Threat Assessment and Management

I. Statement of Policy

UNC Charlotte promotes a safe and secure environment in which to learn and work by prohibiting Threats and acts of Violent Behavior by or against members of the University community, including, but not limited to, the following:

1. Workplace Violence, as defined in University Policy 101.17;
2. Certain Acts of Harm by students, as defined in University Policy 406; and
3. Sexual and interpersonal misconduct, as covered in University Policy 502 and University Policy 504.

Individuals who engage in Threats or Violent Behavior may be disciplined under the policies applicable to their status with the University; trespassed or otherwise restricted from accessing UNC Charlotte people or property; and/or subject to applicable laws and criminal action.

II. Scope

This Policy applies to all University community members, including faculty, SHRA and EHRA staff, and students, as well as non-University community members whose behaviors may affect the safety of the University community.

III. Definitions

1. Imminent Threat is defined as a reasonable belief that there is an immediate probability of an act or consequence that could result in serious bodily harm or death.
2. Threat is defined as an expression of intent to cause physical harm to a person or to cause damage to the property of others or the University. A threat may be direct, indirect, conditional, or veiled. An expression constitutes a Threat without regard to whether the party communicating the Threat has the present ability to carry it out and without regard to whether the expression is conditioned upon certain circumstances, events, or conditions.
3. Violent Behavior is defined as a broad range of behaviors (irrespective of perceived harm or severity) that may affect the UNC Charlotte campus or the workplace and that generate reasonable concerns for personal safety, or that are reasonably likely to result in physical injury to persons or animals. Violent Behavior includes, but is not limited to, aggressive acts, interpersonal violence, physical attacks, or Threats as defined herein.

IV. Procedures

A. Reports

In order to address incidents of Threats and/or Violent Behavior and contribute to a safe campus environment, members of the University community are encouraged to report any and all potential, imminent, or actual Threats or Violent Behavior by employees, former employees, students, former students, vendors, visitors, and guests.

1. Imminent Threats: Individuals should contact UNC Charlotte Police and Public Safety or call 911 immediately.
    
2. Non-Imminent Threats: Individuals are encouraged to make a report through the Threat Assessment and Management website.

Reports will be promptly reviewed and assessed. All reports will be handled as privately as possible, with information released only on a need-to-know basis or as required by law.

The University may provide guidance and resources regarding safety planning to anyone who submits a report or otherwise raises concerns about a Threat or act of Violent Behavior.

Retaliation against any individual who, in good faith, submits a report is prohibited. Any act of retaliation may be considered an instance of unacceptable behavior and may subject the individual to appropriate disciplinary, related administrative, and/or criminal action.

 B. University Response to Reports

Reports are generally screened and managed by the primary campus office that has jurisdiction over the type of situation described in the report (Housing and Residence Life, Human Resources, Office of Civil Rights and Title IX, Office of the Provost, Police and Public Safety, Student Accountability & Conflict Resolution, Student Assistance and Support Services), and may be elevated at the discretion of the primary office in coordination with the Threat Assessment and Management Coordinator (“Coordinator”). Reports that are elevated by the primary campus office and reports or issues related to unaffiliated individuals will be managed by the Coordinator or designee.

1. Preliminary Assessment

Once a report is elevated by the primary office or is being managed by the Coordinator, a preliminary assessment is conducted by the Coordinator or designee in coordination with campus departments and/or local agencies. The preliminary assessment consists of reviewing the information provided in the report and may include gathering additional information (e.g., criminal background, trespass information, online and social media activity, open source material, and conducting collateral interviews) to assist with understanding the totality of the circumstances.

If a preliminary assessment concludes there is no reason to believe a potential, imminent, or actual Threat or Violent Behavior may exist, the threat assessment case is closed. Nothing prevents a threat assessment case from being reopened upon receipt of additional information.

2. Threat Assessment and Management Plan

If a preliminary assessment concludes there is reason to believe a potential, imminent, or actual Threat or Violent Behavior may exist, the information gathered during the preliminary assessment is used to create a Threat Assessment and Management Plan. The goal of the Threat Assessment and Management Plan is to promote the continued safety of the individuals involved, and promote a safe educational environment for students and work environment for employees.

Each Threat Assessment and Management Plan is individualized for the specific incident, and may include, but is not limited to, the following:

• interim actions, as outlined in Section IV.C.2;
• an investigation, including the utilization of the opinions and reports from other University personnel or outside independent professionals, such as physicians and licensed psychologists or psychiatrists;
• reasoned risk analysis and threat assessment techniques and tools; and/or
• recommendations for supportive intervention services.

In coordination with campus offices and in accordance with applicable policies, it may be necessary during an investigation to:

• implement interim administrative measures (e.g., reassignment of duties or office, residential housing relocation, adjustment of courses, no contact orders) for an employee or student;
• request and/or require an employee or student to undergo a medical, psychological, threat, or other assessment to determine any risk of violence in the University community;
• remove a student or employee from campus until the investigation is concluded consistent with the interim actions described in Section IV.C.2.

In some cases, individuals may be issued an Order to Leave and Not Return to UNC Charlotte by Police and Public Safety.

In the event it is determined that the reported behavior or action is not isolated and could endanger the University community, a campus-wide NinerAlert may be issued, with the appropriate measures taken to promote the safety of the University community. Emergency alert procedures are outlined on the Emergency Management website

C. Responsibilities

1. General Oversight
   1. Threat Assessment and Management Coordinator (“Coordinator”)

The Coordinator is the chairperson of the behavioral assessment and intervention team described below and the facilitator of the Pre-Admission Safety Review process noted in Section IV.C.3. The Coordinator is responsible for receiving and managing threat assessment reports when they relate to an unaffiliated individual or when elevated by the primary campus office. The Coordinator is responsible for ensuring that preliminary threat assessments are completed and, as warranted, managing and coordinating threat assessment and management plans. 

2. Behavioral Assessment and Intervention Team

The University has a multidisciplinary team that is responsible for gathering and assessing information and implementing intervention strategies, as appropriate, for cases that include potential, imminent, or actual Threats and/or Violent Behaviors affecting employees and students. Additionally, a subset of members from this team is responsible for managing cases of Imminent Threat. These cases may require various intervention strategies, including immediate actions to be taken with regard to the individual of concern, other involved parties, or the broader University community.

2. Interim Actions

In most cases, interim actions are made and issued by the following individuals or their designees:

1. For cases that involve University Policy 501, University Policy 502, or University Policy 504 (“CRTIX Policies”), the Director of Civil Rights and Title IX determines interim actions.
2. For cases that involve student behavior outside the CRTIX Policies, the Associate Dean of Students and Director of Student Accountability and Conflict Resolution determines interim actions.
3. For cases that involve non-faculty employee behavior outside the CRTIX policies, the Director of Employee Relations assists supervisors in determining interim actions.
4. For cases that involve faculty behavior outside the CRTIX policies, the Associate Provost for Faculty Affairs assists department chairs or deans in determining interim actions.
5. For student cases that involve an Emergency Interim Protective Withdrawal, interim actions will be determined as outlined in University Policy 408, Student Involuntary Protective Withdrawal Policy.

3. Pre-Admission and Employment-Related Assessments
   1. Pre-Admission Safety Review (PASR)

The responsibility and purpose of the PASR process is to assess whether a student applicant to the University poses a potential threat to the University community, property, or resources.

2. Employment-Related Background Checks

UNC Charlotte will conduct background checks on all persons at the time of initial employment, in accordance with University Policy 101.23, Employment-Related Background Check and Criminal Activity Reporting. Additionally, current employees are subject to a background check every five years. Employees are required to report a conviction to their immediate supervisor or unit head as soon as possible and no later than the beginning of the next business day immediately following the conviction.

D. Relationship to Law Enforcement and Related Criminal Investigations

When Threats or Violent Behavior also potentially constitute violations of criminal laws, UNC Charlotte Police and Public Safety and/or other local law enforcement agencies with primary jurisdiction may take the lead role in coordinating and conducting investigations and preparing cases for prosecution, as deemed appropriate by the local District Attorney and University officials. A pending criminal investigation should not delay the relevant University threat assessment and management processes from moving forward.

E. Impacted Persons

UNC Charlotte offers available and reasonable support to University community members affected by Threats or Violent Behavior. Support may include providing reasonable accommodations, granting leave, and/or referring individuals to appropriate University and/or community resources, such as counseling services, health care facilities, law enforcement, legal aid, shelters, and victim advocacy groups.

F. Records

Records related to threat assessment and management are private to the extent permitted by law. The University will maintain pertinent records related to each case in accordance with the UNC System Records Retention Schedule. Access to these records is governed by applicable state and federal laws.
 

V. Other Rights and Obligations

Nothing in this Policy shall be interpreted to infringe on rights protected by other laws and policies, including but not limited to the First, Fifth, and Fourteenth Amendments to the U.S. Constitution; academic freedom; and the Americans with Disabilities Act.