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Violence Prevention and Threat Assessment and Management

  • Responsible Office: VCU Police, Division of Student Affairs, and Human Resources, Office of the Provost
  • Current Approved Version: 03/21/2022
  • Policy Type: Board of Visitors

Policy Statement and Purpose

The university is committed to promoting a safe environment for its students, employees and visitors. Toward this end, it encourages all members of the university community to take reasonable precautions for their own safety and for the safety of others. The university requires all employees (including faculty) to report behavior that may represent a physical threat to any member of the university community to an appropriate university official as described in this policy. The university also encourages all students and visitors to report safety concerns as set forth in this policy.

The university has designated its Threat Assessment Team and Violence Prevention Committee (TAT) to establish procedures for the prevention of violence on campus, including assessment of and intervention with individuals whose behavior poses a threat to the safety of the university community. The university has charged TAT with identifying, monitoring and coordinating the management of threats to the university community. TAT operates according to the procedures outlined in this policy.

This policy is designed to comply with the requirements of the Code of Virginia. In accordance with the university’s Space Use Regulation, in the Virginia Administrative Code, entry upon and use of university property must be in accord with university policies and the Weapons Regulation. University policies that prohibit threatening or violent acts include, but are not limited to, the policy on Reservation and Use of Space (prohibiting “any threat to the health or safety of any passerby or member of the university community” on university property), the employee Code of Conduct, the Student Code of Conduct, and the Title IX Sexual Harassment Policy and Sex-Based Misconduct Policy. Any person who violates the restrictions of university policy may be excluded from university property, subject to criminal penalties for trespass, and/or subject to university action under applicable policy, such as the Student Code of Conduct or applicable employee conduct policies.

Noncompliance with this policy may result in disciplinary action up to and including termination. VCU supports an environment free from retaliation. Retaliation against any employee who brings forth a good faith concern, asks a clarifying question, or participates in an investigation is prohibited.

Table of Contents

Who Should Know This Policy
Definitions
Contacts 
Policy Specifics and Procedures
Forms 
Related Documents 
Revision History
FAQ 

Who Should Know This Policy

All employees (including faculty) are responsible for knowing this policy and familiarizing themselves with its contents and provisions. Students and others may find this policy a helpful resource.

Definitions

Employee

For the purpose of this policy, employee means any person who holds a full- or part-time paid position with the university including, but not limited to, university and academic professionals, classified, hourly, faculty (teaching, research, adjunct and clinical), and student workers.

Student

For the purpose of this policy, the term “Student” includes all persons taking courses through VCU for any type of academic credit; credit or non-credit classes (including auditing a class or English Language Program classes), either full-time or part-time, online or in-person, single or dual enrolled, pursuing undergraduate, graduate or professional studies. “Student” also includes all persons who withdraw after allegedly violating university policy but prior to adjudication, persons who are not enrolled officially for a particular term but who have not officially withdrawn from the university, persons who have been notified of their acceptance for admissions, and persons living in VCU residence halls regardless of course enrollment. Employees of Virginia Commonwealth University or the Virginia Commonwealth University Health System may also be students

Threat mitigation interventions

Strategies or actions designed to reduce the risk of danger or harm in threatening situations.

Contacts

The Division of Student Affairs officially interprets this policy. The Division of Student Affairs is responsible for obtaining approval for any revisions as required by the policy Creating and Maintaining Policies and Procedures through the appropriate governance structures. Please direct policy questions to the Division of Student Affairs and the Senior Vice Provost for Student Affairs.

Policy Specifics and Procedures

Threat Assessment Team and Violence Prevention Committee (TAT)

The Senior Vice Provost for Student Affairs (or designee) and Chief of VCU Police (or designee) serve as co-chairs of TAT, and its membership includes representatives from student affairs, university police, human resources, counseling services, residence life and others as determined necessary by co-chairs.

Any TAT member may designate a substitute as needed and in coordination with a TAT co-chair. University legal counsel attends TAT meetings in an advisory capacity, as available. Other VCU officials may be asked to attend meetings on a case-by-case basis.

The TAT co-chairs and coordinator can be contacted via email at tat@vcu.edu.

TAT’s charge is education on and prevention of violence on campus. It implements assessment, intervention, and action protocols in coordination with other university officials, specifically to do the following:

  1. provide guidance to students and employees regarding recognition of threatening or aberrant behavior that may represent a physical threat to the community;
  2. identify members of the campus community to whom threatening behavior should be reported;
  3. establish policies and procedures that outline circumstances under which all employees (including faculty) are required to report behavior that may represent a physical threat to the community, consistent with state and federal law; and
  4. establish procedures for (a) the assessment of individuals whose behavior may present a threat; (b) the appropriate means of intervention with such individuals; and (c) the sufficient means of action, including interim suspension, referrals to community services boards or health care providers for evaluation or treatment, medical separation to resolve potential physical threats, and notification of family members or guardians, or both, as appropriate.

TAT establishes and maintains relationships with mental health agencies and local and state law-enforcement agencies to expedite assessment of and intervention with individuals whose behavior may present a threat to safety.

Upon a preliminary determination that an individual poses a threat of violence to self or others or exhibits significantly disruptive behavior or a need for assistance, TAT may obtain criminal history record information as provided in the Code of Virginia sections on the threat assessment teams of institutions of higher education and health records as provided in the Virginia Health Records Privacy Act. No member of TAT will redisclose any such criminal history record information or health information or otherwise use any record of an individual beyond the purpose for which such disclosure was made to TAT.

TAT maintains the confidentiality of its records to the greatest extent permitted by law and discloses sensitive personal information about students and employees only as needed for its operations.

Reporting Threats to Safety or Wellbeing

The university reviews and investigates reports of any potential threat to the safety of one or more members of its community. It relies on students, employees and others to report their good faith concerns for threats to safety. The university requires employees (including faculty) and encourages students and others to report information about concerns for threats to safety to the university, as follows: 

  • Report to VCU Police information about an immediate threat to physical safety of any person on university property. In addition, any student or employee who has obtained a court order of protection should notify VCU Police and provide a copy of the order to inform necessary safety planning and facilitate enforcement of the order on university property.
    • For on-campus emergencies, call 804-828-1234.
    • For off-campus emergencies, call 911.
    • For non-emergency reporting, call 804-828-1196 or use the LiveSafe app.
  • Report to TAT information about a threat to the safety of any student, employee or campus visitor that does not require an immediate response. If immediate assistance is needed, please contact VCU Police as indicated above.
    • Complete the Incident Reporting Form by clicking on Share a Concern/Request Assistance on the university’s Life Buoy website (go.vcu.edu/safety) or contact the TAT Coordinator at tat@vcu.edu for assistance.

 

  • Report to the Dean of Students office information about a concern for a student’s health or wellbeing that does not require immediate response.
    • Complete the Incident Reporting Form by clicking on Share a Concern/Request Assistance on the university’s Life Buoy website (go.vcu.edu/safety), email vcudean@vcu.edu, or call 804-828-8940 (during university operating hours) for assistance.
  • Report to Human Resources information about a concern for an employee’s health or wellbeing that does not require immediate response.
    • Call (804) 828-1510 during university operating hours.

When in doubt, call VCU Police, who will evaluate the report to determine the appropriate university official.

Employees who report threats or concerns to any of the above university officials should notify their manager or another administrator with oversight in their area that they have made the report within one business day of making the report. The reporting employee should also advise the official receiving the report that the reporting employee has notified the relevant authority.

Students who report threats or concerns as described above may seek supportive resources from the office of the Dean of Students in addition to those offered by the university official receiving the report.

Cooperating with TAT in Threat Mitigation

TAT may determine that certain threat mitigation interventions should involve other university officials, including the reporter of the threat. The university requires all employees (including faculty) to respond to requests from TAT for information or records and to assist in implementing threat mitigation interventions in accordance with TAT’s guidance. TAT members are authorized to access student records because they are university officials with a legitimate educational interest in the information, as set forth by VCU’s Student Privacy practices and in accordance with the federal Family Educational Rights and Privacy Act (FERPA). Any employee who has questions or concerns about implementing TAT’s guidance should contact a TAT co-chair or the Associate Vice President for Public Safety.

Once TAT has reviewed a reported threat, it may advise certain university employees or departments to take specific precautions and to continue to report further information. In such situations, university employees should seek guidance and await a response from TAT before making further contact with the individual who is the subject or source of the reported concern. Unless specifically advised by TAT to alter standard protocols, university employees should continue conducting standard duties and operations following a reported threat. Any specific interventions by TAT members with an individual identified as potential source of a threat to the university community will generally not replace the ordinary interaction with the individual by other university employees or departments. For example, TAT generally does not engage directly in a student conduct process but rather monitors the process and advises university employees throughout the process, as needed.

If TAT has determined that an individual presents an identified and articulable threat to the university community and the results of an appropriately tailored psychological assessment are necessary to develop a reasonable threat mitigation plan, the university may condition the individual’s continued employment, enrollment or contract upon review by TAT of the results of such a psychological assessment, conducted by a qualified, licensed clinician.

Threat Assessment Team and Violence Prevention Committee (TAT)

The Senior Vice Provost for Student Affairs (or designee) and Chief of VCU Police (or designee) serve as co-chairs of TAT, and its membership includes representatives from student affairs, university police, human resources, counseling services, residence life and others as determined necessary by co-chairs.

Any TAT member may designate a substitute as needed and in coordination with a TAT co-chair. University legal counsel attends TAT meetings in an advisory capacity, as available. Other VCU officials may be asked to attend meetings on a case-by-case basis.

The TAT co-chairs and coordinator can be contacted via email at tat@vcu.edu.

TAT’s charge is education on and prevention of violence on campus. It implements assessment, intervention, and action protocols in coordination with other university officials, specifically to do the following:

  1. provide guidance to students and employees regarding recognition of threatening or aberrant behavior that may represent a physical threat to the community;
  2. identify members of the campus community to whom threatening behavior should be reported;
  3. establish policies and procedures that outline circumstances under which all employees (including faculty) are required to report behavior that may represent a physical threat to the community, consistent with state and federal law; and
  4. establish procedures for (a) the assessment of individuals whose behavior may present a threat; (b) the appropriate means of intervention with such individuals; and (c) the sufficient means of action, including interim suspension, referrals to community services boards or health care providers for evaluation or treatment, medical separation to resolve potential physical threats, and notification of family members or guardians, or both, as appropriate.

TAT establishes and maintains relationships with mental health agencies and local and state law-enforcement agencies to expedite assessment of and intervention with individuals whose behavior may present a threat to safety.

Upon a preliminary determination that an individual poses a threat of violence to self or others or exhibits significantly disruptive behavior or a need for assistance, TAT may obtain criminal history record information as provided in the Code of Virginia sections on the threat assessment teams of institutions of higher education and health records as provided in the Virginia Health Records Privacy Act. No member of TAT will redisclose any such criminal history record information or health information or otherwise use any record of an individual beyond the purpose for which such disclosure was made to TAT.

TAT maintains the confidentiality of its records to the greatest extent permitted by law and discloses sensitive personal information about students and employees only as needed for its operations.

Reporting Threats to Safety or Wellbeing

The university reviews and investigates reports of any potential threat to the safety of one or more members of its community. It relies on students, employees and others to report their good faith concerns for threats to safety. The university requires employees (including faculty) and encourages students and others to report information about concerns for threats to safety to the university, as follows:

  • Report to VCU Police information about an immediate threat to physical safety of any person on university property. In addition, any student or employee who has obtained a court order of protection should notify VCU Police and provide a copy of the order to inform necessary safety planning and facilitate enforcement of the order on university property.
    • For on-campus emergencies, call 804-828-1234.
    • For off-campus emergencies, call 911.
    • For non-emergency reporting, call 804-828-1196 or use the LiveSafe app.
  • Report to TAT information about a threat to the safety of any student, employee or campus visitor that does not require an immediate response. If immediate assistance is needed, please contact VCU Police as indicated above.
    • Complete the Incident Reporting Form by clicking on Share a Concern/Request Assistance on the university’s Life Buoy website (go.vcu.edu/safety) or contact the TAT Coordinator at tat@vcu.edu for assistance.
  • Report to the Dean of Students office information about a concern for a student’s health or wellbeing that does not require immediate response.
    • Complete the Incident Reporting Form by clicking on Share a Concern/Request Assistance on the university’s Life Buoy website (go.vcu.edu/safety), email vcudean@vcu.edu, or call 804-828-8940 (during university operating hours) for assistance.
  • Report to Human Resources information about a concern for an employee’s health or wellbeing that does not require immediate response.
    • Call (804) 828-1510 during university operating hours.

When in doubt, call VCU Police, who will evaluate the report to determine the appropriate university official.

Employees who report threats or concerns to any of the above university officials should notify their manager or another administrator with oversight in their area that they have made the report within one business day of making the report. The reporting employee should also advise the official receiving the report that the reporting employee has notified the relevant authority.

Students who report threats or concerns as described above may seek supportive resources from the office of the Dean of Students in addition to those offered by the university official receiving the report.

Cooperating with TAT in Threat Mitigation

TAT may determine that certain threat mitigation interventions should involve other university officials, including the reporter of the threat. The university requires all employees (including faculty) to respond to requests from TAT for information or records and to assist in implementing threat mitigation interventions in accordance with TAT’s guidance. TAT members are authorized to access student records because they are university officials with a legitimate educational interest in the information, as set forth by VCU’s Student Privacy practices and in accordance with the federal Family Educational Rights and Privacy Act (FERPA). Any employee who has questions or concerns about implementing TAT’s guidance should contact a TAT co-chair or the Associate Vice President for Public Safety.

Once TAT has reviewed a reported threat, it may advise certain university employees or departments to take specific precautions and to continue to report further information. In such situations, university employees should seek guidance and await a response from TAT before making further contact with the individual who is the subject or source of the reported concern. Unless specifically advised by TAT to alter standard protocols, university employees should continue conducting standard duties and operations following a reported threat. Any specific interventions by TAT members with an individual identified as potential source of a threat to the university community will generally not replace the ordinary interaction with the individual by other university employees or departments. For example, TAT generally does not engage directly in a student conduct process but rather monitors the process and advises university employees throughout the process, as needed.

If TAT has determined that an individual presents an identified and articulable threat to the university community and the results of an appropriately tailored psychological assessment are necessary to develop a reasonable threat mitigation plan, the university may condition the individual’s continued employment, enrollment or contract upon review by TAT of the results of such a psychological assessment, conducted by a qualified, licensed clinician.

University Safety Resources

In conjunction with TAT, the university provides support for students and employees in distress, including those who identify a threat against their own safety or the safety of others and those who are subject to intervention related to such threats. The following offices may provide safety resources and guidance.

  • VCU Police provides safety and law enforcement support to foster a safe learning and working environment and respond to reports of urgent or immediately dangerous situations.
  • Human Resources Office of Employee Relations develops and maintains a response plan for concerns about potential violence in the workplace; provides confidential assistance to university employees (including supervisors and faculty) to help resolve work-related problems; and offers information about the employee assistance program.
  • The Division of Student Affairs (DSA) provides resources and assistance to students and to employees concerned with student wellness. It develops and implements policies and procedures regarding student mental health and wellness through its Dean of Students, University Counseling Services and University Student Health Services, consistent with the Code of Virginia section on student mental health. In addition, University Counseling Services has made crisis intervention services available to students after hours by calling 804-828-6200.
  • Managers should provide employees (including faculty) regularly with violence prevention resources and training relevant to their department.

Forms

  1. Share a Concern Reporting Form
  2. VCU Helpline

Related Documents

 

  1. Code of Virginia Section 23.1-805 (Violence Prevention Committee; threat assessment team).
  2. VCU’s Space Use Regulation, 8 VAC 90-70-10 et seq. (https://law.lis.virginia.gov/admincodeexpand/title8/agency90/chapter70and in Policy Library)
  3. VCU Policy: Weapons Regulation, 8 VAC 90-61-10 et seq.
  4. VCU Policy: Reservation and Use of Space
  5. VCU Code of Conduct (governing employees)
  6. VCU Policy: Student Code of Conduct Interim
  7. VCU Policy: Title IX Sexual Harrassment – Interim
  8. VCU Policy: Sex-Based Misconduct - Interim
  9. VCU DSA Interim Suspension Procedure
  10. Code of Virginia sections 19.2-389 and 19.2-389.1 Dissemination of Criminal Background Record Information https://law.lis.virginia.gov/vacode/title19.2/chapter23/section19.2-389/
  11. Virginia Health Records Privacy Act, Va. Code section 32.1-127.1:03 https://law.lis.virginia.gov/vacode/title32.1/chapter5/section32.1-127.1:03
  12. Federal Family Educational Rights and Privacy Act (FERPA) https://www2.ed.gov/policy/gen/guid/fpco/ferpa/index.htm
  13. Code of Virginia section 23.1-802: Student Mental Health Policies; website resources; training https://law.lis.virginia.gov/vacode/title23.1/chapter8/section23.1-802/
  14. VCU Policy: Computer and Network Resources Use
  15. VCU Policy: Duty to Report and Protection from Retaliation
  16. VCU Policy: Expectations of Ethical Conduct
  17. DHRM Civility Policy: https://www.dhrm.virginia.gov/docs/default-source/hrpolicy/policy-2-35-civility-in-the-workplace-policyDD440CEC7486.pdf?sfvrsn=0
  18. State Policy 1.60, Standards of Conduct https://hr.dmas.virginia.gov/media/1244/dhrm-policy-160-standards-of-conduct.pdf

Revision History

This policy supersedes the following archived policies:

Approval/Revision Date                                                 Title

            04/06/2004                                                        Threat Assessment and Violence Prevention

            07/18/2012                                                        Threat Assessment and Violence Prevention

FAQ

1. How do I know whether my concern is serious enough to report?

If you are not sure, report it. The university may reconcile information from your report with other information to draw conclusions about the severity of the threat and the need for any intervention.

2. What kinds of behaviors are threatening?

Trust your judgment in reporting information if it concerns you. If someone you know exhibits concerning behavior that is unusual for them, you may want to report that concern. Some types of behavior that are concerning if exhibited by any person include, but are not limited to, the following, and should be reported immediately:

  • Brandishing a weapon or firearm;
  • Possession of a firearm on university property;
  • Intentionally injuring another person physically;
  • Committing injurious or threatening acts related to sexual assault, stalking, dating or domestic violence, or sexual or gender-based harassment;
  • Threatening to injure an individual or to damage property;
  • Defacing or damaging property;
  • Engaging in verbal or physical behavior that creates a reasonable fear of (physical) injury (to an identifiable person);
  • Intentionally engaging in verbal or physical behavior that subjects (any individual) (an identifiable individual) to extreme emotional distress; and
  • Engaging in threatening or violent behavior based on race, ethnicity, gender, sexual orientation, or other protected status.

3. Will I receive an update about a situation after reporting a concern?

As the reporting party, you can expect that someone from the university will contact you to confirm receipt of the report and inquire about any additional information. To protect the safety and privacy of students, employees and others, the university will treat sensitive information confidentially and may not be able to provide you a full report. But as a reporting party, you may serve an important role in the monitoring of the situation because of your interaction with the individual of concern. If you have shared a concern with TAT and continue to be concerned about the situation, please contact the TAT at tat@vcu.edu or VCU Police at (804) 828-1234.  

4. Can I make an anonymous report?

You are encouraged to identify yourself because you can assist if clarification or additional information is needed. If you provide contact information, the university can contact you to let you know we are addressing your concern. Anonymous entries (such as those submitted through the VCU HELPline) will be evaluated based on the information provided.