Even before VAWA provisions specified that personally identifying victim information shall not be disclosed, Clery regulations created similar protections. As clarified by the commentary, 64 Fed. Reg. at 59063 (Nov. 1, 1999), Clery regulations do not require counselors, pastors, individual faculty, physicians, or any other non‐security personnel to report crime statistics. Rape crisis and domestic violence counselors, even those paid by the college or university, are not campus security authorities and are thus not required to report criminal activity. By way of comparison, many campuses offer students prepaid legal services. If a student client tells a legal services attorney about a criminal act either committed by the student or of which the student is a victim, the legal services attorney is under no obligation to violate attorney‐client privilege and reveal that confidential communication. Clery neither requires nor encourages breaches of privilege or confidentiality.