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Selling Safety: The Rise of Sexual Assault Prevention Products
Posted by On Wednesday, February 3, 2016

Since the 1990s, studies have found that roughly 1 in 5 women will experience some form of sexual assault while in college. Recent results from campus climate surveys have bolstered these numbers. In the past several years, people have been trying to fight this epidemic through many strategies ranging from increased legislation to prevention training.

In addition, companies have recently begun offering other novel solutions. Some are manufacturing wearable gadgets that alert authorities and select emergency contacts when an attack is about to occur. A group of college students is developing a nail polish that changes colors when dipped into a drink that’s been laced with certain date-rape drugs. Entrepreneurs are producing an array of fashionable jewelry that emits a loud alarm when the user pushes a button.

Below, you will find a list of some of the sexual assault prevention products on the market and how they work, followed by an analysis, criticisms, and common misconceptions about sexual assault.

iBall Andi Uddaan: This is a cellular device with a built-in “SOS” button that sends an alert message and phone call to five emergency contacts chosen by the user, posts a Facebook status with a pre-written message asking for help and gives the user’s GPS location (only if connected to the Internet), and emits a loud siren sound to ward off potential attackers.

Athena: Manufactured by Roar for Good, this transformable accessory can be worn as necklace pendant or clip onto clothing, a belt, or purse. The Athena is a “coin-sized personal safety alarm” and comes with an app that allows the wearer to customize their preferences. The device has a button that can sound an alarm “louder than a freight train” while sending a text message with the user’s location to a list of emergency contacts chosen by the user. If the button is held for three seconds longer, the alarm stays silent, but messages are still sent as long as an Internet connection is established. A portion of the company’s proceeds goes to educational programs.

Safelet: A bracelet that sends out alerts with the wearer’s location to the police and emergency contacts (known as “Guardians”) selected by the wearer—this happens when two buttons are pressed simultaneously. Once activated, the device will also call the police and activate the wearer’s cellular microphone, transmitting the sounds coming from the microphone to the police. The wearer can add contacts and security preferences through the Safelet app. The Safelet device operates by using a “secure Bluetooth Low Energy connection.”

First Sign: A hair clip with “built-in gyroscope and accelerometer to detect head impacts indicative of physical assault.” When pressed, the clip turns on a microphone that calls the police while recording the incident. The First Sign clip also emits an audible message when pressed in order to “deter the attacker.” If pressed accidentally, the wearer can access the First Sign app on their phone within 15 seconds to deactivate the false alarm. The First Sign clip uses Bluetooth and an Internet connection must be established in order for the device to work.

Cuff: This is a smart device that can be inserted into the manufacturer’s line of jewelry/accessories (such as a sport band, metal necklaces and bracelets, leather bracelets, and key chains). The device uses a phone app that allows the wearer to set their emergency contacts, and when activated, the Cuff sends the user’s emergency contacts a message. The Cuff device can be paired with any of their jewelry line products to change the look. However, the wearer can’t be more than 20-30 feet from their phone for the device to fully work, and their phone must be connected to the Internet.

Undercover Colors: A nail polish line that detects date rape drugs such as Rohypnol, Ketamine, Ecstasy, and other “roofies” by changing colors when a finger is dipped into a drink to “discreetly” stir. This method can alert the wearer of a spiked drink before they consume it.

It might be reassuring to know that more than pepper spray, mace, rape whistles, and tasers can be used to protect victims before, during, and after an assault. However, the very idea that such a number of up-and-coming devices are necessary is concerning in itself. While the thought of having an aid in sexual assault prevention is undoubtedly a good one, the need for these items is telling of how much of an issue sexual assault has become.

Though prevention gadgets are steps in a good direction, they are not solutions to stopping the act that calls for their existence. And for all the good these products attempt to achieve, they come with a fair amount of criticism:

  • Products such as the aforementioned and others put the burden of rape prevention on the potential victim, not the perpetrators. It is the victims who are going out of their way to obtain and use these products—and while it is a safe, smart thing to ensure one’s safety, perhaps education, accountability, prosecution, and practicing consensual sexual activity should take the forefront.
  • These products may reinforce myths about what sexual assault looks like—for example, a woman who was drugged by a stranger in a bar or was attacked while walking alone at night. While these kind of attacks do happen, research suggests that the vast majority of sexual assaults at college are acquaintance assaults (this is also true for assaults that occur outside of college).
  • Marketing these products to women leaves out male victims. According to a Washington Post-Kaiser Family Foundation survey that polled college students living on or near campus, “twenty percent of women and 5 percent of men reported being sexually assaulted either by physical force or while incapacitated.” This survey and many others reveal that both men and women experience sexual assault.
  • These products are intended to be used before, during, or after a sexual assault has occurred—they do not guarantee that the act will be stopped, that the victim will be safe, or that the attacker will be caught.
  • While date-rape drugs such as roofies are sometimes used to facilitate sexual assault, most often, alcohol is the number one date rape drug.
  • Many of these devices also present some practical challenges: they assume the user already has a smartphone, and many of the devices require that a free mobile app be downloaded and connected to the product itself; for the fashion fashion/jewelry pieces, an accessory cover would be needed to better conceal the product; an Internet connection must also be established in order for the devices to correctly work.

Critics’ assertions that these devices misrepresent the nature of sexual assault and unfairly shift the burden to victims show that these devices cannot solve the problem without educational initiatives providing students the proper context.

Fortunately, many colleges, universities, and now high schools in select states require students to take sexual assault prevention programs or classes. With the well of information, definitions, statistics, and scenarios in these courses, the goal is to educate students about consent and sexual assault, leading to better decision-making and ultimately a safer environment.

These products can save lives, but they need to paired with the proper education and training. The goal is to prevent sexual assault, not just avoid it.

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Why Parents Matter: New Partners in Sexual Assault Prevention
Posted by On Wednesday, July 29, 2015

Red Converse

The decline of universities serving in loco parentis (in the place of parents) began in 1961 with the Dixon versus Alabama case that propelled due process for students into the limelight. Since then, universities have sought to keep parents at arm’s length. Orientation programs are designed to separate students from parents and ensure that parents leave their children as soon as possible so that the process of becoming a college student can begin. And universities use FERPA as a tool for keeping communication solely with the student and the university, despite parents’ objections to the contrary. But recently, parents have emerged as a focal point again for universities who see the value in partnering with them on a variety of strategies: for better 4-year graduation rates; for meeting university deadlines, policies, and procedures; for additional funding opportunities; and for helping their students succeed overall.

Rather than parents hesitating to send their students to college for fear of sexual assault, let’s invite them into the dialogue, and discuss ways they can help us change the culture together. Recent studies have shown that parents can have an effect on reducing not only binge drinking, but also non consensual sexual activity related to binge drinking.

In “Do Parents Still Matter? Parent and Peer Influences on Alcohol Involvement among Recent High School Graduates” published in the Psychology of Addictive Behaviors, the authors found that perceived parent involvement leads to weaker peer influence and related alcohol use and associated problems. And in “Preventing College Women’s Sexual Victimization through Parent Based Intervention: A Randomized Control Trial,” authors Maria Testa, Joseph Hoffman, Jennifer Livingston, and Rob Turris designed a Parent Based Intervention (PBI) to reduce the incidence of alcohol-involved sexual victimization among first-year college students. Students who had conversations with mothers that received the PBI (an educational handbook) saw lower incidences of incapacitated rape.

With the enormous responsibilities and pressure that colleges are facing, it might be daunting to consider adding yet another subset to training and education around sexual assault. Some states, like New York, are even requiring that parents become a part of the college’s educational platform. Asking parents to be a part of your institution’s sexual assault prevention program, however, can be an important part in your prevention toolkit, and it can serve the dual purpose of helping to communicate your institution’s commitment to the issue. With myriad ways for universities to include parents (from admission events to orientation programs, and even a simple letter with resources and guides), the changing culture around parent involvement just might help us also change the culture on sexual assault.

For more resources and our webinar on getting parents involved click here.

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CampusClarity Partners with Kappa Delta Rho
Posted by On Thursday, May 7, 2015

CampusClarity today announced that it will be partnering with national fraternity Kappa Delta Rho to provide anti-sexual violence and substance abuse training to 40 Kappa Delta Rho chapters at colleges and universities across the country.

CampusClarity’s Think About It program is a three-part interactive online course that fulfills the training requirements of Title IX and the Campus SaVE Act. It has been used to meet these requirements and educate students, faculty and staff at over 300 institutions, including other national Greek organizations. Think About It’s cutting-edge design and interactivity has been recognized with a Gold Stevie business award for best online training and a NASPA Gold Excellence Award for Violence Education and Prevention for the University of San Francisco.

“The “Think About It” program will be fully implemented in this upcoming academic year as part of our Legion Program, which is a total member education program designed to provide leadership skills and knowledge to our Brothers that will allow them to lead successfully in their communities,” said Kappa Delta Rho Executive Director Joe Rosenberg.

Kappa Delta Rho was founded May 17, 1905 at Middlebury College. Since then it has initiated more than 29,000 members. “Kappa Delta Rho is an organization characterized by devotion to respect for others and honor above all,” Rosenberg said. “Our national leadership is committed to upholding the high standards our fraternity has always espoused.  One facet of this commitment is reinforcing our values of honor and respect in educating our undergraduate membership in the area of sexual violence and harassment prevention. The Think About It program represents a deepening of that commitment.”

“We are very proud to partner with Kappa Delta Rho. Through conversations with their leadership in the development of this partnership, it became clear to us that we shared a common commitment to sexual violence and substance abuse prevention education,” said LawRoom CRO, Preston Clark.

More About CampusClarity

LawRoom is the leading cloud-based compliance training provider for many of the fastest growing tech companies in the Bay Area, as well as many of the top universities across the country. LawRoom delivers award-winning employee and student training courses through its easy-to-use online platform to help corporations and universities meet federal and state compliance requirements.

In 2011, LawRoom partnered with the University of San Francisco to build an online harm-reduction course for students on alcohol, drugs, and sexual assault under a new brand, CampusClarity. In collaboration with USF’s Division of Student Life, LawRoom spent 18 months developing the course in consultation with various academic departments and with over 40 student focus groups. In early 2013, LawRoom launched Think About It, which is today used by over 300 colleges and universities across the country. Over 500,000 students, faculty, and staff will train with LawRoom in 2015.

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Weekly Roundup
Posted by On Friday, May 1, 2015

Why prevention efforts need to start as early as high school, the University of California’s response to the California State Auditor’s review and OCR investigations, and Bud Light retracts an ill-considered slogan.

Sexual Violence Starts in High School—Prevention Must Too

According to the Rape, Abuse & Incest National Network, 44% of sexual assaults are committed when the victim is not yet 18. This piece in the Huffington Post by writer and activist Soraya Chemaly makes an important point: Clearly sexual assault does not begin in college. Prevention efforts shouldn’t either. Chemaly goes on to outline other alarming statistics about the young ages of both victim/survivors and perpetrators and points to a number of horrific rape cases involving high school-aged victims and perpetrators to make her case that high schools can and must do more to address sexual violence. She also outlines some of the obstacles to that seemingly obvious step, including the lack of available resources and discomfort of having a conversation about these difficult topics with teenagers. Nevertheless, Chemaly stresses beginning prevention as early as possible is crucial not only to protect American high schoolers but also to provide them with the tools they need to protect themselves when they leave home for college.

How the UC System is Starting to Address It’s Sexual Violence Problem

This piece from USA Today follows up on the University of California in the midst of OCR investigations of several of the state’s largest campuses, including UCLA and UC Berkeley, and nearly a year after the California State Auditor released their report on the UC system’s sexual assault practices. The article covers the background of the report and investigations, focusing on the efforts of student activists in filing a Clery Act complaint and Title IX claims against UC Berkeley. It also reports on what the UC system has done to address the inadequacies which led to the investigations and were covered by the CSA report. These changes include mandatory sexual violence prevention training, the hiring of confidential survivor advocates, and a survivor resource specialist. However, university officials and activists alike stress how much more work remains if the UC system is to do all it can to prevent sexual violence and support its victim/survivors.

Bud Light Corrects a Thoughtless Slogan

According to a poorly thought-out slogan featured on new packaging, Bud Light is “the perfect beer for removing ‘no’ from your vocabulary for the night.” It didn’t take long for Reddit and Twitter users to point out what apparently slipped past everyone at Anheuser-Busch: The ugly way that particular slogan recalls the connection between intoxication and sexual assault, and especially the way alcohol can and is used as a weapon by perpetrators against their victims. To the company’s credit, an apology was issued swiftly and the offending slogan won’t be printed again. Still, the whole episode is an important reminder of the need to consider language and how it affects culture and behavior.

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Three Takeaways From the OCR’s Guidance Package
Posted by On Wednesday, April 29, 2015

Without much fanfare, the Department of Education’s Office for Civil Rights issued a “Guidance Package” on April 24, 2015, which includes a Dear Colleague Letter (DCL), a Dear Title IX Coordinator Letter, and a Title IX Resource Guide. The three takeaways from the OCR’s Guidance Package are: (1) all primary, secondary, and postsecondary schools must have a Title IX coordinator; (2) Title IX coordinators must be given adequate authority and training to meet their obligations; and (3) interfering with a Title IX coordinator’s efforts to do their job violates Title IX’s anti-retaliation provision.

The DCL is a seven-page reminder that “all school districts, colleges, and universities receiving Federal financial assistance must designate at least one employee to coordinate their efforts to comply with and carry out their responsibilities under Title IX . . ..” Another significant guidance document—Questions and Answers on Title IX and Sexual Violence, released in April of 2014 — had already pointed out that designating a Title IX coordinator is one of three key procedural requirements in the Title IX regulations. This latest DCL leaves no doubt that this is not a matter of simply adding a title to someone’s long list of job duties:

This position may not be left vacant; a recipient must have at least one person designated and actually serving as the Title IX coordinator at all times.

An OCR spokesperson said that many schools currently under investigation do not have a Title IX coordinator. For example, Brown University just hired its first Title IX coordinator this month. Apparently, the OCR is lighting a fire under schools that have not yet taken this step.

The DCL lays out the Title IX coordinator’s responsibilities and authority, emphasizing that it is a Title IX violation to interfere with the Title IX coordinator’s performance of their job responsibilities:

Title IX’s broad anti-retaliation provision protects Title IX coordinators from discrimination, intimidation, threats, and coercion for the purpose of interfering with the performance of their job responsibilities.

To establish a strong and visible role in the community for the Title IX coordinator, the DCL encourages schools to create a prominent link on its homepage to a dedicated webpage with the Title IX coordinator’s contact information, Title IX policies and grievance procedures, and other resources related to Title IX compliance and gender equity.

To keep informed of the laws, regulations, and OCR guidance on campus safety, the DCL recommends regular training for Title IX coordinators and all employees whose responsibilities are related to the school’s Title IX obligations.

Also included in the guidance package is a Letter to Title IX Coordinators with a Resource Guide, which covers Title IX basics, as well as the Title IX coordinator’s administrative duties and role in helping schools meet their Title IX obligations. The letter contains this warning: “To be an effective Title IX coordinator, you must have the full support of your institution.”

As Catherine Lhamon, assistant secretary for civil rights, said in the OCR’s press release, “A critical responsibility for schools under Title IX is to designate a well-qualified, well-trained Title IX coordinator and to give that coordinator the authority and support necessary to do the job.”

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Free Webinar: Preventing Sexual Violence on Campus with Michelle Issadore
Posted by On Thursday, April 23, 2015

Next week, on Wednesday, April 29, we will host our second free webinar. Michelle Issadore, M.Ed., will talk about strategies “Preventing Sexual Violence on Campus.” You can register now to reserve your place.

Issadore is the Executive Director of the School and College Organization for Prevention Educators (SCOPE). She works with schools, colleges, and community organizations nationwide to assess and improve their strategic prevention efforts, as well as research and understand best practice initiatives.

Issadore’s presentation is a timely reminder of the fast approaching July 1st deadline when the Campus SaVE Act regulations take effect. The Campus SaVE Act requires colleges and universities to offer student and employee education programs “to prevent dating violence, domestic violence, sexual assault, and stalking.”  (You can find our full breakdown of the Campus SaVE Act requirements on our blog.) This webinar will helps schools put together their prevention programs for the 2015-2016 academic year. Register for the free webinar now to reserve your place.

For many colleges and universities, implementing prevention programs seems like a daunting task, especially given the complexity of the issues and the need to coordinate and engage various stakeholders. Indeed, one of our takeaways from the NASPA conference this year was the need to bring together different prevention efforts and initiatives on campus. Similarly, last year, the Centers for Disease Control published its brief, “Connecting the Dots,” on the links between different forms of violence in order to help schools “coordinate and integrate responses to violence in a way that recognizes these connections.”

Our discussion next week will help address these pressing concerns for schools considering how to train a diverse audience on a breadth of issues around sexual and gender-based violence. During our 45-minute webinar, Michelle Issadore will answer questions surrounding sexual assault prevention strategies on campus and what institutions can do to overcome challenges associated with implementing widespread initiatives.

Michelle Issadore will specifically address the following questions:

  • What are some ways schools can achieve a community-level approach?
  • How can departments work together to create consistent messaging?
  • What role does compliance now play in prevention programming?

Even if your institution currently has training solutions in place, Michelle’s experience and expertise will prove invaluable to anyone looking to enhance their efforts.

Register for the free webinar now to reserve your place .

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Free Webinar with Dr. Novak
Posted by On Monday, March 16, 2015

Peter NovakTomorrow, we will be hosting a free webinar with Dr. Peter Novak, the Vice Provost for Student Life at the University of San Francisco. If you haven’t already done so be sure to register today.

During this 45-minute webinar, Dr. Novak will answer questions about how he and USF built and deployed their NASPA Gold Excellence award-winning Campus SaVE Act Training Program for students, faculty, and staff, and overcame challenges associated with deploying the campus-wide initiative.

Dr. Novak has an extensive background in Student Life with considerable experience as an academic and administrator in social justice issues. He received his doctorate in Dramaturgy and Dramatic Criticism from Yale University. In addition to his doctorate, he holds an MFA from the American Conservatory Theater and an MA in English from Loyola University Chicago.

At Yale Dr. Novak served as Dean of Trumbull College , on the Provost’s Committee on Resources for Students and Employees with Disabilities, and on the Fund for Lesbian and Gay Studies. He is also a founding chair and tenured full professor in the Performing Arts and Social Justice program at the University of San Francisco. His research focuses on diversity and language, LGBTQ and HIV/AIDS dramatic literature, and Deaf culture and American Sign Language translation.

In December 2011, dissatisfied with the online training USF was offering incoming students, Dr. Novak approached LawRoom to build Think About It, an online training program for incoming students that addressed campus sexual assault and substance abuse. Dr. Novak had been impressed by the quality of LawRoom’s online harassment training programs developed for faculty and staff, and he felt LawRoom would be a valuable partner in creating a cutting edge, engaging online program on substance abuse and sexual violence for incoming students.

The collaboration brought together LawRoom’s expertise in legal compliance and online training with USF’s experience handling the unique social challenges students face in their transition to college life. As a result of their work, LawRoom developed CampusClarity, a service of LawRoom that is dedicated to creating training solutions for the higher education community.

USF and CampusClarity worked together extensively in the creation of the course. They conducted focus groups and user panels with students to refine the voice and tone of the course and make sure scenarios reflected realistic situations. Additionally, numerous department representatives and programs at USF, including the Gender and Sexualities Center and Health Promotions, helped develop learning objectives and course content. During the development process, USF and CampusClarity also hosted a conference with faculty and staff from 30 universities in order to prepare the course for a diverse group of campuses.

Since the development of Think About It, USF and CampusClarity have continued to collaborate on other initiatives and projects, such as the Talk About It community, a collection of resources administrators can use to implement ongoing programming on their campuses around the issues of sexual violence and alcohol abuse.

Tomorrow, Dr. Novak will talk in more detail about other initiatives he’s implemented at USF. Among other things, he will talk about balancing training with other priorities in Student life and how to create an effective program with limited staff, limited time, and limited budget.

His talk will be valuable for schools looking for ways to improve their current programs, and for schools that are just developing their training programs.

Dr. Novak will also discuss practical solutions for going beyond SaVE Act compliance, including:

- Deploying a campus-wide training program prior to the June deadline.
- How to help ensure adoption of the program by students and faculty.
- On-going educational programming based on institutional data.

Please go to our registration page to sign up for our free webinar if you haven’t already.

 

 

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Weekly Roundup
Posted by On Friday, March 6, 2015

For this week’s roundup we have Grinnell’s unusual request to be investigated by the OCR and two stories related to a topic we’re particularly interested in: preventative training for sexual violence and substance abuse.

Grinnell Requests an OCR Investigation of Themselves

Grinnell College has made the unusual and perhaps unprecedented move of requesting that the OCR investigate their handling of sexual assault cases. According to a statement by Grinnell’s president, Raynard Kington, “If Grinnell has fallen short at any point, I want to know about it now, continue to address the problems, and make things right for our students.” Since then it has also been made known that the request came in anticipation of a now-published Huffington Post piece alleging mishandling of three sexual assault cases at Grinnell. According to a letter Kington sent to the campus, “We have specifically invited OCR to review the cases [The Huffington Post] has highlighted to us.” The student and faculty group Dissenting Voices, which believes Grinnell’s sexual assault policies are inadequate, has described the request as an “unprecedented attempt to preemptively control the framing of the issue,” pointing out that six students had already filed complaints with the OCR.

California SB 695 Would Mandate Sexual Violence Prevention Program for High School Students

Federal law (the Campus SaVE Act) already requires colleges and universities to offer sexual assault prevention training to incoming students, but SB 695 introduced last week would require California students to learn about sexual assault violence, and healthy relationships in high school health classes. The bill would further require health classes to teach the affirmative “yes means yes” definition of consent required for the state’s colleges and universities participating in state financial aid programs. Co-author of SB 695, Senator Hannah-Beth Jackson says that it would “give students the skills they may need to navigate difficult situations, and prevent sexual assault before it occurs.”

Substance Abuse Training Must be Reinforced to be Effective

A new study suggests that the effects of  substance abuse training typically administered to college freshmen at or before the start of their college careers tend to wear off over in the course of the year. A study published in the Journal of Consulting and Clinical Psychology found that a month after receiving alcohol education of any kind, 82% of students reported they were drinking less. However, a year later 84% of those same students reported they were drinking as much as they had at before the alcohol education. They also found that alcohol education was particularly effective for inexperienced drinkers and women. These findings suggest that reminding students how to party smart, through text messages, emails, or ongoing training, should be part of an effective prevention program.

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Weekly Roundup
Posted by On Friday, February 13, 2015

A new study suggests disturbing trends in the frequency of sexual assault reporting, what Canada could learn from American sexual assault laws, and what American colleges could learn from the military academies.

Do Schools Report More Assaults When They’re Being Investigated?

A study published in Psychology, Public Policy, and Law found that schools being audited by the Department of Education saw an average rise of 44% in the number of reported sexual assaults. More worrisome, however, is what happened after the audit ended—the average school went back to the pre-audit number of reports. One possibility is that schools over report assaults while being audited out of an overabundance of caution. Another uglier explanation, favored by the researchers, is that schools under report violence when they think they can get away with it. In any case, the New York Times article points out that climate surveys, a key aspect of the proposed Campus Accountability and Safety Act, could result in more accurate, consistent information.

What Could Canada Learn from America’s Higher Education Laws?

While The New York Times calls for passage of the Campus Accountability and Safety Act, which would amend the Clery Act, Canadian news outlet CBC is pointing to that 1990 law as an example of the sort of legislation needed to address campus sexual violence in their country. While observers in this country often decry what they see as slow or inadequate responses to sexual assault cases on college campuses, CBC points to cases in which students used the Clery Act to force schools to respond to rape and other violence on campus in a relatively timely manner as evidence that similar legislation is needed in Canada, where a lack of such laws at the national level leads to an inconsistent “patchwork” approach.

What Can Colleges Learn from Military Academies?

Just as Canada may have something to learn from the United States, American colleges might take a page out of the military service academy’s book when it comes to sexual assault prevention. The U.S. Naval Academy, Air Force Academy, and West Point have been under scrutiny for their handling of sexual assault cases for some time, as has the military as a whole. As a result, they have implemented more extensive anti-violence programs than many liberal arts universities. For example, at Annapolis, students are required to participate in training during all four years of their education. The program is further distinguished from other higher education training by the fact that current students lead lessons and discussions. That approach is already being considered by Dartmouth College as a potential model for their own anti-sexual violence training programs. It is also worth noting that both Senators Claire McCaskill and Senator Kirsten Gillibrand, who have worked on reforms to improve how the military handles sexual assault, are now working together to pass the Campus Accountability and Safety Act.

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A Rundown of the Campus SaVE Act Final Regulations: Prevention Programs
Posted by On Wednesday, November 5, 2014

On October 20, 2014, the Department of Education published its final regulations to implement the Clery Act amendments (the Campus SaVE Act) enacted under the Violence Against Women Act Reauthorization of 2013 (VAWA). It’s been over a year and a half since VAWA was signed by President Obama on March 7, 2013. The Campus SaVE Act regulations will take effect on July 1, 2015. In this post, we’ll focus on what these new regulations tell us about building prevention and awareness programs that are tailored to a particular campus and satisfy the requirements of a compliance review.

Do the regulations require an actual prevention program or just a policy statement?
A basic question about the Campus SaVE Act requirements was definitively answered by the Department’s discussion of the final regulations: simply having a policy describing the institution’s primary prevention and awareness programs does not satisfy the Campus SaVE Act requirements. Each school must have actual prevention programs that implement these policies.

Do a school’s prevention programs need to be informed by research?
Comments on the proposed regulations asked whether a school’s prevention programs must be both informed by research and assessed for effectiveness. The Department refused to require both because it would limit the types of programs institutions can develop. Since there has not been enough research done to show what makes a program effective, institutions may use “promising practices that have been assessed for value, effectiveness, or outcome but not subjected to scientific review.”

Is there specific content or a mode of delivery required?
In its discussion on the final regulations, the Department also noted that it would not mandate the specific content or mode of delivery. Specifically, computer-based programs and third-party vendors may be used as long as a program’s content meets the definitions under these regulations of “programs to prevent dating violence, domestic violence, sexual assault, and stalking.”

Is it mandatory that students and employees complete prevention programs?
The same students and employees who must receive a copy of the institution’s annual security report must be offered prevention training. While the federal law does not require all students and employees to take or attend prevention training, the Department encourages schools to make the training mandatory “to increase its effectiveness.”

The Department also clarified that employees include union members and an “enrolled” student is anyone who has (1) completed registration requirements, except the payment of tuition and fees, or (2) been admitted into an online or correspondence education program and submitted at least one lesson without the help of a school representative (34 CFR § 668.2). The Department points out that “every enrolled student should be offered prevention training because anyone can be a victim of dating violence, domestic violence, sexual assault, or stalking, not just students regularly on campus.”

What information is required in a school’s prevention program?
Generally, an institution’s prevention and awareness programs must provide information to help students and employees understand their rights under the school’s procedures and programs to address incidents of sexual assault, dating violence, domestic violence, and stalking. In its discussion of the regulations’ costs and benefits, the Department says, “A benefit of these regulations is that they will strengthen the rights of campus victims . . ..”

Additionally, the prevention piece of these programs:

  • should focus on changing the social norms and stereotypes that create conditions in which sexual violence occurs
  • must be tailored to the individual communities that each school serves to ensure that they are culturally relevant and inclusive of, and responsive to, all parts of a school’s community
  • include “ongoing prevention and awareness campaigns,” which, as defined in §668.46(j)(2)(iii), requires that programs be sustained over time

For a list of the specific content required, we have put together a checklist of the Campus SaVE Act and Title IX training requirements for employees and students.

In future blog posts, we’ll explain other important provisions in the final regulations, including the regulatory requirements for disciplinary proceedings, and how to balance protecting a victim’s confidentiality and encouraging members of the campus community to report crimes.

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