2017 - 2018 Administrative Policy Manual Published February 1, 2018 
    
    Feb 20, 2019  
2017 - 2018 Administrative Policy Manual Published February 1, 2018 [ARCHIVED COPY]

Section 10 - Information, Records, and Publications



10.1 Publicity

Reviewed May 26, 2016

See Board of Regents Policy Manual Section 10.1.

 

10.2 Publications

Reviewed May 26, 2016

See Board of Regents Policy Manual Section 10.2.

10.2.1 The System Supplement

Reviewed May 26, 2016

See Board of Regents Policy Manual Section 10.2.1.

10.2.2 Institutional Publications

Reviewed May 26, 2016

See Board of Regents Policy Manual Section 10.2.2.

All publications, including bulletins, annuals, magazines, etc., published either by students, faculty, or staff of Georgia Gwinnett College (GGC) shall be published only under proper supervision and authority of the President of GGC and adhere to the graphic standards of the institution as outlined in APM 10.50.1 GGC Brand Policy. All financial contracts pertaining to such publications shall be approved by the President or his/her designated representative. The official publication of Georgia Gwinnett College shall be ENGAGE magazine, and it shall be published three times annually in the Office of Public Relations and will contain no paid advertisements/sponsorships.

10.2.3 Publishing Notices of Charges

Reviewed May 26, 2016

See Board of Regents Policy Manual Section 10.2.3

All catalogues, college bulletins, or other publications issued by Georgia Gwinnett College shall contain the following provision printed in boldface type: “All tuition, fees, or other charges are subject to change at the end of any academic term.”

10.2.4 Digital Communications Policy

Reviewed May 26, 2016

10.2.4.1 GGC Website

Reviewed May 26, 2016

The public website is instrumental in serving the communications needs of GGC’s diverse audiences including prospective students, family and friends, current students, faculty and staff, donors, and the community. Working in concert with print and other digital communication tools, including social media, the public website represents the College and serves to reinforce the College’s brand and to positively engage audiences with the College.

The GGC website, as pertaining to this policy, is defined as the public website its content (text, images, downloadable documents, feeds, video, etc.), and third-party sites that can be accessed through the public website, including, but not limited to Claw Link, Get Involved, HireTouch and MyGGC.

GGC website content located in the central content management system (CMS) inherits the approved GGC website design determined by strategic branding attributes outlined in APM 10.50.1 GGC Brand Policy and should adhere to the guidelines outlined in the GGC Digital Communications Guide posted at the Strategic Communications and Positioning (SCP) webpage. Content in the CMS is managed by the Office of Digital Communications.

10.2.4.1.1 Design

Reviewed May 26, 2016

GGC website content located in the central content management system (CMS) inherits the approved GGC website design, including the exterior framework and interior colors, fonts and images, and is maintained by the Office of Digital Communications.

All GGC digital design elements should adhere to APM 10.50.1 GGC Brand Policy.

10.2.4.1.2 Graphics

Reviewed May 26, 2016

GGC websites and publications should display an approved GGC logo and demonstrate a professional appearance in keeping with the College’s style and brand. Use of GGC logos and trademarked graphics should adhere to APM 10.50.1 GGC Brand Policy.

10.2.4.1.3 Content

Reviewed May 26, 2016

Information representing the College should be relevant, accurate, accessible (Section 508 compliant), current and approved. Information includes, but is not limited to, body text, announcements, photos, captions, videos and graphics.

It is the responsibility of the division or unit (and their representative content or social media managers) to ensure accuracy of all submitted content for posting to digital communication channels. Additionally, when quoting thoughts, ideas, photos or videos, include citations and/or provide links to original material.

All content should adhere to any copyright laws. For more information on copyright laws, plagiarism, citations and intellectual property, visit the GGC Library’s libguides.

See APM 11.60 Electronic and Information Technology Accessibility Policy .

10.2.4.1.3.1 Questionable Content

Reviewed May 26, 2016

Some forms of content are not allowed in any form except when produced as an educational asset. Content, whether in text, imagery or multimedia form, falling into this category or considered to be in “poor taste” may not be approved for the site.

Examples of some questionable content include, but are not limited to, those listed in the GGC Digital Communications Guide.

10.2.4.1.3.2 Images

Reviewed May 26, 2016

Imagery, including photography, should be accessible (Section 508 compliant) and an accurate and appropriate representation of GGC. Imagery must also adhere to APM 10.50.1 GGC Brand Policy and meet the digital requirements outlined in the GGC Digital Communications Guide.

10.2.4.1.3.3 Accessibility

Reviewed May 26, 2016

The GGC website [see definition, APM 10.2.4.1 GGC Website] falls within the scope of websites that are required by federal law to comply with Section 508 compliance, which mandates that digital information should be equally accessible to people with and without disabilities.

Therefore, in order to comply with this federal mandate, the College’s website should comply with the guidelines defined in the University System of Georgia’s Accessibility website,

The Office of Digital Communications reserves the right to remove or refuse to link to non-compliant content as outlined in the GGC Digital Communications Guide, including documents, images, videos, software and websites.

See APM 11.60 Electronic and Information Technology Accessibility Policy.

10.2.4.1.4 Continuous Improvement

Reviewed May 26, 2016

It is the responsibility of the College community to facilitate continuous improvement of the GGC website. A Web Advisory Council (WAC) was formed in 2013 for this purpose. The WAC includes representatives of various key areas on campus who meet each semester to evaluate feedback from the campus community and provide guidance to the Office of Digital Communications and other areas on campus with a web presence. Members also play a key role in communicating issues to the Council as well as communicating changes to their areas. Additionally, faculty, staff and students may submit feedback about the website through their designated Web Council Advisory representative or by emailing webadvisorycouncil@ggc.edu.

10.2.4.1.5 Public GGC Website

Reviewed May 26, 2016

The public GGC website uses a content management system and is managed by the Office of Digital Communications. Content managers submit content to the Web Content Strategist/Editor for review. The public GGC website should adhere to the guidelines and standards previously outlined in APM 10.2.4.1.1 Design and APM 10.2.4.1.3 Content.

10.2.4.1.5.1 Content Managers

Reviewed May 26, 2016

A content manager is assigned by their division, approved by the Office of Digital Communications and is responsible for the content of his or her organization’s public sub-site, as outlined in the GGC Digital Communications Guide.

Periodic content management system training is required and conducted by the Office of Digital Communications.

10.2.4.1.5.2 Content Management Procedures

Reviewed May 26, 2016

Content managers should follow procedures defined in the GGC Digital Communications Guide when revising his or her assigned content or submitting requests for updates and/or changes for that content. Submitted content will be reviewed by the Web Content Strategist/Editor. Revisions may be made as necessary and, if significant in nature, will be returned to the client for final review and approval. Following final review and approval, the Web Content Strategist/Editor will publish content on the public GGC website. All text, imagery and multimedia are subject to editing for style, grammar, punctuation, spelling, quality or length by the Web Content Strategist/Editor. All content, pages, and sites are expected to comply with the requirements and standards outlined in this policy.

10.2.4.1.5.3 Requesting a Sub-Site

Reviewed May 26, 2016

A sub-site is a school, department, program or organization website located in the CMS and created as part of the public GGC website. Sub-sites may be requested by completing the appropriate request form located on the SCP webpage with a description and justification of the proposed sub-site. Sub-site requests will be evaluated based on GGC’s website goals and strategies, urgency and availability of resources. The Office of Digital Communications reserves the right to approve, prioritize or deny sub-site requests. Content that is denied may be appealed through the Office of Strategic Communications and Positioning. All public websites, with the exception of complex web applications should be created by the Office of Digital Communications and adhere to the GGC Digital Communications Guide.

10.2.4.1.5.4 Content Review

Reviewed May 26, 2016

Content managers are responsible for completing periodic reviews of their content for accuracy and communicating any necessary changes to the Web Content Strategist/Editor. Refer to APM 10.2.4.1.5.5 Requesting Edits for more information.

10.2.4.1.5.5 Requesting Edits

Reviewed May 26, 2016

Requests to edit content should be coordinated between designated content managers and the Web Content Strategist/Editor.

Reference the GGC Digital Communications Guide for more information about collaborative content manager roles and procedures for revising content.

10.2.4.1.5.6 Other Website Requests

Reviewed May 26, 2016

Other website requests, including but not limited to video production, promotional slides, faculty, staff and student announcements, calendar events, and directory profile requests may be submitted by GGC faculty and staff by completing the appropriate request form located on the SCP webpage. The Office of Digital Communications reserves the right to recommend and publish promotional content where it is most appropriate and according to quality standards and target audience.

10.2.4.2 Official Social Media Accounts

Reviewed May 26, 2016

Social media is defined as a means of interaction in which users create, share and develop multimedia and textual content across a wide array of platforms meant for social interaction through electronic distribution. Social media websites are important additions to the overall GGC brand. These sites represent the College and serve to reinforce the College’s brand and to positively engage audiences with the College.

The GGC social media program is managed by the Office of Digital Communications.

10.2.4.2.1 Official Tools and Accounts

Reviewed May 26, 2016

Social media tools approved by the Office of Digital Communications include, but are not be limited to, Facebook, LinkedIn, Twitter, and YouTube. Additional tools may be evaluated by the Digital Communications Manager on a case-by-case basis.

Official GGC social media accounts are listed in the GGC Social Media Directory. In order to be considered an official College account, the social media account should adhere to the requirements as outlined in the GGC Digital Communications Guide.

The Office of Digital Communications reserves the right to revoke or refuse social media accounts and creation. Content that is denied may be appealed through the Office of Strategic Communications and Positioning.

10.2.4.2.2 Social Media Content Managers

Reviewed May 26, 2016

Social media content managers should comply with the requirements outlined in the content section below and sign and adhere to the Social Media Policies and Best Practices agreement located in the GGC Digital Communications Guide.

It is the social media content manager’s responsibility to monitor the account and any comments associated with the account. Additionally, required periodic social media content manager training will be provided by the Digital Communications Manager.

10.2.4.2.3 Content

Reviewed May 26, 2016

The social media content manager is responsible for ensuring content adheres to APM 10.50.1 GGC Brand Policy and to the GGC Digital Communications Guide.

GGC’s Digital Communications team may oversee and evaluate social media pages representative of GGC and require deletion of content if deemed necessary.

10.2.4.2.4 Social Media Account Requests

Reviewed May 26, 2016

To request a social media account, review the GGC Digital Communications Guide and complete the appropriate request form located on the SCP webpage.

 

Media Relations

Policy Number: 10.3
Effective Date: November 6, 2017
Revision History: September 14, 2016
Policy Contact: Vice President of Strategic Communications and Positioning

Purpose and Policy Statement

This policy establishes guidelines for contacts and interaction with news media for all GGC personnel.

Scope

All employees and student media/organizations are responsible for understanding and complying with this policy.

For any questions on this policy, please contact the Office of Public Relations at 678.407.5549.

Definitions

News media: This includes, but is not limited to, electronic media, social media, broadcast media, print media, blogs, and other related media sources.

Roles and Responsibilities

Office of Public Relations: The Office of Public Relations is the College’s primary point of contact for media inquiries. They are responsible for building and sustaining relationships with the news media, providing support and coordinating accurate and appropriate information.

Faculty/staff: Employees are not authorized to speak on behalf of Georgia Gwinnett College unless specifically designated by the President or his designee. Employees of the College may speak on their own behalf as long as it is clear any such employee is not speaking on behalf of GGC in any official capacity. For more details on authorized contacts, please refer to APM 10.1 Publicity.

Any faculty/staff member who wishes to contact the news media for campus business purposes must communicate with the Office of Public Relations for appropriate coordination and any necessary approvals. Adherence to the requirements under this policy will enable the institution to provide accurate, appropriate and consistent messaging in a timely manner.

Members of the news media who contact Georgia Gwinnett College faculty or staff directly must be referred to the Office of Public Relations for initial review. Upon notification, the Office of Public Relations will provide guidance regarding appropriate action to the faculty or staff member.

Student organizations and student media: Student organizations interested in interacting with the news media for official campus matters are encouraged to consult with the Office of Public Relations for assistance in media relations matters.

Student journalists representing campus media outlets who are reporting on topics regarding the institution, such as College policies and developments, must route requests through the Office of Public Relations. A public relations staff member will facilitate interviews with the appropriate sources.

Student journalists representing campus media outlets who are reporting on topics regarding faculty research, course projects or general academic coursework may contact faculty members directly to request information or to schedule an interview.

 

 

10.4 Records Retention

Reviewed May 26, 2016

Georgia Gwinnett College complies with University System of Georgia Board of Regents Policy 10.4 Records Retention and the Board of Regents Records Retention Schedule, which classifies records by function and provides a schedule for storage.

All records created in the course of conducting College business will be regularly reviewed for compliance with the Records Retention Schedule and will be stored or securely destroyed accordingly. This includes electronic records in the form of emails or other electronic communication, all of which must be regularly examined and classified for retention or destruction.

Record review must be completed at least yearly but may be more frequent, depending on specific needs of individual departments and divisions and external compliance requirements.

The record management, retention, and destruction plans and timelines for each division must be approved by the GGC records manager, who will maintain documentation pertaining to the approval and destruction of records.

10.4.1 Definitions

Reviewed May 26, 2016

Record: according to the Georgia Open Records Act (GORA), a record is defined as materials that are prepared, maintained, or received by a GGC employee, volunteer, or third party provider in the performance of College business. It includes records that have been transferred to a private person or entity by GGC for storage or future use (e.g., records stored “in the cloud’). Records include, but are not limited to, documents, papers, letters, maps, books, tapes, photographs, computer-based or -generated information, text messages, social media postings, blogs, instant messages, tweets, and online discussion boards. Any record created on personally-owned computers, phones, or other devices are considered records if they pertain to College business and they are subject to this policy. Personal messages sent on GGC devices and/or via GGC accounts are subject to the Open Records Act and are subject to this policy. Personal messages sent through a personal account on a GGC-owned device are not subject to this policy but are subject to the Open Records Act.

Useful life: the time period during which a record is being actively used to accomplish the work of the College (e.g., current work schedules and policy manuals, documents related to recent projects, etc.).

Employee: any individual who is paid for work performed at Georgia Gwinnett College, including full- and part-time faculty, staff, and student workers.

Volunteer: individuals who volunteer or donate their services, usually on a part-time basis, for public service, religious or humanitarian objectives, not as employees and without contemplation of pay. In the GGC context, this includes, but is not limited to, trustees and board members, participants in any structured volunteer program (see Administrative Policy Manual 8.2.15.51 Structured Volunteer Program Policy ), and alumni working in service of GGC.

Third party provider: any third party person or business that provides a product or service for the College.

Electronic message: a written communication sent over a cellular or computer network, including, but not limited to, emails, text messages, instant messaging, and chat room transcripts. An electronic message includes:

  • The body of the text (the content of the message)
  • The metadata accompanying all messages (To, From, Subject, Date, Time, System, etc.)
  • Any attachments to the message

Transitory: records that do not document decisions or contain significant information about GGC programs, fiscal status, or operations. Transitory records include, but are not limited to, advertising circulars, drafts and worksheets, desk notes, reference files, and other records of a preliminary or informational nature.

Retention period: the timeframe during which records must be retained according to state or federal law, Board of Regents policy, or other regulation or policy. When timeframes for retention of a particular record conflict, the record will be maintained for the longest of the required timeframes.

Non-permanent records: records that are required by state or federal law, Board of Regents policy or other regulation or policy to be stored for a designated timeframe and which will be destroyed after the timeframe expires.

Permanent records: records that must be retained in perpetuity according to state or federal law, Board of Regents policy or other regulation or policy. Permanent records also include records that are not required to be retained in perpetuity but which are historically significant to the College. Permanent records include, but are not limited to Faculty Senate Records, student handbooks, and Commencement Records.

10.4.2 Roles and Responsibilities

Reviewed May 26, 2016

Cabinet-level administrator: manages internal procedures and policy compliance within the scope of responsibility and creates a procedure for regular review of all documents and records, including plans for:

  • Reviewing records for classification and policy compliance
  • Retaining records during their useful life
  • Securely storing records that have exceeded their useful life but which must be retained according to the USG Board of Regents schedule
  • Securely destroying any records that have exceeded their useful life and their retention period
  • Maintaining an inventory of all records sent to GGC storage for permanent retention
  • Creating a timeline of document retention and destruction activity.

Library Head of Access Services: acts as the College archivist and is responsible for maintaining the secure storage of records determined to have historical significance or which must be retained permanently by the College.

Unit head: understands College and divisional policies and procedures related to record management, retention, and destruction and ensures compliance within his/her scope of responsibility; creates and maintains an inventory of all records sent to the GGC library for historical archiving.

Individual employee or volunteer: understands the Records Retention Policy and procedures and complies with their requirements.

GGC records manager: facilitates the creation of all policies and procedures related to College records; acts as a liaison between the Board of Regents and College officials; coordinates the creation of educational materials and training sessions for all staff and faculty on this policy on a regular basis.

10.4.3 Compliance

Reviewed May 26, 2016

Failure to manage College records appropriately violates Board of Regents policy, may violate state or federal law, and could have legal ramifications. All employees are responsible for understanding and complying with this policy. Failure to comply with this policy may result in disciplinary action, up to and including termination.

10.4.4 Storage and Destruction of Nonpermanent and Permanent Records

Reviewed May 26, 2016

Non-permanent records will be stored by the creating unit during their required retention period, after which they will be destroyed in accordance with GGC document destruction procedures or designated as permanent records.

Permanent records will be printed if they are in an electronic form. All permanent records will be inventoried, labeled, and delivered to the GGC document storage area in accordance with GGC document storage procedures.

All historically significant permanent records will be inventoried, labeled according to Library document storage procedures, and delivered to the Library for storage. The Library Head of Access Services should be contacted prior to preparation of materials to assess the historical significance of any document.

Unit heads will maintain an inventory of records that are destroyed or sent to the Library for storage. Records sent to the Library for storage will include a copy of the inventory of the records being sent.

10.4.5 Related Regulations, Statutes, and Policies

Reviewed May 26, 2016

Board of Regents Policy Manual Section 10.4 Records Retention
Board of Regents Records Retention Schedule
Georgia Open Meetings Act
Georgia Open Records Act
United States Department of Labor definition of volunteer
Code of Federal Regulations, Part 1
Code of Federal Regulations, Part 2

See Board of Regents Policy Manual Section 10.4.

 

10.8 Data Management and Classification

Reviewed May 26, 2016

10.8.1 Purpose

Reviewed May 26, 2016

Information is one of Georgia Gwinnett College’s (GGC) most valuable resources and as such requires responsible management by all members of the GGC community. All institutional data should be used with appropriate and relevant levels of access and with sufficient assurance of its security and integrity in compliance with existing laws, rules, and regulations. This policy describes the roles, responsibilities, and classification for institutional data and provides for the regulation, guidance and procedures necessary to:

Facilitate access to institutional data needed by GGC employees, as defined in this policy, and students for the execution of their job responsibilities

  • Protect the privacy of individuals on whom we hold data

This policy was developed with these guiding principles:

  1. Everyone is a data user; some individuals may also have additional designated roles with regard to specific data or databases.
  2. All institutional data are classified as internal unless otherwise designated
  3. All personnel are responsible for ethical use of data

10.8.2 Scope

Reviewed May 26, 2016

This policy addresses the handling of all forms of institutional data by and for all employees and students in the GGC Community, as defined below. The specific definitions of “employee” and “student” in this policy section apply to the purpose of data management only.

10.8.2.1 Institutional Data Definition

Reviewed May 26, 2016

A data element is considered institutional data if it originates or is in the custody and control of GGC. Institutional data do not include personal notes and records or data whose primary purpose is scholarly, such as syllabi and course notes.

Examples of institutional data include, but are not limited to:

  • Elements supporting financial management
  • Student curricula
  • Payroll
  • Student educational records
  • Student financial data
  • Medical data
  • Personnel management
  • Intellectual property
  • Intellectual research property
  • Capital equipment inventory
  • Donor data
  • Alumni data

Information may be considered institutional data if it satisfies one or more of the following criteria:

  • Data used for planning, managing, reporting, or auditing a major administrative function
  • Data referenced or used by an organizational unit to conduct institutional business
  • Data included in an official institutional administrative report
  • Data used to derive an element that meets any of the criteria above
  • Data generated under contractual arrangements (grants, etc.) that specifically designate data as belonging to the institution

10.8.3 User Resposibilities and Compliance

Reviewed May 26, 2016

  • All GGC employees and students are responsible for observing all applicable laws, data classification restrictions, security procedures, and appropriate precautions with data. Any employee found to have violated this policy through unauthorized access, disclosure, alteration or destruction of data will be subject to disciplinary procedures up to and including termination of employment.
  • All GGC employees must complete an annual course in data security and management and sign the GGC Confidentiality Agreement. Data Users, Data Managers, Data Stewards and Data Trustees are not required to make explicit requests for the data to which they have access in the course of day-to-day execution of their job duties. However, any employee who has an identified need for data beyond his/her day-to-day duties or for a special purpose analysis must make a request following the GGC Data Request process available from myGGC.

10.8.4 Data Management and Structure

Reviewed May 26, 2016

A data management structure is required at GGC to ensure proper handling of institutional data. The GGC data management structure consists of the following roles: Data Users, Data Managers, Data Stewards, and Data Trustees.

All GGC employees and students are responsible for understanding their roles as Data Users, Data Managers, Data Stewards or Data Trustees and for understanding the classification of any data they use in the normal execution of job duties.

10.8.4.1 Data Users

Reviewed May 26, 2016

Data users are GGC employees or students who have been granted authorization by the data managers to access institutional data. Authorization is granted for a specific level of access, as defined by the data management policies, solely for the conduct of institutional business.

Data users may have technical access to data, or they may have rights to use data that they need assistance to access. Responsibilities include:

  • Following the policies and procedures established by the data stewards for responsible use of GGC data.
  • Using institutional data only as required to conduct GGC business.
  • Ensuring the privacy of data by viewing and storing data, and the information derived from data, under secure conditions.
  • Ensuring accuracy and timeliness of the data they enter or update.
  • Collecting, preparing, entering or maintaining data for the authorized unit(s), if authorized by the data manager.

10.8.4.2 Data Managaers

Reviewed May 26, 2016

Data managers, designated by the data stewards, are generally operational managers within a functional area overseeing the data for a particular subject area. Data managers have day-to-day responsibility for managing administrative processes and establishing business rules for the transactional systems. They have operational responsibility for the data management activities related to the collection, maintenance, protection, and dissemination of data in their functional areas.

The data manager may authorize operational tasks to be performed by data users outside the units that report to the data manager. The data managers are accountable for the data subsets they manage, whether the data are collected or maintained directly by the data manager (or their staff), by data users in other units or by external sources.

Responsibilities include:

  • Reviewing and approving requests for access by other GGC users, as defined by campus data policy.
  • Determining the type of access given to GGC users.
  • Assuring compliance with federal, state and campus regulations regarding the release of, responsible use of, and access to, data.
  • Training GGC users in relevant regulations and proper understanding of data.
  • Providing data definitions for each data element within the domain of their operational unit(s).
  • Communicating any data definition or database changes to the appropriate data administrator.
  • Ensuring the accuracy, privacy and integrity of the data they manage.
  • Assisting in the design of data warehouse structures that contain data from their subject areas.

10.8.4.3 Data Stewards

Reviewed May 26, 2016

Data stewards, designated by the data trustees, are senior level officials who have planning and policy responsibilities for data in their functional areas. Data stewards, or their designees, are responsible for recommending policies, and establishing procedures and guidelines concerning the accuracy, privacy and integrity of the data subsets for which they are responsible. Individually, data stewards act as advisors to the data trustees and have management responsibilities for data administration issues in their functional areas. They have overall responsibility for the data in the subsets overseen by all their designated data managers. These responsibilities include:

  • Interpreting and implementing federal, state and GGC policies and guidelines.
  • Ensuring data quality and data definition standards are met.
    Identifying the privacy level, (unrestricted, internal, sensitive, or confidential) for the data subsets.
  • Establishing authorization procedures to facilitate appropriate data access as defined by campus data policy and ensuring security for that data.
  • Resolving issues related to stewardship of data elements that cross multiple units or divisions. For example, Social Security number may have more than one data steward since it is collected or used in multiple systems, such as financial, human resources, and student systems.
  • Developing standard definitions for data elements, including those that cross multiple units or divisions. For example, there should either be a single definition of “full-time employee” or new data elements should be created for each unique definition.

Table 1: Data Sources and Stewards

Data Source Group Steward for Data Source Data source
Official Institutional Data (Archive, Permanent) Director of Institutional Research Institutional Research Data/Academic Collection (ADC).
Facilities (Live) AVP for Facilities Banner Facilities data
Facilities (Live) SAVP Business and Finance Operations Bb Claw Card/Transaction Data (includes financial data from bookstore, vending, dining, printing, room access, access data from Fitness Center) Student Org activity admission/participation, ID
Facilities (Live) Director of Residence Life Banner Housing data
Faculty Activity Data (Live) Senior VP for Academic & Student Affairs/Provost Faculty course assignments
Faculty committee assignments
Faculty-student engagement data
Faculty office assignments
Course location data
Financial (Live) SAVP Business and Finance Operations ADP Payroll data
PeopleSoft Financial data
Banner Receivables (Student Accounts)
Financial (Live) Director of Purchasing PeopleSoft Procurement data
HR (Live) AVP for HR Hire Touch HR data
ADP HR data
Banner Employee data
Student Academic Data (Live) Senior VP for Academic & Student Affairs/Provost and Vice President for Educational Technology LMS ( Brightspace, D2L) data
Student Registry Data (Live) Exec Director for Enrollment Management Banner Admissions data
Banner Financial Aid data
Banner Student data
Student Involvement Data (Live) Senior Associate Provost for Student Affairs Intramurals, Varsity Athletics Data
Club Sports
Student Clubs and Organizations
Student-Athlete Data Director of Athletics Varsity Athletics Data
Student Data (health and conduct) Senior Assoc. Provost for Student Affairs/Provost Health related data Counseling services data
Conduct-related data
Surveys and Other Internally Collected Data (Live) Director of Institutional Effectiveness Institutional Effectiveness Data
Library Dean, Library Services Gil, Galileo, Voyager (hosted by UGA)
Police/ Security AVP for Public Safety Ticketrack (Parking permits and tickets)
Office of Development Vice President for Development -Alumni Data
-Donor Data
-Prospect Data
- Event Data (alumni & donor events)
-GGC Foundation Trustee data
GGC Foundation President of GGC Foundation -Foundation finance & accounting data
Aggregated Technology Utilization Data VP for Educational Technology LMS Usage
Email Usage
Etc.

10.8.4.4 Data Trustee

Reviewed May 26, 2016

Data trustees are GGC Senior Administrators who have overall responsibility for all the data sets maintained by the units reporting to them. Institutional data trustees consist of the President, Vice Presidents, the person designated as Chief Information Officer (CIO), and General Counsel. Individually the data trustees are accountable for all the data sets within their division. The Vice President for Educational Technology has the additional responsibility for ensuring an adequate and appropriate technical infrastructure is in place to support the data needs of the institution across all divisions.

The data trustees are responsible for ensuring that campus institutional data resources are used in ways consistent with the mission of the GGC. The data trustees have the responsibility for the appointment and accountability of data stewards.

10.8.5 Data Classification

Reviewed May 26, 2016

By default, all institutional data will be designated as internal data for use within GGC or to satisfy institutional external reporting requirements to the USG Board of Regents (BOR), and to state, federal, or other external agencies. GGC employees will have access to these data for use in the conduct of GGC business. The permission to view or query institutional data should be granted to all data users for all legitimate institutional purposes.

As part of the data definition process, data stewards may assign data elements and data views in institutional data to one of three additional categories: unrestricted, sensitive, and confidential.

Note: In some circumstances, as long as specific identifying data elements are removed, a data view may include elements of institutional data that would otherwise be sensitive or confidential.

All GGC information is categorized into four main classifications:

10.8.5.1 Unrestricted Data

Reviewed May 26, 2016

Unrestricted data are institutional data that have no access restrictions and are available to the general public. These data will be designated as unrestricted or public data.

The following are examples of unrestricted data:

  • Information on the public web site
  • College Fact Books

10.8.5.2 Internal Data

Reviewed May 26, 2016

Internal Data are institutional data that are available to GGC employees and students. Internal data are available freely within the institution but are not available to the public unless required by law. This is the default categorization for institutional data.

The following are examples of internal data:

  • NSSE Report Comparisons
  • Composite course evaluation reports
  • Selected internal survey data
  • Selected directory information, e.g., faculty cell phone numbers

10.8.5.3 Sensitive Data

Reviewed May 26, 2016

Sensitive Data are institutional data that are not legally protected, but should not be made public and should only be disclosed under limited circumstances. Users must be granted specific authorization to access since the data’s unauthorized disclosure, alteration, or destruction could cause perceivable damage to the institution.

The following are examples of sensitive data elements:

  • Any non-confidential information identifiable to an individual (including students, staff, faculty, trustees, donors, and alumni) including but not limited to dates of birth, driver’s license numbers, employee and student id numbers, license plate numbers and compensation information.
  • The University’s proprietary information including but not limited to intellectual research findings, intellectual property, financial data, and donor and funding sources.

10.8.5.4 Confidential Data

Reviewed May 26, 2016

Confidential Data are institutional data for which there is a legal obligation not to disclose. These data elements require the highest levels of restriction due to the risk or harm that will result from disclosure or inappropriate use.

The following are examples of confidential data elements:

  • Data not releasable under the Georgia Open Records Act or the Georgia Open Meetings Act
  • All regulated data
  • Social Security and credit card numbers
  • Data protected under the Family Educational Rights and Privacy Act of 1974 (FERPA)
    • FERPA protects the rights of students by controlling the creation, maintenance, and access to educational records. It guarantees students’ access to their academic records while prohibiting unauthorized access by others.
  • Data protected under the Health Insurance Portability and Accountability Act of 1996 (HIPAA)
    • HIPPA sets standards for securing protected health information in paper, electronic, and oral communication.
    • Protected Health Information (PHI) is individually identifiable health information that is maintained or transmitted in any form or medium. Protected health information excludes individually identifiable health information in education records covered by the Family Educational Right and Privacy Act (FERPA)
  • Data protected under the Gramm-Leach-Bliley Act (GLBA)
    • GLBA provides limited privacy protections for private financial information. Additionally, the GLBA codifies protections against pretexting, the practice of obtaining personal information through false pretenses.
    • GLBA implements rules concerning financial privacy notices and the administrative, technical and physical safeguarding of personal information

10.8.6 Definitions for the Purpose of This Document Section

Reviewed May 26, 2016

Definitions for the purpose of this document section.

Other definitions may be used across GGC for other purposes.

Confidential Data – institutional data for which there is a legal obligation not to disclose.

Data Managers – operational managers within a functional area overseeing the data for a particular subject area.

Data Stewards – senior level officials who have planning and policy responsibilities for data in their functional areas.

Data Trustees – GGC executives who have overall responsibility for all the data sets maintained by the units reporting to them.

Data Users – GGC employees or students who have been granted authorization by the data managers to access institutional data.

Employee - Full-time or part-time worker at GGC, whether directly employed, contracted, sub-contracted, work-study or volunteer. (Note that this definition applies to data management policies only, and does not affect other operational definitions in use at GGC.)

Institutional Data - Any data element that originates or is in the custody and control of GGC excluding personal notes and records or data whose primary purpose is scholarly, such as syllabi and course notes.

Internal Data - institutional data that are available freely within institution but are not available to the public unless required by law. This is the default categorization for institutional data.

Sensitive Data – institutional data that are not legally protected, but should not be made public and should only be disclosed under limited circumstances.

Student - A student is any individual who is or has been in attendance at Georgia Gwinnett College at any time and/or about whom GGC maintains records. (Note that this definition applies to data management policies only, and does not affect other operational definitions in use at GGC.)

Unrestricted Data – institutional data that have no access restrictions and are available to the general public

 

10.9 Student Records Management and Security Policy

Reviewed May 26, 2016

10.9.1 Scope

Reviewed May 26, 2016

Because the ongoing security and confidentiality of student records is critical to the integrity of the institution, Georgia Gwinnett College protects the security, confidentiality, and integrity (including data protection and back up) of student records (regardless of storage media) from creation or receipt through processing, distribution, use retrieval, and maintenance to their ultimate disposition. GGC recognizes the importance of protecting confidentiality of records, preserving the integrity of its students’ academic records, and overseeing the release of records in accordance with state and federal mandates and commonly accepted standards and practices among institutions of higher learning.

Student records include but are not limited to the following:

  • Faculty: Class roles with grades, papers, exams, papers, assessments (paper, learning management system, laptops), advisee notes, confidential conversations in any form (e.g. email, text, print, verbal)
  • Student affairs: Conduct, Medical (HIPPA, Fitness, Physician, mental health), disability, academic integrity violations, career services, e-mails with confidential information
  • Enrollment Management: Admissions, financial aid, Registrar (transcripts, grades, applications, financial documentation about residency), medical (immunization and records submitted as documentation for hardship request, etc.), immigration status, e-mails with confidential information
  • Intra-student e-mail communication within the GGC system

Policies related to confidentiality, security, integrity of records, and data protection and backup are reviewed yearly.

They include:

10.9.2 Records Management Policies

Reviewed May 26, 2016

Georgia Gwinnett College’s policies address records management policies in the following subcategories.

10.9.2.1 Protecting the Right to Privacy

Reviewed May 26, 2016

Georgia Gwinnett College protects the rights of privacy of all student records including academic, medical and financial records, by following all local, state and federal law to include the Family Educational Rights and Privacy Act (FERPA) of 1974, the Health Insurance Portability and Accountability Act ( HIPPA) of 1996), and Gramm-Leach Bliley Act of 1999.

10.9.2.11 Restricting Access to Records

Reviewed May 26, 2016

Restricted physical and electronic access is the first line of defense for protecting records from physical damage, intrusion or theft. A proactive approach will be taken with respect to monitoring for physical and system invasion. In protecting records, the College will require that:

10.9.2.1.2 Releasing Information only in Accordance with Strict Guidelines

Reviewed May 26, 2016

  • In accordance with the provisions of the Family Educational Rights and Privacy Act of 1974 (FERPA), the college maintains the right to require consent to disclosure of personally identifiable information contained in the student’s educational records except to the extent that FERPA authorizes disclosure without consent.
  • In accordance with FERPA, the college permits disclosure without consent if the disclosure of information is to school officials with a legitimate educational interest, such as a person employed by the college in an administrative, supervisory, academic, research, or support staff position (including law enforcement personnel); a person or company with whom the college has contracted (such as an attorney, auditor, or collection agent); a person serving on the Board of Regents; or a student serving on an official committee such as a disciplinary committee, or assisting another school official in performing his or her tasks. A school official has a legitimate educational interest if the official needs to review an educational record in order to fulfill his or her professional responsibility.
  • Upon request, the college discloses education records without consent to officials of another school in which a student seeks or intends to enroll.
10.9.2.1.3 Providing Students and Their Parents with Information Concerning Students’ Rights for the Protection of Their Confidential Records

Reviewed May 26, 2016

  • GGC FERPA Disclosure Notice to Students will be explained to new students and their parents who attend the BEAR ESSENTIALS Orientation session as well as available to students on-line and in the Georgia Gwinnett College Catalog.
  • Signed GGC FERPA Disclose Notice to Students will be maintained in the student file as well as recorded in Banner.
  • GGC recognizes the right of the student to refuse to permit the release of information, including directory information as defined by FERPA.

10.9.2.2 Student Electronic Records Storage and Recovery

Reviewed May 26, 2016

  • The College recognizes the need to provide reliable and efficient student services, therefore coordinates with the University System of Georgia to consolidate the technical environment for the Banner Student Information System for the purpose of providing secure, reliable, and cost effective database administration and system support functions.
  • The Student Information System is managed via a memorandum of agreement with the University System of Georgia Information Technology Systems, which has a contract with Ellucian. A structured recovery plan is well documented and ready for execution in the event of system component failures is part of that arrangement.
  • See APM 11.50.3 Continuity of Operations Plan Policy  for information addressing disaster plans for records.

10.9.2.3 Training of New Employees (Faculty, Staff and Student Workers) as Well as Current Employees

Reviewed May 26, 2016

  • A regular training schedule for faculty and staff will be maintained to assure that the policy and procedures for storage, release, dissemination and disposition (whether physical, printed, or verbal) is consistently adhered to.
  • See APM 10.8 Data Management and Classification for additional information on employee responsibilities.

10.9.2.4 Annual Review of Procedures as Well as Immediate Review of Procedures any Time a Breach of Procedures is Identified

Reviewed May 26, 2016

  • A committee of members responsible for student data will complete an annual review of procedures for records security and privacy.
  • In the event of a breach of procedures, the registrar will be notified of the violation. The appropriate dean, director and/or HR will address the situation and work with the Executive Director of Human Resources to address the issue with the person or the supervisor of the person who has committed the breach of procedures.

10.9.2.5 Records Retention and Disposition

Reviewed May 26, 2016’

  • Records will be kept according to the University System of Georgia Board of Regents Records Retention Schedule.
  • Review of the proper procedures for records disposal will happen annually for faculty and staff via the annual FERPA notification procedure.

10.9.2.6 Release of Records

Reviewed May 26, 2016

Georgia Gwinnett College follows all policies governing the security and confidentiality of records as dictated by the Board of Regents. Georgia Gwinnett College does not publish a student directory; however the student’s name, major field of study, dates of attendance, and degrees conferred may be disclosed without consent of the student. For Georgia Gwinnett College, this is the only information which could be considered “Directory Information” for FERPA or other purposes, including but not limited to external record requests.

Students have the right to refuse to permit the disclosure of any information. If students choose to exercise the right of refusal, they must do so in writing to the Registrar within 30 days of the beginning of each academic semester. It is understood that appropriate college officials will have access to such information and records as shall be necessary for them to perform their professional responsibilities. All official use of student files shall be in accordance with the provisions of the Family Educational Rights and Privacy Act of 1974 (FERPA) and shall be duly recorded and shall be documented as required by its regulations.

In accordance with FERPA, the college permits disclosure without consent if the disclosure of information is to school officials with a legitimate educational interest, such as a person employed by the college in an administrative, supervisory, academic, research, or support staff position (including law enforcement personnel); a person or company with whom the college has contracted (such as an attorney, auditor, or collection agent); a person serving on the Board of Regents; or a student serving on an official committee such as a disciplinary committee, or assisting another school official in performing his or her tasks. A school official has a legitimate educational interest if the official needs to review an educational record in order to fulfill his or her professional responsibility

The following information and records shall not be covered by this policy and access shall not be provided to students: information related to pending admissions decisions, financial records or information relating to students or parents/guardians; confidential statements of recommendation placed in the record obtained if a receipt of a statement from students waiving the right to open accessibility placement records is present; all information relative to the application for and receipt of financial assistance; records created or maintained by a physician, psychiatrist, psychologist, or other professional or a professional acting or assisting in a similar capacity in treatment of a student; institutional employment or faculty files; alumni information; and sole-access educational records. Sole access records are those records of instructional, supervisory and administration and educational personnel that are in the sole possession of the makers and are not accessible or revealed to any other individual except a temporary substitute.

10.9.2.7 Correction of Records

Reviewed May 26, 2016

Pursuant to Family Educational Rights and Privacy Act of 1974, students have the right to inspect their educational records and correct such records if necessary. Students desiring to review their records should make this request to the appropriate official in writing. Such written request will be granted within a period of no more than 45 days from the date of request. In the event the record contains inaccurate, misleading or otherwise inappropriate information, every effort will be made to correct or delete such material, and the student will be so informed of such action in writing. Institutions may release information to governmental agencies for review for purposes of financial aid audits, National Student Loan Clearinghouse, etc. In the event of a subpoena, the institution may disclose information if the institution makes a reasonable effort to notify the eligible student of the order or subpoena in advance of compliance, so that the student may seek protective action, unless the disclosure is in compliance with a Federal grand jury subpoena. Complete information on FERPA policy may be found at www.ed.gov/policy.

10.9.3 Student Records Procedures

Reviewed May 26, 2016

This section details the procedures connected to the Student Records Policies outlines in APM 10.9.2, Records Management Policies.

10.9.3.1 Procedures Related to Privacy

Reviewed May 26, 2016

As outlined in policy, GGC protects the privacy of students. Procedures that relate to privacy include restricting access to records, releasing information only in accordance with guidelines, and providing information to parents and students about student rights for the protection of confidential data.

10.9.3.1 Procedures Related to Restricting Access to Records

Reviewed May 26, 2016

All student records will be kept in a locked, secure location with restricted access. Restricted access to records is given based on job level and a verifiable need to view the record. Faculty and staff who have been given restricted access to view records will:

  • Make sure that all records are kept in a secure, locked location.
  • Lock computer desktops and/or offices when leaving a work station.
  • Refrain from storing student records on the computer desktop. All student data should be stored on a secure network drive.
  • Ensure that College laptops are kept in a secure location whether on or off campus. Laptops must be locked and password protected when not in use.
  • Properly shred printed material that contains information not necessary for storage.
  • Maintain confidentiality of student information by being aware of their surroundings when holding discussions with the student or with others who have a verifiable need to know the information.
  • Attend regularly offered training to faculty and staff to ensure that up-to-date security standards are understood and being adhered to. This training will include an annual review of FERPA, HIPAA, and Gramm-Leach Bliley regulations.

Access to confidential student data is available only to properly authorized personnel. GGC requires that:

  • All users have individual accounts
  • User permissions are controlled by user classes that control access to data
  • Security log tables are monitored
  • Documentation of site security procedures and end-user responsibilities are maintained.

These procedures apply both to information in the Student Information System and to Student Affairs student records including conduct, medical and other records covered under HIPPA such as Fitness, Physician and mental health, disability, academic integrity violations, career services, and e-mails with confidential information.

All student data stored electronically must comply with policies found in the APM in section 11.

10.9.3.1.2 Procedures Related to Releasing Information

Reviewed May 26, 2016

Faculty and Staff with access to student records are expected to use that access appropriately, mindful that they are required to have a legitimate educational interest in the data they access.

Individuals employed by the college who require data beyond their normal levels of access will submit a data request for the specific data needed. These requests will be reviewed for compliance with FERPA regulations before the data are provided.

10.9.3.1.3 Procedures Related to Informing Students and Parents of Students’ Rights for the Protection of Their Confidential Records

Reviewed May 26, 2016

  • GGC FERPA Disclosure Notice to Students will be explained to new students and their parents who attend the BEAR ESSENTIALS Orientation session as well as available to students on-line and in the Georgia Gwinnett College Catalog.
  • Signed GGC FERPA Disclose Notice to Students will be maintained in the student file as well as recorded in Banner.
  • GGC recognizes the right of the student to refuse to permit the release of information, including directory information as defined by FERPA.

10.9.3.2 Procedures Related to Electronic Records Storage and Recovery

Reviewed May 26, 2016

  • The Student Information System is managed via a memorandum of agreement with the University System of Georgia Information Technology Systems. A structured recovery plan is well documented and ready for execution in the event of system component failures is part of that arrangement.
  • See APM 11.50.3 Continuity of Operations Plan Policy for information addressing disaster plans for records. The College recognizes the need to provide reliable and efficient student services, therefore coordinates with the University System of Georgia to consolidate the technical environment for the Banner Student Information System for the purpose of providing secure, reliable, and cost effective database administration and system support functions.

10.9.3.3 Procedures Related to Training

Reviewed May 26, 2016

Faculty and Staff who have been given restricted access to view records will attend regularly offered training to faculty and staff to ensure that up-to-date security standards are understood and being adhered to. This training will include an annual review of FERPA, HIPAA, and Gramm-Leach Bliley regulations.

10.9.3.4 Procedures Relates to Review of Procedures

Reviewed May 26, 2016

  • A committee of members responsible for student data will complete an annual review of procedures for records security and privacy.
  • In the event of a breach of procedures, the registrar will be notified of the violation. The appropriate dean, director and/or HR will address the situation and work with the Executive Director of Human Resources to address the issue with the person or the supervisor of the person who has committed the breach of procedures.

10.9.3.5 Procedures Related to Records Retention and Disposition

Reviewed May 26, 2016

Retention of Student Records: Georgia Gwinnett College follows the approved retention schedule for college records which can be found at the University System of Georgia Board of Regents website. Student records are subject to requirements found in APM 10.4 Records Retention policy.

10.9.3.6 Procedures Related to Release of Records

Reviewed May 26, 2016

Georgia Gwinnett College follows all policies governing the security and confidentiality of records as dictated by the Board of Regents. Georgia Gwinnett College does not publish a student directory; however the student’s name, major field of study, dates of attendance, and degrees conferred may be disclosed without consent of the student. For Georgia Gwinnett College, this is the only information which could be considered “Directory Information” for FERPA or other purposes, including but not limited to external record requests.

Students have the right to refuse to permit the disclosure of any information. If students choose to exercise the right of refusal, they must do so in writing to the Registrar within 30 days of the beginning of each academic semester. It is understood that appropriate college officials will have access to such information and records as shall be necessary for them to perform their professional responsibilities. All official use of student files shall be in accordance with the provisions of the Family Educational Rights and Privacy Act of 1974 (FERPA) and shall be duly recorded and shall be documented as required by its regulations.

In accordance with FERPA, the college permits disclosure without consent if the disclosure of information is to school officials with a legitimate educational interest, such as a person employed by the college in an administrative, supervisory, academic, research, or support staff position (including law enforcement personnel); a person or company with whom the college has contracted (such as an attorney, auditor, or collection agent); a person serving on the Board of Regents; or a student serving on an official committee such as a disciplinary committee, or assisting another school official in performing his or her tasks. A school official has a legitimate educational interest if the official needs to review an educational record in order to fulfill his or her professional responsibility

The following information and records shall not be covered by this policy and access shall not be provided to students: information related to pending admissions decisions, financial records or information relating to students or parents/guardians; confidential statements of recommendation placed in the record obtained if a receipt of a statement from students waiving the right to open accessibility placement records is present; all information relative to the application for and receipt of financial assistance; records created or maintained by a physician, psychiatrist, psychologist, or other professional or a professional acting or assisting in a similar capacity in treatment of a student; institutional employment or faculty files; alumni information; and sole-access educational records. Sole access records are those records of instructional, supervisory and administration and educational personnel that are in the sole possession of the makers and are not accessible or revealed to any other individual except a temporary substitute.

10.9.3.7 Procedures Related to Correction of Records

Reviewed May 26, 2016

Pursuant to Family Educational Rights and Privacy Act of 1974, students have the right to inspect their educational records and correct such records if necessary. Students desiring to review their records should make this request to the appropriate official in writing. Such written request will be granted within a period of no more than 45 days from the date of request. In the event the record contains inaccurate, misleading or otherwise inappropriate information, every effort will be made to correct or delete such material, and the student will be so informed of such action in writing. Institutions may release information to governmental agencies for review for purposes of financial aid audits, National Student Loan Clearinghouse, etc. In the event of a subpoena, the institution may disclose information if the institution makes a reasonable effort to notify the eligible student of the order or subpoena in advance of compliance, so that the student may seek protective action, unless the disclosure is in compliance with a Federal grand jury subpoena. Complete information on FERPA policy may be found on this website.

 

10.50.1 GGC Brand Policy

Reviewed May 26, 2016

The Office of Strategic Communications and Positioning is the “Brand Manager” for Georgia Gwinnett College and, as such, delegates oversight authority to the Office of Public Relations. College communications, including, but not limited to, publications, advertising and promotional material shall comply with the appropriate and consistent use of the Georgia Gwinnett College brand as outlined in the Brand Guidelines.

Defining the College’s brand identity in a way that is clear, understandable, memorable, and authentic is critical to distinguishing it from its competitors. The graphic standards, visual identity and messaging programs solidify institutional communications, enabling a unified and consistent presentation to the community. The programs provide a foundation on which the College’s brand and reputation can be built and optimized.

The ultimate goal in creating a consistent brand is to leave a positive message and a strong memory in prospective clients before they establish a need for service. In the case of Georgia Gwinnett College, consistent use of the brand and visual identity in all parts of the organization create a positive and inviting image for the various constituencies whom the College serves and with whom the College interacts.

 

10.60 Open Records Policy and Procedures

Reviewed August 4, 2016

What is the Georgia Open Records Act?

The Georgia Open Records Act (“GORA”) applies to both Georgia Gwinnett College and The Georgia Gwinnett College Foundation. GORA allows all citizens to view the “public records” of state agencies (and supporting foundations), upon request, and to make copies of such records for a nominal fee.

“Public record” means all documents, papers, letters, maps, books, tapes, photographs, computer based or generated information, data, data fields, or similar material prepared and maintained or received by an agency or by a private person or entity in the performance of a service or function for or on behalf of an agency or when such documents have been transferred to a private person or entity by an agency for storage or future governmental use.

There are applicable exemptions. These include:

Personal and confidential information:

  1. Social Security numbers
  2. Medical information
  3. Insurance information
  4. Bank account information
  5. Credit card and debit card account information
  6. Financial information
  7. Utility account information
  8. Passwords
  9. Mother’s birth name
  10. Month and day of birth
  11. Unlisted telephone number is so designated in a public record
  12. Personal e-mail address or cellular telephone number
  13. Identity of immediate family members of dependents
  14. The home addresses and telephone numbers of public employees, judges, and law enforcement officers
  15. Such information as is required to be kept confidential by federal law – FERPA and HIPPA

10.61 Applicability to Georgia Gwinnett College

Reviewed September 14, 2016

Georgia Gwinnett College’s Designated Open Records Office

The Office of Legal Affairs is designated as the central, open records requests office for Georgia Gwinnett College. This designation ensures that requests are handled in a timely manner, and that all disseminated information complies with applicable Federal and State laws, and Board of Regents and Georgia Gwinnett College policies and procedures.

Georgia Gwinnett College must make such designation in writing and shall immediately provide notice to any person upon request, orally or in writing, of the open records officers. This designation shall be made to the local newspaper, and shall be designated on the Georgia Gwinnett College webpage. The absence of the designated officer does not permit a delay in responding to records requests.

Procedure

A. A citizen must submit a request for records to the Office of Legal Affairs.

NOTE:  Any office or person at Georgia Gwinnett College receiving a request for records, howsoever made, shall inform the requester that all requests must be made to the Office of Legal Affairs.  A courtesy email to the Office of Legal Affairs informing that office of the request should be sent by the Georgia Gwinnett College office or person who has directed the requestor to the Office of Legal Affairs.

  1. Requests may be submitted orally, in written hard copy, or by e-mail or facsimile transmission. THE RECEIVING OFFICE SHOULD BE SURE TO OBTAIN THE CONTACT INFORMATION FOR THE REQUESTER.
  2. Requests to inspect or copy electronic messages, whether in the form of e-mail, text message, or other format, should contain information about the messages that is reasonably calculated to allow the recipient of the request to locate the messages sought, including, if known, the name, title, or office of the specific person or persons whose electronic messages are sought and, to the extent possible, the specific data bases to be searched for such messages.
  3. Requests to inspect or copy electronic messages, whether in the form of e-mail, text message, or other format, should contain information about the messages that is reasonably calculated to allow the recipient of the request to locate the messages sought, including, if known, the name, title, or office of the specific person or persons whose electronic messages are sought and, to the extent possible, the specific data bases to be searched for such messages.
  4. Requests by civil litigants for records that are sought as part of or for use in any ongoing civil or administrative litigation against an agency shall be made in writing and copied to counsel of record for that agency contemporaneously with their submission to that agency.
  5. Georgia Gwinnett College is not required to prepare reports, summaries, or compilations not in existence at the time of the request.

B. What happens when the Office of Legal Affairs receives a GORA request?

  1. The Office of Legal Affairs will immediately contact the office that maintains the requested record.
  2. The maintaining office will estimate and inform the Office of Legal Affairs how long it will take to search for, retrieve, redact, and re-file the records.
  • Many requesters do not realize that their requests for documents can be expensive, so the Office of Legal Affairs will inform the requestor of the costs of the retrieval. If the requester decides to withdraw the request then the Office of Legal Affairs will notify the maintaining office to cease working on the request. Until such time as the requestor does withdraw the request, the maintaining office must continue collecting and redacting the records in a timely fashion.

   3. When the maintaining office finishes searching for the requested documents, it shall notify the Office of        Legal Affairs that the documents are ready for review or mailing.

   4. The Office of Legal Affairs will then request the maintaining office to provide the materials to the Office        of Legal Affairs for review, or if it is extensive material, the Office of Legal Affairs will go to the                      respective office.

   5. The Office of Legal Affairs will review the material to ensure compliance with the GORA, then either              mail the material or inform the requestor that the material is available for review.

   6. The maintaining office shall request an invoice from the Office of Business & Finance, showing all                administrative and copying costs.

  1. Georgia Gwinnett College charges per page as set by state law for any copies in addition to the costs of search, retrieval, redaction and re-filing. This fee may be waived for requests that result in fewer than 20 copies.
  2. If the available information is in electronic format, Georgia Gwinnett College may charge the public the actual cost of the media on which the records or data are produced.  If electronic format is used, Georgia Gwinnett College may not charge a per page charge.
Important Things for Employees to Note
  1. Subpoenas
  1. If an office receives a subpoena, from any source, for Georgia Gwinnett College records, whether the subpoena is delivered by mail or given in person, the receiving office shall immediately contact the Office of Legal Affairs.
  2. THE RECEIVING OFFICE SHALL NOT DISPOSE OF ANY DOCUMENTS (INCLUDING ENVELOPES) RECEIVED WITH THE SUBPOENA.

B. Timeframe

  1. Georgia Gwinnett College only has three (3) business days to send the copies of the records requested or to inform the requestor where the records may be viewed.  In those instances where some, but not all, records are available within three business days, an agency shall make available within that period those records that can be located and produced.
  2. As the Office of Legal Affairs is the designated request office, the three (3) business day period does not begin to run until such time that the Office of Legal Affairs receives the requests.

 C. Georgia Gwinnett College is not required to prepare new reports, summaries, or compilations not in             existence at the time of the request.

  D. Georgia Gwinnett College may decide to withhold all or part of a requested record, in that case it shall          notify the requester of the specific legal authority exempting the requested record or records from                disclosure by Code section, subsection, and paragraph within a reasonable amount of time not to                exceed three (3) business days or in the event the search and retrieval of records is delayed.                        However, with the exception of nonclerical athletic staff salaries, a reasonable time for request for                records relating to intercollegiate sports programs will be ninety (90) days.

Fees
  1. Georgia Gwinnett College is permitted to recover its cost in responding to GORA requests. The hourly rate charged for search and retrieval time may not exceed the rate of the lowest paid full-time employee capable of performing the search. If the expected search and retrieval time will exceed one hour, the maintaining office shall inform the Office of Legal Affairs, who will respond as appropriate.
  2. In addition to a charge for the search, retrieval, or redaction of records, Georgia Gwinnett College may charge a fee for the copying of records or data, not to exceed the applicable statutory amount per page for letter or legal size documents or, in the case of other documents, the actual cost of producing the copy. In the case of electronic records, the agency may charge the actual cost of the media on which the records or data are produced.
  3. If Georgia Gwinnett College seeks costs in excess of $25.00 for responding to a request, it shall notify the requester within a reasonable amount of time not to exceed three business days and inform the requester of the estimate of the costs. Georgia Gwinnett College may defer search and retrieval of the records until the requester agrees to pay the estimated costs unless the requester has stated in his or her request a willingness to pay an amount that exceeds the search and retrieval costs. 
  4. In any instance in which the estimated costs for production of the records exceeds $500.00, Georgia Gwinnett College may insist on prepayment of the costs prior to beginning search, retrieval, review, or production of the records.
Penalties for Violation

Any person knowingly and willfully failing or refusing to provide access to records by knowingly and willingly failing or refusing to provide access to such records within the time limits set forth by law, or by knowingly and willingly frustrating or attempting to frustrate the access to records by intentionally making records difficult to obtain or review shall be guilty of a misdemeanor and upon conviction shall be punished by a fine not to exceed $1,000.00 for the first violation. Alternatively, a civil penalty may be imposed by the court in any civil action brought against any person who negligently violates the terms of the GORA in an amount not to exceed $1,000.00 for the first violation. A civil penalty or criminal fine not to exceed $2,500.00 per violation may be imposed for each additional violation that the violator commits within a 12 month period from the date that the first penalty or fine was imposed.

Special Provisions Based on Specific Departments
  1. Libraries

Records that are of historical research value which are given or sold to public archival institutions, public libraries, or libraries of a unit of the Board of Regents of the University System of Georgia when the owner or donor of such records wishes to place restrictions on access to the records may qualify for an exemption under GORA. No restriction on access, however, may extend more than 75 years from the date of donation or sale. This exemption shall not apply to any records prepared in the course of the operation of state or local governments of the State of Georgia.

  B. Research

Any data, records, or information developed, collected, or received by or on behalf of faculty, staff, employees, or students of an institution of higher education or any public or private entity supporting or participating in the activities of an institution of higher education in the conduct of, or as a result of, study or research on medical, scientific, technical, scholarly, or artistic issues, whether sponsored by the institution alone or in conjunction with a governmental body or private entity, may qualify for an exemption under GORA until such information is published, patented, otherwise publicly disseminated, or released to an agency whereupon the request must be made to the agency.