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As we begin a new semester, it is important that all employees (faculty, staff, temporary employees) and graduate students in roles such as teaching/research or who receive stipends, be aware of �պ�����’s compliance program and of our shared responsibility to continually build upon and improve �պ�����’s culture of compliance. The cornerstone of your compliance program is the Code of Conduct and Ethical Standards (the Code). The intent of the Code is to communicate the principles and standards that have been identified as most relevant to the university's stated values, Our Common Ground.

Please review this information carefully and if you have any questions, reach out to the contact person listed in the policy. Alternatively, you can always email the Office of Compliance Services (email link) directly if you have additional questions.

Learn more about the Office of Compliance and Privacy Services

While the Code identifies those policies that are most relevant to Our Common Ground, �պ�����’s institutional policies and procedures extend beyond those identified in the Code. All members of the university community need to be familiar with those policies and procedures applicable to their roles. A full list of �պ�����’s policies and procedures can be found on the Institutional Policy Website.

Here are some policies that everyone should know about:

Conflict of Interest and Conflict of Commitment

According to �պ�����'s Conflict of Interest and Conflict of Commitment Policy, all �պ����� employees, whether full-time or part-time, whether faculty, staff, administrators, or others identified by the President, are required to disclose potential conflicts of interest/commitment as they arise.

All exempt staff (salaried) and all faculty involved in sponsored research are required to file an annual conflict disclosure form using �պ�����’s electronic disclosure system ().

Faculty not involved in sponsored research currently have the option to either disclose in �պ�����Click or disclose using another approved method (check with your chair or dean).

Non-exempt staff (hourly) do not use �պ�����Click but are still required to disclose potential conflicts to their manager or supervisor prior to entering into an arrangement that could pose a conflict.

Examples of potential conflicts and individual requirements are outlined in �պ�����’s policy. More information can be found on �պ�����'s Conflicts of Interest webpage. 

Safeguarding Personal and Protected Information

(Data Privacy and Information Security)

�պ����� has established controls to safeguard all types of university information that includes non-public protected data (NPPD). If we are collecting, accessing, using, disclosing, or storing university information, especially if that information is NPPD as defined in �պ�����’s Privacy Policy we must do our part to protect it.

Do you know whether the data you collect is at high-risk? If you don’t, you should take a moment to review �պ�����’s Data Classification Matrix (PDF). Controls and safeguards include those specified in �պ�����’s Computer, Communication, and Network Technology Acceptable Use Policy, Privacy Policy, Information Security Policy and Information Security Procedures. All members of the university community who have access to university information and systems are responsible for the proper handling of this information.

For more information, visit �պ�����'s Privacy Program webpage and �պ�����'s Information Security webpage.

Protection of Minors & Vulnerable Adults

�պ����� hosts, sponsors, manages, and oversees events and programs in which minors and vulnerable adults participate. The university is obligated to provide a safe environment for those minors and vulnerable adults participating in such programs. To this end, �պ����� has established policies and procedures that set forth requirements related to programs involving minors and vulnerable adults.

One of these requirements is that anyone who is responsible for the care, custody, and control of one or more minors/vulnerable adults must undergo a background check (fingerprint-supported for minors, HR initiated for vulnerable adults) and must complete training prior to their involvement in the program.

In addition, depending on the nature and scope of the program, there may be other contractual or notification requirements. If your department, division, school, college, unit, or program interacts with minors or vulnerable adults, you are responsible to meet �պ�����’s policy requirements. See Protection of Minors, Minors, Reporting Abuse or Neglect of and Crimes, Minors in Laboratories, and Vulnerable Adults, Reporting Abuse, Neglect or Exploitation of, and Crimes policies and procedures. 

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Policy Spotlight

Americans with Disabilities Act (ADA) & Equal Opportunity

Did you know that �պ����� now has an online form for reporting accessibility barriers? Go to �պ�����’s ADA webpage and click on .

As it relates to equal opportunity, remember that all public materials, whether web, print, or non-print, must contain �պ�����’s reasonable accommodation statement and non-discrimination language. If you are responsible for updating your unit’s website, if you send out electronic newsletters or other materials, whether via email, the internet, or the regular mail, make sure that these statements are included.

If you’re not sure, contact �պ�����’s ADA/504 Coordinator (email link) for more information.

Discrimination, Harassment, and Sexual Misconduct (Interim)

As a recipient of federal funding, �պ����� is required to comply with many laws. One of these is Title IX. Title IX requires schools to take prompt action and provide fair treatment to all parties involved. Read �պ�����’s Discrimination, Harassment, and Sexual Misconduct policy.

For more information, visit �պ�����’s Title IX and Sexual Misconduct website.

Compliance in the Headlines

Compliance & Ethics

Privacy & Cybersecurity