The Clery Act requires all institutions of higher education to collect crime reports from a variety of individuals and organizations that Clery considers to be Campus Security Authorities (CSAs). In its 2016 Handbook for Campus Safety and Security Reporting, the U.S. Department of Education identified two types of individuals working in specific roles who are not CSAs under the Clery Act: Pastoral counselors and Professional Counselors (this includes counselors-intraining working under the license of a professional counselor). Furthermore, directors of campus counseling centers were classified as people who generally meet the criteria for being campus security authorities (CSAs).

The Association for University and College Counseling Center Directors (AUCCCD) takes the position that counseling center directors, in their roles as confidential mental health service providers or supervisors and consultants to those providing such services, have an ethical duty to maintain confidentiality and are, therefore, not CSAs. Mental health professionals functioning in other roles at the university (e.g., faculty, dean of students) rather than in a professional counseling role at the institution could be considered CSA’s in those roles.

Given that many survivors of a crime have already experienced a loss of control, it can be psychologically detrimental for a mental health professional to share students’ experiences of victimization with other campus officials against their will. The fear that information will be disclosed in a manner that is uncomfortable or even traumatic could reasonably discourage a survivor of a crime from getting needed counseling services. College and university counseling center professionals, including Directors, are ethically bound to “do no harm.” Confidentiality is the key part of the counseling relationship and respecting the wishes of students who have sought treatment with the expectation that the information they have shared will be kept in confidence is of the utmost importance.

References: U.S. Department of Education, Office of Postsecondary Education, The Handbook for Campus Safety and Security Reporting, 2016 Edition, Washington, D.C., 2016.