Threat Assessment Regulation 704
|Regulation 704||Approved: February 17, 2011|
|UNIVERSITY OF NORTH CAROLINA SCHOOL OF THE ARTS
Threat Assessment Regulation 704
|Source of Authority:||UNC Code § 502D(3)|
|History:||First Issued: February 17, 2011|
|Related Policies:||Weapons on Campus or Other Educational Property, N.C.G.S. § 14-269.2;
Communicating Threats, N.C.G.S. § 14-277.1;
Code of Conduct & Discipline Regulation 802;
Involuntary Withdrawal Regulation 807;
Weapons Regulation 705;
Workplace Violence Regulation 706
|Responsible Offices:||Department of Police & Public Safety|
|Effective Date:||February 17, 2011|
UNCSA strives to provide a safe environment in which to live, learn, work, and visit. The University will use a variety of strategies to educate members of the University community; prevent and minimize threats and acts of violence; identify and assess threats and potential acts of violence; provide effective intervention in medium and high risk cases; levy appropriate consequences for threats and acts of violence; and mitigate the effects of threats and acts of violence on victims.
This regulation applies to all UNCSA students and employees.
A. “College Mitigation Team” means the committee appointed by the Provost that meets when a college student experiencing academic, social, emotional, and/or behavioral difficulties is identified and referred for their review.
B. “High School Mitigation Team” means the committee appointed by the Provost that meets regularly and identifies high school students experiencing academic, social, emotional and/or behavioral difficulties.
C. “Imminent Potential Threat” means violence or threats believed to be about to occur absent action or intervention of some sort.
D. “Threat Assessment” means the process of identifying, assessing, and managing individuals who might pose a risk of violence to an identified or identifiable target.
E. “UNCSA Threat Assessment Team” and “TAT” means the group of individuals who evaluate and assess potential threats posed by any individuals or situations.
A. UNCSA prohibits threats and acts of violence on UNCSA property; within UNCSA facilities; at any UNCSA sponsored event; while engaged in UNCSA business, educational, performance, and/or recreational activities; and while traveling in UNCSA vehicles (or private vehicles on a reimbursable trip). UNCSA will also assess off-the-job or off-campus violent or threatening conduct by any students or employees and take appropriate measures.
B. UNCSA will use a threat assessment process to respond to potential threats and acts of violence on campus.
C. Reporting Threats
1. Imminent Threats. Anyone who has information to indicate that an imminent threat to a UNCSA student or employee may exist should contact UNCSA Police immediately. The police will respond appropriately to maintain a safe and secure campus based on the facts of the case presented. The Threat Assessment Team will be notified and called together as soon as possible, if needed.
2. Non-Imminent Threats. In the event the concern is NOT IMMEDIATE, the individual may report the threat to UNCSA Police, a threat assessment team member, the Student Affairs Case Manager, or the Department of Human Resources (if the threat involves an employee).
D. No person, who in good faith reports threatening or otherwise troubling behavior in accordance with this regulation, will be disciplined for making the report.
E. All students, employees, and visitors must obey all criminal law, including statutes concerning weapons on campus (N.C.G.S. § 14-269.2) and communicating threats (N.C.G.S. § 14-277.1).
F. UNCSA Police will promote violence prevention efforts and strictly enforce prohibitions against implicit or explicit threats, acts of violence, and possession of unauthorized weapons. Additionally, UNCSA Police will actively promote alternative methods for addressing disputes that arise between or among our population.
G. UNCSA will use a variety of methods to educate members of the University community in the area of threat assessment and violence prevention. A non-exhaustive listing of these methods appears in this policy’s procedures.
H. UNCSA will strive to identify and screen from consideration any potential students and employees that have a known background of making threats or engaging in violent acts.
I. Additionally, UNCSA will review off-the-job or off-campus violent or threatening conduct by current students or employees of which the University becomes aware.
J. UNCSA will provide resources as set forth in the attached procedures for students and employees experiencing conflicts, disputes, personal problems, stress, unusual behavior, and/or other factors that could negatively impact their mental and emotional state.
V. Revision History
A. February 17, 2011 – Adopted by Board of Trustees as part of UNCSA Policy Manual
UNIVERSITY OF NORTH CAROLINA SCHOOL OF THE ARTS
Threat Assessment Procedures
I. Threat Assessment Team (TAT)
A. When a situation or individual becomes the focus of a threat assessment inquiry or investigation, the TAT will gather information, evaluate facts, and make a determination as to whether an individual or group poses a threat of violence. If an inquiry indicates that there is a risk of violence in a specific situation, the authorities conducting the threat assessment will collaborate with others to develop and implement a plan to manage or reduce the threat posed by the individual in that situation.
B. Team members are the Provost, Senior Director of Public Safety and Emergency Management, and the Director of the Counseling Center. Depending on whether the individual posing the threat is a student or employee, the Dean of Students or the Director Human Resources will also participate on the team. Additionally, the Senior Director of Public Safety may at any time decide to include the General Counsel or other employees who may have particular knowledge or expertise which may be beneficial in a particular situation.
C. Classifications. In making assessments, the TAT will strive to classify threats to the best of their ability based on the information available at that time. Classifications include:
1. “Low risk of threat” means a threat deemed to be of minimal risk. The information is vague, unbelievable or the threat seems impossible to carry out.
2. “Medium risk of threat” means a threat deemed possible to carry out, and that has some detail indicating the individual has given some thought to completing the threatened act. This information does not have the level of detail that reflects the individual has developed a detailed plan and taken preparatory steps to carry it out.
3. “High risk of threat” means a threat deemed to pose an imminent and serious risk, likely to result in serious injury, death, and/or substantial deliberate property damage/destruction.
D. If time allows, a concern about a student is pre-screened prior to going to the Threat Assessment Team by either the High School Mitigation Team or the College Mitigation Team (whichever is appropriate). If time allows, a non-student concern is pre-screened prior to going to the TAT by the Police and Public Safety Department and/or the Human Resources Department.
1. If the pre-screening entity believes the potential threat or act of violence is of a serious enough nature, the case will be referred to the TAT.
2. If the nature of the threat or situation is extreme and unfolding at a rapid rate, pre-screening is waived and the possible threat is reviewed immediately by the TAT. See the diagram in Appendix I for the threat assessment information flow and action flowchart. UNCSA Police will conduct any further investigation needed into the possible threat or act of violence. Information from the investigation will be shared with the TAT.
E. In a timely fashion, the TAT will assess the risk level posed by the identified individual or situation, by analyzing all of the information, conducting a threat assessment, and determining a threat/risk level. Information to be reviewed includes, but is not limited to:
1. how the proposed threat was expressed and in what level of detail;
2. the individual’s character, personality traits, and beliefs;
3. past violent or criminal behavior;
4. possession of weapon(s);
5. family dynamics;
6. culture and customs of the individual’s employer, school, or other environment he is exposed to (and part of) on a daily basis.;
7. verbal, written, or symbolic communications;
8. any possible or known triggering event(s);
9. disruptive, intimidating, harassing, bullying, menacing, hostile, frightening, aggressive, excessively isolating, or extreme out-of-the-ordinary behaviors;
10. presence of factors that jeopardize an individual’s ability to continue at the institution or that significantly negatively impact his/her life circumstances;
11. the individual has caused emotional distress, fear or serious concern on the part of students, faculty, staff or visitors to campus;
12. mental health issues/illness;
13. substance abuse;
14. likelihood the individual can carry out the threat considering whether or not she has the necessary means to fulfill the threat; AND
15. For a situation – past history of civil disorder surrounding a particular repeat event;
F. In circumstances where TAT’s analysis indicates that a student or employee needs help but poses no threat, TAT may refer the student to the Case Manager, High School Mitigation Team, or College Mitigation Team Student Concern Team or the employee to Human Resources staff for appropriate follow-up.
G. Based on this assessment, TAT will take or recommend appropriate action and/or consequences in the best interest of the safety, security, and effective operation of UNCSA.
H. The TAT ensures that specific intervention steps are initiated and completed within the needed time frame by the responsible UNCSA faculty/staff, Department and/or Division.
1. Consequences for students may include, but are not limited to: steps of the student judicial process, accepting student voluntary leave, mental health referral/counseling, mandated psychological assessment, emergency suspension to remove the student from the campus immediately, or involuntary withdrawal from school.
2. Consequences for employees may include, but are not limited to: mandatory fitness for duty examination; referral to employee assistance program; steps of the employee disciplinary process, up to and including discharge.
3. The UNCSA Police may use any lawful enforcement measures in connection with threats involving students, employees and visitors or trespassers. Threats by visitors: UNCSA will take steps to prevent or minimize threats or acts of violence by visitors to campus. UNCSA will employ a variety of measures to educate visitors and deal with any potential threat or act of violence from this “non-affiliated” population. Measures include, but are not limited to:
I. All documentation from the TAT will be maintained at the Department of Police and Public Safety in a manner which complies with relevant privacy laws.
J. The TAT will facilitate any available steps to mitigate the effects of threats and acts of violence on any victims. This will be done in conjunction with the Case Manager and Counseling Center.
II. Mitigation Teams
A. High School Mitigation Team. The team reviews the relevant information, talks with the student and the student’s family, and suggests an appropriate intervention to assist the student. The Case Manager is typically part of this process to help facilitate follow-up on any assistance plan.
B. College Mitigation Team. The committee reviews the relevant information, talks with the student, the student’s family (in some, but not all cases), and suggests an appropriate intervention to assist the student. The Case Manager is typically part of this process to help facilitate follow-up on any assistance plan.
III. Education. UNCSA will use a variety of methods to educate members of the University community in the area of threat assessment and violence prevention. Methods that will be used include, but are not limited to:
A. Student Handbooks
B. University policies and procedures
C. Residence hall student meetings
D. UNCSA website postings
E. Tabletop exercises and drills
F. UNCSA police Facebook page
G. Educational materials and training as set forth in the UNCSA Campus Police’s policy.
A. UNCSA will provide a variety of resources for students and employees experiencing conflicts, disputes, personal problems, stress, unusual behavior, and/or other factors that could negatively impact their mental and emotional state.
B. Available resources include, but are not limited to:
1. The Counseling and Testing Service provides certified counselors, and the Service’s website offers links to several topics.
2. Student Health Services provides a full spectrum of services, from crisis intervention, evaluation and treatment of illness to therapies and education to help students grow in their daily lives and learn to stay healthy.
3. The High School and College Mitigation Teams use early intervention plans to assist students in situations that may cause them distress.
4. A full-time clinical case manager assists with student issues, serving as a point of contact for faculty and staff to express concerns about a student. The case manager also consults with families, faculty, administrators, and health service medical providers regarding student mental health issues and treatment options.
5. Residence Life staff observe students in their on-campus housing environment and identify any social or behavioral factors that may cause concern about the students’ mental and emotional state. Staff will report such concerns to the appropriate resource for follow-up.
6. Human Resources will facilitate:
a. Development and revisions to related University policies
b. Management and supervisory awareness of signs that may indicate potential employee threats or acts of violence. (Police will also be available to present information on threat assessment and violence prevention to faculty and staff.)
c. A mechanism for employee-employer dispute resolution
d. Appropriate investigations and corrective actions for violations of related Policy and Work rules
e. The Employee Assistance Program
7. UNCSA Police will provide information and assistance to concerned students and employees as needed. If the threat to a student or employee is located off-campus, UNCSA Police will assist the individual employee in contacting the police agency having jurisdiction.