The State University of New York is committed to operating with integrity and in compliance with all applicable laws, regulations and policies. The State University of New York has established the Compliance initiative to coordinate SUNY’s numerous existing compliance efforts and act as a resource for the campuses on SUNY’s legal, regulatory, and ethical responsibilities.
The Compliance role is located within the SUNY Office of General Counsel and reports to the Senior Vice Chancellor for Legal Affairs and General Counsel.
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What’s New to the Compliance Website
The compliance website is continually adding new pages featuring information and resources for the SUNY campuses. Below is a listing of some of the recently added content.
- Information Security:
- A new System-wide Information Security Policy, Doc. No. 6900, was adopted by the Board of Trustees September 2016 to ensure that the SUNY’s information assets, including academic, health, research, financial, and other information deemed non-public, are adequately safeguarded. The Policy applies to Community Colleges, State-operated campuses, and Statutory Colleges.
- Clery 2016 Updates:
- The 2016 Clery Handbook: New Developments and Important Changes, URMIA - University Risk Management and Insurance Association White Paper, July 2016, written by SUNY Associate Counsel Joseph Storch, and Andrea Stagg, Deputy General Counsel, Barnard College. Available at: http://tinyurl.com/juaynqu (July 21, 2016).
- U.S. Department of Education, Office of Postsecondary Education, The Handbook for Campus Safety and Security Reporting, 2016 Edition, Washington, D.C., 2016, https://www2.ed.gov/admins/lead/safety/handbook.pdf.
- Table of major and minor changes: http://system.suny.edu/counsel/2016-Clery-Changes/
- MS Word Compare: http://system.suny.edu/media/suny/content-assets/documents/generalcounsel/2011-2016-Compare-of-Handbook-for-Campus-Safety-Security-Reporting.docx
- International: NACUA Note Reporting on Student Safety and Security Abroad 2015, National Association of College and University Attorneys Annual Conference, Joseph Storch and Natalie Mello, Washington, DC (June 30, 2015). Featured on the International compliance page.
- Gender Identity Equality: A newly adopted New York State regulation now formally prohibits discrimination and harassment on the basis of gender identity and transgender status under the New York State Human Rights Law. The regulations (9 NYCRR §466.13) are effective as of January 20, 2016. The SUNY Compliance webpage on Gender Identity Equality discusses what we know about the new law and its impact.
- NYS Human Rights Law: The New York State Human Rights Law is Article 15 of the Executive Law prohibits discrimination on the basis of age, race, creed, color, national origin, sexual orientation, military status, sex, marital status or disability in employment, housing, education, credit, and access to public accommodations. The law was updated in 2015 to enhance employees’ rights in the workplace, specifically regarding workplace discrimination and the categories of protected classes that employers are now explicitly prohibited from discriminating against. The laws became effective on January 19, 2016. The compliance webpage includes a guidance document detailing the various changes and newly afforded protections under the law.
- Sexual Violence Prevention Resources:
- SUNY Sexual Assault & Violence Resources (SAVR): Custom “Sexual Assault & Violence Resources (SAVR)” web-based tool to support victims to support victims of sexual assault or interpersonal violence, whether the victim attends a SUNY school or lives in any one of New York State’s communities. Tools can be customized for use by states and colleges nationally at no cost.
- VAWA Customizable Visa and Immigration Resource: Document is a plain language explanation of visa and immigration options for students who are victims or survivors of sexual or interpersonal violence. The resource is available to SUNY and other higher education institutions throughout the country. The resource web site includes two methods for customizing the document with automatic translation into all available languages. Institutions may use the Excel form/spreadsheet or the Google Docs method. Step-by-step instructions are included on the web site.
- A Plain Language Explanation of Distinctions Between the New York State Penal Law and the College Disciplinary Processes: The 2015 NYS legislation creating Article 129-B requires that college or other officials explain differences between the college process and the criminal justice process in addressing sexual and interpersonal violence. To assist public and private colleges across New York State in complying with this requirement, a small team of attorneys got together to develop a uniform, plain-language document that applies generally. The document is intended to help college officials who are working directly with students explain the differences between the criminal justice system and college disciplinary processes and answer questions. The document is available as a user-friendly website. The site includes the text of the cover memo we prepared, the resource table itself, and the options to download the resource (without the cover memo) as a PDF or Word document, so campuses can refine or personalize to their compliance needs.
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What's New on the System-wide Policies and Procedures Website
- NEW - SUNY Policy Doc. No. 3200 Admission of Persons with Prior Felony Convictions, adopted via Board Resolution Sept. 2016. Effective July 2017.
- NEW - SUNY Policy, Admission of Persons with Disciplinary Dismissals, SUNY Policy 3201, amended pursuant to the Board passage of the SUNY Policy Doc. No. 3200 Admission of Persons with Prior Felony Convictions. Effective July 2017.
- NEW - SUNY Information Security Policy Doc. No. 6900, Policy objective: ensure that the State University’s information assets, including academic, health, research, financial, and other information deemed non-public, are adequately safeguarded.
- UPDATED - SUNY Procedure, Guidelines for Conducting Presidential Search, Doc. No. 8400, amended via Board resolution June 2016.
- UPDATED - SUNY Policy Doc. No. 9600 Foundations Guidelines, amended to reflect changes adopted by the Board of Trustees via resolution June 2016.
- UPDATED - SUNY Policy Doc. No. 9400 Auxiliary Services Corporations Guidelines, amended to reflect changes adopted by the Board of Trustees via resolution June 2016.
- NEW - SUNY Policy Doc. No. 9500 Other Related Entities Guidelines, New Policy adopted by the Board of Trustees via resolution June 2016.
- UPDATED - SUNY Policy Doc. No 9300 Alumni Association Guidelines - amended to reflect changes adopted by the Board of Trustees via resolution June 2016.
- UPDATED - The Form A - Revocable Permit – that accompanies the Use of Facilities by Non-Commercial Organizations Policy, SUNY Policy 5603 has been updated within the policy “Forms” and “Appendices” section.
- UPDATED - The Revocable Permit that accompanies activities involving children pursuant to the SUNY Child Protection Policy, SUNY Policy No. 6505 has been updated to include a new Revocable Permit - Use of University Facilities for Covered Activities Under the State University of New York Child Protection Policy (includes Exhibits B, C & D).
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SUNY Compliance Listservs
In addition, several other Compliance listserv's are maintained in conjunction with particular compliance topics. To join one of these listservs, e-mail the Director of Compliance, who will pass the request along to the appropriate SUNY contact.
Internal Listservs for SUNY Personnel
There are many internal SUNY listservs for the following compliance topics/functions:
- Clery Act Compliance
- Title IX Compliance
- Affirmative Action Officers
- Records Management Officers
- FOIL/ Records Access Officers (State-operated campuses only)
- Ethics Officers - those responsible for JCOPE obligations at their campus (SUNY State-operated campuses only)
- Child Protection Listserv - those charged with facilitating the SUNY Child Protection Policy at their campus location
- Internal Controls Officer and Enterprise Risk Management Listserv - for SUNY campuses charged with facilitating compliance with the Internal Controls Act NYS law, and for those who have been designated with ERM responsibilities at their campus
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Title IX and Sexual Violence Prevention
- Title IX and Clery Training Opportunities website: This SUNY website offers information for campuses on all upcoming webinars and live trainings on Title IX, Clery, and Sexual Violence Prevention. The available trainings used to be communicated solely through the Clery and Title IX listservs, but they are now published on the SUNY website for ease of access and sign-up.
- JCOPE Comprehensive Ethics Training - held almost twice a month
- Upcoming Dates:
- Wednesday, September 14 at 2 p.m.
- Thursday, September 22 at 10:30 a.m.
- Thursday, October 13 at 10:30 a.m.
- Wednesday, October 19 at 2:00 p.m.
- To sign up: Contact your local campus Ethics Officer, usually in the HR department. The information on these modules, and their dates and times, is being communicated to campuses via the campus Ethics Officer.
- Summary of the Training: SUNY System Administration offers JCOPE Comprehensive Ethics Training webinar sessions for State-operated campuses to supplement the JCOPE training that occurs locally at each institution. These sessions are held twice every other month, and are facilitated by the Office of U-Wide Human Resources, the Office of General Counsel, the Compliance Office, and the Office of Information Technology. The goal of these system-wide sessions is to help campuses ensure that their new employees who are required by statute to complete the JCOPE Comprehensive Ethics Training, receive that training in a timely fashion, and in accordance with the statute. The training is also required for those who have not completed the training within the last three years. Therefore, all new employees, and those who completed the training three years ago or longer must complete the training.
- When Eating an Elephant, Where Do you Even Begin? Risk Management & Compliance Responsibilities on Campus, online webinar
- This presentation will be appropriate for employees across the campus in all functional areas, whether they are officially charged with compliance, compliance is only a part of their job, or they are part of a team approach to overall or targeted compliance. Everyone should have a sense of why a compliance function is an asset to an institution, not just those facilitating a compliance program directly.
- Summary of the Training: Creating a program to systematically tackle the compliance obligations of a college or university cannot be accomplished overnight. But take comfort that there are methods and practices you can utilize that will ease your path towards developing a comprehensive, enterprise-wide program that allows your institution to systematically tackle its compliance risks. This process protects your campus by ensuring employees are proactively managing and mitigating compliance risks in the most efficient and thoughtful way, and allows for campus employees to spend as much time as possible on their core mission. The webinar will:
- Define the growing world of compliance requirements in higher education, as well as the expanding costs of non-compliance.
- Lay out different methods of developing a compliance program, and discuss the pros and cons of various approaches.
- Discuss the dangers of silos, and the need to engage partners across the campus in compliance efforts.
- Develop a plan for continuously building compliance capacity in a strategic way, tailoring it to your institutional structure and needs, and identifying strengths in your campus colleagues that can quickly be turned into compliance structures.
- Find already existing resources so you don’t have to reinvent the wheel.
- Discuss the importance of ethics within a compliance program.
- Touch on the importance of documentation, benchmarking, tone from the top, training, and assessment as you grow your program.
Child Protection Policy Training
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The information contained on the SUNY Compliance website is for general campus guidance only and is not intended, nor can be relied upon, as legal advice or the imposition on SUNY campuses of specific policies or requirements. The site is intended to be an informational-only clearinghouse for some of the laws, rules, and regulations that may impact the State University of New York’s campuses. Additionally, given the rapid, changing nature of laws, rules and regulations, there may be delays or omissions contained on this site which therefore cannot be relied upon as complete. For complete compliance information, consult your campus compliance officials. For legal advice, consult your lawyer.