Electronic Communications

CCS continues to adopt and make use of new means of communication and information exchange.   This means that many of our employees have access to one or more forms of electronic media and services, including: computers, e-mail, telephones, voice mail, fax machines, external electronic forums, wire services, on-line services, the Internet, and the World Wide Web.

CCS encourages the use of these media and associated services because they can make communication more efficient and effective and because they are valuable sources of information. However, all employees and everyone connected with CCS must be aware that electronic media and services provided by CCS are for the purpose of facilitating and supporting CCS educational and business use.

This policy cannot establish rules to cover every possible situation. Instead, it is designed to support CCS’s Mission Statement and set forth general principles employees should apply when using electronic media and services.

The following procedures apply to all electronic media and services that are:

  • accessed on or from CCS premises;
  • accessed using CCS computer equipment or via CCS paid access methods; or
  • used in a manner that identifies the individual with CCS.

Prohibited Communications

Electronic media cannot be used for knowingly transmitting, retrieving, or storing any communications that are:

  • discriminatory, annoying, or harassing;
  • derogatory to any individual or group;
  • offensive, obscene, defamatory, or threatening;
  • attempting to test, circumvent, or defeat security or auditing systems;
  • SPAMMING, the method of mass distribution of communications, that does not support CCS related business;
  • engaged in for any purpose that is illegal, fraudulent, malicious, or contrary to CCS policy or educational and business interests.
  • CCS reserves the right for interpretation of the above prohibited communications.

Personal Use

Electronic media and services are provided by CCS primarily for employees’ educational and business use. Limited, occasional, or incidental use of electronic media (sending or receiving) for personal, non-business purposes is understandable. Personal use of CCS’s electronic media and services cannot interfere with an employees’ position responsibilities. Employees are expected to demonstrate a sense of responsibility and not abuse this privilege.

Access to Employee Communications

CCS does not routinely access or monitor employee communications directly. However, individual use patterns – telephone numbers called, sites accessed, call length, and time at which calls are made – are monitored for the following purposes:

  • cost analysis;
  • resource allocation;
  • optimum technical management of information resources; and
  • detecting patterns of use that indicate employees are violating CCS policies or engaging in illegal activity

CCS reserves the right to review any employee’s electronic files and messages at any time to ensure electronic media and services are being used in compliance with the law, this policy, and other CCS policies. Employees should not assume that electronic communications are private.

Software Use

CCS licenses the use of various computer software for educational and business purposes and does not own the copyright to this software or its related documentation. The employees of CCS do not have the right to reproduce such software for use on more than one computer, or use the software for purposes other than those authorized by the license.  In most cases, educational use only is allowed by the license and software licensed by the College may not be used for personal, professional, or profit making use.

Employees may only use software on local area networks or on multiple machines according to the software license agreement. CCS prohibits the illegal duplication of software and its related documentation.

Security / Appropriate Use

Employees must respect the confidentiality of other individuals’ electronic communications. Except in cases in which authorization has been granted by CCS management, employees are prohibited from engaging in, or attempting to engage in:

  • monitoring or intercepting the files or electronic communications of other employees or third parties;
  • hacking or obtaining access to systems or accounts they are not authorized to use;
  • using other people’s log-ins or passwords; and
  • breaching, testing, or monitoring computer or network security measures

No e-mail or other electronic communications can be sent using CCS equipment that attempt to hide the identity of the sender or represent the sender as someone else.

Electronic media and services should not be used in a manner that is likely to cause network congestion or significantly hamper the ability of other people to access and use the system.

Anyone obtaining electronic access to other organizations’ or individuals’ materials must respect all copyrights and cannot copy, retrieve, modify, or forward copyrighted materials, except as permitted by the copyright owner.

See also the College’s Information Security Plan which can be found on the CCS Policy Database.

Confidential Information

The confidentiality of student and employee records is protected by state and federal laws. No employee may access confidential information unless authorized to do so. CCS confidential information should never be transmitted or forwarded to outside individuals or organizations without authorization. Employees are required and expected to protect CCS confidential information.
Please also see the College’s FERPA Policy which can be found on the CCS Policy Database.

Participation in On-Line Forums

Employees must be aware that any messages or information sent on CCS provided facilities to one or more individuals via an electronic network (i.e.: Internet mailing lists, bulletin boards, and other on-line services) are statements identifiable and attributable to CCS.

CCS recognizes that participation in some forums might be important to the performance of certain employees’ positions. Employees should include the following disclaimer in all of their postings to public forums:

  • The views, opinions, and judgments expressed in this message are solely those of the author. The message contents have not been reviewed or approved by CCS.

Employees should note that, even with a disclaimer, connection with CCS exists and a statement could be imputed legally to CCS. Therefore, employees should not rely on disclaimers as a way of insulating CCS from the comments and opinions they contribute to forums. Instead, employees must limit their discussion to matters of fact and avoid expressing opinions while using CCS systems or a CCS provided account. Communications must not reveal information about CCS’s business or confidential information and must not otherwise conflict with this or other CCS policies.

Policy Violations

Employees who abuse or violate the privilege of CCS-facilitated access to electronic media or services are subject to corrective action, up to and including termination.

Complete technology-related policies can be found on the CCS policy database.

Employee Conflict of Interest

CCS administrative staff should avoid situations where their own interests materially conflict with their obligations to CCS or create the perception of a conflict. All decisions and actions by administrative staff in the course of their professional responsibilities are to be made consistent with their obligations to CCS.

Generally, a conflict of interest arises when an administrative staff member has a personal or financial interest in a transaction or event – or is a party to a transaction or event – that might adversely affect his or her judgment in performing professional or employment duties for CCS. Examples of potential conflicts of interest include, but are not limited to, the following:

1. Engaging in any business with, or employment by, an employer that is in competition or in conflict with any transaction, activity, or objective of CCS.

2. Engaging in business with or employment by a supplier of goods or services to CCS without prior approval of CCS.

3. Using equipment, supplies, or services owned or provided by CCS in conjunction with any external work, without obtaining prior agreement, in writing, from the department that owns the equipment/supplies.

4. Making use of any confidential information acquired through employment with CCS for personal profit or advantage, or the advantage of a third-party.

5. Publicly associating CCS or its prestige with an outside business interest for personal gain.

Administrative staff members who believe they have a financial, personal, or professional interest that is (or could potentially become) a conflict of interest must fully disclose the nature of the potential conflict in writing to the Director of Human Resources. All decisions concerning whether a conflict of interest exists are within the sole discretion of CCS.

Confidentiality

Due to the nature of the College’s work, you may be privy to confidential information. Certain information is required to be confidential by law, while other material must remain confidential in order to comply with contracts or good professional practice.

If you have access to confidential information, you must not disclose it to anyone inside or outside the College unless express authorization has been obtained from the College. If you have any questions about the confidentiality of the work you perform or the information that you receive, either in written or verbal form, please contact your supervisor or the director of Human Resources.

Family Educational Rights and Privacy Act (FERPA)

The Family Educational Rights and Privacy Act (FERPA) affords eligible students certain rights with respect to their education records. (An “eligible student” under FERPA is a student who is 18 years of age or older or who attends a postsecondary institution at any age.) These rights include:

  1. The right to inspect and review the student’s education records within 45 days after the day the College for Creative Studies (CCS) receives a request for access. A student should submit to the Registrar, a written request that identifies the record(s) the student wishes to inspect.  The Registrar will make arrangements for access and notify the student of the time and place where the records may be inspected. If the records are not maintained by the school official to whom the request was submitted, that official shall advise the student of the correct official to whom the request should be addressed.
  2. The right to request the amendment of the student’s education records that the student believes is inaccurate, misleading, or otherwise in violation of the student’s privacy rights under FERPA.

    A student who wishes to ask CCS to amend a record should write the Registrar, clearly identifying the part of the record the student wants changed and specify why it should be changed.

    If CCS decides not to amend the record as requested, the Registrar will notify the student in writing of the decision and the student’s right to a hearing regarding the request for amendment. Additional information regarding the hearing procedures will be provided to the student when notified of the right to a hearing.
  3. The right to provide written consent before CCS discloses personally identifiable information (PII) from the student’s education records, except to the extent that FERPA authorizes disclosure without consent.

    FERPA permits the disclosure of PII from students’ education records, without consent of the student, if the disclosure meets certain conditions found in § 99.31 of the FERPA regulations. Except for disclosures to school officials, disclosures related to some judicial orders or lawfully issued subpoenas, disclosures of directory information, and disclosures to the student, § 99.32 of FERPA regulations requires the institution to record the disclosure. Eligible students have a right to inspect and review the record of disclosures. A postsecondary institution may disclose PII from the education records without obtaining prior written consent of the student —
    • To other school officials, including faculty, within CCS whom the College has determined to have legitimate educational interests. This includes Board of Trustees, a student serving on an official committee, contractors, consultants, volunteers, or other parties to whom the school has outsourced institutional services or functions, provided that the conditions listed in § 99.31(a)(1)(i)(B)(1) – (a)(1)(i)(B)(3) are met. (§ 99.31(a)(1))
    • To officials of another school where the student seeks or intends to enroll, or where the student is already enrolled if the disclosure is for purposes related to the student’s enrollment or transfer, subject to the requirements of § 99.34. (§ 99.31(a)(2))
    • To authorized representatives of the U. S. Comptroller General, the U.S. Attorney General, the U.S. Secretary of Education, or State and local educational authorities, such as a State postsecondary authority that is responsible for supervising the university’s State-supported education programs. Disclosures under this provision may be made, subject to the requirements of §99.35, in connection with an audit or evaluation of Federal- or State supported education programs, or for the enforcement of or compliance with Federal legal requirements that relate to those programs. These entities may make further disclosures of PII to outside entities that are designated by them as their authorized representatives to conduct any audit, evaluation, or enforcement or compliance activity on their behalf. (§§ 99.31(a)(3) and 99.35)
    • In connection with financial aid for which the student has applied or which the student has received, if the information is necessary to determine eligibility for the aid, determine the amount of the aid, determine the conditions of the aid, or enforce the terms and conditions of the aid. (§ 99.31(a)(4))
    • To organizations conducting studies for, or on behalf of, the school, in order to:
      • develop, validate, or administer predictive tests;
      • administer student aid programs;
      • improve instruction. (§ 99.31(a)(6))
    • To accrediting organizations to carry out their accrediting functions. (§ 99.31(a)(7))
    • To comply with a judicial order or lawfully issued subpoena. (§ 99.31(a)(9))
    • To appropriate officials in connection with a health or safety emergency, subject to § 99.36. (§ 99.31(a)(10))
    • To a victim of an alleged perpetrator of a crime of violence or a non-forcible sex offense, subject to the requirements of § 99.39. The disclosure may only include the final results of the disciplinary proceeding with respect to that alleged crime or offense, regardless of the finding. (§ 99.31(a)(13))
    • Information the school has designated as “directory information” under § 99.37. (§ 99.31(a)(11)).  CCS defines the following as “directory information:”
      • Name
      • Dates of Attendance
      • Graduation Date
      • Major/Academic Program
      • Degrees, honors, and awards received
  4. The right to file a complaint with the U.S. Department of Education concerning alleged failures by CCS to comply with the requirements of FERPA. The name and address of the office that administers FERPA is:

    Family Policy Compliance Office
    U.S. Department of Education
    400 Maryland Avenue, SW
    Washington, DC 20202

Information for Dual Enrolled High School Students

A student attending a postsecondary institution – at any age – the rights under FERPA have transferred to the student. However, in a situation where a student is enrolled in both a high school and a postsecondary institution, the two schools may exchange information on that student. If the student is under 18, the parents still retain the rights under FERPA at the high school and may inspect and review any records sent by the postsecondary institution to the high school.

Student Information Release Authorization

To release PII to a parent, another individual, or organization, the Student Information Release Authorization must be completed and signed. This form is available in the Academic Advising and Registration Office (AARO).

Request to Withhold Release of Directory Information

To request to withhold the release of directory information, the Request to Withhold Release of Directory Information must be completed and signed. This form is available in the Academic Advising and Registration Office (AARO).