On The Books
Centralized and secure record-keeping is key for Virginia colleges
- By Katie Johnson
- Jan 05, 2016
By now, most colleges have taken steps to form a threat assessment team that investigates a range of concerning behaviors and potentially dangerous situations, including threats made by students, employees, faculty and others in the community.
Threat assessment teams typically include five to 10 members and
should be multi-disciplinary, including representatives from college
administration, law enforcement, mental health and legal counsel.
Taking on the role of a threat assessment team member is an added
and important responsibility. Lessons learned reveal the key to keeping
assessment teams from becoming overwhelmed is to ensure the
right processes are outlined and the right tools are used.
A recent survey revealed 70 percent of campus threat teams are
meeting once or twice a week to review current situations. With
mounting job responsibilities, finding time to get together in person
and discuss is difficult.
Several colleges in Virginia have implemented Awareity’s threat
assessment, incident management and prevention services (TIPS)
platform to help manage and coordinate threat team efforts, saving
valuable time and resources, while improving collaboration and information
THE FIRST THING TO DO
When a threat report is received, the first task of an assessment team is
to collect as much information as possible to determine the potential
for risk. Threat cases require an individualized approach, and the more
information gathered the better. Gathering this information may
include interviewing the individuals involved, speaking with faculty
and friends, reviewing social media, and/or conducting a formal law
enforcement investigation. Keeping track of the steps taken during this
investigation and coordinating all actions and communications
between team members is where TIPS delivers valuable advantages.
No longer do assessment teams need to find a time/place for everyone
to meet, but team members can easily login and document their
findings and case notes, set tasks for other team members, etc. and all
other team members can review the investigation and ongoing updates
in real-time, rather than waiting for their next meeting.
All actions are date/time stamped, providing legal-ready documentation
and accountability, while also ensuring appropriate steps are
taken to most effectively intervene and prevent a situation from escalating
into something much worse.
Equipping your threat assessment team with a centralized platform
is critical. Lessons learned reveal how organizations often fail to connect
the dots. A working platform allows all team members to search
related reports involving one or more people, review previous reports,
investigations and actions, and assess a more comprehensive pattern of
behavior. As we learned from the tragic Virginia Tech massacre, many
people observed concerning behaviors prior, but these concerns were
not routed to one central place to be connected and the seriousness of
the threat(s) accurately identified.
Threat assessment record-keeping can be difficult because records
may include sensitive information or even criminal records that do
not fit into previously established conventions, like student records
systems. In fact, if your campus is currently placing threat records in
your student conduct or student information system (SIS), you may
be inadvertently putting this information at risk to unwanted exposure
This common misunderstanding about where to place and maintain
threat records creates a disparity with FERPA and is costing colleges in
numerous ways. Not only are threat records put at risk in an SIS, some
assessment team members are not putting key information into the SIS,
which means other team members are not seeing all details and are
unable to make the right decisions. FERPA clearly identifies “law enforcement
unit” records can and should be kept separate from SIS records.
The Virginia Threat Assessment State Law Guidance also recommends
threat assessment teams keep threat records separate from
student records and treat them as “law enforcement unit” records.
These records should only be accessible to authorized team members
The American National Standards Institute (ANSI) Workplace Violence
Standard also clearly states that organizations should provide
secure, “need to know” and anytime access to a centralized record
TIPS allows teams to be more efficient and track and document
investigation notes in one place. Team members can, of course, still
access SIS to locate information like class schedules or contact information,
and share this information as needed within TIPS, but keeping
the actual investigation details and assessment separate from your SIS
is vital. Once the threat assessment process has been concluded or a
resolution has been determined, for instance, suspension from campus,
a summary can/should be recorded in the SIS, but all investigation
prior should only be discussed between team members and documented
in the secure centralized platform.
Of course, connecting the right dots means collecting all the dots
first. How can threat teams ensure they are receiving information? Use
of a comprehensive platform offers an anonymous incident reporting
option. A TIPS reporting button is strategically placed on the campus
website allowing anyone to securely report concerning behaviors.
Campus threat teams can determine what types of incidents should be
reported (sexual misconduct, threats to harm, weapons, drug/alcohol
abuse, self-harm/suicide threats, suspicious persons).
Thomas Nelson Community College, the first Virginia community
college to implement the TIPS prevention platform in 2012, had established
a web-based reporting form, but the customization features
available in TIPS provided significant advantages.
“Being able to determine what types of incidents could be reported
and design the forms and questions based on our current procedures
made the transition to TIPS simple,” said campus police chief Kelvin
Maxwell. “The way in which reports from different locations and incident
types could be directed to the appropriate staff, helped us ensure
the right people were being notified so immediate and proactive
actions could be taken.”
In addition to Maxwell, Thomas Nelson’s Threat Team also includes
the vice president for Finance and Administration, Human Resources,
campus police and student counseling staff. General counsel is also
added to specific reports; with TIPS third-party resources law
enforcement, mental health, compliance, etc. can become involved
and added to individual reports in the system, if, and only when, their
guidance is requested.
Campus-wide awareness and education regarding reporting of concerning
behaviors is critical—all resident advisors, mental health
counselors, academic advisors, faculty members, etc. need to understand
how concerns should be communicated. Ongoing reminders
should emphasize how everyone plays a role in keeping their campus
safe and helping people in distress, whether or not a direct threat has
At the beginning of the semester, Germanna Community College
posted several awareness posters around campus with examples of the
different behaviors to be reported.
“Students really appreciate that we are taking extra steps to involve
them in safety efforts on campus,” said Pam Frederick, dean of student
development at Germanna. “They really are our best eyes and
ears on campus.
“TIPS allows anyone associated with the college community to
come forward and anonymously share information with us,” Frederick
said. “The information is immediately communicated to our team and
proactively investigated so we can prevent situations from escalating.”
Once an investigation is determined to be “resolved,” it is also important
to follow-up and monitor at-risk individuals. The follow up process
may be as simple as checking in with the student (or parents, roommates,
counselor of the individual involved) periodically
and ensuring the situation is not escalating.
TIPS provides a valuable reminder tool that
ensures follow-up actions are taking place and no
individuals slip through the cracks.
This article originally appeared in the January 2016 issue of Security Today.