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