When Campus Safety Laws Meet Cybersecurity: The Digital Implications of the Jeanne Clery Act
Digital transformation has made the Clery Act’s physical safety mandates a cybersecurity compliance issue.
- 04/09/26
In December last year, a shooting incident at Brown University saw two students lose their lives, and left nine injured. And on March 12, an active shooter killed an ROTC instructor at Old Dominion. Tragically, it seems like such disturbing news from university campuses is becoming normalized. Federal authorities have opened an investigation into Brown, digging into the ‘how’ of the incident, and whether the campus violated the Cleary Act. Campus security must continuously reassess whether its safety frameworks are truly prepared for emergencies.
It’s not as if a regulatory framework to ensure campus safety and transparency around incidents does not exist. The Jeanne Clery Disclosure of Campus Security Policy and Campus Statistics Act is one of them. A 1986 tragedy was the driving force behind the Clery Act. The ensuing investigation found the campus had a history of undisclosed violent incidents.
Anatomy of the Clery Framework
The need for transparency and communication around campus safety defines the compliance obligations of the Clery Act. Institutions that receive federal financial aid are required to prepare an annual security report (ASR) and submit it by Oct. 1. They must diligently record campus crime and include crime statistics covering a three-year period. The ASR must cover campus safety policies. Thorough documentation of criminal incidents in a crime log and their reporting to campus security are mandatory.
Failure to comply can result in fines up to $70,000 per violation and potential loss of federal funding — consequences no campus can afford.
It should never be ‘business as usual’ for an institution to regularly submit to ongoing threats against its students, faculty, and staff. A timely warning must be sent to the campus community. For any imminent danger, such as an active shooter, provisions must be in place to quickly broadcast an emergency notification to alert students and teachers.
Mobile phones didn’t exist when the Cleary Act was introduced. Digital transformation changes the game.
The Clery Act’s Relevance to Cybersecurity
The Clery Act is not primarily about addressing cybercrime, but an institution’s ability to meet the Act’s obligation also depends on its digital infrastructure. Whether it’s the ability to report crimes, emergency notification systems, or the creation of an incident database with a historical record of incidents, information flows through networked software systems. The ASR is also compiled using centralized digital records.
Let’s dig a little deeper into the intersection between campus safety compliance and cybersecurity.
Emergency notifications are one of the most time-sensitive obligations under the Clery Act. In the past, these would have been delivered by sirens or physical announcements. Today, such notifications are sent through mass notification platforms that can deliver alerts via text message, e-mail, campus mobile applications, and digital signage systems. A disruption or compromise of these systems means alerts might reach the campus community too late, not reach them at all, or worse, attackers could send false messages, undermining response efforts and potentially resulting in avoidable tragedies.
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