University Policy
Title
University of North Carolina at Chapel Hill Policy on Behavioral Threat Assessment
Introduction
Purpose
The University of North Carolina at Chapel Hill (“University”) is committed to promoting a safe and secure learning environment in which students, faculty, and staff can live, learn, teach, and contribute to the University’s mission and goals.
This Policy explains how the University evaluates and responds to situations involving any person who may pose a threat to any of the following:
- Members of the University community;
- The University, its operations, and/or its academic processes; and
- The surrounding community.
Scope
This policy applies to everyone who uses University-owned or operated spaces. This includes, but is not limited to, students, faculty, staff, applicants, contractors, vendors, and visitors.
Definitions
Threatening behavior - Any communication or action, including action that is the subject of criminal charges, whether occurring on-campus or off-campus, that indicates that an individual may pose a danger to the safety or well-being of any member of the university community, including the individual engaging in the threatening behavior, through acts of violence or other behaviors that may reasonably cause fear of or harm to persons or property or substantially interfere with or disrupt the educational mission of the University. These behaviors may be expressed or communicated orally, visually, in writing, electronically, or through any other means and may be considered threatening regardless of whether a direct threat is expressed or was received by the intended audience or believed by the intended audience.
Policy
Policy Statement
I. Behavioral Assessment and Management Team Responsibilities
The University has established the Carolina Behavioral Assessment and Management team (“CBAM”) to conduct behavioral threat assessment and management. The CBAM is responsible for the following:
- Identifying, assessing, and managing individuals who may be exhibiting Threatening Behaviors that may suggest a threat to the University community;
- Cooperating with other University teams or offices as appropriate; and
- Implementing appropriate responses to reduce risk.
A.Consider Relevant Information
The CBAM may receive and use any relevant information about the behavior of the individual of concern. The CBAM may consider information regarding threatening behavior both on and off campus. Such information may include, but is not limited to:
- Copies of police records and court documents,
- Written summaries of information obtained by University personnel from others,
- Written statements,
- Oral testimony,
- Publicly available social media, and
- Interviews.
The CBAM must have access to student and employee records where necessary and appropriate. Access to student and faculty/staff records must comply with all relevant and applicable state and federal laws, including but not limited to the:
- Family Educational Rights and Privacy Act (FERPA),
- Health Insurance Portability and Accountability Act (HIPAA), and
- State Human Resources Act.
CBAM members who are not University employees may review student records as provided in 34 CFR §99.31(a)(1)(i)(B) if the CBAM members sign a written agreement with the University including the requirements and responsibilities using student records under FERPA.
B.Recommendations to Other University Departments and Committees
The CBAM will meet regularly and as needed to consider all new referrals and ongoing threat assessment cases.
After receiving a referral, the CBAM will conduct a preliminary review based on the following:
- The individual’s relationship to the University,
- All relevant circumstances including the reported behavior and previous interventions,
- Potential impacts of an assessment on the individual and community, and
- Available options for addressing the concerns to determine if a full CBAM assessment is warranted.
The Director of Threat Assessment may refer cases not accepted for a full CBAM assessment to other University departments/offices for appropriate action.
If the CBAM decides a full CBAM assessment is warranted, the CBAM will collect and consider information to assess the potential threat in accordance with accepted national standards. The CBAM must develop an individualized case management plan for every case the CBAM accepts for a full assessment.
The CBAM may make recommendations to other University departments/offices and committees about appropriate management and mitigation strategies necessary to reduce the risk of harm. These strategies include, but are not limited to:
- Interim separations,
- Investigatory leave with pay,
- Fitness for duty evaluations, and
- Other non-disciplinary safety interventions.
All procedures for implementing interim separations and investigatory leave with pay must be consistent with State and federal law, applicable State and University policies and procedures, and UNC System implementing regulation 1300.7[R], Regulation on Behavioral Threat Assessment and Management Teams, which is incorporated in this policy by reference.
Employee misconduct and student misconduct proceedings, including academic misconduct proceedings, may continue while an individual is subject to any safety interventions determined by the CBAM. The University official responsible for any proceeding that is in progress must keep the CBAM apprised of the status during the course of such proceedings.
C.Monitoring
The CBAM must continue to monitor situations where the CBAM or other University departments/offices have imposed safety interventions. The CBAM must periodically reassess such situations as needed, including monitoring and assessing time frames and conditions for the return to campus of any person who has been removed from campus as a safety intervention.
D.Limitations
The CBAM is only designed to provide expertise, information, recommendations, and referrals to those addressing threatening or disruptive situations. The CBAM is not responsible for handling misconduct cases or disciplining any person who displays Threatening Behavior.
E. Obligation of Other University Units to Cooperate with the Behavioral Assessment and Management Team
All University departments and offices must share information and, to the extent feasible, coordinate investigative activities with members of the CBAM.
- After referring a case to the CBAM, all University departments and offices should consult with the CBAM before taking any action, including further investigation or inquiry, that may change the situation, circumstances, or status of the relevant person(s).
- University offices with independent legal obligations to investigate matters reported to the CBAM must coordinate with the CBAM to the extent permissible by law.
- The Office of Human Resources must report instances of faculty and staff who are exhibiting Threatening Behaviors to the CBAM and consult with the CBAM before taking any action regarding employment status.
II. Behavioral Assessment and Management Team Membership
The Chancellor must appoint core CBAM members and review those appointments annually. The core CBAM includes representatives from several University departments with specific expertise and professional training in assessing and managing Violent Behaviors. These departments are:
- Campus Safety and Risk Management,
- Employee and Management Relations,
- University Police,
- Student Affairs, and
- University Compliance Office.
The Office of University Counsel provides legal guidance to the CBAM. The Director of Threat Assessment or their designee may add other University and community representatives as ad-hoc members of the CBAM when necessary.
III.Behavioral Assessment and Management Team Jurisdiction
The CBAM may receive, evaluate, and act on referrals about any person who may be exhibiting Threatening Behaviors and/or whose behavior may pose a danger to any of the following:
- Members of the University community;
- The University, its operations, and/or its academic processes; and/or
- The surrounding community.
The CBAM is authorized to use threat assessment best practice procedures to objectively assess any threat and make recommendations to reduce risk.
IV.Reporting Potential Threats to the Behavioral Assessment and Management Team
Anyone who has information that a person is attempting or engaging in Threatening Behavior or making statements that generate concern about the potential for violence or a threat to
- Members of the University community;
- The University, its operations, and/or its academic processes; and/or
- The surrounding community
should report that information to the CBAM at CBAM@unc.edu or via on-line at Concerning Behavior Referral as soon as possible.
Reporting violent behaviors to the CBAM is in addition to and does not satisfy or supersede other reporting responsibilities according to law or University policy:
- Responsible Employees must also report Prohibited Conduct to the University Compliance Office.
- Campus Security Authorities (CSA) must also report all Clery-qualifying crimes to the University Clery Coordinator.
- Everyone must report a reasonable suspicion that a minor has experienced child abuse, neglect, or violent offense (as defined in North Carolina Statute (N.C.G.S.) § 14-318.6) to UNC Police and the University’s Protection of Minors Coordinator, per the University’s Protection of Minors Policy.
- Everyone must report a reasonable suspicion that a disabled adult is subject to abuse, neglect, or exploitation (as defined in N.C.G.S. § 108A-102) to the local Department of Social Services.
Everyone should report all situations that pose an IMMEDIATE DANGER/IMMINENT SAFETY CONCERN to UNC Police immediately by calling 911.
A. Confidentiality
The CBAM will treat all reports made under this policy with sensitivity. Members of the CBAM will only share information to the extent necessary to assess and manage the situation and will comply with all relevant State and federal laws and University policies.
B. Retaliation
The University prohibits retaliating directly or indirectly against a person who has made a good faith report under this policy or has supported or participated in a CBAM assessment.
The University may refer anyone for disciplinary action per University policies if they deliberately report false or misleading claims with the intention to harass or misuse the CBAM process.
C. Restraining/Protective or No Contact Orders
If a member of the University community has a civil no-contact order (commonly referred to as a “50C” order) or a domestic violence protective order (commonly referred to as a “50B” order or “restraining order”) that may cover them while on campus in any capacity, they should notify UNC Police at 919-962-3951 and the Director of Threat Assessment and Management at CBAM@unc.edu.
V. Behavioral Assessment and Management Team Training
All permanent members of the CBAM must complete annual training regarding best practices in Threat assessment and management confidentiality, and other relevant laws and policies. The Director of Threat Assessment and Management must provide options for annual training and track all threat assessment training completed by CBAM members.
VI. Behavioral Assessment and Management Team Records
The Office of Threat Assessment and Management must provide a repository for information about behavioral concerns across different University divisions, departments/offices, and/or units. Access to the repository must be limited to CBAM members and others with a legitimate need, as governed by applicable law and policy. The Office of Threat Assessment and Management must comply with all relevant State and federal laws and University policies when maintaining all records of behavioral threat assessments.
Exceptions
None.
Related Requirements
External Regulations
University Policies, Standards, and Procedures
Contact Information
Primary Contact
Name: Angel Gray, Director of Threat Assessment and Management
Telephone: 919-962-6256
Email: angel.gray@unc.edu