Author: Fearney, Kimberly

Financial Conflicts of Interest in Research

Posted on May 24, 2011January 30, 2023 by Fearney, Kimberly

Title:	Financial Conflicts of Interest in Research
Policy Owner:	Vice President for Research
Applies to:	Faculty, Staff, Students
Campus Applicability:	Storrs and Regional Campuses
Approval Date:	January 30, 2023
Effective Date:	January 30, 2023
For More Information, Contact	Director, Sponsored Program Services
Contact Information:	(860) 486-3622
Official Website:	https://ovpr.uconn.edu/services/rics/fcoi/

BACKGROUND

Investigators at the University of Connecticut (University) promote the research mission of the University relating to the discovery and dissemination of knowledge that emerges from that research. Participation in activities of professional associations, industry collaborations, and other public and private entities can assist in meeting these expectations, while also serving the academic interests of the University. In addition, such participation brings enhanced national and international status to the University and the State. Over the past decade, the opportunity for University faculty and staff to engage in external professional and entrepreneurial activities has increased markedly, and is encouraged by the state and federal governments because of the resulting economic development beneﬁts. The State of Connecticut has determined that the commercialization of University research and technology transfer is critical to Connecticut’s long-term economic growth.

However, it is vital that Investigators adhere to state and federal regulations dealing with avoiding and managing potential and existing conﬂicts of interest. In order for the University to maintain public trust and support in carrying out its mission, including all sponsored activities, the University must demonstrate that it subjects itself to the highest standards of ethical behavior.

PURPOSE

This Policy on Financial Conﬂicts of Interest in Research (Policy) provides guidelines to promote objectivity in research. The Policy establishes standards to ensure that the design, conduct, and reporting of research funded by extramural sponsors will not be biased by any conﬂicting ﬁnancial interest of an Investigator. The University encourages Investigators to engage in appropriate outside relationships, but signiﬁcant ﬁnancial interests related to these relationships need to be disclosed, reviewed, and managed in accordance with this Policy.

APPLICABLE FEDERAL REGULATIONS

The following federal regulations inform this policy:

Department of Energy (DOE) Interim Conflict of Interest Policy
https://www.energy.gov/sites/default/files/2022-10/Department%20of%20Energy%20Interim%20Conflict%20of%20Interest%20Policy.pdf

Public Health Service (PHS)
https://grants.nih.gov/grants/policy/coi/index.htm

National Science Foundation (NSF)
http://www.nsf.gov/pubs/policydocs/pappguide/nsf10_1/aag_4.jsp

Food and Drug Administration (FDA)
https://www.fda.gov/RegulatoryInformation/

In summary, the federal policies and regulations stipulate:

Disclosures of signiﬁcant ﬁnancial interests by ALL Investigators;
Institutional certiﬁcation that all proposed and ongoing sponsored research is either free of ﬁnancial conﬂicts of interest, or that such conﬂicts are managed, reduced or eliminated, and reported as required by applicable regulations;
The implementation of an institutional mechanism for managing ﬁnancial conﬂicts of interest in research;
Notiﬁcation of sponsors, as required, of management plans and if the University is unable to manage ﬁnancial conﬂicts of interest satisfactorily;
Monitoring of compliance, procedures for retroactive review in cases of non-compliance, enforcement mechanisms, and sanctions where appropriate;
Maintenance of records relating to this policy for at least three years following the termination of a given project; and,
Providing information and training to Investigators, as required by applicable regulations.

DEFINITIONS

Business: any corporation, partnership, sole proprietorship, ﬁrm, franchise, association, organization, holding company, joint stock company, receivership, business or real estate trust, or any other legal entity organized for proﬁt or charitable purposes.

Clinical Investigation(PHS): any experiment in which a drug is administered or dispensed to, or used, involving one or more human subjects. An experiment here is any use of a drug, except for the use of a marketed drug in the course of medical practice.

Clinical Investigation (FDA): any experiment that involves a test article and one or more human subjects, and that either is subject to requirements for prior submission to the Food and Drug Administration under section 505(i) or 520(g) of the act, or is not subject to requirements for prior submission to the Food and Drug Administration under these sections of the act, but the results of which are intended to be submitted later to, or held for inspection by, the Food and Drug Administration as part of an application for a research or marketing permit. The term does not include experiments that are subject to the provisions of part 58 of the chapter, regarding non-clinical laboratory studies.

Financial Conﬂict of Interest (FCOI): a situation in which signiﬁcant ﬁnancial interests in a business, or other personal considerations provided by a business, may compromise, or have the appearance of compromising, an Investigator’s professional judgment in conducting or reporting research, the results of which could affect the aforementioned business, either directly or indirectly. An FCOI exists when the University, through its designated oﬃcial(s), reasonably determines that an Investigator’s Signiﬁcant Financial Interest is related to a research project and could directly and signiﬁcantly affect the design, conduct or reporting of the research.

Human Subject (PHS regulations “Protection of Human Subjects” 45 CFR Part 46, as administered by OHRP): a living individual about whom an Investigator conducting research obtains data through intervention or interaction with the individual, or identiﬁable private information.

Human Subject (FDA regulations 21 CFR 50): an individual who is, or becomes, a participant in research, either as a recipient of the test article or as a control. A subject may be either a healthy human or a patient.

Immediate Family: the Investigator’s spouse/domestic partner and dependent children.

Institutional Responsibilities: an Investigator’s professional responsibilities on behalf of the University, which include research, teaching, and service as, e.g., outlined in the Policy on Faculty Professional Responsibilities (http://policy.uconn.edu/?p=659).

Intellectual Property: a product of the intellect that has commercial value, including copyrighted works, patents, business methods, and industrial processes.

Investigator: the principal investigator and any other person (regardless of title or position) who is responsible for the design, conduct or reporting of research or educational activities*. This may include faculty and research staff (research associates and assistants, postdoctoral fellows, graduate students, visiting scientists engaged in research conducted at the University) as well as consultants.

*For DOE funded projects, the definition states that the Principal Investigator or any other person, regardless of title or position, who is responsible for the purpose, design, conduct, or reporting of a project.

Research (PHS regulation 45 CFR 46.102(d)): a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge. Activities which meet this deﬁnition constitute research for purposes of this Policy, whether or not they are conducted or supported under a program which is considered research for other purposes.

Signiﬁcant Financial Interest (SFI):

Signiﬁcant Financial Interest means:

For DOE, PHS and all sponsors that follow the 2011 PHS FCOI Regulations[1]

For NSF and all other sponsors:

With regard to any publicly traded entity, an SFI exists if the value of any remuneration[2] received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000; or

With regard to any non-publicly traded entity, an SFI exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator (or the Investigator’s Immediate Family) holds any equity interest(e.g., stock, stock option, or other ownership interest); or

Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.

An equity interest that when aggregated for the Investigator and the Investigator’s Immediate Family exceeded $5,000 over the last 12 months, and/or is expected to exceed $5,000 in value over the next 12 months as determined through reference to public prices or other reasonable measures of fair market value; or when the Investigator (or the Investigator’s Immediate Family) holds a 5% or greater equity interest (e.g., partnership, ownership, stock, stock option, or other ownership interest) in a single publicly traded entity or holds any equity interest in a non-publicly traded entity; or

Salary, royalties or other payments not from the University for services (e.g., consulting fees or honoraria) that when aggregated for the Investigator and the Immediate Family over the last 12 months exceeded $5,000 or are expected to exceed $5,000 over the next 12 months;

Investigators also must disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), related to their Institutional Responsibilities.

In addition, the following needs to be disclosed for Clinical Investigations covered by FDA regulations:
1. Compensation made to the Investigator in which the value of compensation could be affected by the outcome of the study/research project.
2. A proprietary interest in the tested product, including, but not limited to, a patent, trademark, copyright or licensing agreement.
3. Signiﬁcant payments of other sorts, which are payments that have a cumulative monetary value of $25,000 or more made by the sponsor of a covered study to the investigator or the investigators’ institution to support activities of the investigator exclusive of the costs of conducting the clinical study or other clinical studies, (e.g., a grant to fund ongoing research, compensation in the form of equipment or retainers for ongoing consultation or honoraria) during the time the clinical investigator is carrying out the study and for one year following completion of the study.
Department of Energy
1. For each disclosure investigators will comply with the DOE specific certification statement requirements.

The term Signiﬁcant Financial Interest does not include the following types of ﬁnancial interests:
1. 1. Salary, royalties, or other remuneration paid by the Institution to the Investigator if the Investigator is currently employed or otherwise appointed by the University, including intellectual property rights assigned to the University and agreements to share in royalties related to such rights;
  2. Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles;
  3. Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, an institution of higher education as deﬁned at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is aﬃliated with an Institution of higher education;**; or
  4. Income from service on advisory committees or review panels for a federal, state, or local government agency, an Institution of higher education as deﬁned at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is aﬃliated with an institution of higher education.**
  5. Travel that is reimbursed or sponsored by a federal, state, or local government agency, an Institution of higher education as deﬁned at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center,** or a research institute that is aﬃliated with an Institution of higher education.
** Department of Energy policy does not exclude academic teaching hospitals or medical centers for letters c, d and e above.

Sponsor: an individual company, or any entity which takes responsibility for the initiation, management, and/or ﬁnancing of a research project, but which does not actually conduct the investigation.

PROCEDURES

I. Notification

A copy of this policy will be sent to all current Investigators and will be provided to all new Investigators upon hire. The policy is also available on the UConn website under “University Policies.”

II. Training

All PHS-funded and DOE- funded Investigators must complete training prior to engaging in PHS or DOE funded research and at least every four years thereafter as well as under the following circumstances (in the timeframes noted in parentheses):

The University’s Financial Conﬂict of Interest policy changes such that Investigator requirements are affected (within 60 days).
An Investigator is new to the University (prior to engaging in PHS or DOE funded research).
The University ﬁnds that an Investigator is not in compliance with the Policy or a management plan, as applicable.

III. Disclosure of Significant Financial Interests

Each Investigator must disclose his/her known SFIs (including those of the Investigator’s Immediate Family) that reasonably appear to be related to the Investigator’s Institutional Responsibilities, or that would reasonably appear to be affected by the research for which funding is sought or are in entities whose ﬁnancial interests would reasonably be affected by the research. In determining whether a ﬁnancial interest has to be disclosed, the Investigator shall consult the deﬁnition of SFI within this policy and, if in doubt, resolve in favor of disclosure.

Disclosure for each Proposal Submission: At the time of submission of a new proposal, an Investigator must have completed their online ﬁnancial disclosure in the I nfoEd External Interests Module. The University will not submit a proposal until such disclosure has been submitted.
Changes in SFI: An updated disclosure shall be completed and ﬁled within thirty (30) days at any time when an Investigator acquires or discovers a new reportable SFI not disclosed in the last disclosure. For existing Investigators on a project, new or newly identiﬁed SFIs will be reviewed promptly to determine if an FCOI exists, create a management plan if necessary and report the newly identiﬁed FCOI to the sponsor within 60 days if required.
Human Subject Research: When research involves human subjects, the Investigator must disclose SFIs to the Institutional Review Board (IRB) with every submission of protocols. If an Investigator has an FCOI, but a management plan is not on ﬁle, the IRB will contact the VPR or their designee and hold approval of the protocol until the FCOIR makes a determination.
New Investigators: If research is ongoing and an Investigator newly participating in the project discloses an SFI related to that research, those SFIs will be reviewed promptly to determine if an FCOI exists, create a management plan if necessary and report the newly identiﬁed FCOI to the sponsor within 60 days if required.

IV. Determination, Resolution, and Management of a Conflict of Interest

The VPR will review SFI Disclosure Forms and, if an SFI is disclosed, the Investigator will be required to complete a Supplemental Information Request to Signiﬁcant Financial Interest Disclosure. The VPR or his/her delegate performs an initial administrative review and refers all disclosed SFIs to the Financial Conﬂict of Interest in Research Committee.
The Financial Conﬂict of Interest in Research Committee (FCOIR) is appointed by the VPR and serves as the resource with respect to the determination of relatedness of SFIs and the identiﬁcation and management of COIs. The FCOIRC shall include an appointed chair and (5) additional appointed members with broad representation across the University, and may include one community member who is not a University employee.
The FCOIRC, with the help of the Investigator and/or his/her department head and based on guidelines consistent with all applicable regulations, will determine if the SFI is related to a sponsored research project and, if so related, whether the SFI constitutes a ﬁnancial conﬂict of interest (FCOI).
If the FCOIRC identiﬁes an FCOI, it will resolve the conﬂict by elimination, mitigation, or the creation of a management plan. The Investigator has to agree in writing to the conditions listed in such management plan. The following are examples of conditions that may be imposed:

Public disclosure of SFIs, including disclosure on manuscripts submitted for publication, on abstracts and posters submitted for presentation, and on informed consent documents;

1. Monitoring of the research by independent reviewers;
2. Modiﬁcation of the research;
3. Disqualiﬁcation from participation in all or a portion of the activities that could be affected by the FCOI;
4. Divestiture or reduction of the SFI;
5. Severance of relationships that create actual or potential conﬂicts.

An FCOI must be eliminated or a management plan agreed to before a related award will be set up. Neither the institution nor an Investigator may expend funds unless it has been determined that no FCOI exists or that the FCOI is manageable in accordance with the terms of a management plan.

V. Notification/Reporting

If an FCOI is identiﬁed, the FCOIRC is responsible for:

Notiﬁcation of the Investigator of the management plan designed by the Committee for his/her FCOI;
Notiﬁcation of the Oﬃce for Sponsored Programs (OSP) to assure that no spending of funds from related grants occurs without prior approval of the FCOIRC.
Notiﬁcation of the Oﬃce of Research Compliance of FCOI management plan when the research involves human subjects.
Notiﬁcation of research sponsors, as required, of any FCOIs, including any measures taken to reduce, manage, or eliminate such conﬂicts. The elements of such a report shall include, at least, the items enumerated under the FCOI Regulations.

The VPR or his/her delegate will notify the above individuals, oﬃces, and sponsors on behalf of the FCOIRC. Reasonable efforts will be made to maintain the privacy of information gathered in the FCOIRC’s deliberations, within the limits imposed by applicable laws and regulations.

VI. Maintenance of Records

All records related to the implementation of this policy (e.g., Individual Financial Disclosure Forms, Supplemental Information Forms, minutes of the meetings of the COI in Research Management Committee, notiﬁcations to funding agencies, actions taken to resolve or mitigate FCOIs, etc.) will be maintained securely by the VPR for a period of at least three (3) years beyond the termination or completion of the sponsored award to which they relate, or until the resolution of any action involving those records, whichever is longer. FCOI records shall be subject to periodic review for compliance with this policy by the VPR or by any agency per applicable regulations.

VII. Subrecipients

If a subrecipient carries out a portion of the work, University shall take reasonable steps to ensure that any subrecipient and subrecipient Investigator complies with the applicable FCOI regulation.

University will establish, via a written agreement, the governing FCOI policy.

Sub-recipient will certify that its FCOI policy complies with the respective regulations and, further, sub-recipient will report identiﬁed FCOIs for its investigators in a time frame that allows University to report identiﬁed FCOIs to the awarding agency.
Alternatively, if a sub-recipient lacks a compliant FCOI policy, the subrecipient will be governed by the University’s FCOI policy; University will solicit and review sub-recipient Investigator disclosures and identify, manage and report FCOIs to the sponsor.

In the event that a sub-recipient notiﬁes University of an FCOI for sub-recipient Investigators for which University is the prime awardee, University will promptly notify the sponsor.

VIII. Public Accessibility

Prior to expending any funds under a PHS-funded grant, cooperative agreement or contract, the VPR shall ensure public accessibility of information about the FCOI, via a written response to any requestor within ﬁve (5) business days of a request, of information concerning an SFI which was disclosed and is still held by the senior/key personnel on the project, which is determined to be related to the PHS-funded research, and which is determined to be a FCOI. The information shall consist of the information required to be provided under the FCOI Regulations.

IX. Monitoring Compliance/Mitigation

The VPR will monitor for compliance with the policy.
If the VPR learns of an SFI that was not timely disclosed or was not timely reviewed, the VPR, or his/her delegate, shall, in consultation with the FCOIRC and no later than the sixtieth (60th) day after learning of the SFI:
1. determine whether the SFI is an FCOI; and
2. if an FCOI exists, implement an interim management plan or implement other interim measures to ensure the objectivity of the research going forward.

If an FCOI was not timely identiﬁed or managed or if an Investigator fails to comply with a management plan, the VPR shall no later than the 120th day after determining noncompliance:
1. complete and document a retrospective review and determination as to whether research conducted during the period of noncompliance was biased in the design, conduct, or reporting of the research; and
2. implement any measures necessary with regard to Investigator’s participation in the research between the date that the noncompliance is identiﬁed and the date the retrospective review is completed.

For PHS and DOE-covered research projects, the retrospective review shall cover key elements as speciﬁed by federal regulations and may result in updating the Financial Conﬂict of Interest Report, notifying the PHS or DOE awarding component, and submitting a mitigation report as required by federal regulation.
University will notify the PHS and DOE of instances in which the failure of an Investigator to comply with this policy or a management plan appears to have biased the design, conduct, or reporting (and purpose for DOE funded research) of funded research. The University will make information available to HHS, PHS and DOE awarding component as required by federal regulation.

X. Appeals

In situations where an Investigator disputes the decision of the FCOIRC, the Investigator may request to present the case to the FCOIRC in person. An Investigator who disagrees with the FCOIRC’s determination may appeal in writing to the VPR. An appeal may be made in regard to whether the professional judgment of the Investigator is likely to affect his or her conduct of research, but Investigators may not contest the terms and conditions of this.
The VPR may agree with the FCOIRC’s ﬁndings and/or recommendations, or may amend such ﬁndings and/or recommendations. The VPR shall promptly notify the Investigator and the FCOIRC in writing of the conclusions of his/her review, including the actions that must be taken by the Investigator to comply with this policy.
Upon receipt of the VPR’s written report, the Investigator must promptly comply with the actions speciﬁed in that report.

XI. Implementation and Enforcement

The Provost is the senior administrator responsible for overseeing the implementation of this Policy. The Provost has delegated the disclosure/review/management process to the Vice President for Research or his/her designee (VPR). The VPR, in consultation with the Dean of the appropriate School and the Investigator(s) Department Head, will review all breaches of the policy, including:

failure to comply with the process (by refusal to respond, by responding with incomplete or knowingly inaccurate information, or otherwise);
failure to remedy conﬂicts; and
failure to comply with a prescribed management plan

Sanctions and penalties for those who knowingly and willfully disregard this policy, or refuse to comply with its terms, will be determined by the VPR, in consultation with the Dean of the appropriate School, with advice from the Investigator(s) Department Head and the Department of Faculty and Staff Labor Relations . Sanctions include, but are not restricted to:

Letter of reprimand
Notiﬁcation to professional and/or scientiﬁc societies, funding agencies and/or professional journals
Reassignment of duties Termination of grant support
Adjustment of research space allocation Adjustment of salary
Suspension
Dismissal

XII. Audit Procedures

In order to ensure that all declarations are being made and ﬁnancial conﬂicts managed, the University will implement a relevant audit program through the University’s Oﬃce of Audit and Management Advisory Services.

REFERENCES

[1] E.g. American Heart Association and American Cancer Society

[2] For purposes of this deﬁnition, remuneration includes salary and any payment for services not

otherwise identiﬁed as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value

POLICY HISTORY

Policy created: 01/23/2015

Revisions: 01/30/2023 (Approved by Senior Policy Council and the President)

Financial Aid Code of Conduct

Posted on May 24, 2011February 26, 2019 by Fearney, Kimberly

Title:	Financial Aid Code of Conduct
Policy Owner:	Board of Trustees
Applies to:	Faculty, Staff, Others
Campus Applicability:	All Campuses
Effective Date:	January 22, 2008
For More Information, Contact	Director, Financial Aid Office
Contact Information:	(860) 486-2470
Official Website:	http://financialaid.uconn.edu/

Definitions
1. “Lending Institution” or “Lender” shall mean (i) any entity that itself, or through an affiliate, engages in the business of making loans to students, parents or others for purposes of financing higher education expenses or that securitizes such loans, or (ii) any entity, or association of entities, that guarantees education loans. “Lending institution” or “Lender” shall not include the University or the state or federal government.
2. “University” shall mean the university, college, professional trade school or other entity providing post-secondary education that adopts this Code of Conduct.
3. “Opportunity Loans” shall mean loans to international students or other students who, because they have poor or no credit history, do not have access to student loans on reasonable terms.
4. “Compensation” shall mean anything of value including, but not limited to, money, credits, loans, discounts, payments, fees, forgiveness of principal or interest, reimbursement of expenses, charitable contributions, stock options, consulting fees, educational grants, vacations, prizes, gifts or other items of value, whether given directly or indirectly.
5. “Trade Association” shall mean any higher education, financial aid, lending or banking trade, industry or professional association that receives Compensation within the preceding 12-month period from any Lending Institution or Lender. The Connecticut Conference of Independent Colleges shall not be deemed to be a “trade association” solely by virtue of its contract to administer the Connecticut Higher Supplemental Loan Authority (“CHESLA”).
6. “Outside Director” shall mean a member of a Lender’s Board of Directors or Board of Trustees who receives Compensation from such Lender in connection with his or her service on the Board of Directors or Board of Trustees and who receives no other compensation from the Lender as an officer, employee, or agent of the Lender or otherwise.
7. “Agent” shall mean a person acting as a representative of and at the direction of or under the control of a University where such person’s responsibilities with respect to the University relate primarily to the University’s activities involving financial aid or the business of higher education loans.
Code of Conduct
1. Prohibition of Certain Compensation to University Employees
  1. No University trustee, director, officer, or Agent, or any employee who is employed in the financial aid office of the University or who otherwise has responsibilities with respect to higher educational loans or other financial aid at his or her University, and no spouse or dependent children of any such persons (“Family Member”), shall accept any Compensation of more than nominal value (not to exceed the gift limits established in the State Code of Ethics), directly or indirectly, during any 12-month period from or on behalf of a Lending Institution or Trade Association, except that this provision shall not be construed to prohibit any officer, trustee, director, Agent or employee of the University, or any of their Family Members, from receiving Compensation for the conduct of non-University business with any Lending Institution or Trade Association or from accepting Compensation that is offered to the general public, if such Compensation is permitted pursuant to the State Code of Ethics.
  2. Notwithstanding the prohibitions in subsection II.A.1 or any other provision of this Code of Conduct: (a) The University may hold membership in any nonprofit professional association; (b) A University trustee, director, officer, or employee who does not have responsibilities with respect to higher educational loans or financial aid, may serve as an Outside Director of a Lending Institution or Trade Association and receive Compensation at the Lending Institution’s or Trade Association’s established compensation rates for Outside Directors, provided that any University trustee, director, officer or employee serving on the board of the Lending Institution or Trade Association is precluded from participating in such board’s discussions or decisions that might affect the interests of the University, and provided further that such University trustee, director, officer or employee complies with the University’s conflict of interest policy, and receives annual written notice of the requirements of both this Code of Conduct and the University’s conflict of interest policy. Further, notwithstanding the prohibitions in subsection II.A.1, a trustee, director, officer or employee of a Lending Institution or Trade Association who does not have responsibilities with respect to higher education loans or financial aid shall not be prevented from serving on the Board of Directors of a University solely by virtue of his or her position with the Lending Institution or Trade Association, provided that any such person serving on the board of the University is precluded from participating in such board’s discussions or decisions that might affect the interests of such Lender or Trade Association or that relate to financial aid or higher education loans.
  3. Nothing in this Code of Conduct shall be construed to conflict with the requirements of Connecticut General Statutes ?10a-201 et seq., including without limitation ?10a-203(a), and ?10a-221 et seq.
  4. The prohibitions set forth in this subsection II.A shall include, but not be limited to, a ban on any payment or reimbursement by a Lending Institution or Trade Association to a University employee or Family Member for lodging, meals, or travel to conferences or training seminars unless such payment or reimbursement is related solely to non-University business University employees whose duties relate to financial aid may accept food or refreshments of nominal value provided or paid for by a Lender or Trade Association at a meeting, conference or seminar related to their professional development or training, as permitted pursuant to the State Code of Ethics. University employees are not precluded from attending any educational or training program related to financial aid or higher education loans where no registration fee is charged to any attendee because of a Lender’s or Trade Association’s sponsorship or support of the program, and provided that the registration fee is limited to covering the costs associated solely with the education or training component of the program, if permitted pursuant to the State Code of Ethics.
2. Limitations on University Employees Participating on Lender Advisory Boards No University officer, trustee, director, Agent or employee, or any of their Family Members, shall serve on an advisory board for a Lender. Lenders can obtain advice and opinions of financial aid officials on financial aid products and services through Trade Associations, industry surveys or other mechanisms that do not require service on Lender advisory boards and provided such person receives no Compensation for such service. This provision shall not apply to participation on advisory boards that are unrelated in any way to financial aid or higher education loans.
3. Prohibition of Certain Compensation to the University
  1. Neither the University, nor any alumni association, booster club, foundation, athletic organization, social organization, academic organization, professional organization or other organization affiliated with the University (“Affiliated Organizations”), may accept any Compensation from any Lending Institution or Trade Association in exchange for any advantage or consideration provided to the Lending Institution or Trade Association related to the Lending Institution’s or Trade Association’s financial aid or education loan activity. This prohibition shall include, but not be limited to (i) revenue sharing by a Lending Institution or Trade Association with the University or Affiliated Organizations, (ii) the receipt by the University or Affiliated Organizations from any Lending Institution or Trade Association of any equipment or supplies, including without limitation, computer hardware and software, for which the University pays below-market prices, and (iii) printing costs or services, provided that a University or Affiliated Organizations shall not be prohibited from accepting a Lender’s or Trade Association’s own standard printed brochures or informational material that does not contain the University’s logo or otherwise identify the University.
  2. Notwithstanding anything else in this subsection II.C., the University may accept assistance comparable to the kinds of assistance provided by the Secretary of the U.S. Department of Education to schools under or in furtherance of the Federal Direct Loan Program.
  3. Nothing in this subsection shall prohibit a University from accepting endowment gifts, capital contributions, scholarship funding, or other financial support from a Lender or Trade Association, so long as the University gives no competitive advantage or preferential treatment to the Lender or Trade Association related to its education loan activity in exchange for such support.
4. Preferred Lender Lists
  In the event that the University promulgates a list of preferred or recommended lenders or similar ranking or designation (“Preferred Lender List”), then:
  1. Every brochure, web page or other document that sets forth a Preferred Lender List must clearly disclose, textually or by clearly designated hyperlink, the process by which the University selected Lenders for said Preferred Lender List, including but not limited to the criteria used in compiling said list and the relative importance of those criteria; and
  2. Every brochure, web page or other document that sets forth a Preferred Lender List or identifies any Lender as being on said Preferred Lender List shall state in the same font and same manner as the predominant text on the document that students and their parents have the right and ability to select the education loan provider of their choice, are not required to use any of the Lenders on said Preferred Lender List, and will suffer no penalty from the University for choosing a Lender that is not on said Preferred Lender List;
  3. The University’s selection of Preferred Lenders and the University’s decision as to where or how prominently on the list the Lending Institution’s name appears shall be based solely on the best interests of student and parent borrowers, utilizing stated criteria that are limited to benefits provided to borrowers (such as competitive interest rates and repayment terms, quality of loan servicing, and whether loans will be sold) and the ability to work efficiently and effectively with the University to process loans, without regard to the pecuniary interest of the University or to any benefits provided by Lending Institutions to the University or any of the University’s officers, trustees, directors, Agents or employees or their Family Members. The University’s selection of any Preferred Lender shall be limited to the types of loans for which that Lender has been selected, based on the benefits to the borrower for those types of loans, and the University’s Preferred Lender list shall indicate the types of loans for which each Lender has been selected as a Preferred Lender. Nothing in this provision is intended to restrict the University’s ability to exercise its discretion in making its own, final judgment about which lenders best meet the University’s criteria and the needs of its student and parent borrowers.
  4. The University shall review its Preferred Lender List at least annually;
  5. The University shall require that all Preferred Lenders commit, in writing to disclose to the borrower, at the time a loan is issued: (a) whether the loan may be sold to another Lender; (b) that the loan terms and benefits will not change if the loan is sold to another Lender; and (c) that the loan benefits may change if the borrower chooses to consolidate his or her loans; and
  6. The University shall ensure that any Preferred Lender list that it publishes to students contain no less than three (3) Lending Institutions.
5. Prohibition of Lending Institutions’ Staffing of University Financial Aid Offices
  1. No employee or other agent of a Lending Institution may staff the University financial aid offices at any time. The University shall ensure that no employee or other representative of a Lending Institution is ever identified to students or prospective students of the University or their parents as an employee or agent of the University. The foregoing prohibitions notwithstanding, if the University believes that it would benefit students, the University may allow representatives of Lenders to conduct informational sessions, such as exit interviews and presentations on loan payment and loan consolidation options, so long as: (a) student attendance is voluntary; (b) a University representative explains that other Lenders may provide similar services; (c) the affiliation of the Lender representative is disclosed at the start of the presentation; (d) the Lender representative does not promote the products or services of any Lender, and (e) the University takes reasonable steps to ensure compliance with the requirements of this paragraph.
  2. In the event that the University permits a Lender to conduct information sessions or exit interviews as set forth in subsection E.1. above, the University must retain control of any interview or presentation offered by Lenders. Control may be evidenced by: (a) a University employee attending such interview or presentation; (b) the University recording or videotaping the interview or presentation; or (c) with respect to an exit interview conducted electronically via the internet, the University creating or approving in advance the content of such electronic exit interview.
6. Proper Execution of Master Promissory Notes The University shall not link or otherwise direct potential borrowers to any electronic Master Promissory Note or other loan agreement unless the Master Promissory Note or agreement allows borrowers to enter the Lender code or name for any Lender offering the relevant loan or the University’s link to the electronic Master Promissory Note or agreement informs borrowers of alternative means of entering into a Master Promissory Note or agreement with any Lender of the borrower’s choice. Any information the University provides to borrowers about completing a Master Promissory Note or agreement with a Preferred Lender must provide the information required in subsections II.D.1 and II.D.2 above.
7. Requirements for Opportunity Loans The University may enter into arrangements with Lenders to provide Opportunity Loans to students whose credit rating would otherwise preclude them from obtaining loans with reasonable rates and terms. The University may enter into such arrangements with a Preferred Lender after the University has selected Preferred Lenders in accordance with the provisions of Section II.D above, or it may use a separate process for selecting Lenders to provide Opportunity Loans, so long as that process also complies with the provisions of Section II.D. above. The University shall not request, accept, solicit or consider a Lending Institution’s offer to provide any Opportunity Loans in exchange for the University providing concessions, benefits or promises to the Lender.
8. Revolving Door Prohibition
  1. In the event a University hires an employee who will be employed in the financial aid office of the University or who otherwise will have responsibilities with respect to higher educational loans or other financial aid and such employee was employed by a Lender during the 12 month period prior to the date of hire by the University, such employee shall be prohibited from having any dealings or interactions with such Lender on behalf of the University for a period of 12 months from the date such employee’s employment with the Lender was terminated.
  2. In the event a Lender hires an employee who was employed by the University during the 12-month period prior to the date of such employee’s hire by the Lender, the University shall be prohibited from having any dealings or interactions with such employee for a period of 12 months from the date such employee’s employment with the University was terminated.

Policy History

Approved by the Board of Trustees on January 22, 2008
Reviewed September 21, 2018

FERPA Policy

Posted on May 24, 2011April 19, 2024 by Fearney, Kimberly

Title:	FERPA Policy
Policy Owner:	Office of University Compliance and Registrar
Applies to:	Faculty, Staff, Students, Others
Campus Applicability:	All Campuses
Effective Date:	August, 2016
For More Information, Contact	University Privacy Officer
Contact Information:	privacy@uconn.edu
Official Website:	http://ferpa.uconn.edu/

FERPA Policy

Policy Statement on Protection of Rights and Privacy of Students

A. Definitions: As used in this policy, the following terms have the following meanings.

1. 1. Alleged Perpetrator of a Crime of Violence: A student who is alleged to have committed acts that, if proven, would constitute any of the following offenses or attempts to commit the following offenses: arson; assault offenses; burglary; criminal homicide (manslaughter and murder); destruction, damage, or vandalism of property; kidnapping or abduction; robbery; and/or sexual assault.
  2. Attendance: Participation in University course(s) in person, or via paper correspondence, videoconference, satellite, Internet, or other electronic information and telecommunications technologies for students who are not physically present in the classroom. It also includes the period during which a person is working under a work-study program.
  3. Dates of Attendance: The period of time during which a student attends or attended the University. The term does not include specific daily records of attendance.
  4. Directory Information: Information contained in an Education Record of a student that by itself would not generally be considered harmful or an invasion of privacy if disclosed. Directory information includes: the student’s name; date of birth; addresses (including but not limited to physical address and email address); telephone number; PeopleSoft Number, NetID; school or college; major field of study; degree sought; student level (freshman, sophomore, etc.); degrees, honors, and awards received; residency/match information (for medical and dental students); dates of attendance; participation in officially recognized activities and sports, weight and height of athletic team members and other similar information including performance statistics, photographic likenesses and video of athletic team members; for student employees, employing department and dates of employment.
    The University reserves the right to amend this listing consistent with federal law and regulations and will notify students of any amendments by publication in the Annual FERPA Notification. Directory Information may only be disclosed in accordance with the provisions outlined in Section D. below.
  5. Disclosure Logs: Documents maintained by the appropriate University records custodians that records for each request for and each disclosure of Personally Identifiable Information of a student, and that indicates everyone who has requested or obtained Personally Identifiable Information and their legitimate interests in obtaining it (other than those enumerated in section F. below).
  6. Education Records: Any records maintained in any form or medium by the University that are directly related to a student.
  7. FERPA: Family Educational Rights and Privacy Act, 20 U.S.C. sec. 1232g, et seq. as amended, and the regulations at 34 C.F.R. Part 99.
  8. Hearing Body:
    1. Storrs and Regional Campuses: One or more persons assigned by the Vice President of Student Affairs or designee to determine whether an educational record is inaccurate, misleading or otherwise in violation of the student’s privacy rights, and therefore should be amended or deleted from the student’s records.
    2. University of Connecticut Health Center (UCHC): One or more persons assigned by the Dean of Students for each school (Medical and Dental) or designee to determine whether an educational record is inaccurate, misleading or otherwise in violation of the student’s privacy rights, and therefore should be amended or deleted from the student’s records.
    Individuals who have a direct interest in the outcome of the hearing may not serve on the Hearing Body (i.e., may not be from the University department or division with whom the student has the conflict under FERPA).
  9. Legitimate Educational Interest: A University Official has a legitimate educational interest if it is in the educational interest of the student in question for the official to have the information, or if it is necessary for the official to obtain the information in order to carry out his or her official duties or to implement the policies of the University of Connecticut. Any University Official who needs information about a student in the course of performing instructional, supervisory, advisory, or administrative duties for the University has a legitimate educational interest.
  10. Parent: Includes a parent of a student, a guardian, or an individual acting as a parent in the absence of a parent or guardian.
  11. Personally Identifiable Information: A student’s name; the name of a student’s parent or other family member; the address of a student or student’s family; a personal identifier, such as the social security number or student number, or any portion thereof; biometric record (meaning, biological or behavioral characteristics used for automated recognition of an individual, such as fingerprints, retina and iris patterns, voiceprints, DNA sequence, facial characteristics, handwriting); other indirect identifiers, such as the student’s date of birth, place of birth, and mother’s maiden name; other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty; or information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.
  12. Student: One who is presently enrolled and attending or who has been enrolled and attended the University’s degree, non-degree and non-credit programs. It does not include deceased students.
  13. Student Code: Regulations governing student conduct; also known as “Responsibilities of Community Life: The Student Code.”
  14. University: for the purposes of this policy, “University” means the University of Connecticut, all campuses.
  15. University Official: The term “University Official” (sometimes called “School Official”) means any person employed by the University in an administrative, supervisory, academic, research or outreach, or support staff position (including law enforcement unit personnel and health staff). The term also includes any contractor, consultant, volunteer, or other party to whom the University has outsourced institutional services or functions where the outside party–
    1. Performs an institutional service or function for which University would otherwise use employees;
    2. Is under the direct control of the University with respect to the use and maintenance of education records; and
    3. Is subject to the requirements of FERPA governing the use and redisclosure of personally identifiable information from education records.
    Examples of “University Officials” include, but are not limited to: attorneys, auditors, collection agents, officials of the National Student Clearinghouse, or the; a person serving on the Board of Trustees; Reserve Officers’ Training Corps (ROTC) cadre members (limited to their relationship with students enrolled in the ROTC program and/or enrolled in ROTC courses); or a student serving on an official committee, such as a disciplinary or grievance committee, or assisting another University Official in performing his or her tasks.

B. Rights of Students

1. Students of the University have a right to:

1. 1. - Be provided a list of the types and location of educational records maintained by the University and the titles and contact information of the officials responsible for those records.
    - Inspect and review Education Records (except as excluded in section H. below), within 45 days of a written request being presented to the authorized custodian of the records in question;
    - Receive a response from the University to reasonable requests for explanations and interpretations of Education Records within ten (10) business days;
    - Request amendments to their Education Records if the student believes that they are inaccurate, misleading, or otherwise in violation of privacy rights. If the University refuses to make such amendments, the student shall have an opportunity for an administrative hearing to challenge the content of the record on the same grounds and to insert a written statement or explanation commenting upon the information in the record;
    - Inspect and review only such parts of educational material documents as relate to him/her or to be informed of such specific information;
    - Receive a copy, if desired, of all records supporting enrollment or transfer to another school, and have an opportunity for an administrative hearing to challenge the content of these records;
    - Revoke, in writing, any previously executed waiver of rights under FERPA, with respect to any actions occurring after revocation;

1. 1. - Inspect the Disclosure Logs maintained by appropriate University record custodians with regard to the student’s Education Record(s); and
    - File complaints with the Family Policy Compliance Office, U.S. Department of Education, 400 Maryland Avenue S. W., Washington, D.C. 20202-4605. Complaints may also be filed with the University’s Compliance Office by calling the Assistant Director of Compliance/Privacy at (860) 486-5256 or online at https://www.compliance-helpline.com/uconncares.jsp, or the UCHC Compliance Office by calling the Associate Education Compliance Officer at (860) 679-1280 or email compliance.officer@uchc.edu.

C. Disclosure of Education Records. Education Records or other Personally Identifiable Information (other than Directory Information, as described in Section D. below) may not be disclosed without the student’s prior written consent except in the following instances. For purposes of compliance with FERPA, the University considers all students, regardless of age or tax dependency status to be independent. Therefore, educational records will not be provided to parents without the written consent of the student, except where one or more of the exceptions below applies.

1. 1. To the student himself/herself, unless he/she has waived the right;
  2. To University Officials who have a legitimate educational interest in the records.
  3. To officials of other schools in which the student seeks or intends to enroll or has enrolled, as long as the disclosure is for purposes related to the student’s enrollment or transfer, and provided the student may upon request have a copy of the records so transferred;
  4. In connection with determining eligibility, amounts, and conditions, or enforcing terms of financial aid for which the student has applied or that which he or she has received;
  5. To comply with a judicial order or lawfully issued subpoena, provided the University makes a reasonable effort to notify the student of the order or subpoena in advance of the compliance therewith, unless such notification is not required by FERPA;
  6. To appropriate parties in connection with a health and safety emergency where the University determines that there is a articulable and significant threat to a student or any other individuals, where the knowledge of such information is necessary to protect the health or safety of the student or other individuals;
  7. To law enforcement agencies and to certain other governmental authorities and agencies as are enumerated in and required or permitted by FERPA;
  8. To a court in connection with legal action by the University against a student or a student’s parent or by a student or student’s parent against the University;
  9. To the parent of a student regarding the student’s violation of any Federal, State, or local law or of any rule or policy of the University, governing the use or possession of alcohol or a controlled substance where:
    1. The University has determined that the student has committed a disciplinary violation with respect to that use or possession; and
    2. The student is under the age of 21 at the time of the disclosure to the parent. Such disclosure will occur in accordance with the University’s Parental Notification Policy through the Division of Student Affairs. For more information, visit the Division of Student Affairs Community Standards website at: http://www.community.uconn.edu.
  10. To a victim of an Alleged Perpetrator of a Crime of Violence or a Non-forcible Sex Offense. Such disclosure may only include the final results of the disciplinary proceedings conducted by the University with respect to the alleged crime or offense. The University may disclose the final results of the disciplinary proceeding regardless of whether the University concluded a violation was committed;
  11. Disclosure of the final result of a disciplinary proceeding where the alleged perpetrator-student is found to have violated University policy with respect to a criminal allegation. Such disclosure may be made (even to members of the public in certain circumstances) where the University has determined through its disciplinary proceedings that a student is (a) an Alleged Perpetrator of a Crime of Violence or a Non-forcible Sex Offense; and (b) with respect to the allegation made against the student, the student has committed a violation of the Student Code. Such a disclosure may only include the Final Results of the disciplinary proceedings conducted by the University with respect to the alleged crime or offense. The University may not disclose the name of any other student, including a victim or witness, without the prior written consent of the other student. This paragraph applies only to disciplinary proceedings in which the Final Results were reached on or after October 7, 1998;
  12. To authorized representatives of the federal, state and/or local government as permitted by FERPA in connection with an audit of federal- or state-supported education programs or with the enforcement of or compliance with federal legal requirements relating to those programs.
  13. To accrediting organizations to carry out their accrediting functions; and
  14. To organizations conducting studies for, or on behalf of, educational agencies or institutions to:
    1. Develop, validate, or administer predictive tests;
    2. Administer student aid programs; or
    3. Improve instruction.
    Disclosures made pursuant to this paragraph are subject to the requirements that (i) the studies are conducted in a manner that does not permit personal identification of parents and students to individuals other than representatives of the organization; and (ii) the information is destroyed when no longer needed for the purposes for which the study was conducted.
  15. Pursuant to a student record release request made under the Solomon Amendment. (See section E. below.)

D. Disclosure of Directory Information/Limited Directory Information Policy:

The University hereby gives notice that the categories of information defined herein as Directory Information may be released without the prior written consent of the student under the circumstances enumerated below. The University reserves its right to determine when and to whom it is appropriate to release Directory Information in response to third party requests. Any release of information deemed to be appropriate by the University will only occur as enumerated below:

1. The following categories of Directory Information may be disclosed to anyone who so requests:

Name
NetID
PeopleSoft Number
School or College
Major Field of Study
Degree Sought
Student Level
Degrees, Honors & Awards Received
Residency/Match Information (medical/dental students)
Dates of Attendance
Participation in Officially Recognized Activities and Sports
Weight and Height of Athletic Team Members and Other Similar Information Including Performance Statistics
Photographic Likenesses and Video of Athletic Team Members
For Student Employees, Employing Department & Dates of Employment

2. In addition to the information in category #1, the following categories of Directory Information may be disclosed to the UConn Foundation (including the UConn Alumni Association) and/or the UConn Law School Foundation:

Date of Birth
Addresses (physical and email)
Telephone Number

3. In addition, any member of the University community with a NetID may access student email addresses, as long as the access is for University-related purposes. However, such individuals may not use any student emails accessed through this process for commercial purposes or otherwise in violation of other University policies or applicable state or federal law.

4. Opting Out of Directory Information: Students who wish to opt-out of having their directory information disclosed without their prior consent must make the request in writing. At the Storrs and Regional Campuses, all requests shall be directed to the Office of the Registrar, Wilbur Cross Building, Unit 4077, Storrs, CT 06269-4077. At UCHC, all requests shall be directed to the Student Services Center, 263 Farmington Avenue, Farmington, CT 06030-1827. Such requests shall apply only to subsequent actions by the University and shall remain in place until removed by written request of the student. A student may not use the right to opt out of Directory Information disclosures to prevent the University from disclosing or requiring a student to disclose the student’s name, identifier, or institutional e-mail address in a class in which the student is enrolled. Student employees must contact the Student Employment division within the Office of Student Financial Aid Services to restrict access to any employment-related Directory Information. The University will not use Social Security Numbers as a means of verifying the identity of a student, nor to confirm identity of the student upon the request for the release of Directory Information about the student.

E. Military Access to Education Records. The Solomon Amendment is not a part of FERPA, but it allows military organizations access to information for the purposes of military recruiting which information may otherwise be protected from disclosure under FERPA. Failure to comply with this requirement could result in the loss of various forms of federal funding including various forms of Federal Student Aid.

At the University of Connecticut, all items included under the Solomon Amendment’s list of required information are included within the University’s definition of “Directory Information.” These include name, addresses, telephone numbers, age, major, dates of attendance and degrees awarded.
Information released is limited to military recruiting purposes only. The request for information must be in writing on letterhead that clearly identifies the military recruiting organization. Military recruiters must be from one of the following United States military organizations: Air Force; Air Force Reserve; Air Force National Guard; Army; Army Reserve; Army National Guard; Coast Guard; Coast Guard Reserve; Navy; Navy Reserve; Marine Corps; Marine Corps Reserve.
If a student requests that their Directory Information be withheld under section D.4. of this policy, the student’s records will not be released to military recruiters.

F. Disclosure Logs. The appropriate University records custodian shall maintain a log of each request for and each disclosure of Personally Identifiable Information from the Education Records of a student, that indicates the persons who have requested or obtained Personally Identifiable Information and their legitimate interests in obtaining it. However, this requirement does not apply to:

Disclosures pursuant to the written consent of the student, when the consent is specific with respect to the party or parties to whom the disclosure is to be made;
Disclosures to University Officials, when it has been determined that the official has a legitimate educational interest; and
Disclosures of Directory Information; and
Disclosures to the student upon the student’s own request.

G. Redisclosure. University Officials who disclose personally identifiable information from an Education Record must inform the recipient of the information that he/she/it may not redisclose that information without the consent of the student, and that the recipient may only use the information received for the purpose for which the disclosure was made, except where one of the exceptions in Section C. above applies.

H. Records Excluded from the Definition of Education Records. The following materials, information, and records which are excluded from the definition of Education Records are not available to students for inspection, review, challenge, correction, or deletion:

Confidential letters and statements of recommendation which were placed in the Education Records prior to January 1, 1975, if they are not used for purposes other than those for which they were specifically intended;
Confidential letters and statements of recommendations, used solely for the purposes for which they were specifically intended, if the student has waived the right to inspect and review recommendations:
1. regarding admission to an educational institution,
2. regarding an application for employment, and
3. regarding the receipt of an honor or honorary recognition;
Financial records and statements of the student’s parents or any information contained therein;
Records of instructional, supervisory, or administrative personnel or educational personnel ancillary thereto, which are kept in the sole possession of the maker thereof, are used only as a personal memory aid, and are not accessible or revealed to any other person except a temporary substitute for the maker of the record;
Records which are created or maintained by a physician, psychiatrist, psychologist or other recognized professional or paraprofessional acting or assisting in that capacity, used only in providing treatment to the student, and not available to anyone other than persons providing such treatment, except that such records may be personally reviewed by a physician or other appropriate professional of the student’s choice;
Records made and maintained in the normal course of business which relate exclusively to the individual in his or her capacity as an employee and are not available for any other purpose; this exclusion does not apply to an individual who is employed by the University as a result of his/her status as a student (i.e., interns, graduate assistants, work-study, etc.);
Records that only contain information about or related to a former student once he or she is no longer enrolled at the University (e.g., information regarding alumni or regarding individuals who attended the University at some point but are no longer enrolled);
Records of a law enforcement unit of the University created and maintained by that law enforcement unit for the purpose of law enforcement. This exception does not include those records created by a law enforcement unit, even if the records were created for law enforcement purposes, if such records are maintained by a component of the University other than the law enforcement unit; and
Grades on peer-graded papers before they are collected and recorded by a teacher.

Student Rights to Inspect and Challenge Education Records. The University shall provide a student the opportunity to challenge the content of his or her Education Records where the student believes the record(s) to be inaccurate, misleading, or otherwise in violation of privacy rights, and to correct, delete, or insert written statements of explanation into such record(s). This does not give a student a right to contest or challenge an assigned grade. Although disagreements may be settled through informal meetings and discussions, either the student or the University may request an administrative hearing to resolve the dispute. The student or University administrator seeking the hearing shall make his or her request in writing.

Send a written request to:

University Privacy Officer
University of Connecticut
Office of University Compliance
28 Professional Park Unit 5084
Storrs, Connecticut 06268-5084

The Hearing Process:

The hearing shall be conducted and decided within a reasonable period of time following the request, and the student shall be given notice of the date, time, and place reasonably in advance of the hearing. Normally, the hearing will be conducted within ten (10) business days following the date the hearing request has been received.
The student will have, at the formal hearing, the opportunity to present evidence and argument to a Hearing Body in support of his or her contention that the records are inaccurate, misleading or otherwise inappropriate. The student may, at his or her own expense, be assisted by one or more individuals of his or her own choice, including an attorney. The student may present evidence and question witnesses. The burden shall lie with the student to show that it is more likely than not (preponderance of the evidence) that the University department should have made the student’s requested changes to his or her records, and/or that a violation of the student’s rights under FERPA has occurred.
The University department with whom the student has the conflict may present a case in rebuttal with the same aforementioned procedural rights. The University department shall be provided an opportunity to present evidence relevant to the issues raised by the student;
The hearing shall be conducted by a Hearing Body who will hear all testimony, review all evidence presented at the hearing and render a decision. The Hearing Body shall be appointed by the Vice President of Student Affairs for the Storrs and Regional Campuses, or by the Dean of Students for each school (Medical and Dental) at UCHC, provided that person(s) does not have a direct interest in the outcome;
The Hearing Body shall ensure that the decision is rendered to the student in writing within a reasonable time after the conclusion of the hearing, is based solely upon the evidence presented at the hearing, and shall include a summary of the evidence and the reasons for the decision. The decision of the Hearing Body shall be final.
If the matter is not resolved to the satisfaction of the student, the student may draft a written response to be included with the Education Record(s) in question that details the student’s issue(s) with the Education Record(s) in question, and a description of why the student believes the Education Record(s) in question to be inaccurate, misleading, or otherwise in violation of privacy rights.

Faculty Compensation, Policy on

Posted on May 24, 2011June 2, 2023 by Fearney, Kimberly

Title:	Faculty Compensation, Policy On
Policy Owner:	Office of the Provost / Department of Human Resources
Applies to:	All Faculty excluding UConn Health
Campus Applicability:	All campuses except UConn Health
Effective Date:	November 11, 2022
For More Information, Contact	Office of the Provost: provost@uconn.edu Human Resources: hr@uconn.edu
Contact Information:	(860) 486-3034
Official Website:	http://www.hr.uconn.edu/

PURPOSE

To establish the standards under which regular payroll faculty may receive compensation from the University or external entities. As defined in this policy, such compensation must be in conformance with relevant state and federal regulations, including 2 CFR Part 200 (commonly referred to as Uniform Guidance) and the Connecticut Guide to the State Code of Ethics. This policy also defines the administration of faculty appointment terms.
This policy does not define rates of pay for activities or other contractual terms outlined in the collective bargaining agreement between the University of Connecticut and American Association of University Professors.

APPLIES TO

All Faculty excluding UConn Health. Faculty refers to all regular payroll faculty: tenured and tenure-track, clinical, in-residence, research, extension, visiting, and lecturers. This policy does not apply to coaches/trainers, adjuncts, or academic staff: research assistants/associates, academic assistants, or scientist/scholars.

POLICY STATEMENT

Compensation for all applicable audiences must fall under regular compensation, summer salary, overload pay, consulting, or prizes and awards. All applicable employees and employees responsible for appointing or administering compensation for applicable employees must consider the full compensation landscape at UConn and comply with this policy and its accompanying Faculty Compensation Procedures.

I. Regular Compensation

Appointment Term and Work Period. All faculty are appointed to either an academic year or annual year position. An academic year position has a nine- or ten-month assignment, in which the regular duties and responsibilities of the role fall primarily during the academic year[i]. The work period for an academic year position is defined in the Procedures. An annual year position has an eleven-month assignment, in which the regular duties and responsibilities of the role require effort consistently throughout the full year. The work period is all year round. Under the University’s faculty pay model, faculty are paid for 9-, 10-, and 11-month appointments over 12 months. Both academic year and annual year positions are paid over twelve months.

Salary. Full-time annual salary represents full renumeration for the duties and responsibilities associated with a faculty member’s regular workload and respective appointment term. Faculty may not receive additional compensation from university or external sources during the regular work period[ii] unless explicitly approved according to the summer salary, overload, consulting, or prizes/awards sections of this policy.

Annual salary: Annual salary is the total compensation over the course of the year for the regular faculty appointment. Faculty have one or more pay components which comprise their annual salary:

1. Base salary: Base salary is the base component of a faculty member’s annual salary, reflecting the pay tied only to the base term and respective workload. All faculty have a base term and base component of their annual salary.
2. Additional Months: Faculty may have one or two additional months of effort/pay depending on the scope and complexity of a faculty administrator assignment. The rate of pay for this component is tied to the base salary rate.
3. Administrative Supplement: Faculty may earn a supplement for administrative work that is above their base pay or additional months. The rate of pay is not tied to the base salary rate.

b. Institutional Base Salary (IBS) is a term used specifically for sponsored projects and stems from the Office of Management and Budget’s Uniform Guidance. IBS is the annual compensation paid for an individual’s regular appointment term and corresponding workload. At UConn, this is the equivalent of “annual salary” as defined above. IBS is inclusive of all regular pay components. A faculty member’s IBS is compensation for time spent on research, teaching, administration, or service. Institutional base salary does not include one-time payments, summer salary, or consulting.

Workload. Every faculty member has a defined workload. The scope of work for a base faculty appointment typically includes some combination of teaching, research, and service, as defined in the appointment letter or the department’s governance documents. Any change to a faculty member’s defined workload such as a course reduction or administrative assignment must be approved by appropriate parties based on school/college policy and clearly documented with the dean’s office.

Administrative Assignment. Faculty may be appointed to an administrative assignment with pay when the duties and responsibilities clearly exceed an individual’s base faculty appointment, and the required effort takes place over the course of the year. Administrative assignments may include a temporary redefinition of the individual’s appointment term, annual salary, or workload for the length of the appointment. Administrative assignments must be approved in writing by the Dean and any other supervisors in advance of an offer. Appointments must include an appointment letter describing the terms of the appointment and must be processed through regular payroll. The new full-time annual salary associated with an administrative assignment represents full renumeration for the new workload and may consist of multiple pay components. The University applies salary increases proportionately to each pay component, with the exception of promotional increases which apply only to the base salary component. Administrative appointments are at-will and subject to non-renewal or termination at the discretion of the supervisor. Should a faculty member no longer continue in an administrative appointment, the faculty member will return to the base faculty appointment term and base faculty rate in effect at that time.

Compensation above the institutional base salary is not permitted on activities funded by federal grants or contracts.

Research/Professional and Sabbatical Leaves. Research/professional leaves and sabbatical leaves are considered active service to the University and a redefinition of the faculty member’s regular workload for the leave period. Sabbatical pay is based on the faculty base appointment. Please refer to the provost’s guidelines for the administration of faculty leaves of absence.

II. Summer Salary

Faculty may be assigned teaching, research, service, or administrative duties during the period in which they are not already scheduled to work according to their regular academic year or annual year appointment. The table below describes the maximum effort and compensation a faculty member may earn as summer salary according to regular appointment term. Time and pay for faculty working on externally funded sponsored projects or the equivalent effort on university funds cannot exceed the daily rate of pay for daily effort (i.e., max pay cannot be condensed and paid out over a shorter period).

Appointment Term	Effort	Proportion of Current Full-Time Annual Salary	Time Period[iii]
Nine-month	Three months	3/9	May 23 – August 22
Ten-month	Two months	2/10	June 23 – August 22
Eleven-month	One month	1/11	Eligible to be paid out at any point in the year

Eleven-month faculty appointments are unique in that faculty are scheduled to work all year round, with one additional month of non-work time spread out over the course of the year. Given there is no pre-determined period in which this additional month takes place, faculty may earn their additional month of compensation at any point in the year, subject to all other requirements of this policy.

It is the responsibility of the faculty performing research activities for grants or contracts to adhere to the policies of the applicable funding agency during this period. Many federal agencies have additional compensation stipulations. For instance, at the time of this writing, NSF has proposal limits on summer earnings to the equivalent of two months of salary, and HHS “restricts the amount of direct salary of an individual under an NIH grant or cooperative agreement or applicable contract to Executive Level II of the Federal Executive Pay scale.”

Summer salary compensation may be waived if the faculty member chooses to accept payment in the form of faculty research funds. Such requests must be clearly documented, in advance of performing services, in line with the Procedures. Waived compensation in the form of faculty research funds is not considered personal compensation and cannot be used to supplement a faculty member’s full-time annual salary or summer salary in future years. Waived compensation is not included in the determination of the aforementioned maximum compensation.

III. Overload Pay

On occasion, faculty may be asked to perform work for the University that is substantially different from or in addition to the essential duties and responsibilities defined in the faculty member’s regular appointment. Such work must contribute to the mission and necessary business of the University. Faculty being considered for overload activities must demonstrate a unique qualification to perform the work. Overload pay may be appropriate for activities including, but not limited to, teaching during winter or May intercession, online course development sponsored by CETL, outreach, performance, or academic/student support. All requests for overload pay must be approved by the department head, dean, provost, and human resources as needed via the University’s formal approval process[iv] in advance of the start of the activity. Total overload pay should not exceed 25% of the twelve-month equivalent of annual salary each year. Any exception to the 25% cap will be rare and requires department head, dean, provost, and president approval. Overload assignments will only be considered if they meet the following criteria:

The activity must not interfere with the faculty member’s ability to carry out the duties and responsibilities associated with their regular faculty appointment. The individual must be satisfactorily performing regularly assigned duties.
The activity must clearly fall outside of full-time (100%) effort in the regular appointment and should not be used as a regular supplement to an individual’s salary.

Overload compensation may be waived if the faculty member chooses to accept payment in the form of faculty research funds. Such requests must be clearly documented, in advance of performing services, in line with the Procedures. Waived compensation in the form of faculty research funds is not considered personal compensation and cannot be used to supplement a faculty member’s full-time annual salary or summer salary in future years.

IV. Consulting

Consulting is an activity performed by a faculty member for compensation because of their expertise in their field (while not acting as a university employee), across any period of the year. Consulting encompasses work including, but not limited to; receiving honoraria for talks, consulting on research with other entities, clinical work with other entities (even when required to continue licensure needed for the faculty member’s appointment), teaching at other institutions, consulting with private industry, and compensated or uncompensated work with faculty-affiliated companies. Consulting is governed by the “Policy on Consulting for Faculty and Members of the Faculty Bargaining Unit” and associated Procedures. It is the responsibility of the faculty member to adhere to all policies and to follow all procedures related to faculty consulting. These can be found at policy.uconn.edu.

Royalties received by a faculty member do not fall under the purview of the consulting policy or any other aspect of this compensation policy.

V. Prizes and Awards

Compensation in recognition of internal or external awards is allowable according to the criteria defined below and does not contribute towards total eligible earnings for regular, summer, and overload pay.

Internal Awards. The University may award faculty in recognition of exceptional teaching, research, or service to the University. Awards should represent significant accomplishment and can in no way reflect payment for services. Whenever appropriate and possible, award programs should reward faculty with faculty research funds (waived compensation) rather than personal compensation. Whether waived compensation or personal compensation, the payment type must be determined and communicated clearly when establishing award criteria and cannot be changed once an award has been granted. An individual faculty member may not normally accept more than $10,000 in personal compensation awards each year. Criteria for awards should be established and communicated in advance of the selection process; the selection of awardees should be conducted by a committee with expertise in the relevant area. Newly established award programs must be approved in writing by the dean and provost in advance. Once an award program has been established, individual award payments in the form of personal compensation must be approved in writing by the dean prior to payment. Internal awards are not considered part of a faculty member’s full-time annual or institutional base salary. Internal awards cannot be charged to grants.

External Prizes and Awards. The University acknowledges that faculty may be the recipient of national and international awards of excellence which may include a monetary award. Such external awards bring recognition to the recipient and to the University. Awards should represent significant accomplishment and can in no way reflect payment for services. Faculty must notify the provost upon notice of award recognition, prior to accepting any compensation, to evaluate whether a monetary award qualifies for this status.[v] External awards are not considered part of a faculty member’s full-time annual or institutional base salary.

ENFORCEMENT

Violations of this policy or associated procedures may result in appropriate disciplinary measures in accordance with University By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, the University of Connecticut Student Code, or other applicable University Policies.

PROCEDURES/FORMS

Procedures for the Faculty Compensation Policy and other resources are available here.

Guide to the State Code of Ethics

[i] Dates defined in Faculty Compensation Procedures/Pay Model

[ii] Defined in Faculty Compensation Procedures/Pay Model

[iii] Dates may vary in leap years. Office of Payroll determines exact dates of work period according to Faculty Pay Model.

[iv] Defined in Faculty Compensation Procedures

[v] Provost will consult with appropriate offices, including Office of University Compliance and Tax and Compliance. Protocols defined in Faculty Compensation Procedures

POLICY HISTORY

Policy Created: April 11, 2006 [Extra Compensation Policy Approved by the Board of Trustees]

Revisions: June 13, 2022 [Approved by the President; Effective date November 10, 2022]; June 10, 2015 [Approved by Board of Trustees]; September 26, 2006 [Approved by Board of Trustees];

Employment and Contracting for Service of Relatives, Policy on

Posted on May 24, 2011February 6, 2024 by Fearney, Kimberly

Title:	Employment and Contracting for Service of Relatives, Policy on
Policy Owner:	Office of University Compliance and the Office of Faculty & Staff Labor Relations/Human Resources
Applies to:	Faculty, Staff, Others
Campus Applicability:	All Campuses
Effective Date:	February 7, 2011
For More Information, Contact	Office of University Compliance and the Office of Faculty and Staff Labor Relations (Storrs) or Human Resources (UConn Health)
Contact Information:	UConn Health: (860) 679-4180 or (860) 679-2426 Storrs/Storrs Based Campuses: (860) 486-2530 or (860) 486-5684
Official Website:	https://compliance.uconn.edu/ethics-overview/ or http://lr.uconn.edu

PURPOSE

The employment or contracting for service of relatives in the same department or area of an organization may cause conflicts and serve as the basis for complaints concerning disparate treatment and favoritism as well as violations of the state’s Ethics statute.

This policy is established to protect against such conflicts and complaints, and to provide for the ethical and legally consistent treatment of individuals with relatives seeking employment or who are employed by the University.

POLICY

No employee of the University of Connecticut may be the direct supervisor of or take any action which would affect the financial interests of one’s relative. This may include decisions regarding appointment, award of a contract, promotion, demotion, disciplinary action, discharge, assignment, transfer, approval of time-off, and approval of training or development opportunities, as well as conducting performance evaluations or participating in any other employment action, including serving on a search committee acting on a relative’s application, or otherwise acting on behalf of a relative except as noted under “Procedure” below. Further, no employee may use his/her position to influence an employment action of a non-relative if such action would benefit one’s relative.

For purposes of this policy, relative is defined as: spouse, child, step-child, child’s spouse, parent, brother, sister, brother-in-law, sister-in-law, dependent relative or a relative domiciled in the employee’s household.

PROCEDURE

The University recognizes the potential for conflict of interest, claims of disparate treatment and/ or discrimination in the employment of relatives in the same department, work unit or in a direct or indirect supervisory relationship. The University further recognizes that there are infrequent but compelling circumstances under which such employment relationships may be in the best interests of the institution. Thus, to protect both the involved employee and the institution in those situations, the following procedure must be followed.

No employee may sign any document that would affect an employment action on behalf of a relative.
An employee who is confronted with an employment decision or action involving a relative must inform the immediate supervisor in advance, in writing, of the situation. The employee will describe the relationship and the proposed action requiring a decision by using Section 1 of the Conflict of Interest (COI) Disclosure form available here.
The COI is submitted through the supervisory chain to the dean/director and then to the appropriate senior manager. Using Section 2 of the COI Disclosure form, the dean/director shall propose to the senior manager an appropriate conflict resolution plan (CRP) to resolve the conflict. In general the CRP should address how the required decisions will be made to avoid any conflicts.
The senior manager shall determine if the proposed plan for the resolution of the conflict is within the best interest of the institution, and approve or modify the plan using Section 3 of the COI Disclosure form. The written resolution and implementation of the plan shall be communicated to the dean/director and through the supervisory chain to the employee(s) involved in the conflict of interest.
The supervisor, dean/director, or provost/vice president (the first level outside of the reporting process of each person in the conflict) shall oversee the implementation of CRP.
Should the conflict involve the provost or a vice president, then the actions/decision shall be directed to the president or designee.

Note: Under no circumstances will the University approve the employment of dependent children or step-children as student employees under direct or indirect supervisory relationships.

* Senior Manager is defined as the Provost or Vice President level.

POLICY HISTORY

This policy was approved by the Board of Trustees on 11-09-2010.

Electronic Privacy and Disclaimer Notice

Posted on May 19, 2011April 5, 2019 by Fearney, Kimberly

Title:	Electronic Privacy and Disclaimer Notice
Policy Owner:	Information Technology Services
Applies to:	Faculty, Staff, Students
Campus Applicability:	Storrs and Regionals
Effective Date:	June 14, 2007
For More Information, Contact	Information Technology Services
Contact Information:	(860) 486-4357
Official Website:	https://its.uconn.edu/

Background and reason for the policy: The University of Connecticut maintains the University of Connecticut website (http://www.uconn.edu/) as a service to its students, employees and external constituencies.

It is the policy of the University of Connecticut to respect and protect the privacy of its website users consistent with Federal and State laws such as:

Family Rights and Privacy Act (FERPA),
the Health Insurance Portability and Accountability Act (HIPAA),
the Electronic Communications Privacy Act (ECPA),
the Gramm-Leach-Bliley Act (GLB),
the Children’s Online Privacy Protection Act (COPPA),
the Connecticut Freedom of Information Action (FOIA), and
the Connecticut Personal Data Act.

Purpose of Policy: The purpose of this policy is to ensure that all official University of Connecticut websites include an electronic privacy statement about the information that is collected by their website (both automatically and voluntarily) and how that information is used.

Expected Institutional Outcome: It is expected that this policy will result in better protection of visitor’s privacy by clarifying the University’s commitment to privacy and to address concerns about the types of information gathered during the course of visiting any official website, and how the University uses that information.

Applicability of Policy: This policy applies to all information collected by or submitted to official websites of the University of Connecticut and to all visitors to these websites.

Definitions:

Official University Websites: Websites that are sponsored by the University of Connecticut, whether they are stored on the University’s central server, on a University distributed server, or on a hosted or managed web server provided by a third party.

Official University Webpages: Official University of Connecticut webpages are those that have been created by the University, its campuses, colleges, schools, departments or other administrative unit, for University business. Official University webpages clearly convey a relationship to the entire University and support and advance the University’s mission.

Statement of Policy:

All official University of Connecticut websites will be required to adhere to the terms and conditions employed at the University of Connecticut as outlined in this policy and inform visitors of how information at that site is managed through the posting of an electronic privacy and disclaimer statement. Individual web sites may either link to the University’s Electronic Privacy and Disclaimer Notice (University’s Notice) or develop specific notices about the collection and use of any information associated with their pages consistent with the University’s policies.

Terms and Conditions Governing Official University of Connecticut websites:

1. Use of Social Security Number: As indicated by the Social Security Number policy, the University of Connecticut considers the social security number as registered confidential and legally protected data. Collection, storage and use of the social security number will be in accordance with the Social Security Number policy.

2. Public and Non-Public Information: The University of Connecticut designates certain information pertaining to students as public or “Directory Information.” The specific data that is classified as “Directory Information” can be obtained from the Registrar’s Office FERPA web page (http://ferpa.uconn.edu/). Except when requested in writing by the individual, “Directory Information” may be distributed electronically and/or made available on the web without providing any security protection for the information. Non-public information (or when requested by the individual, public information) must not be made available via the web, nor stored for internal use via the web, nor transmitted electronically, even to those who are entitled to the information, without utilizing adequate security measures.

3. Use of Cookies: Cookies are small pieces of data passed from a web site to your hard drive usually to enable some online services to work more efficiently or to make the use of services more convenient. The University of Connecticut generally will not use cookies to track and/or retain personally-identifiable information without proper notification. However, the University reserves the right to associate personally- identifiable information with cookies. Such information will not be disclosed to outside parties unless legally required to do so in connection with legal proceedings or law enforcement investigations.

4. Use of Email: In spite of the good intentions of the University to respect the privacy of individuals, it should be understood that it is impossible to assure the privacy of email. Not only may email be sent to someone other than the intended recipient (either through mis-addressing or forwarding), but email sent as plain text may also be intercepted as it travels over the network. In addition, as part of the University’s backup and archival practices, email may continue to exist in spite of the owner’s belief that the message had been deleted.

5. Use of Forms: The University of Connecticut respects your privacy and does not condone providing any of your personal information to third parties without your permission, unless compelled by law or court order to do so, or to sell any personal information to third parties for purposes of marketing, advertising, or promotion.

6. Collection and Use of Information: In the course of visiting a web site, the University of Connecticut permits the following information to be collected, stored and used:

a. Automatic Information Collected

i. Routing information such as IP address. Routing information is used to route the requested web page to your computer for viewing.

ii. Essential technical information including, but not limited to: page accessed; time and date accessed; operating system used; type of browser used; information about the web site from which you accessed a University of Connecticut web site and connection statistics (e.g. ports, number of bytes, number of packets, time of 1^st and last packet, etc.). Essential technical information is used for such purposes as helping to respond to your request in an appropriate format and helping to plan website improvements.

This information is not to be reported or used in any manner that would reveal personally identifying information or to be released to any outside (third) parties unless legally required. However, it should be noted that when required by law, this information, along with other information that might be available, may enable us to identify an individual involved in a specific transmission.

b. Personal Information Voluntarily Provided by the Individual

In the course of visiting a web site (e.g. sending an email message, filling in an on-line form, etc.), individuals may choose to provide additional personally- identifying information such as name, address, email address, social security number, password, bank account information, credit card information, or any combination of data that can be used to identify an individual. Optional information, including any email communications, is retained in accordance with the University’s records retention schedules and may be subject to public inspection and copying if not protected by federal or state law.

7. Links: The provision of links from official University of Connecticut web sites to other sites does not imply endorsement of the information or services offered by these linked sites nor does the University’s privacy policies apply to these other sites. Individuals who choose to link to any third party site should review the privacy practices of that site before providing any personally identifiable information to that site.

8. Limits to Privacy: The use of University resources, including computing and networking equipment and services, purchased with University funds, are intended for University business. While it is not the intention of the University to actively monitor communications or files stored or transmitted on University systems or devices, individuals must understand that under certain circumstances they may not have a right to privacy to such information. Such circumstances include but are not limited to: compliance with legal requirements or process; investigation of suspected violations of law, regulation or University policy; maintaining the integrity of the University’s computing systems.

9. Freedom of Information Requests: Under the “Connecticut Freedom of Information Act,” except as otherwise provided by federal law or state statute, all records maintained or kept on file by or at the University of Connecticut are considered public records and are subject to inspection by members of the public. As a member of the University community, your email and any information collected in the course of visiting a web site are considered public records and may be subject to Freedom of Information disclosure. In some cases, email messages about students may fall under the FERPA definition of “education records” and therefore may be subject to the provisions of FERPA regarding the release of the information and the student’s right to inspect and review the information.

10. Disclosure of Personal Data to Third Parties: In some cases the University may share personal data with third parties with whom we have a business arrangement. In all cases, the department entering into the agreement will ensure that the third party has formally agreed to protect the security of that data in compliance with the University’s Confidential Electronic Data Security Standard.

Responsibilities:

The Chief Information Officer has overall responsibility for this policy.

Questions concerning this policy may be directed to the IT Security Officer or to the University Privacy Officer.

The Chief Information Officer will review this policy on a bi-annual basis and respond to formal complaints resulting from the implementation of this policy.
Violations of this policy will result in appropriate disciplinary measures in accordance with University Laws and Bylaws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Conduct Code.

Electronic (E-mail) Communication Policy

Posted on May 19, 2011August 31, 2023 by Fearney, Kimberly

Title:	Electronic (E-mail) Communication Policy
Policy Owner:	Information Technology Services
Applies to:	Faculty, Staff, Affiliates and Student Employees
Campus Applicability:	Storrs and Regionals, except UConn Health
Approval Date:	August 30, 2023
Effective Date:	October 1, 2023
For More Information, Contact:	UConn Information Technology Services
Contact Information:	techsupport@uconn.edu
Official Website:	https://its.uconn.edu

DEFINITIONS

University Provided Email Services – University-provided email services refers to the email accounts and related services that educational institutions offer to their students, faculty, and staff. These email services can be hosted on the University’s servers or in the cloud and come with an email address in the form of username@uconn.edu

PURPOSE

This policy applies to all uses and users of University provided email services, including faculty, staff, volunteers, contractors and affiliates. The purpose of this policy is to describe the permitted and appropriate use of University provided email to ensure compliance with relevant laws, regulations and policies, including those concerning the retention and protection of emails and attendant data.

POLICY STATEMENT

The University provides email services to support activities associated with academic, administrative, research and philanthropic functions in support of its overall mission. The University recognizes and has established email as an official means of communication. All faculty and staff are provided a UCONN.EDU email account which is the official address to which the University will send email communications. All communications related to University functions shall use the University provided email services to ensure compliance with University policies and regulatory compliance.

Individual Users are expected to read in a timely manner all official University email messages sent to their University email address.

University email services are provided solely for the purpose of conducting University business and are subject to all applicable University policies including the Code of Conduct as well as state and federal laws. Occasional use of email services for personal, non-University related purposes is allowed but subject to the Code of Conduct.

University email accounts and information sent via University email services are the property of the University. As a public institution, with limited exceptions, virtually all University records, including email communications, are subject to laws governing public records. Because University email accounts are University property, the University has the right to access such accounts for legitimate business purposes as may be required and/or authorized by appropriate parties. This includes but is not limited to access necessary to respond to requests made pursuant to the Connecticut Freedom of Information Act (FOIA), the Family Educational Rights and Privacy Act (FERPA),and/or subpoenas. Individuals are prohibited from directly accessing the email accounts of others unless they are authorized to do so for University business purposes.

Users of University email services are responsible for safeguarding the privacy and security of information sent electronically in accordance with applicable laws and policies. Automated copying or forwarding of email from University accounts to non-University accounts is prohibited. Any user who moves a copy of email sent to a University email account to a non-University email account expressly assumes personal responsibility for the security and privacy of that email and any information contained therein. Moving a University email into a non-University account may subject the non-University account to review in response to a subpoena, FOIA request or other legal process.

RELATED UNIVERSITY POLICIES

Code of Conduct

Electronic Privacy and Disclaimer Notice

FERPA Policy

General Rules of Conduct

Records Management Policy

University Guide to the State Code of Ethics

POLICY HISTORY

Policy adopted: November 14, 2003

Revisions:
June 1, 2005
June 19, 2007
March 13, 2015
August 30, 2023 (Approved by the Senior Policy Council and the President)

Health and Safety Policy

Posted on May 19, 2011April 27, 2023 by Fearney, Kimberly

Title:	Health and Safety Policy
Policy Owner:	Department of Environmental Health and Safety
Applies to:	Faculty, Staff, Students, Others
Campus Applicability:	UConn Storrs, Regionals, and the Law School
Effective Date:	April 27, 2023
For More Information, Contact	Department of Environmental Health and Safety
Contact Information:	(860) 486-3613 or ehs@uconn.edu
Official Website:	http://www.ehs.uconn.edu/

PURPOSE

The University of Connecticut is committed to providing a safe and healthful environment for all activities under the jurisdiction of the University. Accordingly, the University has developed this top level over-arching health and safety policy to outline responsibilities and establish the framework of compliance with all applicable Federal, State and local regulations and University policies and procedures pertaining to worker safety and public health.* Compliance with this policy along with subordinate health and safety policies, programs and procedures linked at the end of this policy document is mandatory.

APPLIES TO

This policy applies to all faculty, staff, students, researchers, and all other individuals working at the University of Connecticut Storrs, regional campuses and the Law School.

POLICY STATEMENT

The health and safety of all faculty, staff, students and visitors shall be a principal consideration in the planning and conduct of all University activities and programs, and in the design, construction, modification, or renovation of all University buildings and facilities.

This broad policy requires that health and safety regulations of Federal, State and local authorities, appropriate consensus standards of recognized organizations, and University specific policies are met.

ENFORCEMENT

Violations of this policy including, subordinate health and safety policies, programs or procedures may result in disciplinary measures in accordance with University Laws and By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Code.

PROCEDURES/FORMS

Building and Emergency Contact (BEC) list
Employee Safety Training Assessment (ESTA)
Workplace Hazard Assessment (WHA)

RESPONSIBILITIES

Individuals – Safety is the responsibility of each and every person at the University of Connecticut. All members of the University community are individually and collectively the owners of safety and share the responsibility to provide and maintain a safe environment. Each individual is expected to comply with health and safety regulations and University policies, programs and procedures; perform work in a safe and sensible manner and to act to ensure the health and safety of self, coworkers, fellow students and all others at the University.

Individuals working for the University (employees) are required within five days of employment, transfer or job change to discuss potential hazards that they may encounter during the course of their employment with their supervisor. That discussion shall include identification of workplace hazards along with required controls, personal protective equipment (PPE) and requisite safety training. Completion and submission of an employee specific Employee Safety Training Assessment defines required safety training. Individuals are responsible to comply with defined controls, wear the appropriate PPE and attend requisite safety training in a timely manner.

Principal Investigators/Unit Managers – All personnel who assign and/or oversee work are responsible to ensure that compliant work controls and procedures consistent with Federal, State and local regulations and University policies are implemented to provide for the protection of all personnel and to safeguard the environment. PIs/Unit Managers in consultation with EHS shall respond in a timely manner to address safety complaints, non-compliances and mitigate potentially unsafe conditions. PIs/Unit Managers should set, by example, high standards for health and safety. These standards must be consistently applied and appropriate action taken when personnel fail to meet them.

PIs/Unit Managers (supervisors) are responsible to identify hazards in the work environment along with required controls and PPE using the Workplace Hazard Assessment (WHA) form. The WHA must be kept current and reviewed regularly.

The WHA and the ESTA are generic tools that must be used by the PI/Unit Manager (or designee) to document review of hazards in the workplace along with appropriate controls, PPE and safety training. The ESTA must be completed with the employee within five days of their arrival, transfer or job change. Failure to complete an ESTA or to ensure that employees attend the required training may result in disciplinary action.

Deans, Directors, and Department Heads – Each Dean, Director, and Department Head is charged to ensure organizational compliance with regulations and University policies and with maintaining a healthful and safe environment for all personnel. They are expected to take appropriate action to ensure all identified hazards are addressed and identified issues of non-compliance corrected in a timely manner.

Updates are requested from each Dean, Department Head and Director to the Building and Emergency Contact Listing (BEC List) to ensure the timely and effective communication of information to assigned contacts within each building, regarding emergencies, incidents, projects, and other activities that may impact the health and safety of building occupants.

The Department of Environmental Health and Safety (EHS) – EHS is charged by the University with implementing all University health and safety policies and procedures* in the Biological, Chemical, Occupational, Public Health, Environmental, and Radiation health and safety fields. EHS has been authorized by, and is accountable to, the University President and Senior University Management to identify, assess and enforce this Health and Safety policy and subordinate health and safety regulations, policies, and procedures.

EHS is responsible for maintaining a comprehensive program that combines training, consultation, control, and inspection to protect the health and safety of all personnel in the course of University sanctioned activities. EHS staff provides professional services to measure and evaluate hazards to which the University community may be exposed and ensure compliance with regulations and University policies. EHS’s responsibilities include:

Ensure that all written policies, procedures, and training materials for applicable health and safety regulatory standards are established, current, and available for delivery to appropriate campus groups;
Maintain an up-to-date webpage to enhance access to health and safety policies, procedures, technical guidance documents, and compliance assistance information;
Facilitate health and safety communications with the University community, and stress the importance of campus wide adherence to appropriate regulations, standards, and policies;
Provide graded approach (risk based) inspection services to enhance campus health and safety; and facilitate timely correction of identified non-compliances through escalating notification and enforcement;
Verify completion, adequacy, and adherence to required health and safety tools (e.g., WHA, ESTAs);
Promote EHS’s role as an environmental health and safety information resource ready to meet the needs of the campus community; and
Take appropriate measures (including Stop Work Authority for imminent hazard situations) to maintain acceptable margins of safety and regulatory compliance over all University operations.

* Matters pertaining to public safety, fire safety, and building code compliance, are addressed by other units within the Division of University Safety.

Administrative Oversight – The Associate Vice President of University Safety and the Director of EHS review and approve health and safety policies for the University on behalf of the President and Board of Trustees. The Associate Vice President of University Safety is the responsible Senior University Manager for EHS and oversees the implementation of these policies.

COMMITTEES

Environmental Health and Safety Committee

The Environmental Health and Safety Committee has a diverse membership appointed by the Associate Vice President of University Safety. Members represent the administration, faculty, and staff along with collective bargaining units, and students. The Committee meets quarterly, as mandated by CT General Statute 31-40v, “Establishment of Safety and Health Committees by Certain Employers,” to fulfill its functions and responsibilities. The committee is charged with but not limited to establishing procedures for sharing ideas with the employer concerning:

Safety inspections;
Investigating safety incidents, accidents, illnesses, and deaths;
Evaluating accident and illness prevention programs;
Establishing training programs for the identification and reduction of hazards in the workplace which damage the reproductive system of employees; and
Establishing training programs to assist committee members in understanding and identifying the effects of employee substance abuse on workplace accidents and safety.

Focused Subject Matter Safety Committees

A number of safety committees reporting to the Vice President of Research have been established that address aspects of health and safety specific to research activities or focused subject matter. These committees serve as advisory boards and research protocol review boards working in partnership with EHS to fulfill University goals. Committee and subject matter information is linked below.

Chemical Hygiene Committee
Institutional Biosafety Committee (IBC)
Institutional Animal Care and Use Committee (IACUC)
Institutional Review Board (IRB)
Laser Safety Committee
Radiation Safety Committee

ENVIRONMENTAL HEALTH and SAFETY POLICIES, PROGRAMS AND PROCEDURES

The University Health and Safety Policy is implemented through a series of policies, programs, procedures and other documents, as appropriate to the operations of UConn. These documents have been developed by EHS in response to regulatory requirements and/or University committee decisions. These items, listed below, are mandatory in nature, and must be followed to ensure compliance. They can also be found on the EHS website at: http://www.ehs.uconn.edu/ppp/

Analytical X-Ray Safety Program
Arboricultural Operations Procedures
Asbestos Management Plan
Biological Safety Manual
Bloodborne Pathogens Exposure Control Plan
Chemical Hygiene Plan
Chemical Waste Disposal Manual
Confined Spaced Program
Contractor EHS Manual
Controlled Substances Policy
Electrical Safety Program
Excavation and Trenching Procedures
Fall Protection Program
Food Service Policies
General Workplace Health & Safety Inspection Program
Hazard Communication Program
Hearing Conservation Program
Laboratory Chemical Inventory Program
Laboratory Inspection Program
Laser Safety Manual
Lockout/Tagout Program
Occupational Health and Safety Program for Animal Handlers
PCB Management Plan
Powered Industrial Truck Program
Radiation Safety Committee Policy on Minor Modifications to an Existing Protocol
Radiation Safety Manual
Respirator Program
Rooftop Laboratory Exhaust Systems Maintenance Procedure
Silica in Construction Exposure Plan
Silica in General Industry Exposure Control Plan
Space Heaters Policy
Transportation of Biological Materials
Working Alone Policy

POLICY HISTORY

Policy created: 10/14/2014 (Approved by Senior Policy Council)
Revisions: 03/10/2023 (Approved by Senior Policy Council 04/26/2023)

By-Laws, Rules, and Regulations of the University Senate

Posted on May 19, 2011September 4, 2024 by Fearney, Kimberly

Title:	By-Laws, Rules, and Regulations of the University Senate
Policy Owner:	University Senate
Applies to:	Faculty, Staff, Students, Others
Campus Applicability:	All University Campuses, except UConn Health
Effective Date:	August 26, 2024
For More Information, Contact	University Senate Office
Contact Information:	(860) 486-2236
Official Website:	http://www.senate.uconn.edu/

The University Senate By-Laws, Rules, and Regulations are available for download as a PDF.

Driving and Motor Vehicle Policies

Posted on May 19, 2011October 10, 2017 by Fearney, Kimberly

Title:	Fleet Services Manual
Policy Owner:	Transportation Services
Applies to:	Faculty, Staff, Students, Others
Campus Applicability:	Storrs and Regional Campuses
Effective Date:	October 9, 2017
For More Information, Contact	Transportation Services
Contact Information:	(860) 486-6685
Official Website:	http://transpo.uconn.edu/

Purpose

The University of Connecticut (UConn) Fleet Services relies on the operation of UConn-owned motor vehicles to conduct official business. UConn Fleet Services is committed to minimizing transportation costs, reducing risk, safeguarding personnel, protecting and maintaining property, and clarifying acceptable use This policy manual was developed to support these commitments.

The full Fleet Services Manual is available via PDF.

University Policies

Author: Fearney, Kimberly

Financial Conflicts of Interest in Research

BACKGROUND

PURPOSE

APPLICABLE FEDERAL REGULATIONS

DEFINITIONS

PROCEDURES

REFERENCES

POLICY HISTORY

Financial Aid Code of Conduct

FERPA Policy

Faculty Compensation, Policy on

Employment and Contracting for Service of Relatives, Policy on

PURPOSE

POLICY

PROCEDURE

POLICY HISTORY

Electronic Privacy and Disclaimer Notice

Electronic (E-mail) Communication Policy

DEFINITIONS

PURPOSE

POLICY STATEMENT

RELATED UNIVERSITY POLICIES

POLICY HISTORY

Health and Safety Policy

By-Laws, Rules, and Regulations of the University Senate

Driving and Motor Vehicle Policies

Reportline

Related Links