In 1990, Congress enacted the Crime Awareness and Campus Security Act of 1990 (Title II of Public Law 101-542), which amended the Higher Education Act of 1965 (HEA). This act required all postsecondary institutions participating in HEA’s Title IV student financial assistance programs to disclose campus crime statistics and security information. The act was amended in 1992, 1998, 2000 and 2008.

Under the Clery Act, the on-campus category includes the following: Any building or property owned or controlled by an institution within the same reasonably contiguous geographic area and used by the institution in direct support of, or in a manner related to, the institution’s educational purposes, including residence halls; and Any building or property that is within or reasonably contiguous to the area identified in paragraph (1) of this definition, that is owned by the institution but controlled by another person, is frequently used by students, and supports institutional purposes (such as a food or other retail vendor).

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

Premier Academy of Cosmetology strictly maintains and enforces the safety and security of the campus population. Premier Academy of Cosmetology complies with safety and security guidelines as requested and suggested by the Crime Awareness and Security Act of 1990; The U.S Department of Education; State and Local Laws and local law enforcement agencies; and various publications. Premier Academy of Cosmetology strictly forbids the possession of firearms or other weapons on school property or during school related outings. Premier Academy of Cosmetology has zero tolerance policy regarding immoral conduct and enforces campus safety and security regulations pertaining to verbal, sexual, and physical harassment of a fellow student or staff member as well as threat of physical violence against a fellow student or staff member. 

Director

•  Appoint a Campus Security Awareness(CSA) Coordinator and CSA Team
•  Oversee the CSA Coordinator and Team
•  All incidents are evaluated by School Director and/ or CSA Coordinator
•  Criminal incidents may be turned over to local authorities for further investigations. 
•  Due to the nature of the incident other sanctions may be implemented on the accused or   

                the accuser. 

•  School must distribute by October 1 each year, a security report.
•  The security report will be posted on the class bulletin.
•  Yearly a one (1) hour presentation will be held in the spring to address dating violence,  domestic violence, sexual assault, and stalking.

Campus Security Awareness Coordinator

• Perform yearly trainings for the CSA team’s members on Crime Logs and Emergency Reporting (ER) procedures
• Submit the Crime Logs to School Director and alert Campus Director of all criminal activities. 

The campus crime statistics is updated yearly and is made available to all prospective students, current employees, and current students. Copies of this information are duplicated and may be found available at any time. They are located: 

•  www.premiercosmo.com 
•  Student break area on the bulletin board/student classroom
•  At the Financial Aid Office

Admission Administrator 

•      Alert the prospective student of the report during the enrollment process through the  

                    enrollment packet.

Admission/Financial Administrator

•      Alert current students of the report and it’s components and location on the campus      

                    and the website. 

•      Have students complete an acknowledgment form

Director 

•      Obtain the Crime Logs from the Crime Security Awareness Coordinator no later than    

                    Sept 1 of each year

•      Contact local police department with a formal request via email or postal mail service 

                    requesting a crime report for the geographical location of Premier Academy of     

                    Cosmetology for previous year. 

•      Based on the information retrieved, compile a report with the most 3 completed years 

                    updated.                                                                                   

•      Send notifications to all employees and students of the newly reported report via email 

                    and text messaging 

•      Release the report by Oct. 1 of each year. 

On March 7, 2013, President Obama signed the Violence Against Women Reauthorization Act of 2013 (VAWA) (Pub. Law 113-4). The HEA defines the new crime categories of domestic violence, dating violence, and stalking in accordance with section 40002(a) of the Violence Against Women Act of 1994 as follows: 

“Domestic violence” means a “felony or misdemeanor crime of violence committed by: 

• A current or former spouse or intimate partner of the victim,
• A person with whom the victim shares a child in common,
• A person who is cohabitating with or has cohabitated with the victim as a spouse or intimate partner,
• A person similarly situated to a spouse of the victim under the domestic or family violence laws of the jurisdiction receiving grant monies [under the VAWA], 
• Any other person against an adult or youth victim who is protected from that person’s acts under the domestic or family violence laws of the jurisdiction”

In the event of a crime act of this nature, all information will be held in the strict confidence. Only information pertain to the incident will be disclosed to the personnel or law enforcement on an as needed basis. The victim must sign a FERPA to release information to other parties (family members etc.).

Premier Academy of Cosmetology is committed to providing options, support and assistance to victims/ survivors of sexual assault, domestic violence, dating violence, and stalking

     Responsibilities: 

• In the absence of the Director, individuals should seek out any Premier Academy of Cosmetology staff member. 
•  Premier Academy of Cosmetology encourages all students and employees to be responsible for their own security and the security of others. Please report any known criminal offenses occurring on campus to the school administration.
• In the event a sex offense should occur on campus; the victim should take the following steps:

                     1.  Report the offense to the school administration.

                     2.  Preserve any evidence as may be necessary to the proof of the criminal offense.     

                     3.  Request assistance, if desired, from school administration in reporting the crime to  

                          local law enforcement agencies.

                     4.  Request a change in the academic situation if necessary.

Campus disciplinary action in cases of alleged sexual assault will be based on the findings of the law enforcement agency investigating the facts pertaining to the crime and other mitigating circumstances. 

These records are available upon request through the administrative offices.

Information for crime victims about disciplinary proceedings. The institution will, upon written request, disclose to the alleged victim and the accuser of any crime of violence, or a non-forcible sex offense, (alleged dating violence, domestic violence, sexual assault, or stalking as defined in 34 CFR 668.46(a) the results of any disciplinary proceedings conducted by the institution against a student who is the alleged perpetrator of such crime or offense. If the alleged victim is deceased because of the crime or offense, the information shall be provided, upon request to the next of kin of the alleged victim. This provision applies to any disciplinary proceeding conducted by the institution on or after August 14, 2009.

The institutions will provide a prompt, fair, and impartial disciplinary proceeding in which:

1. officials are appropriately trained conflict of interest or bias for or against the accuser or the accused; 
2. the accuser and the accused have equal opportunities to have others present, including an advisor of their choice; 
3. the accuser and the accused receive simultaneous notification, in writing, of the result of the proceeding and any available appeal procedures; 
4. the proceeding is completed in a reasonably prompt timeframe; 
5. the accuser and accused are given timely notice of meetings at which one or the other or both may be present; and
6. the accuser, the accused, and appropriate officials are given timely access to information that will be used after the fact-finding investigation but during informal and formal disciplinary meetings and hearings.

Responsibilities:

Student

• Formal complaint via writing, video, or verbally
• Accuser will be notified in writing or verbally of alleged crime

School Director 

• Report allegation to official authorities at Premier Academy of Cosmetology and/ or law enforcement (may be optional)
• Premier Academy of Cosmetology and/or Law enforcement conducts a full investigation of allegations along with collection of evidence 
• Possible sanctions during investigation may include suspensions, Leave of Absence, or change in program section until investigation is complete.
• Victim may have the option of utilizing Victim Rights (see rights on Financial Aid website) 
• Based on the findings made by law enforcement or NAME OF INSTITUTION, a written notice will be issued to the accuser and the victim of the outcome.

Campus Security Awareness Team members are defined as an individual or individuals who have responsibility for campus security but who do not constitute a campus police department or campus security department. CSA’s Coordinator and/ or team members are responsible for documenting all crimes on official log and reporting them to the CSA Coordinator. These individuals collect data throughout the year on activities that fall under the VAWA and Campus Crime Reports. They are assigned by the School Director. 

    Policy: See above policy 

    Purpose: To gather data and documentation of crimes.     

    Responsibilities:

• Campus Security Awareness Team

                1.  Collect data yearly via Crime logs

                2.  Submit logs to Director monthly

• School Director

                1.  Reviews the logs 

                2.  Ensures that all incidents have been reported to local officials

                3.  Contacts the local law enforcement by July each year via email for the information for the annual report

                4.  Compile the information for the annual report

                5.  Updates the information 

                6.  Submits by October 1 to Clery department, current students, and employees. 

Premier Academy of Cosmetology will conduct yearly school wide event each Spring that incorporates information on the Sexual Violence and Violence Against Women. It offers resources and information on how to protect and protect others who may be a victim of criminal activity. 

  Responsibilities:

• Financial Aid Administrator

                  1.  Contacts the local battered women’s shelter or qualified counselor to schedule a  

                      presentation to address the students during an assembly. 

                  2.  Place order to any promotional items at least a month in advance, if desired.

                  3.  Ensure that each students and employee signs the sign in sheet. 

• Instructors

                  1.  Prepare lesson plans to incorporate 1 hour for a presentation on Sexual Violence and  

                       Violence Against Women.

• Campus Director

                  1.  Keeps copies of sign in sheets and documents of presentation in Director’s office.

During an emergency evacuation, each instructor is responsible for the safe and orderly evacuation of his/her class. Instructors not in class should assist with any evacuation problems that may arise. It is the instructor’s responsibility to prevent panic, control traffic, and provide calm leadership. The following guidelines should be observed:

Responsibilities: This policy is the primary duty of all employees on staff

• All parties are notified of a Fire Emergency by the building fire alarm/ and or verbal drill.
• All Instructors are to immediately announce verbally and begin vacating from the building.
• All instructors and students are to immediately exit to the nearest and safest exit door.
• Once all persons are exited, everyone should move to the parking lot away from the building.
• Instructors should immediately take role to ensure all students are accounted for using sign-in sheets.
• Once emergency staff gives clearance, all parties will be allowed to exit or enter into the building. 

• All instructors and staff members should move to the middle of building away from all windows. This procedure should be done until all is clear it is safe to either exit the building or return to designated classroom.

Upon signing a Program Participation Agreement (PPA), Premier Academy of Cosmetology agreed to comply with the Family Educational Rights and Privacy Act (FERPA), the U.S. Department of Education’s implementing regulations at 34 C.F. R. Part 99, and the Standards for Safeguarding Customer Information, 16 C.F.R. Part 314, issued by the Federal Trade Commission (FTC), as required by the Gramm-Leach-Biley (GLB) Act, P.L. 106-102. Premier Academy of Cosmetology is responsible for complying the limitations on the disclosure of PII in students’ education records under FERPA and is subject to Sections 501 and 505(b)(2) of the GLB Act.

The GLB Act, also known as the Financial Services Modernization Act of 1999 (Public Law # 106-102, 113 Statute 1338), regulates the collection, disclosure, and protection of consumers’ nonpublic personal information or personally identifiable information (PII) by financial institutions. Section 501 of GLB Act established the following information security standards for financial institutions:

Premier Academy of Cosmetology shall establish appropriated standard for the institution relating to administrative, technical, and physical safeguards:

1. To ensure the security and confidentiality of students and employees records and information
2. To protect against any anticipated threats or hazards to the security or integrity of such records; and
3. To protect against unauthorized access to or use of such records or information which could result in substantial harm or inconvenience to any student or employee.

Program Objectives: 

The objectives of this Information Security Program (“Program”) are as follows: 

1. Insure the security and confidentiality of the institution students and employee’s information. 
2. Protect against any anticipated threats or hazards to the security and/or integrity of the institution’s Student’s and employee’s information.
3. Protect against unauthorized access to or use of the Institution’s students and employee’s information that could result in substantial harm or inconvenience to any customer. 

Purpose:

For purposes of security, “student information” means any information about a student and/or employee, or information the institution receives about the student of another financial institution, that can be directly or indirectly attributed to the student. This Security Program, in and of itself, does not create a contract between the student and any person or entity. 

Responsibilities:

Program Coordinator(s) 

This Program and the safeguards it contemplates shall be implemented and maintained by an employee or employees (“Program Coordinator”) designated by the institution’s Director. The Program Coordinator shall design, implement and maintain new safeguards as he or she determines to be necessary from time to time. The Program Coordinator shall report to the Director and team members who have responsibility for overseeing the Program. The Program Coordinator may delegate or outsource the performance of any function under the Information Security Program as he or she deems necessary from time to time. 

In the event the Program Coordinator leaves the employment of the Institution, the Director, shall take over the responsibilities of the Program Coordinator until a new Program Coordinator is designate. 

Procedures:

1. All records containing customer information shall be stored and maintained in a secure area.

• Paper records shall be stored in a room, cabinet, or other container that is locked when unattended. The Director and Program Coordinator shall control access to such areas. 
• All storage areas shall be protected against destruction or potential damage from physical hazards, like fire or floods. 
•  Electronic customer information shall be stored on secure servers. Access to such information shall be password controlled, and the Program Coordinator shall control access to such servers.
• Student and employee information consisting of financial or other similar information (e.g., social security numbers, etc.) shall not be stored on any computer system with a direct Internet connection. 
• All customer information shall be backed up on a [daily] basis. Such back up data shall be stored in a secure location as determined by the Program Coordinator. 

2. All electronic transmissions of student and employee information, whether inbound or outbound, shall be performed on a secure basis. 

• Social Security, IRS information, or other sensitive financial data transmitted to the Institution directly from students shall use a secure connection, such as a Secure Sockets Layer (SSL) or other currently accepted standard, so that the security of such information is protected in transit. Such secure transmissions shall be automatic. Students shall be advised against transmitting sensitive data, like social security, via electronic mail. 
• The Institution shall require by contract that inbound transmissions of student information delivered to the Institution via other sources be encrypted or otherwise secured. 
• All outbound transmissions of student information shall be secured in a manner acceptable to the Program Coordinator. 
• To the extent sensitive data must be transmitted to the Institution by electronic mail, such transmissions shall be password controlled or otherwise protected from theft or unauthorized access at the discretion of the Program Coordinator. 
• The Program Coordinator and third party service shall review all students’ applications to ensure an appropriate level of security both within the Institution and with the Institution’s business third party server and IRS. 

3. All paper transmissions of customer information by the Institution shall be performed on a secure basis. 

• Sensitive student information shall be properly secured at all times.
• Student information delivered by the Institution to third parties shall be kept sealed at all times.  Paper-based student information shall not be left unattended at any time it is in an unsecured area. 

4. All student information shall be disposed of in a secure manner. 

• The Program Coordinator shall supervise the disposal of all records containing student information.
• Paper based student information shall be shredded and stored in a secure area until a disposal or recycling service picks it up.
• All hard drives, diskette, magnetic tapes, or any other electronic media containing student information shall be erased and/or destroyed prior to disposing of computers or other hardware. 
• All hardware shall be effectively destroyed. 
• All student information shall be disposed of in a secure manner after any applicable retention period. 

5. The Program Coordinator shall maintain an inventory of Institution computers, including any handheld devices or PDAs, on or through which student information may be stored, accessed or transmitted. 

6. The Program Coordinator shall develop and maintain appropriate oversight or audit procedures to detect the improper disclosure or theft of student information. 

Information Security Policies and Procedures: 

Detecting, Preventing and Responding to Attacks, Intrusions or Other Systems Failures In keeping with the objectives of the Program, the Institution shall implement, maintain and enforce the following attack and intrusion safeguards: 

• AVG Anti-Virus 
• ONLINE SMART (Compiled Net Code and anti SQL Injection Technology-Encrypted with SSL encryption on DELL Server)
• Carbonite Back-up 
• FAS-utilizes Financial Aid Services school interface that is encrypted. The school must be secured with a unique logon ID and password for access to systems. 

1. The Program Coordinator shall ensure the Institution has adequate procedures to address any breaches of the Institution’s information safeguards that would materially impact the confidentiality and security of customer information. The procedures shall address the appropriate response to specific types of breaches, including hackers, general security compromises, denial of access to databases and computer systems, etc.
2. The Program Coordinator shall utilize and maintain a working knowledge of widely available technology for the protection of student information. 
3. The Program Coordinator shall communicate with the Institution’s computer vendors from time to time to ensure that the Institution has installed the most recent patches that resolve software vulnerabilities. 
4. The Institution shall utilize anti-virus software that updates automatically.
5. The Institution shall maintain up-to-date firewalls. 
6. The Program Coordinator shall manage the Institution’s information security tools for employees and pass along updates about any security risks or breaches. 
7. The Program Coordinator shall establish procedures to preserve the security, confidentiality and integrity of student information in the event of a computer or other technological failure.
8. The Program Coordinator shall ensure that access to student information is granted only to legitimate and valid users.
9. The Program Coordinator shall notify students promptly if their student information is subject to loss, damage or unauthorized access.