is notified of the availability of the reports by email and newsletter when the reports are published.

Reporting of Criminal Offenses

To report a crime, call 911 (emergencies) or campus police/security (emergencies and non-emergencies).

The following sections regarding Emergency Notification and Evacuation and Timely Warnings are also included in the ASRs and expanded upon in the College’s Emergency Response Plan, which is available on the College website at https://mercycollege.edu/student-affairs/campus-safety

Emergency Notification and Evacuation Policy

Emergency Notification Policy.  The College will, without delay, and taking into account the safety of the community, determine the content of the notification and initiate the notification system, unless issuing a notification will, in the professional judgment of responsible authorities, compromise efforts to assist the victim or to contain, respond to or otherwise mitigation the emergency.

Confirmation.  Determination of an emergency or dangerous situation will be made by any or all of the following:

1. Mercy Health policy/security
2. National Incident Management System (NIMS) campus incident management team (Mercy Healthcare Campus, Mercy St. Vincent Medical Center, or St. Elizabeth Health Center).
3. President or his/her designees

Notification.  The President, his/her designee and any advisory staff will determine if the situation affects the entire campus or a segment of campus, and whether the entire campus or only a segment should be notified.  This will be based on geography, impact on operations, and safety.  The situation will be assessed continually.

Content/initiation of notification.  The content of the notification will be developed with input from campus security/police/NIMS team, the President (or designee), as well as any advisory staff.  Notification will be made through applicable and multiple means, if necessary, including email, text messaging, TV/radio message, phone message, alarms, PA announcements, and signage.

Persons responsible for carrying out the actions described above include:
Campus police/security/NIMS team President or designee, and Vice President, Director of Communication

Emergency Drills, Testing, and Evacuation Procedures.
Annual testing.  On an annual basis, the institution will test its emergency response and evacuation procedures.  Each test will be documented with a description of the exercise, the date, start/end time, and whether the test was announced or unannounced.

Annual notification.  Emergency response and evacuation procedures will be publicized in conjunction with at least one test per calendar year.

Timely Warnings
In the event of crimes, either on or off-campus, that in the judgment of the head of security (Mercy Public Safety Director of Emergency Management-Toledo Campus or Mercy Health Youngstown-Chief of Police), or his/her designee constitute an ongoing or continuing threat, a campus wide "timely warning" will be issued.  In the event a warning is needed, the Director or Chief, or his/her designee, shall provide the Vice-President of Student Affairs or his/her designee with the specifics of the case for the purposes of drafting the timely wanting notice.  The warning will be issued through the RAVE Emergency Alert system to students, faculty, and staff.  Depending on the particular circumstances of the crime, especially in situations that could pose an immediate threat to the community and individuals, notices may be posted around campus, as well.