ANNUAL SECURITY REPORT 2015 EMERGENCY CONTACT INFORMATION AND RE SOURCES Emergency Contact Information • Police (Policia Nacional), Fire, and Emergency Medical Services (Servicios de Emergencias Medicas): Dial 112 • Berklee Valencia Program Front Desk: +34 963 332 802 (Ext. 3400 from on-campus phones) • Berklee Public Safety Department (Boston campus): 617 747-2333 • Medical Assistance: +34 681 137 915 • Berklee Valencia Security Control Center: +34 961 975 817
Other College Resources • General Information: [email protected] • Office of Graduate Admissions: [email protected] • Summer Programs: [email protected] • Study Abroad Program: [email protected] • International Career Center: [email protected] • Office of the Registrar: [email protected] • Office of the Bursar: [email protected] • Marketing Department: [email protected] • Communications Department: [email protected] • IT Support: [email protected] • Operations: [email protected] • Library: [email protected] • Berklee Valencia Employment Opportunities: [email protected]
Health Resources 1 • Hospital Nisa 9 de Octubre; Valle de la Ballestera 59, 46015 Valencia; +34 963 179 100 • Doctor Moliner Hospital; Porta Coeli, 46117 Serra; +34 961 687 900 • Doctor Peset University Hospital; Avenida Gaspar Aguilar 90, 46017 Valencia; +34 961 622 300 • Casa de Salud Hospital; Avenida Manuel Candela 41, 46021 Valencia; +34 963 897 700 • Biological and Immunological Medicine Clinic; Calle San Valeriano 27 Torrent, 46900 Valencia; +34 961 564 929 • Hospital de Sagunto; Avenida Ramon y Cajal s/n Sagunto, 46520 Valencia; +34 962 659 400 • Hospital de la Ribera; Crta Corbera km 1 Alzira 46600, Valencia; +34 962 458 100 • La Fe Hospital; Avenida de Fernando Abril Martorell 106, 46026 Valencia; +34 961 244 000 • Hospital Nisa Valencia al Mar; Rio Tajo, 1 46011 Valencia; +34 963 352 500 • Quiron; Avenida Blasco Ibanez 14, 46010 Valencia, +34 963 390 400 • Hospital Nisa Virgen del Consuelo; Callosa d’en Sarria 12, 46007 Valencia; +34 963 177 800 • Hospital Aguas Vivas; Ctra Alzira Tavernes CV-50 km 11 Carcaixent, 46740 Valencia; +34 962 588 800
1 Berklee does not endorse or otherwise recommend any of these medical facilities listed. Rather, Berklee simply intends to consolidate publicly available information for students to review and consider while studying in Valencia. A MESSAGE FROM THE SENIOR DIRECTOR OF PUBLIC SAFETY As the Senior Director of Public Safety, I am responsible for the leadership, management, planning, organization, and administration of the Berklee Public Safety Department (“BPS” or the “Department”). In addition to coordinating safety and security services provided to the Berklee (or the “college”) community, I am the college’s liaison with local, state, and federal law enforcement and safety agencies. It is also my responsibility to see that the college’s students, faculty, staff, and visitors recognize that the Department is a resource that is available to all members of the Berklee community. The federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (the “Clery Act”), 20 U.S.C. § 1092, requires that certain colleges and universities publish an annual report concerning various campus safety-related policies and procedures. As the senior director of Public Safety, it is my responsibility to oversee preparation and publication of this report by the Operations Department at the Valencia campus. The Department assembles statistics for this report based on its own records, communications with the Palau de les Arts Security Department, the Student Affairs Office, local law enforcement, and information derived from other various campus security authorities at the Valencia campus. These communications are directed at acquiring information necessary to the college’s effort to disclose annual crime statistics to the Berklee community concerning our Valencia location. Following is Berklee Valencia’s 2014 Annual Security Report. Paper copies of this report are available upon request, and the report is available online at berklee.edu/sites/ default/files/ValenciaASR.pdf. An email notification is sent to all active Valencia students, faculty, and staff that provide a direct web link to this report. Requests for paper copies of the report may be submitted via email to [email protected], or made in person at the Palau de les Arts Reina Sofia–Anexo Sur, Avenida Profesor Lopez Pinero, 1, 46013 Valencia, Spain. Prospective employees and students may similarly obtain copies of the report through direct requests to the Public Safety Department. As it is with your experience at our Boston campus, your safety and well-being are important features of your overseas experiences in Valencia, and your welfare while abroad is every bit as important to the college as it is when you are in Boston. Please review the safety-related information and statistics in this report, and please remember that while you study in Spain, you are subject to Spanish laws. On behalf of Berklee, I thank you for choosing to study and work at the Valencia campus, and I encourage you to call upon the Public Safety Department or those at the Valencia campus whenever necessary. Berklee is committed to the goal of providing a safe campus environment for its students, faculty, staff, and visitors; however, each of us must also take personal responsibility for our own safety, as well as the safety of those around us. And please remember one fundamental rule of crime prevention: If you see something, say something. Best wishes for a healthy and successful year at Berklee’s Valencia campus.
Roy J. Murphy, CPP Chief of Police TABLE OF CONTENTS Notice of Non-Discrimination 4 Description of the Safety Department 4 Description of the Operations Department 4 Law Enforcement Authority and Interagency Relationships 4 Reporting Crimes and Other Emergencies 5 Access and Securities of Campus Facilities/Monitoring Criminal Activity 5 Maintenance of Campus Facilities 6 Daily Crime Incident Log 6 Campus Security Authorities 6 Security Awareness and Crime Prevention 7 General Safety Tips 8 Timely Warnings and Emergency Notifications 10 Evacuation Procedures and Drills 12 Drug and Alcohol Policies 13 Substance Abuse Resources 14 Sexual Misconduct 14 Sexual Assault Education Programs and Resources 19 Clery Act Geography Definitions 20 Clery Act Crime Definitions 21 Crime Statistics 24
3 NOTICE OF NON-DISCRIMINATION Berklee does not discriminate on the basis of race, color, religion, gender, gender identity, transgendered status, national origin, age, disability, military or veteran status, sexual orientation, genetic information, marital status, pregnancy, or any other characteristic protected by applicable law in employment or admission to and participation in any of its programs and activities. Nor does Berklee tolerate retaliation in any form in response to initiating a complaint or participating as a wit - ness in an investigation of alleged discrimination or harassment. Any inquiries or grievances may be directed to the Title IX Coordinator for the college, Toni Blackwell, the Vice President for Student Affairs/Dean of Students, and/or the Director of Employee Relations and Staffing in Human Resources, Berklee, 1140 Boylston Street, Boston, Massachusetts 02215, 617 747-2232.
BERKLEE PUBLIC SAFETY DEPARTMENT BPS is responsible for campus safety, security, law enforcement, and emergency response on the Boston campus. It is the Department’s mission to provide a complement of services designed to enhance campus security and safety so that Berklee remains an enriching environment in which it is safe to live, study, and work. BPS shift commanders and command personnel administer day-to-day operations of the Department. Although located in Boston, BPS works closely with the Valencia campus to assist in enhancing safety and improving quality of life.
DESCRIPTION OF THE OPERATIONS DEPARTMENT In coordination with Berklee’s Public Safety Department in Boston, the Operations Department (“OD”) in Valencia is responsible for campus safety, security, and emergency response at that location. It is the OD’s mission to provide a complement of services and programs to help facilitate safety and an enriching work, study, and living experience. Due to the Valencia campus location and the unique demands of the program, the OD is comprised of Berklee staff supplemented by the contract security com pany, contract security officers who patrol the Valencia campus 24 hours a day, 7 days a week while the program is in session. The Senior Director of Operations is the senior command level officer within the OD and reports to the college’s chief financial officer/senior vice president of Administration and Finance.
LAW ENFORCEMENT AUTHORITY AND INTERAGENCY RELATIONSHIPS The contract security company has limited law enforcement rights provided under the Spanish Law of Private Security (Ley de 23/1992 de Seguridad Privada). The contract security company and Berklee main tain cooperative working relationships with La Policia Nacional Espana (the Spanish National Police), La Comisaria de Policia de Valencia (the Valen cia local municipal police), local consulates, and relevant elements of the Spanish criminal justice sys tem. In the event of an incident requiring joint investigative efforts, resources, crime-related reports, and exchanges of infor mation, contract security company and the OD work as closely as possible with investigators 4 from the appropriate local law enforcement agency. REPORTING CRIMES AND OTHER EMERGENCIES The Berklee community, whether in Boston or Valencia, needs your help in address ing crime on and near the various campuses. If you witness a crime, immediately go to a safe place and call the law enforcement agency for the jurisdiction in which you are located. Stay on the line, and tell the dispatcher everything you can remember about the suspect (his/her clothing and appearance, vehicle, direction of travel, and anything else that may be helpful to law enforcement in their effort to apprehend the suspect). Berklee students, faculty, staff, and guests are encouraged to promptly and accurately report all crimes and public safety-related incidents La Comisaria de Policia de Valencia or La Policia Nacional. To report a crime, emergency, or suspicious activity, the community should call 112 by phone. Alternately, the contract security company can be reached at + 34 961 975 817. A report may also be made directly in person to front desk personnel at the Valencia campus, Students Affairs personnel, the Human Resources manager, or the senior director of the Operations Department, who may investigate. Some reports are forwarded to the appropriate office at Berklee for review and potential action. Where a matter necessitates the assistance of law enforcement, the OD will assist the reporting party in securing the appropriate law enforcement resources. Berklee also uses a service called EthicsPoint to allow the community to report crimes anonymously and confidentially. Even if a victim or witness does not wish to be involved in the investigation of an incident, crimes should be reported to the Berklee Operations Department should a timely warning or emergency notification (discussed below) be required, and for inclusion in the college’s required annual statistical disclosures. This service can be used either online through berklee.edu or by calling 888 286-5092.
ACCESS AND SECURITY OF CAMPUS FACILITIES AND MONITORING OF CRIMINAL ACTIVITY The Valencia campus is contained within the Palau de les Arts building, but does not contain any on-campus residential facilities. The area is openly accessible to mem bers of the campus community, guests, and visitors during normal hours of business, and during designated hours on weekends and holidays. The building is staffed 24 hours a day, seven days a week by the contract security company. The contract security company presence provides both reactive services and proactive deterrence. The contract security company performs both routine and directed patrols, inspecting doors to campus facilities for actual and potential security breaches. This process involves testing of alarms and automatic closing and locking units. Access to some buildings is controlled by electronic card readers and readily accessible by those with activated Berklee college identifications. Closed-circuit cameras continually monitor many areas of the campus, including interior and exterior locations twenty-four hours per day, seven days per week. Berklee’s Valencia campus does not have any student organizations that have off- campus housing facilities. Incidents reported to the Operations Department that fall into one of the Clery-reportable crime categories (discussed below) will be disclosed in the statistical portion of this report. 5 MAINTENANCE OF CAMPUS FACILITIES Berklee Valencia maintains a strong commitment to safety and security on its campus. Common areas, pedestrian walkways, and building exteriors are well lit to reduce the likelihood of criminal activity and enhance safety. Berklee Valencia’s contract maintenance company routinely conducts inspections and surveys of exterior lighting and other maintenance issues on campus to identify and correct problems, and it gives priority to security-related concerns. Members of the Berklee Valencia campus community are encouraged to report any maintenance concerns to the contract security company or to the front desk (ext. 3400).
DAILY CRIME INCIDENT LOG The Operations Department prepares and maintains a daily incident log of all crimes reported to the Department. The log contains the information entered by call takers following receipt of a call for service, including the location of the incident reported, the resulting action(s) by OD and/or the contract security company, a brief descrip tion of the incident reported, and the disposition of the report to the extent it can be ascertained. This annual security report contains statistics concerning Clery Act crimes only and does not contain statistics concerning all incidents reported to Berklee Valencia. The crime log, however, captures all incidents reported, both on and off campus. The daily log is updated each business day with information concerning reports made the prior day. Reports received on weekends and college holidays are recorded in the log on the next business day.
CAMPUS SECURITY AUTHORITIES Federal law requires the college to disclose statistics concerning the occurrence of certain crimes enumerated in the Clery Act that occur within the college’s Clery geography and that are reported to college campus security authorities (“CSAs”). 2 Under the law, CSAs include any member of the Berklee Public Safety Department; any individual who has responsibility for campus security, but who is not a member of BPS (e.g., contract security officers); any individual identified by the college as someone to whom a crime should be reported; and any college official who has significant responsibility for student and campus activities.
Examples of the college’s CSAs include, but are not limited to, the following:
• Berklee Public Safety Department • Contract security staff (e.g. the contract security company) • Dean of Students • Residence Directors • Resident Assistants
6 2 Definitions of Clery Act crimes and geographical locations are included later in this report. A CSA is not required to disclose to the Department confidential information concerning an incident, such as information that would identify a victim of a crime who wishes for his or her identity to remain confidential. However, CSAs are required to inform the Department of the existence of all known incidents, including confidential incidents, so that those incidents can be recorded as statistics, and, where appropriate, disclosed in the college’s annual security report. If a reporting party does not consent to the disclosure of his or her identity to the Department, CSAs are expected to inform the Department of the reporting party’s wish for confidentiality and to report the incident for statistical purposes only without disclosing identifying information. Berklee will maintain confidentiality under this framework to the extent permissible under law and consistent with the college’s obligation to investigate allegations and provide accommodations. Professional and pastoral counselors acting in those roles are not campus security authorities, and the law specifically exempts them from the responsibility to report to BPS crimes disclosed to them. The professional counselors in the Students Affairs Office do not have a confidential reporting procedure, but may notify their clients of the Operations Department anonymous and confidential reporting procedures when they deem it appropriate. The college urges all community members who are not CSAs to consider report ing any criminal incident to BPS or law enforcement for the geographical jurisdiction in which an incident occurs, particularly where a victim is unable to do so themselves. In the event an individual chooses not to report to BPS, the college urges the person to at least disclose the occurrence of the incident to a campus security authority so it may be counted, as appropriate, in the college’s annual security report. Given the distance between the Valencia and Boston campuses, it is particularly important that crimes be reported, even anonymously, to campus security authorities. If you have a question about who may be a CSA, please call BPS or speak with an administrator at the Valencia campus.
SECURITY AWARENESS AND CRIME PREVENTION The Operations Department’s goal is to eliminate or minimize opportunities for crime on campus, and to create an atmosphere in which community members become more responsible for their own safety and security. Below is a list of programs, services, committees, and technologies designed to raise awareness of crime, enhance prevention efforts, and improve quality of life for community mem bers.
New Student Orientation New student orientation presents an ideal opportunity to both educate captive audiences about the realities of studying in Spain, and to prepare newcomers for the awareness and mindset that contributes to enhancement of personal safety. Presentations are provided to students to inform them of the services provided by the Valencia Campus as well as some general safety tips they should follow.
Closed-Circuit Television Surveillance Closed-circuit cameras located throughout campus are monitored by the contract security company 24 hours a day, 7 days a week, 365 days a year. These cameras are designed to give heightened visibility to the contract security company and OD, both for proactive prevention and quickened emergency response. 7 Rape and Sexual Assault Prevention Committee The objective of the Rape and Sexual Assault Prevention Committee is to review ongoing efforts to promote sexual assault awareness, education, and prevention, and to improve the quality of services offered and delivered to the community related to these topics.
Rape and Sexual Assault Prevention Booklet Berklee’s Public Safety Department in Boston has created a publication titled Rape and Sexual Assault: A Guide to Prevention, Reporting, and Changing the Culture on Campus. Contact the Operations Department to request a copy or view it online at berklee.edu/public-safety/rape-sexual-assault-prevention-booklet.
GENERAL SAFETY TIPS Crime can be perpetrated anywhere at any time. The cooperation and involvement of students, faculty, and staff in working to enhance their own personal safety and security is crucial to maintaining a safe campus environment. Although no one set of guidelines can completely protect you, following the tips below may help to reduce exposure to victimization.
Apartment Security • Never prop a door open. Doing so could allow an unauthorized person to enter a building, thus endangering the well-being of those inside.
• Always lock your room, regardless of how long you may be gone. Never leave money, jewelry, or other valuables out in the open, even if you are present.
• Get to know others around you, and watch out for each other. Report any suspicious persons to the front desk or the Operations Department.
• Do not leave notes stating that you are gone or for how long you will be gone, where anyone will be able to view those notes.
• Close your drapes and blinds at night.
• Always ask who is at the door before you open it.
• Notify the front desk or the Operations Department if there are maintenance or lighting deficiencies, particularly where they may compromise security.
While You are Out and About • Communicate nonverbal cues (body language) that you are calm, confident, and aware.
• Stay in well-lit, busy areas.
• When using public transportation, use a busy, well-lit bus stop, sit near the driver, and do not sleep. 8 • If someone is harassing you, get help immediately, and if necessary, instruct the harasser to leave you alone using a firm, loud voice.
• Trust your instincts. If something or someone makes you uneasy, take steps to remove yourself from the situation.
• Walk or jog with a companion.
• Keep your car locked at all times.
• Avoid displaying cash or valuables.
• Have your keys in your hand as you approach your car, dorm, apartment, or office so you may gain access to those areas quickly if necessary.
Online Social Networking The internet has created an entirely new social arena and exposed a new world of communication, resources, and information. While social networking sites allow us to communicate with others in efficient and interesting ways, a new way, communications via social networks are not without their risks. For example, web-based social interaction has resulted in the removal of a social barrier—in person interaction. It can be easy to let down one’s guard when those barriers are removed, particularly where the internet is concerned.
Internet safety relies upon similar common sense to what we use to stay safe on the streets. Following is a non-exhaustive list of suggested internet safety tips.
• Use common sense and limit what you disclose. Remember, you may not know who is on the other side of a communication.
• Never share a full name, social security number, phone number, address, or credit card or bank account numbers.
• Consider the nature of the information you share with anyone, even with persons known to you. Will you be comfortable with family members, future employers, or school admissions officials seeing the information and photos you are sharing or posting? Information posted online should be considered permanent.
• Carefully consider your screen name, and consider avoiding selecting screen names that may identify you.
• Consider the actual and potential impact of posting photos or videos of yourself, family, or friends.
• Do not accept files or downloads from people you do not know.
9 • Be wary of online friends who want to meet in person, particularly where you have never before met the person.
• Limit your online friends to people you actually know.
• Consider password-protecting or limiting access to your social networking page or account.
• Before participating in social networking, review the safety and privacy policies.
• Report any problems to the webmaster, moderator, or, if needed, local police.
TIMELY WARNINGS AND EMERGENCY NOTIFICA TIONS The Clery Act requires colleges and universities to issue “timely warnings” to the campus community regarding any Clery Act crime that is reported to campus security authorities (or to local law enforcement where local law enforcement informs the college of the incident); occurs within the college’s Clery geography and patrol area; and is deemed to represent a serious or continuing threat to the college community. The Clery Act also requires colleges and universities to issue an “emergency notification” to the campus community upon confirmation of a significant emergency or dangerous situation occurring on campus and involving an immediate threat to the health or safety of employees or students. “Timely warnings” and “emergency notifications” are each discussed separately below.
Timely Warnings The Operations Department and Students Affairs issue timely warnings concerning serious crimes that occur on or near campus, which pose an immediate, continuing, and ongoing threat to the safety of the campus community. The decision to issue a timely warning is made on a case-by-case basis in light of all known circumstances surrounding a crime, including factors such as the nature of the crime reported, whether there exists a continuing danger to the campus community, and the possible risk of compromising law enforcement efforts. 3 The process the college will follow when issuing or determining whether to issue a timely warning is simple and designed to expedite decision making about personal safety and notification to the community. All crime should be reported directly to the Operations Department, particularly where an incident may involve the need for issuance of a timely warning. All reports of crimes to the Department may be made on a confidential, anonymous basis. Upon receiving a report that may result in the issuance of a timely warning, OD command staff will analyze the incident and consult, when necessary, with other departments (e.g., Student Affairs, the college’s Title IX coordinator, etc.). This consultation is typically conducted in person, via telephone, email, or text messag - ing and is undertaken for the purpose of discussing relevant facts, the level of threat to the community, whether a timely warning will be issued, and the content of any timely warning notice. When a timely warning is issued, Berklee Valencia will deploy resources consistent with the table below and will withhold the names of victims to preserve confidentiality.
3 A “timely warning” or “emergency alert” may not be issued if the subject(s) is apprehended and the threat of imminent danger to the community has been mitigated, or if a report was not filed with the college, or the college is not notified in a 10 manner that would allow the issuance of a “timely” warning to the community. This type of situation will be evaluated on a case-by-case basis. Emergency Notifications The Operations Department and the contract security company receive information from offices and departments on campus, local municipal law enforcement, email, and/or text messages, and other media sources. If the OD or contract security company confirms, based on information received from these sources, or any oth ers, that there is an emergency or dangerous situation that poses an immediate threat to the health or safety of the Berklee Valencia Campus community, the college will, through the contract security company, without delay and taking into account the safety of the community, determine the content of an emergency notification and activate some or all of the systems described below to communicate an appropriate warning (i.e., an emergency notification), unless issuing a notification will, in the professional judgment of responsible authorities, compromise efforts to assist a victim or to contain, respond to, or otherwise mitigate an emergency. contract security company will also notify the Berklee Public Safety Department on the Boston campus.
In determining an appropriate communication, the college will take into account several factors, including, but not limited to, the building or segment of the population threatened, the nature of the threat, and the credibility of the information received. The message will contain information regarding the event, as well as instructions as to what steps to take to enhance safety. The system will send notifications to the affected population in the form of: email, voice message, text message, and social media. The information will also be posted by the Communications Department on a publicly available webpage on berklee.edu/alerts, which is accessible to the larger community. The system is tested on an annual basis to ensure proper functionality. Follow up messages are sent to the Berklee community using some or all of the above listed communication systems when follow up instructions are required and/or emergency conditions have abated. When an emergency notification is issued, Berklee will deploy resources consistent with the table below and will withhold the names of victims to preserve confidentiality.
Method Authority Primary Backup for Approving Message Message Creating, and Sending Sender Sender Primary Email Sr. Director Sr. Director Student Affairs of Operations of Operations Manager/HR Manager Fliers Sr. Director Sr. Director Student Affairs of Operations of Operations Manager/HR Manager Secondary Social Media Sr. Director Sr. Director Student Affairs of Operations of Operations Manager/HR Manager SMS/Text Sr. Director Sr. Director Student Affairs of Operations of Operations Manager/HR Manager Voice Message Sr. Director Sr. Director Student Affairs of Operations of Operations Manager/HR Manager
11 Timely warnings and emergency notifications may be distributed to the campus community using some or all of the following methods of communication:
• Email Blast: An email to staff, faculty, and all currently registered students with information concerning the time/location/nature of threat, relevant details, including suspect description, and tips on how to stay safe (collectively, “pertinent information”).
• Fliers: Fliers posted on the front of all academic buildings and residence halls affected by the incident(s) containing pertinent information.
• Social Media: Various social media outlets either directly or indirectly to disseminate pertinent information.
• SMS/Text Message: Text messages with pertinent information to community members whose phone numbers are registered in the emergency contact database.
• Voice Message: Voicemail messages with pertinent information to community members whose phone numbers are registered in the emergency contact database.
An alert may not be issued if:
• The subject(s) have been apprehended and/or the threat of imminent danger to community has been mitigated.
• A report was not filed with the Operations Department or the Operations Department was not notified in a manner that would allow the department to post a “timely” warning to the community. This type of situation is evaluated on a case-by-case basis.
EVACUATION PROCEDURES AND DRILLS An unannounced emergency evacuation drill is coordinated by the Operations Department at least once per calendar year at the Valencia campus. The purpose of the evacuation drill is to prepare building occupants for an organized evacuation. In addition to educating the occupants of each building, the process also provides the college an opportunity to evaluate the efficiency of the emergency evacuation plan 4 and to test the operation of fire alarm system components. Occupants are encouraged to report any deficiencies or provide any suggestions to the Operations Department.
12 4 A specific emergency evacuation plan for the building provides the proper policies, procedures, and guidelines for occupants to follow during an evacuation. DRUG AND ALCOHOL POLICIES Berklee is committed to providing a safe, productive, and healthy environment in which all members of the Berklee community can learn, work, and grow from a wealth of varying experiences. The college is determined to establish and maintain working, living, and learning conditions that are free from the negative effects of alcohol and other drug (“AOD”) abuse. With this goal in mind, the college encourages responsible decision-making regarding the use of legal drugs (alcohol, tobacco, pharmaceuticals, etc.). Berklee college and the members of its community are responsible for observing and complying with all laws together with all college policies concerning the use of AOD. These policies apply to conduct on the Berklee Valencia campus as well as at any college-related activities, regardless of whether such conduct occurs on or off campus. Berklee’s Valencia campus enforces all local and national laws on alcohol and drugs, including prohibitions against possession, use, and sale. Berklee’s Valencia campus also has its own drug and alcohol policies. The following acts are prohibited on college premises or at Berklee-sponsored activities and events:
• Sale, possession, or use of any illegal drug and/or the use, possession, or distribution of any controlled substance without legal authorization
• Sale, possession, or use of alcoholic beverages in violation of underage drinking laws
• Providing alcoholic beverages to individuals under 18 years of age
• Possession of alcoholic beverages by individuals under18 years of age
• Illegal possession of an open container of an alcoholic beverage
• Public intoxication
• Driving while under the influence of alcoholic beverages
• Drinking alcoholic beverages in an unlicensed public place
Sanctions for violation of the policy may include, but are not necessarily limited to, probation, suspension, dismissal from the program or the college, and referral for prosecution. The Policy Handbook for Students lists details of felony and misde - meanor crimes and subsequent disciplinary actions for students. college staff mem - bers may be disciplined under the human resources progressive discipline process initiated by their department heads. Faculty members may be disciplined by their re - spective department. Faculty and staff members are not excluded from prosecution under the law merely by virtue of their employment. 5
5 A copy of the Berklee Alcohol and Other Drug Policy is available at berklee.edu/sites/default/files/PolicyHandbookforStudents_ 13 2014_2015.pdf. Human Resources’ policy concerning AOD is available at berklee.edu/human-resources-policy-manual. SUBSTANCE ABUSE RESOURCES Berklee recognizes that the misuse and abuse of alcohol and drugs can be detrimental to the health, safety, learning, and well-being of individuals, as well as to the Berklee community. Therefore, the college offers substance abuse prevention programming for its community members and will identify other resources and provide assistance for students, faculty, and staff who have or develop problems with alcohol or other drugs (“AOD”).
Counseling and Advising Center In addition to the above programs and trainings, the Counseling and Advising Center (“CAC”) provides assessment and referral services to students. For more information about any educational materials and programs contact the CAC at 617 747-2321 or berklee.edu/counseling-and-advising-center. In compliance with the Drug Free Schools and Communities Act, Berklee’s drug and alcohol policies can be found in the “Policy Handbook for Students,” which can be accessed at berklee.edu/policy-handbook-students.
SEXUAL MISCONDUCT As a general matter, it is the policy of Berklee to maintain a working and learning environment that is safe, respectful, productive, and free from unlawful discrimination and/or harassment based on race, color, religion, gender, gender identity, transgendered status, national origin, age, disability, military or veteran status, sexual orientation, genetic information, marital status, pregnancy, or any other characteristic protected by applicable law. All such harassment or discrimina tion is strictly prohibited on the college campuses and at all college sponsored functions, events, and activities, regardless of location. Berklee, its faculty, staff, students, customers, and suppliers will be held responsible for acts of discrimination and harassment and are subject to appropriate disciplinary and/or remedial action. Berklee expects that all members of the college community should be able to pursue their work and education in a safe environment, free from sexual harass ment, gender-based violence, coercion, violence, and sexual intimidation. The college is committed to fostering a safe campus environment where sexual misconduct and violence are not tolerated, and where those who believe they were harmed by another in violation of this policy are provided support and avenues of redress as appropriate. All members of the college community are expected to conduct themselves in a manner that does not infringe upon the rights of others. This sexual misconduct policy statement reaffirms these principles and provides an overview of the recourse available for individuals whose rights have been violated. In order to fulfill its responsibilities under the Violence Against Women Reauthorization Act of 2013 (“VAWA”), the college has revised its sexual miscon duct policy and provided clarification of the spectrum of behaviors included in sexual misconduct, sexual harassment, sexual assault, and stalking. This revised policy prohibits sexual misconduct of all types, including, but not limited to, groping, fondling, sexual contact, sexual assault, domestic violence, dating violence, and stalking.
14 Sexual Harassment Sexual harassment is a form of sexual discrimination that violates federal and state laws, as well as college policy. Sexual harassment, whether between people of different sexes or of the same sex, is defined to include, but is not limited to, unwanted sexual advances, unwelcome requests for sexual favors, and other behaviors of a sexual nature when:
1. Submission to such conduct is made either explicitly or implicitly a term and condition of an individual’s academic or employment status; 2. Submission to, or rejection of, such conduct by an individual is used as a basis for employment or academic decisions affecting him or her; or 3. Such conduct, whether verbal or physical, has the purpose or effect of unreasonably interfering with the individual’s academic or work performance, or of creating an intimidating, hostile, or offensive environment in which to work or learn.
Sexual Violence Sexual violence is a broad term that encompasses sexual assault, sexual violence, rape, dating violence, domestic violence, and stalking. Sexual violence also includes any conduct of a sexual nature that is nonconsensual, or has the purpose or effect of threatening, intimidating, or coercing an individual. When there is no consent to sexual activity, or it is unclear whether consent has been given, the activity may constitute a form of sexual misconduct. Sexual misconduct can involve persons of the same or opposite sexes. Sexual assault is a form of sexual discrimination and encompasses behaviors ranging from unwanted touching to rape. Sexual assault is broadly defined as any type of sexual contact or behavior that occurs without the explicit consent of the recipient—whether a “hook-up” partner, friend, acquaintance, or stranger initiates the contact or behavior. Falling under the definition of sexual assault are sexual activities such as forced sexual intercourse, forcible sodomy, child molestation, incest, fondling, and attempted rape.
Dating Violence Under federal law, dating violence is any act of violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the victim. The existence of such a relationship shall be determined based on the victim’s statement and with consideration of the type and length of the relationship and the frequency of interaction between the persons involved in the relationship. Two people may be in a romantic or intimate relationship, regardless of whether the relationship is sexual in nature; however, neither a casual acquaintance nor ordinary socializing between two individuals in a business or social context shall constitute a romantic or intimate relationship. This definition does not include acts covered under domestic violence.
15 Domestic Violence Under federal law, domestic violence is a felony or misdemeanor crime of violence committed by the victim’s current or former spouse or intimate partner, 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 or a person similarly situated under domestic or family violence law, or anyone else protected under domestic or family violence law. 6
Stalking Under federal law, stalking is a course of conduct directed at a specific person that would cause a reasonable person to fear for her, his, or others’ safety, or to suffer substantial emotional distress.
Consent Consent is giving explicit permission to engage in specific sexual contact. It can only be given when partners have equal power in determining the level of sexual activity that will or will not occur. Consent is an active and on-going choice to knowingly, and without pressure, engage in a sexual encounter. Consent is not giving in because of fear, or due to pressure, manipulation, deception, or lying. Silence, previous sexual relationships, current relationships, or the use of alcohol and/or drugs is not an indication of consent. Consent can never be given if a person is intoxicated, drugged, asleep, unconscious, incapacitated, impaired because of a physical or mental condition, or underage (under 16). Consent may be initially given, but it may be revoked at any point, either verbally, through physical resist ance, or by losing consciousness. Failure to cease sexual contact promptly in response to a withdrawal of consent constitutes prohibited nonconsensual sexual contact. “No” or any other negative statement or acts/physical gestures suggesting the desire to cease contact in response to sexual contact or an invitation to sexual contact will be regarded as a denial of consent to such sexual contact. 7
Procedures to Follow if an Offense Occurs It is essential that evidence of a sexual assault be preserved for proof of a criminal offense regardless of whether a survivor wishes to pursue criminal charges. Hospital emergency room personnel are trained in obtaining and securing evidence of a sexual assault during a medical evaluation, and the survivor is under no obligation to report the crime to the authorities. The college will facilitate transportation to a medical center if a survivor wishes to obtain medical care following an assault.
6 Spanish domestic violence laws are available at: • hsph.harvard.edu/population/domesticviolence/spain.dv.03.htm • hsph.harvard.edu/population/domesticviolence/spain.dv.03(2).htm; • hsph.harvard.edu/population/domesticviolence/spain.dv.99.htm; • hsph.harvard.edu/population/domesticviolence/spain.domesticviolence.08.pdf.
7 Under Spanish law, “Any unauthorized sexual contact is criminally punishable per Spanish law. The law defines various sexual crimes and sentencing varies by crime. For example, sexual abuse is subject to lower sentencing while rape may be 16 subject to the highest possible sentence. Acquaintance or date rape is considered as serious as any other type of sexual assault.” See photos.state.gov/libraries/spain/164311/citizen-services/SpainVictimAssistanceHandout0412.pdf. Reporting and Prosecution If a survivor chooses to move forward with criminal prosecution, the appropriate law enforcement agency to notify will depend upon where the incident occurred; however, survivors are encouraged to call 112 for emergency police assistance. In addition to pursuing a matter through law enforcement, if the accused is a Berklee student or employee, survivors may file a complaint through the college by contacting either the Dean of Students or the college’s Title IX Coordinator for the Valencia campus.
The college’s Policy Handbook for Students, including a description of the grievance procedures, can be found at berklee.edu/policy-handbook-students. Employ ees can access the college’s Harassment Policy through the Human Resources area: berklee.edu/human-resources (password required). Prospective employees should contact the Human Resources Department at 617 747-2375 to request a copy of the policy.
College Disciplinary Process To enable the college to respond to all reports in a prompt, thorough, and equitable manner, the college encourages all individuals to report any incident of sexual misconduct to either or both the Title IX Coordinator (Toni Blackwell at 617 747- 2462/[email protected]); the Public Safety Department (617 747-2333 or X2333); or the Operations Department or Student Affairs at the Valencia campus.
In addition, individuals may report incidents of sexual misconduct as follows:
• For complaints against students: Office of the Vice President for Student Affairs, Student Judicial Officers; Office of Student Conduct and Community Standards
• For complaints against staff/administrators: Vice President for Human Resources, Diversity and Inclusion; Director, Employee Relations and Staffing
• For complaints against faculty: Senior Vice President for Academic Affairs/Provost
Berklee seeks to investigate and adjudicate complaints of sexual misconduct in a prompt, thorough, and equitable manner. Accordingly, complainants and respon dents are afforded certain written rights during the course of an investigation and adjudication, including, but not necessarily limited to, the following:
• The procedures associated with review of an incident will be conducted by individuals who receive annual training on issues related to domestic violence, sexual assault, dating violence, and stalking, as well as how to conduct investigations and hearings that protect victims and promote accountability.
• When a student or employee reports that she or he has been the victim of sexual misconduct, regardless of whether the incident may have occurred on or off campus, the college will provide the student or employee a written explanation of
17 the complainant’s rights and options with respect to the report. This includes written information concerning: information about the importance of preserving evidence; how and to whom to report crimes; options for notifying law enforce - ment and campus authorities (and the option to decline to notify such entities); and, where applicable, the complainant’s rights and the college’s responsibilities concerning orders of protection, no contact orders, restraining orders, or other similar lawful orders issued by a criminal, civil, or tribunal court or by the college. • Information concerning protection of the complainant’s and other necessary parties’ confidentiality and maintenance as confidential of any accommodations or protective measures provided to the complainant (to the extent that maintenance of such confidentiality would not impair the ability of the institution to provide accommodations or protective measures). • Options and resources for counseling, health, and mental health services, victim advocacy, legal assistance, visa and immigration assistance, and other services available for complainants, both within the college and the community. • Options for assistance in changing academic, living, transportation, and working conditions (regardless of whether the complainant chooses to report the incident to law enforcement). • Procedures for college disciplinary action. This includes a description of each type of disciplinary proceeding used by the college; the steps, anticipated timelines, and decision-making process for each type of disciplinary proceeding; how the college determines which type of proceeding to use based on the circumstances of an allegation; a description of the standard of proof (i.e., preponderance of evidence) that will be used during any disciplinary proceeding arising from an allegation; a listing of all possible sanctions that the college may impose following a disciplinary proceeding; and the range of protective measures the college may offer following receipt of an allegation. • Both the complainant and respondent have an opportunity to provide relevant information and names of relevant witnesses during a proceeding. • In no case is it appropriate for students to be involved in deliberations related to sexual behavior of other students. • Both the complainant and respondent may be accompanied to meetings and hearings by an (one) advisor of his or her choice. • Both the complainant and respondent will receive simultaneous written notice of the outcome of the investigation and disciplinary measures. 8 • Neither the institution, nor any officer, employee, or agent of the college, may retaliate, intimidate, threaten, coerce, or otherwise discriminate against any individual for exercising their rights to avail themselves of the institution’s grievance procedures. 8 Under federal law, the college will, upon request, disclose to the victim of a crime of violence (as that term is defined in Section 16 of Title 18 of the United Stated Code), or a non-forcible sex offense, the report on the result of any disciplinary 18 proceeding conducted by the college. If the alleged victim is deceased as a result of such crime or offense, the next of kin of such victim shall be treated as the alleged victim for purposes of this requirement. • The college endeavors to investigate and adjudicate sexual misconduct complaints in a reasonable amount of time, usually approximately fifteen (15) days, unless mitigating circumstances compel a longer duration. This process involves receipt of a complaint (or intake); administrative review; an opportunity for both parties to be heard and present evidence; a factual determination; and, where appropriate, sanctioning and possible appeals.
If an individual is found responsible for sexual misconduct, potential sanctions in - clude mandated education, formal warning, suspension or expulsion (for students), or termination (for faculty or staff).
SEXUAL ASSAULT EDUCATION PROGRAMS AND RESOURCES 9
Counseling and Advising Center (CAC) The CAC offers a variety of support services, including academic advising, first-year advising, international student advising, personal counseling, and services for students with disabilities.
Rape and Sexual Assault Prevention Committee This group meets regularly to promote the awareness of all forms of sexual assault, education, and prevention.
Rape and Sexual Assault Prevention Booklet The BPS created a publication titled Rape and Sexual Assault: A Guide to Prevention, Reporting, and Changing the Culture on Campus . Copies can be obtained at the BPS Office, Student Activities, the CAC, and the Valencia campus.
Sex Signals This presentation to incoming students covers the definition of sexual consent, the importance and necessity of consent, the intersection of alcohol, morality issues, bystander intervention, victim impact, and myths.
Resident Assistant (RA) Training The Housing Department trains each RA regarding date rape, drugs, and sexual assault reporting and protocol.
Boston Area Rape Crisis Center (BARCC) BARCC provides both regular in-service training for RAs, as well as other sexual assault related presentations. BARCC also maintains a 24-hour hotline: 800 841- 8371, staffed by trained counselors who provide support and resources to survivors of sexual assault.
Engaging Bystanders in Sexual Violence Prevention This training focuses on encouraging bystanders to not “look the other way” when they have knowledge of sexual violence.
9 Not all programs may be immediately available in Valencia, but are offered to students prior to their attending the 19 Valencia campus. SEXUAL ASSAULT RESOURCES 10 In addition to the Counseling and Advising Center on the Boston campus, local Spanish sexual assault resources include:
• Centro de la mujer 24 horas (Woman Center 24 hours) Address: Calle de Guillen de Castro 100, Valencia Phone: 900-58-08-88
• Dirección General de la Mujer (Woman General Center) Address: Calle Naquera no. 9, Valencia. Phone: 961-971-600
• Valencia University Clinic Hospital Avenida Blasco Ibáñez 17, 46010
CLERY ACT GEOGRAPHY DEFINITIONS The following definitions apply to the geographical locations of incidents disclosed in the crime statistics tables contained in this report:
On-Campus: 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 property described above in 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).
On-Campus Residence Halls: An institution that has on-campus student housing facilities must separately disclose two sets of on-campus statistics: the total number of crimes that occurred on campus, including crimes that occurred in student housing facilities, and the number of crimes that occurred in on-campus student housing facilities as a subset of the total. 11
Public Property: All public property, including thoroughfares, streets, sidewalks, and parking facilities, that is within the campus, or immediately adjacent to and accessible from the campus.
Non-Campus: Any building or property owned or controlled by a student organization that is officially recognized by the institution; or any building or property owned or controlled by an institution that is used in direct support of, or in relation to, the institution’s educational purposes, is frequently used by students, and is not within the same reasonably contiguous geographic area of the institution.
10 Spain does not have a registry of sexual offenders and their crimes that is available to the public. 20 11 In other words, if a Clery Act crime is reported to have occurred in an on-campus residence hall, the incident is counted twice. It is reported in the overall on-campus statistics table and once in the on-campus residence hall statistics table. However, the Valencia campus has no on-campus housing and thus no statistics to report for on-campus residential loca tions. CLERY ACT CRIME DEFINITIONS The following definitions apply to the incidents of crime disclosed in the crime statistics tables contained in this Report:
Clery Act Felonies Murder and Non-Negligent Manslaughter: The willful (non-negligent) killing of one human being by another.
Negligent Manslaughter: The killing of another person through gross negli gence.
Aggravated Assault: An unlawful attack by one person upon another for the pur - pose of inflicting severe or aggravated bodily injury. This type of assault usually is ac - companied by the use of a weapon or by means likely to produce death or great bodily harm. Simple assaults are excluded.
Arson: Any willful or malicious burning or attempt to burn, with or without intent to defraud, a dwelling house, public building, motor vehicle or aircraft, or personal property of another. 12
Burglary: The unlawful entry of a structure to commit a felony or a theft. Attempted forcible entry is included.
Robbery: The taking or attempting to take anything of value from the care, custody, or control of a person or persons by force or threat of force or violence and/or by putting the victim in fear.
Motor Vehicle Theft: The theft or attempted theft of a motor vehicle.
Sexual Assault: Any sexual act directed against another person without the consent of the victim, including instances where the victim is incapable of giving consent.
• Forcible Sex Offenses : > Rape: The penetration, no matter how slight, of the vagina or anus with any body part or object, or oral penetration by a sex organ of another person, without the consent of the victim.
> Sodomy: Oral or anal sexual intercourse with another person, without the consent of the victim, including instances where the victim is incapable of giving consent because of his/her age or because of his/her temporary or permanent mental or physical incapacity.
> Sexual Assault with an Object: The use of an object or instrument to unlawfully penetrate, however slightly, the genital or anal opening of the body of another person, without the consent of the victim, including instances where the victim is incapable of giving consent because of his/her age or because of his/her temporary or permanent mental or physical incapacity.
12 Incidents involving both arson and some other Clery Act crime are counted twice, once in the arson row in the statistical table and once in the row concerning the other Clery Act crime involved. In addition, a report of arson is the only Clery Act crime that must be investigated to determine if the reported conduct constitutes arson under the Act. All other reported Clery Act crimes must be disclosed in the statistical table where the report is made in “good faith.” No investigation or 21 validation of such reports is required. > Fondling: The touching of the private body parts of another person for the purpose of sexual gratification, without the consent of the victim, including instances where the victim is incapable of giving consent because of his/her age or because of his/her temporary or permanent mental incapacity. • Non-forcible Sex Offenses : > Incest: Non-forcible sexual intercourse between persons who are related to each other within the degrees wherein marriage is prohibited by law. > Statutory Rape: Non-forcible sexual intercourse with a person who is under the statutory age of consent. Arrest and Referrals for Discipline for Violations of Liquor, Drug, and Weapons Laws 13 Liquor Law Violations: The violation of state and local municipal laws and ordi - nances prohibiting the manufacture, sale, transporting, furnishing, possessing of in - toxicat ing liquor; maintaining unlawful drinking places; bootlegging; operating a still furnishing liquor to a minor or intemperate person; using a vehicle for illegal transportation of liquor; drinking on a train or public conveyance; and all attempts to commit any of the aforementioned. (Drunkenness and driving under the influence are not included in this definition.) Weapons Law Violations: The violation of federal, state and local laws or ordinances dealing with weapon offenses, regulatory in nature, such as: manufacture, sale, or possession of deadly weapons; carrying deadly weapons, concealed or openly; furnishing deadly weapons to minors; aliens possessing deadly weapons; and all attempts to commit any of the aforementioned. Drug Law Violations: Violations of federal, state, and local laws relating to the unlawful possession, sale, use, growing, manufacturing, and making of narcotic drugs. The relevant substances include opium or cocaine and their derivatives (morphine, heroin, codeine), marijuana, synthetic narcotics (demerol, methadone), and dangerous non-narcotic drugs (barbiturates, benzedrine). Hate Crimes Under the Clery Act, a hate crime is a criminal offense committed against a person or property that is motivated, in whole or in part, by the offender’s bias. 14 For Clery purposes, hate crimes include any Clery Act felony (murder or non-negligent manslaughter, sexual assault, robbery, aggravated assault, burglary, motor vehicle theft, or arson) together with any of the following crimes to the extent they manifest evidence of bias: Larceny/Theft: The unlawful taking, carrying, leading, or riding away of property from the possession or constructive possession of another.
13 Under the Clery Act, an arrest is defined as the processing of a person by arrest, citation, or summons. A referral for disciplinary action is defined as the referral of any person to an institution official who institutes a disciplinary action of which a record is kept and which may result in the imposition of a sanction. Disciplinary action occurs where an official receiving the information initiates a disciplinary action, a record of the action is kept, and the action may, but not need have to, result in a sanction. Disciplinary actions may be initiated in both informal and formal manners and can include an interview or a simple, initial review of names submitted to an institutional official. An incident involving both an arrest and a referral for discipline is counted only as an arrest. 22 14 “Bias” is a preformed negative opinion or attitude toward a group of persons based on their race, gender, religion, disability, sexual orientation, ethnicity, national origin, or gender identity. Simple Assault: An unlawful physical attack by one person on another where neither the offender displays a weapon nor the victim suffers obvious severe or aggravated bodily injury involving apparent broken bones, loss of teeth, possible internal injury, severe laceration, or loss of consciousness.
Intimidation: To unlawfully place another person in reasonable fear of bodily harm through the use of threatening words and/or conduct, but without displaying a weapon or subjecting the victim to actual attack.
Destruction, damage or vandalism of property: To willfully or maliciously destroy, damage, deface, or otherwise injure real or personal property without the consent of the owner or the person having custody or control of the property.
23 CRIME STATISTICS Offense Year On Campus Residential Non- Public Facility/NA Campus Property Murder/ 2013 0000 Non-Negligent 2012 0000 Manslaughter 2011 0000
Negligent 2013 0000 Manslaughter 2012 0000 2011 0000
Sex Offenses— 2013 0000 Forcible 2012 0000 2011 0000
Sex Offenses— 2013 0000 Non-Forcible 2012 0000 2011 0000
Robbery 2013 0000 2012 0000 2011 0000
Aggravated 2013 0000 Assault 2012 0000 2011 0000
Burglary 2013 0000 2012 0000 2011 0000
Motor Vehicle 2013 0000 Theft 2012 0000 2011 0000
Arson 2013 0000 2012 0000 2011 0000
Domestic Violence 2013 15 0000 Dating Violence 2013 0000 Stalking 16 2013 0000
15 Under VAWA, the college was required to begin disclosing statistics concerning domestic violence, dating violence, and stalking for the 2013 calendar year with a three-year phase in such that the first report for which there will be three years worth of these statistics will be the 2016 report (which will include statistics for 2013, 2014, and 2015).
16 Stalking is counted uniquely under VAWA. When recording a stalking report, an institution is required to record a crime statistic only for the calendar year in which the course of conduct was reported to a local police agency or campus security authority. If the course of conduct involves the same parties and continues in a subsequent year, then the stalking must also be recorded for the subsequent year as well. A report of stalking must be counted as a new and distinct crime and is not associated with a previous report of stalking when the stalking behavior continues after an official intervention (including, but not limited to, an institutional disciplinary action) or the issuance of a no-contact, restraining order, or any warning by the institution or a court. An institution must record each report of stalking as occurring at only the first location within the institution’s Clery geography in which the perpetrator engages in the stalking or a victim first becomes aware of the stalking. Therefore, a report of stalking must be reported in an institution’s ASR if it meets the definition of 24 stalking even though the stalking course of conduct does not occur on the institution’s campus or in or on any of its other Clery geography. Arrests and Referrals for Discipline for Alcohol, Drug, and Weapons Law Violations
Offense Year Arrest Judicial Referral
On Resident Non- Public On Resident Non- Public Campus Facility Campus Property Campus Facility Campus Property
Weapons 2013 0000 0000 Violation 2012 0000 0000 2011 0000 0000 Liquor 2013 0000 0000 Law 2012 0000 0000 Violation 2011 0000 0000 Drug 2013 0000 0000 Law 2012 0000 0000 Violation 2011 0000 0000
Hate Crimes There were no reported or discovered hate crimes for the years 2011, 2012, and 2013.
Addendum For the year 2013, Berklee Valencia did not publish an Annual Security Report (ASR) as was required. This was due to misunderstanding of the separate compliance requirements surrounding a foreign campus. The Department of Education was subsequently informed of this failure. Berklee College 1140 Boylston Street of Music Boston, MA 02215-3693 U.S.A. berklee.edu