BPPM 50.71

For more information contact:
   Compliance and Civil Rights
   509-335-8288 / ccr@wsu.edu
   WSU Pullman Police Department
   509-335-8548 / police@wsu.edu

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Contents

1.0 Purpose

The purpose of this policy is to establish guidelines and procedures for assessing the geography of Washington State University (WSU) in accordance with the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act). (20 USC 1092(f))

This policy supports the accurate and comprehensive reporting of crime statistics, timely warnings, emergency notifications, and promotes transparency within the campus community. (See also BPPM 50.70 and 50.72.)

2.0  Scope

This policy covers the process WSU utilizes to determine the specific geographic locations that are considered part of WSU’s Clery geography.

3.0  Definitions

Clery geography. Specific geographic areas that constitute campus, non-campus buildings or properties, and public property pursuant to the Clery Act.

WSU System Clery Coordinator. The WSU Pullman Chief of Police serves as the WSU system Clery Coordinator and chair of the system Clery Committee.

4.0  Assessment of Clery Geography

4.1    Identification of Campus

The University identifies the geographic boundaries of its campus specific Clery geography. This includes:

• All property and buildings owned or controlled by the University, within the same reasonably contiguous geographic area, and used in direct support of, or in a manner related to, the institution’s educational purposes, including residence halls; and
• Any building or property that is within or reasonably contiguous to the area identified above, that is owned by the institution but controlled by another person or entity, is frequently used by students, and supports institutional purposes (such as a food or other retail vendor).

The University has control over a property or building or a portion of a property or building when the University directly or indirectly rents or leases for primary use of all or a portion of the location.

The University distinctly identifies separate campuses for the purpose of reporting meaningful information. Campuses may be traditional academic sites or may include sites such as a research or extension center. A location is considered a separate campus if:

• The University owns or controls the site;
• It is not reasonably geographically contiguous with another local WSU campus;
• It has an organized program of study (i.e., offers for-credit courses in educational programs leading to a degree, certificate, or other recognized credential and a student can complete that degree or credential without going to the main campus); and
• There is at least one person on site acting in an administrative capacity.

4.2    Identification of Non-Campus

The University identifies non-campus Clery geography. This includes:

• Buildings or properties that are owned or controlled by a student organization officially recognized by the institution; or
• Buildings or property that are owned or controlled by the University that:
  • Are used in direct support of, or in relation to, the institution’s educational purposes;
  • Are frequently used by students; and
  • Are not within the same reasonably contiguous geographic area of the institution (such as a research center).

The University has control over a property or building or a portion of a property or building when the University has a written agreement allowing the University primary use of that property or building, or a portion of that property or building, for University activities.

When the University has a written agreement with a third party to house students, the student rooms and common areas of the location are included in the University’s non-campus property.

The University intends the annual crime statistics to be meaningful to the University community. Therefore, the University defines “frequently used by students” to mean extended student use on a regular basis. Short trips or brief one-night stays are not usually considered locations frequently used by students and are not included in the University’s non-campus geography. When one-night stays occur at the same location repeatedly, such as monthly or annually, the location is included in the University’s non-campus geography. Overnight stays exceeding one night are also included in the University’s non-campus geography.

Further, where students are participating in study abroad programs, WSU does not consider locations where students may travel and stay at a hotel(s) or be enrolled and stay at a host campus for short period of time part of WSU’s non-campus or campus property. WSU takes the safety of students traveling globally seriously and requires a number of other risk mitigation practices, as documented in the annual security report. 

4.3    Identification of Public Property

The University identifies public property that is considered Clery geography. This includes property that is:

• Public (e.g., publicly-owned); and
• Within or immediately adjacent to campus; and
• Accessible from campus.

Public property does not include private property. 

5.0  Consultation with Relevant Departments and Agencies

In order to accurately identify the University’s Clery geography, the Clery Coordinator and/or Clery Committee assigns a representative to annually consult with the following departments for a review of campus geography:

• Center for Fraternity and Sorority Life
• Campus Police or Security Department
• WSU Extension
• Provost’s Office
• WSU Athletics
• Facilities Information Resource Management
• International Programs
• Real Estate and Business Operations (REBO)

The consultation includes a review of this policy and current Clery geography (as reported in the prior year’s Annual Security Report) and a consideration of any geography changes.  The consultation may occur more frequently than annually if significant changes occur in the campus or surrounding areas.

6.0  Documentation and Reporting

The University maintains documentation of the assessment process, including the criteria used, consultation with relevant departments and agencies, and any changes made to the Clery geography. The annual security report must include a description of the Clery geography. Annual security report(s) are available online from the WSU Clery Act Compliance website.

Records are maintained in accordance with the University’s record retention schedule. See the records series “Reporting to External Agencies (Mandatory)” in the All-University Records Retention Schedule — Administrative-General Office Operations table.

7.0  Compliance and Review

The Clery Coordinator periodically reviews this policy and makes necessary updates to ensure compliance with the Clery Act and the changing needs of the campus community. This may include updating the assessment process and criteria for determining the Clery geography.

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Revisions:  July 2024 – new policy (Rev. 630).