Threat Assessment and Threat Management

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ADMINISTRATIVE PROCEDURE MANUAL
SECTION TITLE
THREAT ASSESSMENT AND THREAT MANAGEMENT
BASED ON BOARD OF TRUSTEES’ RULE AND TITLE
6Hx7-6.2 Safety and Traffic Control
NUMBER
PAGE
06-0913
1 of 5
DATE REVISED
March 3, 2015
Background
This procedure establishes the protocol for dealing with issues that may potentially develop into acts of
violence on a campus/center. Threat assessment focuses on preventing future student behaviors that
threaten violence or physical harm to one’s self or others on a campus College property or at College
events. The response to present danger is covered by the current College Emergency Response Plan. This
APM is designed to describe a standard procedure for slower developing issues that need to be monitored,
engaged or addressed. Example 1: a student describes violence in a paper which the faculty member
presents to the Dean. Example 2: an employee’s comments or behaviors are making other employees feel
uncomfortable and concerned about a potential incident of workplace violence.
Purpose
The purpose of this procedure is to establish a College threat assessment process and to describe the steps
necessary in threat assessment and threat management. This procedure covers issues in which a threat may
exist but is not currently occurring on campus. The mission of the College threat assessment process is to
prevent targeted violence by students or employees. Threat assessment Case Teams accomplish this
mission by gathering information, evaluating facts, determining from the facts whether an individual poses
a threat of violence or physical harm to a target or to others, and, if necessary, developing and
implementing a plan to monitor, reduce or manage the threat.
Procedure
A. Administration
1. An Administrative Team for the threat assessment shall consist of the following:
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
Director of Security;
Director of Risk Management;
Director of Law Enforcement Training;
Executive Director of Employee Relations and the College Equity Officer (Equity Officer);
Chief Human Resource Officer (CHRO);
General Counsel or assigned College attorney;
Executive Dean of Student Services and Enrollment Management;
Deans of Student Success (5);
Faculty Members (2);
One Campus Security Officer;
Counselor Coordinator or Counselor;
ADMINISTRATIVE PROCEDURE MANUAL
SECTION TITLE
THREAT ASSESSMENT AND THREAT MANAGEMENT
BASED ON BOARD OF TRUSTEES’ RULE AND TITLE
6Hx7-6.2 Safety and Traffic Control
NUMBER
PAGE
06-0913
2 of 5
DATE REVISED
March 3, 2015
2. The Director of Security shall chair this Administrative Team and be responsible for leading the
College threat assessment program described in this APM. The Chair shall schedule meetings,
document actions and maintain records as necessary to accomplish the mission of the program.
3. The Administrative Team shall establish additional desktop procedures for the implementation of
the program, make recommendations to the Cabinet regarding changes to the APM or Board Rule
as related to threat assessment and develop tools to promote the program and improve its
effectiveness.
4. A subcommittee of the Administrative Team shall annually screen applicants for admission who are
designated sexual offenders in accordance with APM 10-0701. The Chair shall assign members of
the Administrative Team to this screening subcommittee, which shall at a minimum include the
Chair, two Campus Deans of Student Success, and the General Counsel or College attorney
assigned to B below.
B. Case Teams
1. A Case Team to conduct a threat assessment may be convened by the following officers of the
College (hereafter referred to as “Team Leader”):
Situation
Student cases
Employee cases
Team Leader
Vice President of Student Services or appropriate Campus President
Vice President of Business Services or Chief Human Resource Officer
2. A team for an individual case can be called into action by a Team Leader. Action may only be
taken by a Case Team consisting of the Team Leader and the appropriate campus Dean of Student
Success (“Dean”), or designee, for student cases, either the Equity Officer or the Chief Human
Resource Officer (CHRO) for employee cases, and at least 3 additional members from the
Administrative Team.
3.
As needed, one or more of the following may be included as a resource for a case:
a. a Jacksonville Sheriff Office (JSO) officer appropriate to the specific situation;
b. a representative of the College’s Student Assistance Program (SAP) or Employee Assistance
Program (EAP) contractor;
c. Director of Student Support Services, or designee;
d. the Director of International Student Services;
e. and others with relevant knowledge to the case as determined by the Team Leader.
ADMINISTRATIVE PROCEDURE MANUAL
SECTION TITLE
THREAT ASSESSMENT AND THREAT MANAGEMENT
BASED ON BOARD OF TRUSTEES’ RULE AND TITLE
6Hx7-6.2 Safety and Traffic Control
NUMBER
PAGE
06-0913
3 of 5
DATE REVISED
March 3, 2015
C. Responsibilities
1. The Team Leader has the responsibility and authority to convene a Case and shall keep the College
President, or designee, informed regarding cases.
2. For student cases, the Dean, or designee, from the campus of the student involved shall maintain
case records and coordinate the transition of cases between the College’s Student Disciplinary and
Threat Assessment processes. The Dean’s assigned administrative assistant may attend case
meetings for the purpose of assisting the Dean in recording minutes.
3. For employee cases, the CHRO shall maintain the records and facilitate the transition of cases
between the employee discipline and the Threat Assessment processes. The CHRO’s
administrative assistant may attend case meetings for the purpose of recording minutes.
4. The Director of Student Support Services may be included to assess the applicability of disability
laws in a specific instance and to help the team avoid discriminating against individuals based on a
disability or a perceived disability.
5. The Security Officer in Charge and/or the off-duty JSO officer from the campus shall conduct
initial investigations, interview witnesses and others, conduct incident report searches for related
instances, maintain security records and provide security as requested during team member
interviews with the student of interest. For employee cases, the Equity Officer shall conduct the
initial investigation, tasking campus security as may be required.
6. The assigned General Counsel attorney shall advise the team on applicable legal considerations and
the options the team is considering.
7. The off-duty JSO officer or other appropriate JSO officer may be requested by the appropriate
Campus President to conduct off-campus information gathering in support of case inquiries.
8. A representative of the Student Assistance Program or Employee Assistance Program vendor may
be included, as appropriate, to provide general mental health information and guidance.
D. Member Training - The members of the Administrative Team shall receive basic threat assessment
training at least annually through trainers and/or online sessions selected by the Director of Security
using funds budgeted for threat assessment administration.
E. Relation to Student and Employee Discipline Procedures - The College threat assessment processes
augment the College’s Student Disciplinary Procedures and applicable employee disciplinary
procedures. Activation of a Case Team should not affect the continued implementation of the
ADMINISTRATIVE PROCEDURE MANUAL
SECTION TITLE
THREAT ASSESSMENT AND THREAT MANAGEMENT
BASED ON BOARD OF TRUSTEES’ RULE AND TITLE
6Hx7-6.2 Safety and Traffic Control
NUMBER
PAGE
06-0913
4 of 5
DATE REVISED
March 3, 2015
disciplinary procedures. Consequences of past behaviors shall be assessed through the disciplinary
processes.
F. Threat Inquiry - Case Teams may use the Threat Assessment Worksheet to assist in evaluating the
information gathered. Case teams are authorized:
1.
2.
3.
4.
to gather all available information as allowed by law,
to assign security to conduct additional investigations,
to interview the individual of concern or others with one or more team members,
to enlist the services of the College’s Student Assistance Program (SAP) or Employee
Assistance Program (EAP) vendor as appropriate,
5. to utilize the services of the off-duty JSO officer at the Campus
6. to conduct background checks as approved by the General Counsel representative.
G. Threat Investigation
1. In the event a Case Team determines there is the potential for targeted violence, the case shall be
reported to the JSO. The JSO should be involved in cases as soon as possible whenever a threat of
imminent violence is determined.
H. Response Plan
1. A Case Team might choose to develop and the Dean of Student Success and Vice President of
Student Services shall implement an individual response plan for students. The CHRO may choose
to develop and implement individual response plans for employees. The team shall monitor a case
until such time as it is determined there is no longer the potential for targeted violence on a
Campus. The plan shall:
a. Control/contain the situation and/or individual in a way that will minimize the risk of violence;
b. Protect and aid possible targets; and
c. Provide reasonable support and guidance to help the individual deal successfully with
contributing problems.
I. Administrative Actions
1. Any of the following recommendations to the College President, or designee, concerning students
will be made in collaboration with the Office of General Counsel and the Vice President of Student
Services:
ADMINISTRATIVE PROCEDURE MANUAL
SECTION TITLE
THREAT ASSESSMENT AND THREAT MANAGEMENT
BASED ON BOARD OF TRUSTEES’ RULE AND TITLE
6Hx7-6.2 Safety and Traffic Control
NUMBER
PAGE
06-0913
5 of 5
DATE REVISED
March 3, 2015
a. Administrative withdrawal;
b. Conditional readmission;
c. Dismissal.
2. Employment actions shall be made using established College procedures. The CHRO may direct
an employee to remain off campus or otherwise restrict their access to College facilities and
programs while a situation is under review.
J. Records and Reporting
1. A Threat Assessment Report, including all documentation, shall be completed and filed by the Dean
of Student Success, or designee, for student cases and by the CHRO, or designee, for employee
cases. For students, an informational security report shall be made by the appropriate security
department noting the name of the student and the name of the campus that completed the threat
assessment. Student case records and meeting minutes mentioned in this APM shall be maintained
by the Director of Security and with each Dean of Student Success. Employee case records and
minutes shall be maintained by the CHRO.
REFERENCES: F.S. 1001.64, SBE Rule 6A-14.0261
Adopted Date: November 6, 2012
Revision Date: September 24, 2013, March 3, 2015
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