Kansas State University

Threat Management Policy

Chapter 3015

Revised May 2, 2000, August 20, 2012, April 27, 2015, September 6, 2018, September 4, 2020, and September 5, 2021

Table of Contents

.010 Scope

.020 Jurisdiction

.030 Policy Statement

.040 Threat Management Team/Critical Incident Response Team Members

.050 Investigation and Decision-Making Process

.060 Potential Risk Management Measures

.070 Required Reporting of Threatening or Violent Conduct, Restraining Orders

.080 Required Reporting of Child Sexual Abuse

.090 Questions

.010 Scope

This Policy applies to persons who are on campus or who are otherwise participating in University-sponsored programs and activities, such as employees, students, contractors, vendors, visitors, and guests.

.020 Jurisdiction

This Policy covers conduct that occurs on campus or otherwise within the context of University-sponsored programs and activities, whether those are on campus or off campus. Conduct that occurs off campus and outside the context of University-sponsored programs and activities is covered by this Policy to the extent such conduct presents a substantial risk of physical harm to person(s) on campus or in the context of a University-sponsored program or activity.

.030 Policy Statement

The safety and security of all Kansas State University employees, students, visitors, and guests are very important. Threats, threatening behavior, acts of violence, and any conduct that substantially disrupts another’s work performance or the University's ability to execute its mission are prohibited.

Retaliation against persons making reports or otherwise participating in this process in good faith also is prohibited.

.040 Threat Management Team/Critical Incident Response Team Members

The Threat Management Team is chaired by a member of the Office Risk and Compliance, or designee. Other members will include representatives from:

• K-State Police
• Office of General Counsel, as legal advisor

Other members of the Threat Management Team shall serve on the team as deemed necessary by the Chair and may include subject matter experts from:

• Supervisory department(s) of employee(s) involved
• Office of Student Life - in cases involving students
• Human Resources
• Employee Relations and Engagement
• Provost’s Office
• Office of Institutional Equity
• K-State Athletics, Inc.
• K-State Student Union
• Veteran Services
• International Student and Scholar Services
• Diversity, Equity, and Inclusion
• Housing & Dining Services
• Student Access Center
• Counseling and Psychological Services
• Lafene Health Center

The Critical Incident Response Team is chaired by the Director of Student Support & Accountability, or designee. Other members may include representatives from:

• Risk and Compliance
• Counseling Services
• K-State Police
• Office of General Counsel, as legal advisor

Other members of the Critical Incident Response Team shall serve on the team as deemed necessary by the Chair and may include subject matter experts from:

• Student’s Academic Dean’s Office
• Office of Institutional Equity
• Center for Advocacy, Response, and Education
• K-State Athletics, Inc.
• K-State Student Union
• Veteran Services
• International Student and Scholar Services
• Diversity, Equity, and Inclusion
• Housing & Dining Services
• Student Access Center
• Lafene Health Center
• Other support staff as needed

.050 Investigation and Decision-Making Process

The Threat Management Team (TMT) meets about potential violations of this Policy that involve non-students. The TMT meets to seek and obtain legal advice as it conducts an initial risk assessment and makes recommendations about how to mitigate any potential threat. The Chair of the TMT investigates and makes the decision about whether the Policy was violated and determines necessary actions to immediately and thereafter manage and alleviate any determined threat.  The procedural steps for the TMT proceedings, including but not limited to the appeal process, are incorporated by reference, and made a part of this Policy.

The Critical Incident Response Team (CIRT) meets about potential violations of this policy involving students. The CIRT meets to seek and obtain legal advice as it conducts an initial risk assessment and makes recommendations about how to mitigate any potential threat. The Chair of the CIRT investigates and makes the decision about whether the Policy was violated and determines necessary actions to immediately and thereafter mitigate and alleviate any determined threat. The procedural steps for the CIRT proceedings, including but not limited to the appeal process, are incorporated by reference, and made a part of this Policy.

When incidents involve a combination of faculty, staff, visitors or guests, as well as students, the CIRT and TMT meet jointly to seek and obtain legal advice as they conduct an initial risk assessment and make recommendations about how to manage mitigate any potential threat. The Acting Chairs jointly investigate and make the decision about whether the Policy was violated and determine necessary actions to immediately and thereafter manage mitigate and alleviate any determined threat.

The University may take immediate risk mitigation steps as outlined on following websites:

https://www.k-state.edu/studentlife/policies/cirt/index.html

Threat Management Process

.060 Potential Risk Management Measures

Violations of this Policy will lead to disciplinary action and/or risk mitigation measures, as appropriate and applicable under the circumstances, and may include without limitation suspension or expulsion, dismissal, arrest, barring the person(s) from University-owned or leased premises, termination of business relationships with an individual, and/or prosecution of the person(s), all as applicable. In cases alleging Title IX Sexual Harassment, as defined in PPM 3010, emergency removal measures will be considered if the University determines that an immediate threat to the physical health or safety of any student or other individual justifies removal.

In all cases, the appropriate Chair (TMT or CIRT) will provide individuals notice and an opportunity to challenge any proposed risk mitigation measures before a decision is reached. If circumstances warrant, an individual may be removed prior to an opportunity for hearing. In such case, the individual will be provided notice of the decision to remove and the grounds therefor, and an opportunity to be heard immediately following the decision.

Nothing in this Policy shall be construed as preventing the University from taking risk mitigation measures, or otherwise addressing a substantial disruption to a University campus, program or operations, that it deems necessary either for the continued business operations of the University or for the physical safety of persons and/or property on campus or in the context of University programs.

.070 Required Reporting of Threatening or Violent Conduct, Restraining Orders

All employees must notify the chair of the Threat Management Team of any threats that they have witnessed, received, or have been told that another person has witnessed or received when the conduct is covered by this Policy. Employees must also report any behavior they have witnessed that they regard as threatening or violent when that behavior is job-related or might be carried out on University-owned or -leased property or in connection with University employment. Additionally, you may report any concerning behavior through the following form: https://cm.maxient.com/reportingform.php?KansasStateUniv&layout_id=56

Each employee and/or student who receives a protective or restraining order (often referred to as a Protection from Abuse or Protection from Stalking order) that lists University-owned or -leased premises as a protected area, or otherwise prohibits the employee or student from being within a certain proximity or near another University employee or student, is required to provide a copy of such order to the Director of Student Support & Accountability (for orders pertaining to students) and/or the Chair of the Threat Management Team (for orders pertaining to all others) , as well as the K-State Police Department.

.080 Required Reporting of Child Sexual Abuse

All employees are required to report to the campus police and/or other appropriate law enforcement agencies any incidents of child sexual abuse, meaning those crimes defined in K.S.A. 21-5501, et seq. that relate to minors as victims that employees witness on the University's campus or at a University-sponsored event as required in PPM 3130.

.090 Questions

Questions about this Policy pertaining to non-student issues should be directed to the Office of Risk and Compliance at 785-532-2832. Questions about this Policy pertaining to student issues should be directed to the Director of Student Support & Accountability, 785-532-6432.