Office of University Compliance

University Policy on Policies

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Title: Policy on Policies
Policy Owner: Office of University Compliance
Applies to: University Workforce Members
Campus Applicability: All UConn Campuses, except UConn Health
Approval Date: April 20, 2026
Effective Date: June 15, 2026
For More Information, Contact: Director of Policy, Office of University Compliance
Contact Information: policy@uconn.edu
Official Website: https://policy.uconn.edu

PURPOSE

To establish standards for the development, approval, revision, and decommissioning of University Policies for the Storrs and Regional Campuses, and institution-wide policies that affect all campuses, including UConn Health. This policy aims to ensure that University policies are well defined, understandable, consistent with the University’s mission, values, and goals, and sanctioned by the University’s administrative authorities through standardized processes.

APPLIES TO

All University Workforce Members engaged in the University Policy Process.

DEFINITIONS

Guideline: Recommended guidance or additional information used to support policies and procedures, industry best practice, or intended to educate the workforce on how to achieve a desired outcome. Allows end-user discretion in interpretation, implementation, or use. Non-compliance with, or violation of, guidelines does not create the same level of risk.

Policy Owner: The unit, senior institutional official and/or designee responsible for authoring, implementing, maintaining, and monitoring a policy. Committees may advise on content or participate in review processes, but they cannot serve as Policy Owners.

Procedures: Operational processes established for the implementation of policies. If a policy is “what” the institution does, its procedures are “how” it carries out the requirements of a policy. Non-compliance with, or violation of, procedures may result in disciplinary action.

Procedures

  • outline required actions by objective and/or job function;
  • state clearly and succinctly the step-by-step instructions that must be followed to implement policy effectively;
  • specify the structure to enforce the policy;
  • University Policy procedures shall not be revised without consultation with University Compliance.

Revision, Editorial: Includes modifications related to spelling, grammar, format, and updates to hyperlinks or URLs, contact information, references, titles of individuals and organizations.

Revision, Non-substantive: Includes modifications intended to enhance clarity without changing the intent of the policy, such as adding or modifying definitions, rearranging or re-wording sentences without changing their meaning or the policy’s requirements for compliance.

Revision, Substantive: Includes significant modifications to the nature and/or scope of the policy that affect its requirements, principles, or intent.

Senior Institutional Official (SIO): The appropriate University officer (Vice President, Vice Provost, or similar) who has authority and responsibility for the area or activity to which a policy may apply.

Stakeholder: University members with expertise in the subject matter of the policy, or whose operations will be significantly affected by the policy.

University Policy: An official statement expressing the position of the University on an issue of university-wide importance. A university policy

  • is a governing principle that mandates or constrains actions, establishes rights or obligations, or guides the decisions and actions of the University;
  • has broad application;
  • exists to achieve compliance with applicable laws, regulations, and organizational requirements; to promote operational efficiencies; to enhance the University’s mission; to reduce institutional risk; and/or to promote ethical standards, integrity and accountability;
  • is approved by the administrative authority of the University and/or the Board of Trustees

Policies that do not fit the criteria of a University Policy, such as school, college, center or department policies (“unit policies”), must be vetted through the appropriate Dean or Director to ensure consistent application and to avoid conflict with any University or unit policies. Final approval must be from the Provost or other appropriate Vice President. Units should use a similar policy review process as outlined in this document. Please contact University Compliance or refer to the Policy website for assistance.

University Senior Policy Council: The University Senior Policy Council is a standing committee whose role is to review and approve new and revised University policies.  Additional information, such as membership, can be found on the Senior Policy Council page of the University Policies website.

POLICY STATEMENT

All University Policies shall be developed, approved, revised, and decommissioned in accordance with the procedures outlined in this policy. In rare circumstances, exceptions to this process may be approved by the President in consultation with the University Senior Policy Council with notification to the Board of Trustees, as appropriate.

Units of the University may establish policies within the scope of their delegated authority, provided such policies are consistent with and subordinate to University Policies. Unit-level policies, procedures, and guidelines shall not supersede, contradict, or otherwise diminish the requirements of University Policies.

PROCEDURES

I. New University Policy
II. Revising a University Policy
III. Decommissioning a University Policy
IV. Archiving University Policy
V. Expedited (Emergency) Policy Approvals
VI. Managing and Revising Procedures

I. New University Policy

1. Determine Need

  1. University Policies should only be created when they define University values, institutional objectives or mandates; address federal or state law, regulations, or rules; or manage potential risk or liability.
  2. Any individual or unit may identify the need for a new University Policy. However, a Senior Institutional Official, in consultation with University Compliance, must confirm the need for the policy considering
    • whether the proposed policy meets the criteria of a University Policy as defined;
    • if an alternative such as workforce guidance or procedures is the most effective and efficient approach;
    • if existing University policy addresses or resolves the identified need;
    • implications of the policy including risks and costs (i.e., will adoption of the proposed policy require new resources or reassignment of existing resources?)

2. Development

  1. If a proposed policy involves matters within the purview of more than one Senior Institutional Official, they will ensure consultation and coordination among appropriate leadership.
  2. The Senior Institutional Official may assign the development and administration of the policy to a responsible office or individual (Policy Owner).
  3. The Policy Owner is responsible for developing a draft policy in consultation with key stakeholders and University governance groups (e.g., University Senate, Deans Council). It is advisable that the Policy Owner convene a stakeholder policy development group to provide initial vetting of the proposed policy.
  4. University policy
    • must follow the Policy Template [link];
    • must meet the requirements of the Policy Submission Checklist; and
    • must be written so that it is clear and concise with sufficient information on the subject without being excessive in length or complexity.

3. Engage the Office of University Compliance

  1. Early in the development stages, the individuals or groups developing the policy must notify University Compliance.
  2. University Compliance is responsible for
    • stewardship of the policy development process to ensure consistency with existing policies, language, clarity, format and appropriate vetting and approval;
    • reviewing stakeholder and partner input;

4. Approval

  1. Although the development or administration of a policy may be delegated, the SIO is responsible for ensuring all necessary approvals are obtained.
  2. Once the SIO is satisfied with the final policy draft, it must be forwarded along with the Policy Submission Checklist to University Compliance at policy@uconn.edu. The OUC may consult with the Office of General Counsel for final review.
  3. For policies that apply to the Storrs, Regional and UConn Health campuses, University Compliance will coordinate review and approvals with the appropriate UConn Health policy committees before advancing the policy to the Office of the President. Policies that apply to UConn Health must be approved through that campus.
  4. University Compliance will work with the Office of the President and the SIO to present the draft policy to the University Senior Policy Council for their review and recommendation to the President. There may be occasions when a University Policy requires review and approval by the Board of Trustees prior to adoption.
  5. The President, in consultation with the Senior Policy Council, will make the final determination regarding when a University Policy shall be presented to the Board of Trustees for approval. If so, the proposed policy will typically be assigned to one or more standing Board committees to review and approve before the proposed policy goes to the full Board for final approval. University Policies that advance to the Board for approval are often those that relate to:
    • University governance and describe the composition, powers, and duties of the Board of Trustees, the President, or University Senate;
    • University By-Laws (e.g., academic appointment and tenure; grievances; leaves of absence; naming of facilities; intellectual property; the establishment of new regional campuses, schools or colleges; expressions of dissent; and student residency);
    • Code of Conduct;
    • high-level university financial operations such as investments and the establishment of, or significant changes in existing, major University fiscal policies (e.g., capital expenditures).

5. Publication & Notification

  1. Once the University Policy has been approved, the SIO will collaborate with University Compliance to ensure the policy is posted to policy.uconn.edu (and Policy Manager at UConn Health when appropriate).
  2. The SIO shall oversee the communication, implementation, training, administration, and maintenance of the University Policies within their purview. The SIO must publicize and distribute the policy to the University community members to whom it applies and to offices with implementation requirements.
  3. Policies published to the University’s Policy site are the official and current versions.
  4. Members of the University community are responsible for familiarizing themselves and complying with University Policies.

II. Revising a University Policy

Regularly reviewing policies and procedures ensures that the University’s operations and administration are

  • in compliance with new laws and regulations;
  • current with new systems or technology;
  • consistent with best practices.

1. Review

  1. Policies must be reviewed at least once every three (3) years, or sooner if legal or regulatory requirements or changes in operational processes deem necessary. The Senior Institutional Official, or designee, must ensure the periodic review and revision of policies related to their areas of responsibility.
  2. University Compliance monitors policies for compliance with the required review schedule.
  3. The Senior Institutional Official must notify University Compliance at policy@uconn.edu
    • of necessary changes by providing a strikethrough or “redline” copy of the policy with proposed revisions;OR
    • if review was conducted and there are no necessary changes.
  4. The date of review, even in the absence of revision, shall be noted in the Policy History of the document.

          2. Revision Approvals

          University Compliance, in conjunction with the Senior Institutional Official, will determine if the proposed revisions are editorial, non-substantive or substantive.

          1. Editorial revisions will be completed by University Compliance.
          2. Non-substantive revisions will be completed by University Compliance, who will notify the University Senior Policy Council.
          3. Substantive revisions must follow the same review and approval process as a new policy.

            III. Decommissioning a University Policy

            When a policy is no longer needed or is more effectively combined with another policy, the responsible office will submit a formal request to the Senior Institutional Official responsible for the policy. The SIO shall confer with applicable University governance groups and subject matter experts as appropriate to ensure overall impact is considered.  The SIO will collaborate with University Compliance to seek formal decommissioning approvals. If there is disagreement as to whether a policy should be decommissioned, the University Senior Policy Council will decide.

            University Compliance will remove decommissioned policies from the policy.uconn.edu website and inform the Senior Policy Council of decommissioned policies at the next scheduled Council meeting.

            IV. Archiving a University Policy

            University Compliance will work with University Archives to properly maintain the record. Policy Owners are strongly encouraged to retain policy records.

            V. Expedited (Emergency) Policy Approvals

            The expedited policy approval process is reserved for policies that the President or the Senior Policy Council deem crucial for the health and safety of the University community, the continuity of University operations, to address legal requirements or significant institutional risk and, therefore, must be processed in a shorter time than possible through the established approval process.

            In such cases,

            • the President or the Board of Trustees identifies an emergency policy need and assigns a Senior Institutional Official;
            • the stakeholder review process may be bypassed, but the draft policy must be reviewed by the Senior Policy Council;
            • the Senior Policy Council shall consider any immediate and significant impact on operations;
            • emergency policies that apply to UConn Health shall be provided to the appropriate policy committees for expedited review and approval.

            Unless a shorter duration is specified in the expedited policy, all expedited policies will be reviewed in one (1) year by the Senior Policy Council to determine whether the policy should be extended, made permanent, or decommissioned.

            VI. Managing and Revising Procedures

            Procedures are enforceable operational requirements and so must be formally maintained in a manner that supports auditability, version control, and historical reference. Procedures must not consist solely of links to external websites, webpages, or system content without maintained document history. Instead, Procedures must be embedded within the policy or, if lengthy or operationally detailed, maintained as a separate attendant document with its own approval and revision history.

            ENFORCEMENT

            Violations of this policy and any related 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, and the University of Connecticut Student Code.

            POLICY HISTORY

            Policy created: 03/30/2022 (Approved by the Board of Trustees)
            Revisions:
            12/23/2025 (Approved by the University Senior Policy Council and President)
            04/20/2026 (Approved by the University Senior Policy Council)

            Protection of Minors and Reporting of Child Abuse and Neglect Policy

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            Title: Protection of Minors and Reporting of Child Abuse and Neglect, Policy on
            Policy Owner: Office of University Compliance
            Applies to: All personnel associated with the University including faculty, staff, volunteers, graduate and undergraduate students, interns, residents and fellows.
            Campus Applicability: All UConn Campuses
            Approval Date: April 2, 2025
            Effective Date: April 2, 2025
            For More Information, Contact Compliance and Youth Protection Coordinator/Office of University Compliance
            Contact Information: minorprotection@uconn.edu or (860) 486-2530
            Official Website: https://compliance.uconn.edu/minor-protection/

            Reason for Policy

            The University of Connecticut is committed to promoting a high quality, secure and safe environment for minors who are active in the University community. This policy and the accompanying procedures establish consistent standards intended to support the University in meeting its commitments to promote protection of minors who participate in activities sponsored by the University and to inform all members of the University community of their obligation to report any instances of known or suspected child abuse or neglect.

            Applies to

            This policy applies to all University employees, including faculty, staff, volunteers, graduate and undergraduate students, interns, residents and fellows. Except as provided below, it also applies to any activity that takes place on University property or is sponsored by the University and is open to the participation of minors.

            This policy does not apply to: (1) events open to the public where parents/guardians or adult chaperones are expected to accompany and supervise their children; (2) undergraduate and graduate programs in which minors are enrolled for academic credit or have been accepted for enrollment for academic credit; (3) students who are dually enrolled in University credit-bearing courses while also enrolled in elementary, middle, and/or high school, UNLESS such enrollment includes overnight housing in University facilities; (4) minors employed by the University; (5) field trips or visits to the University that are solely supervised by a minor’s school or organization; (6) patient-care related activities relating to minors; (7) non-University programs undertaking activities in or on University land or facilities under the sole supervision of said program; (8) University programs that take place outside of the University under the supervision of a separate organization; (9) licensed child care facilities; (10) Institutional Review Board (IRB) approved research; and (11) other activities granted advance and written exemption from part or all of this policy.

            Definitions [1]

            A. Authorized Adult: A University employee, student, or volunteer (paid or unpaid) who has (1) successfully passed a Background Screening within the last four years, (2) completed the University minor’s protection training within the last year, and (3) has been registered with the University’s Minor Protection Coordinator.

            B. University Sponsored Activities Involving Minors: A program or activity open to the participation of minors that is sponsored, operated, or supported by the University and where minors, who are not enrolled or accepted for enrollment in credit-granting courses at the University or who are not an employee of the University, are under the supervision of the University or its representatives.

            C. Background Screening: A criminal history search that is consistent with University criminal background check policies and that has been successfully completed within the past four years. Such criminal history search must include the following searches by a nationally recognized background check vendor:

            i.    Social Security Number verification/past address trace;

            ii.   federal criminal history record search for felony and misdemeanor convictions covering, at minimum, the last seven years in all states lived in;

            iii.   a statewide or county level criminal history record search for felony and misdemeanor convictions covering, at minimum, the last seven years in all states lived in; an;

            iv.   sex offender registry searches at the county level in every jurisdiction where the candidate currently resides or has resided.

            D. Child Abuse: A non-accidental physical injury to a minor, or an injury that is inconsistent with the history given of it, or a condition resulting in maltreatment. Examples include but are not limited to, malnutrition, sexual molestation or exploitation, deprivation of necessities, emotional maltreatment, or cruel punishment.

            E. Child Neglect: The abandonment or denial of proper care and attention (physically, emotionally, or morally) of a minor, or the permitting of a minor to live under conditions, circumstances, or associations injurious to the minor’s well-being.

            F. Minor: Any individual under the age of 18, who has not been legally emancipated.

            G. Mandated Reporter: An individual designated by the Connecticut law as required to report or cause a report to be made of Child Abuse or Child Neglect. All employees of the University, except student employees, are Mandated Reporters under state law.

            H. Minor Protection Coordinator: An individual designated by the University to develop procedures to implement this policy and best practices for the protection of minors involved in University Sponsored Activities Involving Minors, and to provide coordination, training, and monitoring in order to promote the effective implementation of this policy.

            Reporting Child Abuse/Neglect

            Pursuant to state law, all University employees (except student employees) are Mandated Reporters of Child Abuse and/or Child Neglect and must comply with the reporting requirements in Connecticut’s mandated reporting laws. See Conn. Gen. Stat. §§17a-101a to 17a-101d.

            Connecticut state law, requires that reports of known or suspected child abuse or neglect be made orally, as soon as possible (but no later than 12 hours), to law enforcement or the Connecticut Department of Children and Families (DCF), and followed up in writing within 48 hours.

            DCF’s 24-hour hotline for reporting suspected Child Abuse or Child Neglect is (800) 842-2288, and additional guidance on these reporting requirements may be found here:

            https://portal.ct.gov/DCF/1-DCF/Reporting-Child-Abuse-and-Neglect (Last accessed July 23, 2018).

            University employees are protected under state law for the good faith reporting of suspected Child Abuse or Child Neglect, even if a later investigation fails to substantiate the allegations.

            In addition to this statutory reporting requirement, University employees must also comply with any other University policies that impose additional reporting obligations, such as the Policy Against Discrimination, Harassment, and Related Interpersonal Violence.

            Requirements for University Sponsored Activities Involving Minors

            To better protect Minors participating in activities sponsored by the University, all University Sponsored Activities Involving Minors must meet the following requirements, in addition to any applicable federal, state, or local law, and all University policies. Please Note: A more comprehensive description of the following requirements are detailed in the accompanying procedures.

            A.   University Sponsored Activities Involving Minors must register with the University’s Minor Protection Coordinator with sufficient advance notice to confirm the requirements of this policy have been met.

            B.   No individual, paid or unpaid, shall be allowed to supervise, chaperone, or otherwise oversee any Minor who participates in University Sponsored Activities Involving Minors unless he or she is an Authorized Adult.

            C. All University Sponsored Activities Involving Minors must implement standards to safeguard the welfare of participating Minors. At minimum, all University Sponsored Activities Involving Minors must implement and comply with University standards of conduct included in the accompanying procedures.

            D. All University Sponsored Activities Involving Minors are subject to periodic audits to verify compliance with this policy and the accompanying procedures.

            E. Any exceptions to these requirements must be requested with sufficient notice and approved in writing by the Minor Protection Coordinator, in consultation with Minor Protection Oversight Committee prior to the start of program operations.

            Enforcement

            Violations of this policy and accompanying 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, and applicable Student Code.

            Policy History

            Policy Created: April 1, 2016 [Approved by the President's Cabinet]

            Revisions:
            August 9, 2018
            April 2, 2025 [Approved by Senior Policy Council]

            Procedures

            Procedures for the Protection of Minors and Reporting of Child Abuse and Neglect

             

            Footnotes

            [1] Several of these definitions are adapted in whole or in part from the Connecticut General Statutes. See Conn. Gen. Stat. § 120. For additional guidance from the Connecticut Department of Children and Family Services about the definitions of child abuse and neglect, see https://portal.ct.gov/DCF/1-DCF/Reporting-Child-Abuse-and-Neglect. (Last accessed 7/23/2018.) Back

            HIPAA- Health Insurance Portability and Accountability Act

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            The University’s Privacy Officer maintains a separate website providing access to HIPAA related resources, including policies, procedures, and forms.

            Please note that the resources at hipaa.uconn.edu apply to HIPAA practices on the Storrs and Regional Campuses.  If you are interested in learning more about HIPAA practices at the University of Connecticut Health Center and its affiliates, please visit UConn Health.

            Use of Students in Outside Employment

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            Title: Use of Students in Outside Employment
            Policy Owner: Office of University Compliance
            Applies to: All Employees
            Campus Applicability: All UConn Campuses
            Approval Date: March 19, 2026
            Effective Date: April 1, 2026
            For More Information, Contact Office of University Compliance
            Contact Information: (860) 486-2530 or universitycompliance@uconn.edu
            Official Website: https://compliance.uconn.edu/

            BACKGROUND

            Involvement of students in the outside professional activities of employees may, under certain conditions, offer the potential for substantial benefits to the education of our students. While these relationships may have educational value for the student, they also have the potential for conflicts of interest. The Code of Ethics for Public Officials precludes public employees from accepting other employment which may impair the employee’s independence of judgment or otherwise create a conflict of interest.

            PURPOSE

            To define requirements for University employees who seek to hire or engage in a business relationship with students for activities external to the University, including both for profit and not for profit activities.

            APPLIES TO

            All employees

            DEFINITIONS

            Business Relationship: A formal association between two or more parties based on mutual economic or organizational interests that include, but are not limited to, equity ownership, voting rights or membership in an LLC. This also includes interests in any company that participates in the University’s Technology Incubation Program (TIP).

            POLICY STATEMENT

            Potential conflicts of interest may occur when a University employee hires or enters into a business relationship with a student in any non-University activity. Therefore, employees who wish to employ or enter into a business relationship with students in any non-University activity must obtain written approval from their Department Head/Dean/Director prior to entering into the arrangement. Employees who wish to employ or enter into a business relationship with a student who they advise or supervise in their University role must receive additional approval from the next level of management above their Department Head/Dean/Director to manage the inherent power difference present in such an arrangement.

            Faculty members who wish to hire a student and who teach a course in which the student is enrolled, serve as a member of the student’s thesis or dissertation committee, or serve as the student’s advisor or director of the student’s thesis or dissertation research, must also receive written approval from the Dean of the Graduate School (for graduate students) or the Vice Provost for Academic Affairs (for undergraduate students).  Faculty members in these cases are not permitted to enter into a business relationship with a student until after the student has graduated or has otherwise left the University.

            Until such time as the employment or business relationship ceases, for the protection of students who may participate in research involving a faculty member’s business or whose work on a thesis or dissertation draws from the faculty member’s business data or research, the student shall have a second (joint or primary) advisor who is not affiliated in any way with the outside employment.

            The University requires that the university employee who hires a student for a non-University activity execute a written Employment Agreement with the student and which includes a specific scope of work or job description, the rate of compensation, and the expected hours of work.  The scope of work in the business or startup should be different from and have no overlap with the student’s thesis or course-based project work.

            The student’s external engagement as an employee should not interfere with the student’s class time and participation in university course work or delay his/her completion of degree. Students must be provided with information about their rights under this policy at the beginning of their employment or business relationship.  In addition, the employed student must receive a fair market value rate of pay.

            Students have the option to discontinue their employment or business relationship at any point with no repercussion, with a recommended best practice of providing appropriate advanced notice. The university employee may not retaliate against a student for the student’s decision to depart from employment or business relationship. Students who feel they have been aggrieved or otherwise have concerns that arise during their term of employment or beyond employment after they may decide to leave may go to the Provost to address their issue. The issues should be documented and substantiated with evidence.  When addressing potential issues regarding the non-University employment of students, or student-employee business relationships, the Provost will consult with the Dean of the Graduate School (for graduate students) or the Vice Provost for Academic Affairs (for undergraduate students).

            ENFORCEMENT

            Violations of this policy and any related 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, and the University of Connecticut Student Code.

            PROCEDURES/FORMS

            Approval Form for Employee and Student Business Relationships
            Use of Students in Outside Employment Letter Template

            REFERENCES

            Intellectual Property and Commercialization Policy

            POLICY HISTORY

            Policy created: 03/01/2004

            Revisions:
            06/23/2008
            12/16/2014
            07/13/2015
            03/19/2026 (Approved by the University Senior Policy Council, President, and State of Connecticut Citizens Ethics Advisory Board)

             

             

            Non-Retaliation Policy

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            Title: Non-Retaliation Policy
            Policy Owner: Office of the President
            Applies to: University Workforce Members, Students, Affiliated Persons
            Campus Applicability: All UConn Campuses
            Approval Date: November 19, 2025
            Effective Date: November 19, 2025
            For More Information, Contact Office of University Compliance
            Contact Information: universitycompliance@uconn.edu
            Official Website: https://compliance.uconn.edu

            PURPOSE

            To demonstrate the University of Connecticut’s responsibility and commitment to protecting individuals within the University Community from Retaliation. The University encourages community members to report suspected violations of University policy or applicable laws and reporters must be able to do so without the fear of Retaliation.

            POLICY STATEMENT

            The University strictly prohibits any form of Retaliation against individuals who engage in a Protected Activity as defined within this policy.

            This policy does not extend protection to those who knowingly submit a Bad Faith Report.

            DEFINITIONS

            Retaliation: Any materially Adverse Action taken or threatened against an individual because of their actual or suspected participation in a Protected Activity or any action taken to discourage or prevent an individual from engaging in a Protected Activity.

            Adverse Action: Any harmful or punitive measure intended to negatively impact an individual’s employment or academic standing, or an individual’s participation in University activities. Examples may include, but are not limited to:

            • termination, demotion, or interference with or denial of promotion or advancement opportunities (whether employment or academic);
            • reduction in grades or academic standing;
            • denial or removal of co-authorship on a publication;
            • poor performance evaluation or disciplinary action without substantiation;
            • exclusion from University programs or activities;
            • decisions related to the terms and conditions of employment or education that create a material disadvantage;
            • physical threats or destruction of personal or University property;
            • any form of harassment, intimidation, or discrimination including humiliation, derogatory or insulting remarks, or social isolation, whether direct or indirect.

            Good Faith Report: A report made with an honest and reasonable belief that a violation of University policy or applicable law may have occurred, regardless of whether it is ultimately substantiated.

            Bad Faith Report: A report made that is knowingly false or that is made with malicious intent.

            Protected Activity: A report made in good faith whether internally or externally; inquiring about suspected  violation of policy or applicable law; opposing or refusing to engage in actual or perceived violations of policy or applicable law; assisting others in making a good faith report; and/or participating in an investigation, review, or proceeding related to such reports.

            REPORTING PROCESS

            If an individual believes they have been subjected to Retaliation, they should contact the office to which their initial complaint was filed or any of the following University offices:

            Storrs & Regional Campuses UConn Health
            The Office of University Compliance
            28 Professional Park, Unit 5084
            Storrs, CT  06269-5084
            Telephone: (860) 486-2530
            Reportline: 1-888-685-2637 or compliance.uconn.edu/reporting-concerns/
            Website: compliance.uconn.edu            		 The Office of University Compliance
            Administrative Services Building
            263 Farmington Avenue
            Farmington, CT 06030-5329
            Telephone: (860) 486-2530
            Reportline: 1-888-685-2637 or compliance.uconn.edu/reporting-concerns/
            Website: compliance.uconn.edu
            The Office of Inclusion and Civil Rights (OICR)
            241 Glenbrook Road
            Wood Hall, Unit 4175
            Storrs, CT  06269-4175
            Telephone: (860) 486-2943
            Email: equity@uconn.edu
            OICR’s Discrimination Complaint Procedures: equity.uconn.edu/policiesprocedures/            		 The Office of Inclusion and Civil Rights (OICR)
            Munson Building
            263 Farmington Avenue
            Farmington, CT 06030-5130
            Telephone: (860) 679-3563
            Email: equity@uconn.edu
            OICR’s Discrimination Complaint Procedures: equity.uconn.edu/policiesprocedures/
             Labor Relations
            9 Walters Avenue, Unit 5075
            Storrs, CT  06269-5075
            Telephone: (860) 486-5684
            Website: hr.uconn.edu/labor-relations/             		 Labor Relations
            Munson Building
            263 Farmington Avenue
            Farmington, CT 06030-4035
            Telephone: 860-679-8067
            Website: health.uconn.edu/human-resources/services/employee-labor-relations/

            ADDITIONAL RESOURCES

            In addition to the resources above, the following offices may be helpful to University workforce members and students who believe they are experiencing retaliation.

            Employee Assistance Program
            Website: https://hr.uconn.edu/employee-assistance-program/

            University Ombuds
            Website: https://ombuds.uconn.edu/

            Dean of Students Office
            Website: https://dos.uconn.edu/

            UConn Cultural Centers
            Website: https://studentactivities.uconn.edu/cultural/

            ENFORCEMENT

            Violations of this policy or related procedures may result in appropriate disciplinary measures in accordance with University By-Laws, General Rules of Conduct for All University Employees and/or Rules of Conduct, applicable collective bargaining agreements, the University of Connecticut Student Code, or resident/fellow codes of conduct.

            POLICY HISTORY

            Policy Created: 9/22/2009

            Policy Revised:
            10/22/2012 (No substantive revisions)
            05/03/2021 (Approved by President’s Cabinet)
            11/19/2025 (Approved by the Senior Policy Council and President)

            Guide to the State Code of Ethics

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            Title: Guide to the State Code of Ethics
            Policy Owner: Office of University Compliance
            Applies to: Faculty, Staff
            Campus Applicability: All Campuses
            Approval Date: October 25, 2023
            Effective Date: October 25, 2023
            For More Information, Contact Office of University Compliance
            Contact Information: (860) 486-2530 or universitycompliance@uconn.edu
            Official Website: https://compliance.uconn.edu

            PURPOSE

            Pursuant to state law, the University is required to adopt in cooperation with the Office of State Ethics, an ethics statement as it relates to the mission of the University. The Code of Ethics for Public Officials (the Code) sets forth principles of ethical conduct that all state employees, including employees of the University, must observe. All employees of the University are expected to become familiar with the Code and comply with all its provisions. This statement is intended to be a general guide to assist you in determining what conduct is prohibited so that it may be avoided. It is not intended to supersede the Code. Please note that under state statute, compliance with the Code is the responsibility of the employee, not the University.

            The Office of State Ethics has jurisdiction to interpret and enforce the Code. Violations may result in a formal complaint proceeding filed against the employee and sanctions of up to $10,000 per violation. The entire Code and regulations, as well as a summary of these rules, may be found at the Office of State Ethics website. For formal and informal interpretations of the Code of Ethics, employees should contact the Office of State Ethics.   In addition, the University must designate an Ethics Liaison as an information resource regarding compliance. An employee who has a question or is unsure about the provisions of this policy, or who would like assistance in contacting the Office of State Ethics, should contact the University’s Ethics Liaison.

            The following general provisions of the Code are applicable to all employees of the University of Connecticut:

            CONFLICT OF INTEREST

            •  GIFTS:  In general, employees are prohibited from accepting gifts, discounts or gratuities of any kind from prohibited donors: (1) doing business with or seeking to do business with the University; (2) directly regulated by the University; (3)  known to be a registered lobbyist or a lobbyist’s representative, or; (4) pre-qualified under Conn. Gen. Stat. §4a-100.  A list of registered lobbyists can be found on the web site of the Office of State Ethics.  Certain items are excluded from the definition of “gift,” including: items offered to the public at large (for example, trinkets provided at an open house), items valued at under $10, food and beverage up to $50 in a calendar year from each donor and training for a product purchased by the University provided such training is offered to all customers of that vendor.  “Gifts to the state” are also permitted as long as the gifts facilitate University actions or functions.  If an employee is offered a benefit from someone other than the prohibited donors listed above, and the benefit is offered because of the employee’s position at the University, the total value of benefits received from one source in a year must not exceed $100.  Additionally, supervisors may only accept gifts valued at no more than $100 from a subordinate; a subordinate may only accept gifts valued at no more than $100 from his/her supervisor.  This provision not only applies to direct supervisors and subordinates, but to any individual up or down the chain of command.  Questions regarding specific facts and circumstances surrounding various gift-giving scenarios should be directed to the University’s Ethics Liaison or the Office of State Ethics.
            • OUTSIDE EMPLOYMENT:  No employee may accept outside employment that will impair their independence of judgment with regard to their state duties or would encourage the disclosure of confidential information gained in state service. Additionally, although an employee may use their expertise, they may not use their state position to obtain outside employment. An employee is not allowed to use their business address, telephone number, title or status in any way to promote, advertise or solicit personal business.  Employees interested in pursuing outside employment may seek and receive written approval from their Supervisor and, if uncertain about the application of the Code, the Ethics Liaison or the Office of State Ethics. For faculty and professional staff, the University of Connecticut By-Laws specifically address consulting, private professional practice, teaching, and other outside employment situations. Faculty and members of the AAUP bargaining unit must adhere to the University’s Faculty Consulting policy as well as the policy on assigning textbooks which they have authored. Union members are referred to contract articles, if such exist, relating to outside employment in their respective collective bargaining agreements. If you are thinking about an opportunity for outside employment, you may also consult with the University’s Ethics Liaison for guidance.
            • FINANCIAL BENEFIT:  Employees may not use their official position or confidential information gained in their service for personal financial benefit, or the financial benefit of a family member or a business with which they, or a family member, are associated.  Employees are prohibited from using state time, personnel or materials, including telephones, computers, e-mail systems, fax machines, copy machines, state vehicles and any other supplies, for personal, non-state related purposes.  It is understood, however, that incidental use of state property for personal use is permissible so long as you reimburse the state for any identifiable charges.
            • CONTRACTS WITH THE STATE:  Employees, their immediate family members, and/or a business with which an employee or their family member is associated may not enter into a contract with the state valued at $100 or more, unless the contract has been awarded through an open and public process. The Code permits an exemption for contracts with a public institution of higher education to support a collaboration with such institution to develop and commercialize any invention or discovery.  The Office of State Ethics has ruled that immediate family members may not be hired as an independent contractor unless there has been an open and public process.
            • APPEARANCE FEES:  No employee may personally accept any fee or honorarium given in return for a speech or appearance made or article written in the employee’s official capacity.  Employees may, however, direct that the fee or honorarium be deposited in a University account to be used for future University-related business activities.
            • NECESSARY EXPENSES/GIFTS TO THE STATE: payment or reimbursement of expenses to participate in a particular event may be acceptable under certain circumstances and, if received from a non-governmental entity, may also require a disclosure filing with the Office of State Ethics. “Necessary expenses" are limited to: necessary travel expenses, lodging for the nights before, of and after the appearance, speech, or event; meals and any related conference or seminar registration fees. “Gifts to the state” may also be acceptable to attend an event that is relevant to your state duties and do not require “active participation”.

            POLITICAL ACTIVITY

            1. Employees are not prohibited from seeking political office as long as it is not done on State time or with State equipment. However, any State employee who is elected to state political office may not be employed by two branches of state government simultaneously. Therefore, any employee who accepts an elective state office must resign or take a leave of absence from his/her position with the University. Consult the University By-Laws and inform your supervisor prior to participating in a political campaign.
            2. No employee of the University will engage in partisan political activities while on state time. Additionally, no employee will use state materials or equipment for the purpose of influencing a political election of any sort.

            MISCELLANEOUS: POST-EMPLOYMENT (REVOLVING DOOR) AND VENDOR NOTIFICATION

            The State Code of Ethics contains several provisions regarding post-state employment. Prior to leaving employment with the University, all employees should review the applicable rules and, if necessary, seek guidance from the Ethics Liaison or The Office of State Ethics.

            • You may never use confidential information for financial gain for yourself or any other person. This is a lifetime prohibition. “Confidential Information” is any information not generally available to the public.  The information may be in any form (written, photographic, recorded, computerized, etc.) including orally transmitted information, e.g., conversations, negotiations, etc.
            • You may not represent anyone concerning any particular matter in which you personally and substantially participated while in state service in which the state has a substantial interest.
            • You may not, for one year, represent anyone before your former agency for compensation
            • If you participated substantially in the negotiation or award of a state contract valued at $50,000 or more, you may not accept employment with a party to the contract for one year after leaving state service, if you resign within one year after the contract was signed.

            No official or employee shall counsel, authorize or otherwise sanction action that violates any provision of the Code of Ethics.

            The provisions of this document shall apply to all employees of the University of Connecticut. All current and future employees of the University shall be supplied with a copy of this document, and it shall be the responsibility of each employee to be familiar with these provisions and to comply with them. It is strongly suggested that employees avoid those situations which may give the appearance of being a conflict of interest. When in doubt or unsure about these provisions, an employee should contact either his or her supervisor, department head, or the University’s Ethics Liaison. Ultimately, The Office of State Ethics is the authority that determines what conduct constitutes an ethics violation under the law. Therefore, you are strongly encouraged to discuss any situation which may pose a conflict of interest or other ethics problem with the Office’s staff attorneys.

            The University will notify vendors/contractors doing business with it of these provisions through its procurement officers. A summary of the State Code of Ethics as it applies to vendors will also be provided. Copies of this policy will be provided upon request.

            Please note: Violations of the Code of Ethics may subject an employee to sanctions from agencies or systems external to the University. Whether this occurs or not, the University retains the right to independently review and respond administratively to violations. The conduct of the review and response will be in accordance with contractual and regulatory guidelines.

            IMPORTANT ETHICS REFERENCE MATERIALS

            It is strongly recommended that every employee read and review the following ethics materials:

            The University’s Ethics Liaison is:

            Kimberly Fearney, Associate Vice President and Chief Compliance Officer
            Office of University Compliance
            28 Professional Park Road (Unit 5084)
            Storrs, CT 06268
            Telephone Number: (860) 486-2530
            Email: Kim.Fearney@uconn.edu

            The contact information for the Office of State Ethics:

            20 Trinity Street
            Hartford, CT 06106
            Office of State Ethics
            Tel: (860) 263-2400
            Fax: (860) 263-2402

            POLICY HISTORY

            Policy created: July 2006
            Revisions: October 25, 2023; February 26, 2014; July 2009

            FERPA Policy

            Posted on by
            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. 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:

                  • 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;
                  • 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. 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.

            1. 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.
            2. 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.
            3. 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:

            1. 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;
            2. Disclosures to University Officials, when it has been determined that the official has a legitimate educational interest; and
            3. Disclosures of Directory Information; and
            4. 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:

            1. 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;
            2. 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;
            3. Financial records and statements of the student’s parents or any information contained therein;
            4. 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;
            5. 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;
            6. 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.);
            7. 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);
            8. 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
            9. 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:

            1. 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.
            2. 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.
            3. 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;
            4. 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;
            5. 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.
            6. 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.

            Employment and Contracting for Service of Relatives, Policy on

            Posted on by
            Title: Employment and Contracting for Service of Relatives, Policy on
            Policy Owner: Office of University Compliance and 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 Human Resources, Labor Relations
            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 https://hr.uconn.edu/employee-relations/

            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.

            1. No employee may sign any document that would affect an employment action on behalf of a relative.
            2. 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.
            3. 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.
            4. 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.
            5. 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.
            6. 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.

            Consulting for Faculty and Members of the Faculty Bargaining Unit, Policy on

            Posted on by
            Title: Consulting for Faculty and Members of the Faculty Bargaining Unit, Policy on
            Policy Owner: Office of the Provost
            Applies to: Faculty and members of the faculty bargaining units; Management-exempt personnel with faculty appointments
            Campus Applicability: All Campuses
            Effective Date: June 29, 2022
            For More Information, Contact: Faculty Consulting Office
            Contact Information: Storrs and Regional Campuses: Sarah Croucher, sarah.croucher@uconn.edu

            UConn Health: Carla Rash, rash@uchc.edu
            Official Website: http://consulting.uconn.edu/

             

            1. BACKGROUND

            The University recognizes the benefits derived from faculty members participating in consulting activities with outside entities. Such activities are vital for professional service, provide intellectual enrichment of faculty members and students, may foster economic development, and enhance the reputation of the University. Participation in such activities is a norm for faculty at all highly ranked U.S. public research universities. All activities where outside compensation is received that are related to the expertise of a faculty member fall within the purview of this policy, as are any activities with faculty affiliated companies.

            2. PURPOSE

            This policy provides a framework for consulting work with external entities to ensure compliance with the State of Connecticut Code of Ethics (Conn. General Stat §1-84(r)), other applicable policies, and to ensure such work does not conflict with University employment.

            3. SCOPE

            This policy applies to all faculty at the University of Connecticut and the University of Connecticut Health Center, and all staff eligible to be members of the faculty bargaining units (hereafter described as “faculty members”). The policy applies to management-exempt employees only when they have a base faculty appointment, as determined by their appointment letter. Faculty members who are employed by the University below 0.5 FTE (full-time equivalent) do not need approval to engage in consulting activities. However, such faculty may voluntarily elect to request prior approval for consulting activities. Once a faculty member in this position has requested approval to consult, all subsequent consulting activities in that reporting year must also obtain such approval.

            4. DEFINITIONS

            1.  Consulting: an activity (e.g., provide services, give advice or analysis) undertaken by a faculty member for compensation as a result of their expertise or prominence in their field, while not acting in their official capacity as a State employee (i.e., in their own time). Activities such as serving on grant review panels, giving talks, or reviewing academic works are classified as consulting when undertaken for compensation. Paid or unpaid work conducted for a faculty affiliated company is also considered consulting.
            2.  Compensation: any form of payment received for the consulting activity. Compensation for consulting activities includes, but is not limited to; honoraria, stipends, payments in goods or services, stocks or stock options, other interests of value, or any forms of compensation (including “luxury travel”) above necessary expenses, even if this is intended to support costs associated with undertaking the activity.
            3.  Contracting entity: the business, nonprofit organization, government body, individual, or other organization that engages and compensates the faculty member for the consulting activity.
            4.  Faculty affiliated company (FAC): A faculty affiliated company (or other legal entity) is a for-profit or not-for-profit business where a faculty member or member of their immediate family: 1) is a director, officer, owner, or limited or general partner or, 2) is a beneficiary of a trust, or holder of stock constituting five percent or more of the total outstanding stock of any class.
            5.  Time due to the University: any time necessary for successfully carrying out the workload duties assigned to a faculty member. The University’s Bylaws and policies prohibit faculty from consulting on “time due to the university.”
            6.  Normal work time: the usual time during which a faculty member is expected to perform their job duties. These times and job duties may be defined in specific appointment letters, workload policies, or other workload assignment documentation.
            7.  Reconciliation: the process of closing out each approved consulting request after the activity has taken place (or was due to take place if it does not occur) by confirming or updating information regarding the time spent consulting and the compensation received.

            5. POLICY

            All full-time faculty members must receive written permission from the appropriate supervisory hierarchy prior to engaging in any consulting activity. All consulting requests and reconciliations must be submitted via the University online consulting request system. Faculty must adhere to the University’s procedures associated with this policy.

            Consulting approval is not required for compensation received from royalties.

            The provost will submit an annual report of consulting activities for all faculty members to the Joint Audit and Compliance Committee of the Board of Trustees. The University's Office of Audit and Management Advisory Services (AMAS) shall develop and implement a plan of regularly recurring monitoring and audits to ensure the complete and accurate implementation of this policy.

            The disclosure of proprietary information (i.e., intellectual property owned in part or in total by the University) is prohibited when consulting unless specific permission is granted.)

            6. ENFORCEMENT

            Violations of this policy may result in appropriate disciplinary measures in accordance with University Bylaws, General Rules of Conduct for all University Employees, and applicable collective bargaining agreements.

            Faculty members who do not receive prior approval under this policy are subject to the jurisdiction of the Office of State Ethics. In addition, the faculty member may be subject to sanctions issued by the University for violating this policy, as outlined in the associated Procedures.

            7. PROCEDURES 

            Procedures on Consulting for Faculty and Members of the Faculty Bargaining Unit are linked here.

            POLICY HISTORY

            *Policy Created: September 25, 2007

            *Revisions: 06/29/2022, 06/29/2019, 03/25/2015, 04/24/2013, 11/12/2012, 04/13/2011, 04/20/2010

            *Approved by the Board of Trustees.

            Compliance Training Policy

            Posted on by
            Title: Compliance Training Policy
            Policy Owner: Office of University Compliance
            Applies to: Workforce Members
            Campus Applicability: All University campuses, including UConn Health
            Approval Date: June 27, 2024
            Effective Date: June 27, 2024
            For More Information, Contact Office of University Compliance
            Contact Information: (860) 486-2530
            Official Website: https://compliance.uconn.edu/

            PURPOSE

            Training is an essential part of an effective compliance and ethics program. As recipients of federal funding, the University is required to provide all Workforce Members, including graduate assistants and affiliated parties, with training on the elements of the University’s Compliance Program and the University’s expectations that all will act in accordance with all applicable University policies, and federal and state laws and regulations. Compliance training is intended to benefit the University community by helping to ensure that its members understand their responsibilities and by fostering a culture of compliance and ethical behavior.

            DEFINITIONS

            Workforce Members: Employees, volunteers, trainees, and other persons whose conduct, in the performance of work for the University, is under the direct control of the University, whether or not they are paid by the University.

            POLICY STATEMENT

            Training Requirements
            All University Workforce Members are required to complete compliance training. Specific training requirements may differ in content, delivery, or frequency based on a Workforce Member’s role and responsibilities at the University in conjunction with other University policies, laws, and regulations.

            Additional or Specialized Training
            Workforce Members may be required to participate in additional and/or specialized compliance-related training to maintain the University’s compliance with applicable University policies, and federal and state laws and regulations. Training may be provided by the Office of University Compliance or another University department or entity with compliance-related responsibilities.

            Attestation
            Upon completion of any required compliance training, Workforce Members may be required to attest that they completed the training, understand the content and resources provided,  as well as the potential disciplinary actions or sanctions that may result from any incidents of non-compliance with University policies and applicable laws and regulations.

            ENFORCEMENT

            Failure to complete assigned compliance trainings by the established deadline may result in appropriate disciplinary measures in accordance with University By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and/or the University of Connecticut Student Code. Management, in consultation with the Department of Human Resources and in accordance with collective bargaining agreements, will be responsible for issuing appropriate disciplinary action for non-compliance.

            POLICY HISTORY

            Policy created: 08/13/2008 Approved by Executive Compliance Committee

            Revisions:  06/27/2024 Approved by the Senior Policy Council and the President; 06/11/2020 Approved by University Compliance Committee and UConn Health’s Administrative Policy Committee on 06/25/2020.