Preserving the safety and security of Central Virginia Community College (CVCC) faculty, staff, students and visitors requires vigilance, diligence, communication, and coordination. The purpose of this policy is to provide a framework for threat assessment, intervention and management strategies designed to reduce the risk of violence. This policy is guided by the Code of Virginia 23.1-805 (Violence Prevention; Threat Assessment Team), Virginia DHRM Policies 1.60 (Standards of Conduct) and 2:35 (Civility in the Workplace), and VCCS Policy 3:12 (Faculty Sanctions) and 3.14 (General Policies).
Code of Virginia 23.1-805 requires higher education institutions to have policies and procedures for the prevention of violence on campus, including assessment and intervention strategies for individuals whose behavior may pose a threat to the safety of the campus community. This policy applies to concerning behaviors demonstrated by CVCC faculty, staff, students, vendors, visitors or third parties.
- Course of Conduct: A course of conduct is any series of acts over a period of time, however limited, that evidences a continuity of purpose, such as following or stalking an individual, inappropriate telephone calls to and/or other correspondence and by whatever means.
- Credible Threat: A credible threat is defined as a knowing and willful, action(s), statement(s) or course of conduct that would cause a reasonable person to believe there is a threat or concern for harm.
- Threat: A threat is the expression of intent to cause physical or mental harm. An expression constitutes a threat without regard to whether the party communicating the threat has the present ability to carry it out, and without regard to whether the expression is contingent, conditional, for the future or communicated directly or indirectly.
- Threat Assessment: Threat assessment is an investigative procedure involving a possible or potential act(s) to cause physical or mental harm. The goal of threat assessment is to prevent the violence and not necessarily identification and/or arrest or removal of a perpetrator.
- Substantive Threat: A substantive threat is one that requires some form of protective action to prevent the threat from being carried out, such as separation of the perpetrator and potential victim(s).
- The team evaluates the particulars of the reported or potential threat and takes appropriate actions according to the identified or potential risk factors to include but not limited to:
- PRIORITY 1 (Extreme Risk): Appears to pose a clear/immediate threat of violence or self-harm and requires immediate action or containment. Immediate actions required that may include but is not limited to law enforcement intervention, suspension, medical separation, target protection, emergency notification of others and case management plan.
- PRIORITY 2 (Severe Risk): Appears to pose a threat of violence or self-harm but lacks immediacy or access to target. Action may include but not limited to active monitoring, dismissal, separation, law enforcement response and case management plan.
- PRIORITY 3 (Elevated Risk): Does not appear to pose an immediate threat of violence or self- harm, but exhibits significantly disruptive behaviors and/or need for assistance. Actions may include but is not limited to active monitoring, interim suspension, case management plan and/or appropriate referrals.
- PRIORITY 4 (Moderate Risk): Does not appear to pose a threat of violence or self-harm at this time, but may exhibit some disruptive behavior and/or need for assistance. Actions may include active or passive monitoring, behavior contract, case management and/or referrals as appropriate.
- PRIORITY 5 (None or Mild Risk): Person/situation does not appear to pose an immediate threat of violence or self- harm, nor is there evidence of immediate disruption to the campus community. No active case management or monitoring, passive monitoring and/or appropriate referrals may be initiated if deemed applicable or necessary.
- Prohibited Conduct: conduct that includes, but is not limited to an act(s) or expression:
- of intent to injure another person(s) physically;
- that creates a reasonable fear of injury to others;
- that subjects another individual(s) to extreme emotional distress; and
- of intent to damage the property of another, to include an animal/pet.
- Such actions/conduct can be verbal, nonverbal, direct, indirect, implied and/or conditional and may be communicated by any means.
- Threats will be subject to disciplinary action by the institution, and/or may include criminal prosecution if the behavior constitutes a violation of law.
- Threat Assessment Team: The Code of Virginia Section 23.1-805, defines the makeup of the threat assessment teams for institutions of higher education. At a minimum, the team must include members from law enforcement, mental health professionals, representatives of student affairs and human resources, and, if available, college or University counsel. The TAT is not a disciplinary body, but it may refer cases as a matter of student conduct, standards of conduct and in accordance with VCCS Policy Manual.
Members of the CVCC Threat Assessment Team (CVCCTAT) include the:
The Threat Assessment Team (TAT) may also include one or more members as appropriate, such as a legal advisor, Academic Deans, other CVCC faculty or staff and/or a member(s) of the community. It shall be at the sole discretion of the Threat Assessment Team to determine the appropriate individual(s) on a case by case basis.
- CVCC Chief of Police
- Dean of Student Success
- Human Resources Director
- Dean of Enrollment Management
- Vice President for Academic and Student Affairs
- Coordinator of Student Accessibility Services or another member of the Counseling Center.
The Threat Assessment Team shall be chaired by the CVCC Chief of Police, and/or the Vice President of Academic and Student Affairs shall serve as chair in his/her absence.
The Threat Assessment Team shall establish relationships or utilize existing relationships with local and state law enforcement agencies as well as mental health agencies to expedite assessment and intervention with individuals whose behavior may present a threat to safety.
The college will maintain its MOA/MOU with Horizon Behavior Health and/or another counseling/mental health providers and with the local and state police agencies.
- Threat Assessment Team Scope of Authority: The Team is charged with developing comprehensive fact-based assessments of individuals who may present a threat to CVCC, and is empowered to take timely and appropriate action, consistent with CVCC and VCCS policy, and applicable laws.
- The Threat Assessment Team shall be referred all cases that involve threat of violence by student, faculty, staff, community member or anyone else that would affect the campus community. If there is any doubt whether a case will be referred to the Threat Assessment Team, the case shall be referred and the Team will determine what action, if any is appropriate. In an emergency the report should be directed to campus police at 434–832–7700 and/or 911.
- The team may make referrals to the campus CARE team, Mentoring program and/or other campus or community resources, services or assistance programs.
- CVCC Threat Assessment Team may provide recommendations for student conduct and administrative actions, disciplinary actions or other methods of interventions, such as counseling, dispute resolution and/or mandated assessments. All such actions will be taken according to Student Conduct policy, Commonwealth of Virginia Standards of Conduct Policy, VCCS Policy Manual, CVCC Student Handbook or other applicable federal or state laws.
- In a health or safety emergency, no information that is necessary to protect the health or safety of an individual or others shall be withheld as confidential. In such cases, health or safety emergency, medical, mental health, employment, criminal histories and academic records that are ordinarily regarded as confidential or sensitive in nature may be released to the Threat Assessment Team.
- All CVCC employees, students, contract employees and vendors are expected to cooperate with the Threat Assessment Team in order to respond to a threat or threatening situation.
- Once a threat has been determined not to be substantive, the subject of investigation shall be informed by the threat assessment team, campus police or the appropriate supervisory staff of the investigation and their actions or behavior that led to the investigation.
- Record Keeping: The threat assessment files are separate files and maintained by CVCC Chief of Police or his designee and within a secure file in the Central Virginia Community College Police Department. Access to the threat assessment files shall be limited to members of the Threat Assessment Team and legal counsel, if necessary. All records will be kept for a minimum of seven years to assure compliance with federal and state requirements.
- Threat assessment files shall be protected for security purposes as other investigations of possible criminal behaviors. Because threat assessments may be investigations of potential criminal behavior, these records created by the threat assessment team are not educational records and are not subject to state regulations or eligible for release under the Freedom of Information Act, as reports generated by the threat assessment team are exempt under Va. Code, 2.2-3705.4(A8), 19.2-389, 19.2-389.1 and 32.1-127.1:03
- Any response by the Team that includes a criminal arrest and prosecution may be exempt from release pursuant to Va. Code 2.2-3705.4(A8) and 2.2-3706. This protection from disclosure applies to records generated by the Threat Assessment Team specifically for threat assessment purposes.
- Faculty, staff and students who fail to abide by this policy and/or bully, harass or retaliate against individuals reporting threats according to this policy shall be subject to disciplinary action according to Commonwealth of VHRM Policy 1.60, the VCCS Policy Manual, or the CVCC Student Handbook.
- CVCC TAT serves as the violence prevention committee and coordinates safety related efforts with the Department of Public Safety/Campus Police and collaborates with the Safety & Security Committee to promote campus safety. The TAT collaborates with campus police and student success to educate and provide information, via blast emails, social media postings, presentations and training to the campus community during convocation, SDV, new employee and new student orientations and to various campus associations/groups and/or governance committees.
- CVCC TAT members completes the Virginia Department of Criminal Justice approved threat assessment team training and participates in on-going training to include but are not limited to crisis intervention training, mental health, suicide intervention/prevention training and engage in exercises to facilitate the team understanding of their roles and obligations as it pertain to confidentiality of sensitive information/records provided to the team in accordance with Va. Codes, 19. 2-389, 19.2-389.1 and 23.1-805.
- CVCCTAT members are bound by policy and/or of state law, and commit to non- disclosure. Each member acknowledges that it is a violation to redisclose information and/or files/records obtained via a threat assessment process to non-team members, unless the team determines the disclosure serves a significant violence management or prevention purpose or the disclosure is required by law.
*** CVCC local board authorized the Threat Assessment Team (TAT) as the college threat assessment, prevention and management body, and approved the TAT to serve as the college sexual assault review committee as permitted by Va. Code 23.1-806. CVCC President’s Cabinet authorized the TAT to serve as the sexual offender registry review committee for applications for admission or readmission.
This Policy approved by the President’s Cabinet on February 18, 2019.