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Acceptable Use of College Computing Resources Policy

This policy was posted for public comment from February 18 – March 5, 2025

Comments

The general use of this TOS is on the point and appropriate. I would love to see, as someone in the field of Cybersecurity, there be a clause to protect those exploring field-related tools to be allowed access to possibly isolated networks where Virtual Machines can live and allow for exploration there. We have been able to work with the IT department in the past but at highly restricted levels - no NAT allowed, for example, which severely limits these tools, like VMs, to the point where they hardly function.

I would like more clarification on the final sentence in the definition of D. Incidental Personal Use. Could you clarify what "This does not include external personal business transactions." actually means? For instance, can I use my school laptop to make a purchase on Amazon? If you look at 4.c.2.a-c it looks as though making an online purchase is permitted, which seems to conflict with the last sentence of definition D.

Section B2k, when combined with Sections M1-4, makes it challenging to protect personal and sensitive information during work hours because we use a college device or its network. While I understand that OIT's changes are intended to enhance security, they can feel restrictive from a regular user's perspective. For example, the implementation of Admin By Request significantly limits a user's control over their device.

Item 2a may be problematic in that one could accidentally violate this policy by attempting to open a link to a restricted file. In this case, if you were navigating SharePoint and clicked on a restricted file, you could violate this policy as written without malicious intent.
2. Users must not:
a. access or attempt to access any restricted resource or private data owned by the college or another user without express permission;

As it is currently written, 4.H.1. means, in a literal sense, (a) that all college business must be conducted through email or (b) (if read more narrowly to apply only to “college computing resources”) that email is the only computing resource that can be used for college business. It would be a violation of policy, therefore, to conduct business using RingCentral, SharePoint, Zoom, most apps within the Microsoft Office suite, etc.

I would hope, of course, that a reasonable person would not read the policy this broadly, but I raise this point anyway to emphasize the importance of explicitly tailoring the policy to its intended scope. An example of more narrow wording might be “Any college business that is conducted by email must use the college’s enterprise email system.” In fact, it appears that the intent may have been to limit “college business” specifically to “Institutional Business Email Communications,” since that term was defined in Section 3.E. but never used elsewhere in the policy. Section 4.H.1. could, therefore, be revised to simply read, “Institutional business email communications must use the college’s enterprise email system.”

F.3
3. When off campus, especially on public or unsecured networks, users must use the college-provided VPN to access college resources.

Not all users have access to a SLCC-provided VPN. AllAccess or other means should also be authorized. This rule would prohibit the use of Canvas, SharePoint, Teams, Email, and other software while off campus. As written, it would apply to students who don't have VPN access.

[F.3] It would also prevent many of us from doing things like grading papers from home or even teaching online courses from our home offices.

1. Policy Statement

A. General Comment-This policy needs to more clearly state that it applies to faculty, staff, and students. As drafted, its application to students seems to be an afterthought. Are students going to look at this policy? There is little in the Code of Student Rights and Responsibilities regarding guidance or restrictions on how students use computers.
Bottom line: Students are not going to know that this policy applies to them. This policy needs to be better integrated with the Code of Student Rights and Responsibilities.

B. General Comment-Similar to our comments in the Code of Student Rights and Responsibilities policy, the inclusion of Artificial Intelligence provisions, while necessary, is an elusive problem. Both this policy and that policy do not provide clear guidance as to what is and what is not allowed. Despite robust committee discussion on this topic, we don’t have concrete suggestions to provide clarity to employees or students on acceptable and unacceptable uses of AI. In addition, if SLCC is too specific with AI policy provisions, our concern is that these specific provisions will be outdated in three to six months given rapid changes with AI. The committee sees the potential for significant inconsistency across the college regarding authorized and unauthorized AI use. For example, one academic department may state use of AI does not constitute cheating, while the same usage will be allowed in another department.

C. General Comment-Many of the updates to the policy are good and the policy has been improved. Since all employees use college issued laptops, this is an important policy.

2. Procedures
A. Section 4.B.1.d -Consider including a link to allow persons to report theft or misuse of computers to Public Safety or OIT.
B. Section 4.B.2-discusses access to restricted materials. Committee members expressed concern that they have unintentionally or accidentally accessed restricted materials as they were searching on Banner or Canvas for unrelated information. For example, you can access all of Canvas with the password. Another example is that sometimes you can access Board of Trustee information through SharePoint. Given that we share so much information at the college, this is a problem. Concern was expressed that this accidental access would result in corrective action. Can we create better firewalls so employees or students cannot access this restricted information?
C. Section 4.C.2-The committee had an extensive discussion regarding the “substantial personal gain” element for computer usage not considered to be incidental use. Some examples in the committee’s discussion addressing this concern were as follows:
1. Some faculty use their college-issued laptops to provide private tutoring lessons to students for which they are paid. There may be several Zoom lessons over the course of a semester for which they are paid $300 or $400. Does that violate this provision?
2. Some college faculty are paid to provide a virtual deposition as an expert witness in litigation. They provide their Zoom deposition on their college computer and are paid $500 or $1,000 for this service. Does this violate section 4.C.2?
3. Some college faculty conduct research and author articles on their laptop. In some cases, they are paid to write and publish this article. Does this violate section 4.C.2?
4. Besides being a vague term, “substantial personal profit” depends on who is profiting from the use of the computer. For example, a Vice President who earns $100 using his or her computer may not have a substantial personal gain; however, for an adjunct faculty member, a $100 earning may constitute substantial personal gain.
5. Make sure that this incidental use section is consistent with similar provisions in the Employee Conduct policy and Intellectual Property Policy.
D. Section 4.C.3- is new and seems to infringe upon an employee’s right without giving him or her the opportunity to be heard. While the college should be able to restrict access to a user accessing a pornographic webpage, this section, as drafted, is too broad.
E. Section 4.H.1- discusses the use of the email system. Consider rewording the sentence to state, “The college’s enterprise email system must be used to conduct college business” or words to this effect.
1. Does this section include Canvas messages?
F. Section 4.J-Use of Social Media
1. The social media section is not very robust. Consider adding more guidance or rules.
2. Should this section distinguish between an individual’s social media account and an institutional or college-wide social media account?
3. Should there be approval for college-wide social media programs?
4. How is this section being enforced and who is enforcing it?
5. Is “Linked In” considered social media? Is it subject to this section?
G. Section 4.L-Artificial Intelligence
1. There was concern that this section was more informational and did not belong in a policy setting forth rules. For example, do we need 4.L3 in the policy which states “AI systems’ training data and algorithms can perpetuate biases. . .”
2. In section 4.L.4, is there a need to reference the Code of Student Rights and Responsibilities?
3. Section 4.L.5 seems like an onerous responsibility to place on faculty and staff. Isn’t most everything thing done on work computers have potential transmission “across the college?”
H. Section 4.N-Enforcement
1. Who has the responsibility to enforce this policies’ provisions?

Responses

General Comments

Many of the updates to the policy are good and the policy has been improved. Since all employees use college-issued laptops, this is an important policy.

Thank you for your comment.

This policy should more clearly state that it applies to faculty, staff, and students. As drafted, its application to students seems to be an afterthought. Are students going to look at this policy? This policy needs to be better integrated with the Code of Student Rights and Responsibilities.

Thank you for your comment. The policy statement (section 1) clearly states that “SLCC faculty, staff, students, contractors, vendors, third-party agents, and community members who access [SLCC computing resources] must comply with this policy.”

Authorized and unauthorized uses of Artificial intelligence are not consistent across the college. This policy and the Code of Student Rights and Responsibilities do not provide clear guidance as to what is and what is not allowed, especially for faculty and students. We recognize that AI policy provisions are necessary. Will the AI provisions in this policy be outdated in three to six months due to the rapid growth of AI technologies?

The AI provisions in this policy were intentionally left broad to allow for future developments. The OIT Guidelines for AI Use at SLCC, hyperlinked in 4.N.8, will be updated with specifics as AI technology and use evolve.

As someone in the field of Cybersecurity, I’d like there to be a clause to protect those exploring field-related tools. I'd like them to be allowed access to possibly isolated networks where Virtual Machines can live and allow for exploration. We have been able to work with the IT department in the past, but at highly restricted levels—no NAT allowed, for example, which severely limits these tools, like VMs, to the point where they hardly function.

For requests of this nature, please follow the SLCC Technology Approval and Prioritization Process and submit a Technology Request Form. Section 4.F.2 now includes a hyperlink to the Technology Request Form.

3.D Incidental Personal Use Definition – Could you provide more clarity regarding the last sentence, “This does not include external personal business transactions.” For example, can I use my school laptop to make a purchase on Amazon? If you look at 4.C.2.a-c, it appears that making an online purchase is permitted, which seems to conflict with the last sentence of 3.D.

In the case of the example you provided, yes, this would be considered incidental personal use. “External personal business transactions” refers to the specifications in section 4.C.

4.B. User Responsibilities

4.B.1.d – Consider including a link to allow persons to report theft or misuse of a computer to Public Safety or OIT.

4.B.1.e has hyperlinks to IT support and the Security Office. A hyperlink to the Public Safety Contact webpage has been added.

4.B.2.a may be problematic because employees may accidentally violate this policy without malicious intent. For example, you can access all of Canvas with the password; you can sometimes access Board of Trustees information through SharePoint; and sometimes, employees searching on Banner can access unrelated information that is restricted. Concern was expressed that this accidental access would result in corrective action. Can we create better firewalls so employees or students cannot access this restricted information?

The word “intentionally” has been added at the beginning of 4.B.2.a. Users knowingly accessing a restricted document or asset are misusing computing resources.

4.B.2.k, when combined with sections 4.M.1-4, makes it challenging to protect personal and sensitive information during work hours because we use a college device or its network. While I understand that OIT's changes are intended to enhance security, they can feel restrictive from a regular user's perspective. For example, the implementation of Admin By Request significantly limits a user's control over their device.

OIT is responsible for the security of college-owned devices. Incidental personal use is permitted on college-owned devices; however, a college-owned device should not be used for storing personal information unrelated to college duties. Admin by Request intentionally limits a user’s control over a college device to enhance security.

4.C Incidental Personal Use

4.C.2 – Concerns about the phrase “…substantial personal profit, gain…” in 4.C.2.c. “Substantial personal profit” is vague and would appear to depend on who is profiting from the use of the computer. Would the following examples violate 4.C.2?
  1. Some faculty use their college-issued laptops to provide private tutoring lessons to students for which they are paid. There may be several Zoom lessons over the course of a semester for which they are paid $300 or $400.
  2. Some college faculty are paid to provide a virtual deposition as an expert witness in litigation. They provide their Zoom deposition on their college computer and are paid $500 or $1,000 for this service.
  3. Some college faculty conduct research and author articles on their laptops. In some cases, they are paid to write and publish these articles.

None of these examples violates the incidental personal use defined within this policy. An example that would violate the policy would be using a college-owned device to host and manage a personal website and/or leverage college internet bandwidth for hosting a personal business.

This section on Incidental Personal Use should be consistent with similar provisions in the Employee Conduct and Intellectual Property policies. Is it?

Section 4.C, Incidental Personal Use, aligns with the definition of incidental use in the Employee Conduct policy and the Intellectual Property policy.

4.C.3—This section is new and appears to infringe on employees’ rights without giving them the opportunity to be heard. While the college should be able to restrict a user's access to a pornographic webpage, this section, as drafted, is too broad.

Section 4.C.3 is intended to protect college resources from inappropriate personal use. If a user’s personal use is rescinded, OIT would then reach out to the applicable user for discussion. Employees do not have a recognized right to due process regarding computer access.

4.F Use of College Networks

4.F.3 – Not all users have access to an SLCC-provided VPN. AllAccess or other means should also be authorized. This rule would prohibit the use of Canvas, SharePoint, Teams, Email, and other software while off campus. This rule, as written, would apply to students who don't have VPN access. 4.F.3 would also prevent many employees from doing things like grading papers from home or even teaching online courses from home offices.

4.F.3 has been revised to state, “From any public or unsecured networks, faculty and staff must use the college-provided VPN to access college resources.” The intent is to not use unsecured open public networks. A personal home network is not a public or open/unsecured network in this context. AllAccess is considered a VPN in this situation and is available to faculty, staff, and students.

4.H. Use of College Email
4.H.1 is currently a bit broad. Suggest rewording as “Institutional business email communications must use the college’s enterprise email system,” “The college’s enterprise email system must be used to conduct college business,” or something similar.

Thank you for your comment. No changes were made.

Does 4.H.1 include Canvas messages?

Unless a user is forwarding their Canvas messages to a personal email, this is not an issue. Canvas messages are considered a college enterprise system.

4.J Use of Social Media

This section is not very robust. Should this section distinguish between an individual’s social media account and an institutional or college-wide social media account? Should there be approval for college-wide social media programs?

Thank you for your comment. This policy is concerned with prohibiting publishing information on social media that violates laws or acts such as FERPA, HIPAA, GRAMA, etc. That is the responsibility of every user. The differentiation between types of media accounts is not the purview of this policy.

How is this section being enforced, and who is enforcing it?

If brought to the college’s attention, then appropriate action, potentially including corrective action, may be taken.

Is “LinkedIn” considered social media? Is it subject to this section?

Yes, LinkedIn is considered social media for this policy.

4.L Use of Artificial Intelligence (AI)

This section is more informational. Does it belong in a policy setting forth rules? For example, do we need 4.L.3 stating, “AI systems’ training data and algorithms can perpetuate biases…?”

The AI provisions in this policy were intentionally left broad to allow for future developments. The OIT Guidelines for AI Use at SLCC, hyperlinked in 4.N.8, will be updated with specifics as AI technology and use evolve.

4.L.4 – Is there a need to reference the Code of Student Rights and Responsibilities?

Thank you for your comment. No changes were made.

4.L.5 seems like an onerous responsibility to place on faculty and staff. Isn’t most everything done at work on computers have potential transmission “across the college?”

4.L.5 has been revised to clarify that the concern is about how faculty and staff are individually using AI technologies for college business purposes (which includes teaching, research, and administration).

4.N Enforcement – who has the responsibility to enforce this policy’s provisions?

OIT, with the assistance of PWC, the Dean of Students, and Public Safety as appropriate.