New Disclosure Act Interpretation causes backup for Public Safety

by John Hollinger

News Reporter

In July of 2016 the Federal Department of Education changed their interpretation of the definition of off-campus incidents that is required to be reported, according to the Director of Public Safety, H. Wil Johnson. As a result of the change, there has been a “tremendous amount of work” in regards to reporting off-campus incidents said Johnson.

“It’s been an awful lot of work that was really not in the spirit of why the Jeanne Clery Act was made in the first place, which was to protect students all around campus,” said Johnson.

The Jeanne Clery Act was initially put into action in 1990 and requires colleges to “share information about crime on campus and their effort to improve campus safety, as well as inform the public around campus,” according to


But now the Department of Education, which oversees Clery, has added a new token to what is considered off-campus.  

“So they [Department of Education] didn’t even just change the definition, or their definition, they changed their interpretation [of the definition of off-campus],” said Johnson.

Essentially, this new interpretation states that if students stay at a hotel for more than one night, for a club, sports, school event, etc. public safety has to report if there were any incidents at all at that hotel’s location.


Even if it did not involve any of the students, public safety has to put that incident in the crime report. This requires public safety to reach out to the police agency in that particular jurisdiction to find out if there was any incidents reported.


And because this was implemented in July, Public Safety had to send letters to police agencies dating back a year and a half because they were required to put it in the annual reports for entire years of 2015 and 2016, even though this was new off-campus interpretation was implemented halfway through 2016.

“We had to send out letters to over a hundred police agencies… and that includes international,” said Johnson.

Johnson described the notice in July as “weird” because they normally are notified around February if a change is made so that it does not fall too far back in the annual report, according to Johnson.


“It’s crazy, it’s crazy. Cause, you know, out of those hundred plus letters we sent out. [We had] one incident. One incident. It was a domestic assault that happened at Disney,” said Johnson.

And this domestic assault at Disney did not even involve the students whatsoever, according to Johnson.

“Our students aren’t affected in any way, shape, or form because they most likely would have never known about it,” said Johnson.

“We could have students in the upper right-hand corner of a 600 room hotel and have a domestic assault happen in the lower right-hand corner of the hotel… and we have to report on that,” said Johnson


With there being only a single incident that occurred out of hundreds, should the Department of Education reconsider this new change? Johnson has admitted that it is a great deal of work and takes time away from other important and relevant issues.

“For us, and we’re a small school, it took an enormous amount of work to get that done.”

Thankfully, according to Johnson, he wasn’t alone on sending out the hundreds of letters and doing the research.

“I’m fortunate to have an officer on light duty who is able to do that, to generate the letters and find out the jurisdictions. I would have been in big trouble if it weren’t for that officer on light duty,” said Johnson.


And Canisius is not alone on this. Other colleges and universities have to do this as well.

“This has taken it far beyond,” said Johnson. “I guess if a college has a reputation for putting their students in some city hotel where everything is happening. But I don’t think most colleges are doing that, they’re trying to take good care of their students and at least put them up in decent places,” said Johnson.



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