Project Sunlight

Project Sunlight

Project Sunlight, a component of the Public Integrity Reform Act of 2011 (Ch. 399, Part A, §4, L. 2011), is a New York State online database that provides the public with an opportunity to see what entities and individuals are interacting with government decision-makers at the various State entities. Effective January 1, 2013, State entities (including SUNY State-operated campuses) are required to report to the OGS database any'appearances' by individuals/firms who "appear" before State decision-makers, or persons who advise decision-makers (decision makers and decision advisors are considered 'covered individuals' under the law). The Project Sunlight database, hosted by the NYS Office of General Services, aggregates the inputted data and and makes it available to the public for viewing. A New York State Project Sunlight Policy was developed to clearly define what 'appearances' must be reported under the law.

Law and Regulation

Law

S5679-2011: Public Integrity Reform Act of 2011, Ch. 399, Part A, §4, L. 2011.

Regulation

New York State Project Sunlight Policy, prepared by the New York State Governor's Counsel's Office and the Office of General Services.

∧ Back to Top  

New York State Resources

Project Sunlight Database

New York State Project Sunlight Public Database, URL: http://www.projectsunlight.ny.gov/

FAQ

Office of Governor’s Counsel FAQ Regarding Project Sunlight, prepared by the New York State Governor's Counsel's Office and the Office of General Services.

Database Login Access:

The following are instructions to obtain Administrative Access to the Project Sunlight Database (to be able to enter Project Sunlight Appearances). In order to input campus appearances into the NYS Office of General Services (OGS) DATABASE, SUNY Campuses need to obtain specific login credentials. Campuses are responsible for entering their appearances into the database in order to fulfill their reporting obligations.

There are two steps for campuses to be able to enter appearances into the database:

  1. Obtaining Login Credentials to the Database:
    A. Fill out form Project Sunlight User Request and send to Contact@ProjectSunlight.ny.gov.
        Campuses must fill out the Project Sunlight User Request to request database access for the specific campus employees who will be entering the campuses appearances into the Project Sunlight Database.
        In order to complete the form, the employee will need to provide their individual SUNY ID when requested. The SUNY ID is also their NYSDS #, and the HR or payroll office at each campus should have this information.  
        Once the User Request is filled out, it should be sent to the Office of General Services directly OGS at Contact@ProjectSunlight.ny.gov
  2. Add Project Sunlight Portal Access to the SUNY Employee Services Portal 

    SUNY campuses must access the Project Sunlight database through the SUNY Portal.  this is different than all other State agencies that access the database.  
    Since SUNY employees must have the link to appear on the SUNY Employee services portal, SUNY employees who will be users of the Project Sunlight Portal must request the “Project Sunlight - Access to NYS application” permission from their campus security administrator.  To find Campus Security Administrators, look at the SUNY help page [URL: https://idm.suny.edu/security/login/help.do?action=chooseCampus].

  3. Entering Appearances into the Database:
    Once a campus has fulfilled Step 1 and has established credentials to access the OGS database, they must log into the database by accessing it via the SUNY Portal, NOT by going to the Project Sunlight Login webpage as other NYS Agencies would do.
    • To Access the SUNY Portal:
      • Once the permission is assigned to the SUNY Employee, they will need to log into the SUNY Portal, select the E-Business Services tab, and choose the “NYS – Project Sunlight” link provided. The SUNY portal URL: https://www2.sysadm.suny.edu/employeeServices/main/employeePortal.cfm?category=E-Business].
      • After logging into the Portal with your SUNY Campus ID and Password, you click on NYS – Project Sunlight, which brings you to the NYS/SUNY landing page: https://ws04.nyenet.state.ny.us/SUNYfederation/.
      • Then you click a button to go to the NY.gov ID portal: https://my.ny.gov/bin/MyNy.
        • At this point the user will be directed to the NYS Portal via the OFT/SUNY federation. User’s should then follow the directions provided on the NYS Portal and proceed to the web page where the Project Sunlight option will be available. If this is the first time you have accessed a NYS federated service the initial login can take some time, please be patient.
        • SUNY users should not access the Project Sunlight application directly via the NYS Portal Login page. This will lead to problems with their NYSDS account and is not the approved method of access for SUNY members.
        • In case there are any problems please close your browser and try logging in again. If you continue to have a problems accessing the “Project Sunlight” link or if the link does not appear in your SUNY Portal please contact your local SUNY Portal Security Administrator or help desk. Campus specific contact information is available on your individual campus SUNY Portal login screen.

New York State Training Materials

∧ Back to Top  

SUNY Project Sunlight Information and Resources

Training

Forms

SUNY System Administration Microsoft Word Form for Campus Use: The campus can use this microsoft word form as a template to create their own fillable PDF form for purposes of gathering information that must be reported into the Project Sunlight database.

Communications

System Administration - Specific Information and Forms

∧ Back to Top  


Project Sunlight at SUNY - Guidance for SUNY Campuses

Compliance Mandate

SUNY is required to report to an electronic OGS database appearances by individuals and firms (whether they represent themselves or others) who or that appear before State decision-makers or persons who advise decision-makers, with respect to five categories of matters if:

5 categories of matters that require reporting to the Project Sunlight Database:

  1. Procurement of a State contract for real property, goods, or services over $25,000 (including SUNY purchases, revenue contracts, real estate sale contracts, facilities use contracts, etc.)
  2. Rate-making
  3. Regulatory matters
  4. Judicial or quasi-judicial proceedings, and
  5. Rule-making per the State Administrative Procedures Act

Time Requirement:

Appearances must be reported to the database within five (5) business days of the appearance.

Definition of "Appearance":

An "appearance" for purposes of Project Sunlight is a substantive interaction that is meant to have an impact on the decision making process of a state entity. In order to constitute an appearance, the interaction must be an in-person meeting or a video conference. For Project Sunlight purposes, it does not matter WHO initiated the appearance.

Project Sunlight's Impact on SUNY Business:

SUNY is mostly impacted in the areas of procurement and activity related to contracts (SPENDING OF STATE FUNDS or appearances related to potential SUNY CONTRACTS), and to a lesser extent in rule-making activities (including rule-making related to tuition and fees) and some activities of the Charter Schools Institute.

∧ Back to Top  

Reporting

∧ Back to Top  

Other Important Notes about the law:

∧ Back to Top

WHO is a Covered Individual Under the Project Sunlight Law?

Project Sunlight requires agencies to report appearances between vendors and covered individuals. A covered individual is defined as someone with the power to exercise agency discretion in one of the covered categories, e.g. procurement, or someone who advises a person who has such discretion. Who qualifies as such a decision maker within SUNY for Project Sunlight purposes? The statute and guidance issued by the Governor’s Office are intended to be interpreted broadly. However, the following is offered in order to assist campuses with their Project Sunlight compliance efforts. In the procurement area, campuses will have different levels of employees who have the authority to make or influence procurement decisions and will be covered individuals under Project Sunlight. Campuses should evaluate their own administrative structure and err on the side of caution to include necessary training and reporting by those individuals who have the authority to make or influence purchasing decisions in the magnitude covered by Project Sunlight.

At the least, this category of decision makers will include:

Retaining a list of Covered Individuals at Each Campus: Each SUNY campus will be required to retain a list of those employees who will always be reporters under the law. Those who could be ‘decision-makers’ based on a factual analysis, on a case-by-case basis, will have to be trained in the event that any interaction they have would become an ‘appearance’ under the law. Each campus is required to keep records of all of those individuals who have been trained.

∧ Back to Top

WHAT needs to be Reported into the OGS Database?

∧ Back to Top

Required Action by SUNY Campuses for Compliance with Project Sunlight

  1. Each campus and other operational centers/units (e.g. Charter Schools Institute) should designate one or more individuals who are responsible for entering data in the OGS Project Sunlight database and individuals who should undergo Project Sunlight training. These individuals must be reported to OGS so that they can be given access to the database portal.
  2. Each campus and operation center/unit should develop procedures to assure that SUNY individuals before whom outside individuals and firms make reportable appearances either complete the OGS form or convey notice of the appearance to the SUNY individual responsible for entering data in the OGS database.
  3. SUNY System created a compliance plan with Project Sunlight to be used by all campuses per the Governor's Counsel's Office communication mandating compliance plans are adopted by each state entity.
    1. Obtaining Login Credentials to the Database: Fill out form Project Sunlight User Request and send to Contact@ProjectSunlight.ny.gov.
      Campuses must fill out the Project Sunlight User Request‌ to request database access for the specific campus employees who will be entering the campuses appearances into the Project Sunlight Database. Once the User Request is filled out, it should be sent to the Office of General Services directly OGS at Contact@ProjectSunlight.ny.gov
    2. Entering Appearances into the Database:
      Once a campus has fulfilled Step 1 and has established credentials to access the OGS database, they must log into the database via the SUNY Portal (not by going to the Project Sunlight Login webpage[https://projectsunlight.ny.gov/login] as other NYS Agencies would do).
      • Once the permission is assigned the SUNY Employee, they will need to log into the SUNY Portal, select the E-Business Services tab, and choose the “NYS – Project Sunlight” link provided. The link to access the SUNY portal is here [URL: https://www2.sysadm.suny.edu/employeeServices/main/employeePortal.cfm?category=E-Business].
      • After logging into the Portal with your SUNY Campus ID and Password, you click on NYS – Project Sunlight, which brings you to the NYS/SUNY landing page: https://ws04.nyenet.state.ny.us/SUNYfederation/.
      • The you click a button to go to the NY.gov ID portal: https://my.ny.gov/bin/MyNy.
        • At this point the user will be directed to the NYS Portal via the OFT/SUNY federation. User’s should then follow the directions provided on the NYS Portal and proceed to the web page where the Project Sunlight option will be available. If this is the first time you have accessed a NYS federated service the initial login can take some time, please be patient.
        • SUNY users should not access the Project Sunlight application directly via the NYS Portal Login page. This will lead to problems with their NYSDS account and is not the approved method of access for SUNY members.
      • In case there are any problems please close your browser and try logging in again. If you continue to have a problems accessing the “Project Sunlight” link or if the link does not appear in your SUNY Portal please contact your local SUNY Portal Security Administrator or help desk. Campus specific contact information is available on your individual campus SUNY Portal login screen.
    • The New York State Technical and Substantive Training provides helpful information on how to enter an appearance into the database. The training includes screen-shots to illustrate the step-by-step process for entering all the required information.

∧ Back to Top  


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.

Compliance