The review found UNC had violated the Clery Act in many areas that were very serious, including the omission of dozens of serious crimes from its Annual Security Reports (ASR), the violation of a non-retaliation provision and the lack of administrative capability.
The Department characterized UNC’s lack of compliance as a “systemic failure to provide students and employees with important campus crime information and services essential to their safety and security.” The amount of the fine hasn’t been determined yet.
Specifically, UNC failed to:
Properly issue timely warnings for certain ongoing threats
Compile and disclose accurate crime statistics in their ASRs
Reconcile statistics in the ASR with data submitted to the Department
Identify and advise Campus Security Authorities (CSAs) about their reporting obligations
Collect crime reports from these same CSAs
Comply with Clery requirements related to sexual assault prevention, response and discipline, and administrative capacity
Define campus/Clery geography
Retain records of potential Clery-reportable crimes to the Honor Court for Clery reporting purposes
The report, however, noted that UNC has strengthened its Clery Act compliance program since the initiation of the review and that those remedial actions “have resulted in process improvements that should result in better operations going forward.”