Reproduction and Use of Copyrighted Materials

This policy was posted for public comment from January 26 – February 10, 2026

Responses

General Comments

Is there a resource we could link to that walks a person through the fair use analysis process?

Thank you for this suggestion. The Copyright Guide linked in 4.A.2 is designed as a repository for resources like this.

Why does the policy link to Cornell Law School Legal Information Institute instead of the actual laws? Why are there no references to any of the Copyright Office’s circulars?

After consultation with General Counsel, the links in the policy to Cornell Law School Legal Information Institute have been removed. Due to their stated scope and purpose, the Copyright Office’s circulars are not referenced in this policy. The resource linked in 4.A.2 may be a better place for the circulars to be referenced, which is outside the scope of this policy.

What kind of documentation is required by our legal team for fair use analysis or for playing music in a course, etc.?

Thank you for this question. Unfortunately, it falls outside this committee’s scope to provide an answer. Please direct this question to the Office of the General Counsel.

2. References

Consider including a reference to the Copyright Ownership and Intellectual Property Policy in this section of the policy.

The “Copyright Ownership and Intellectual Property Policy” is referenced at the beginning of the procedures section. This is in alignment with the reciprocal mention of this policy in 4.A.4 of the “Intellectual Property” policy. References are reserved for laws, statutes, and similar requirements; references to internal college documents and policies are not placed in this section.

3. Definitions

General Note on Definitions: This section relies heavily on legal jargon and specialized terminology, making it difficult to understand. Several definitions are also circular or overly interdependent, reducing clarity and usability for faculty and staff. Suggestion to simplify the language and ensure each definition stands on its own to improve comprehension.

Thank you for the feedback. The following definitions have been revised to increase clarity and reduce interdependence:

C. Copyright: the legal right that governs how original works of authorship may be used by others.

D. Copyright Owner: the individual or institution that holds the right to control how a work is used.

3.E. – Multiple comments: Why are the four fair use factors in the definition? They seem to be an important procedure rather than just a definition. If the four factors are retained in the definition, commenter provided a suggested rewrite.

Thank you for your comment. The fair use factors are included within the definition to clearly indicate that they apply whenever fair use is referenced in the policy. This placement is consistent with other USHE institutions’ policies, including the University of Utah’s “Copyright Policy: Copying of Copyrighted Works” ( Policy 7-013, Section 2.E) and Snow College’s “Libraries Copyright Policy” ( Policy #407, Section 2.2). To improve clarity, the language in 3.E has been revised to read: “Fair Use or Fair Use Exception: the right to use a work under certain conditions without the permission of the copyright owner. Fair use is evaluated on the following factors: 1. the purpose or character of the use, e.g., for commercial purposes or for nonprofit educational purposes; 2. the nature of the copyrighted work; 3. the amount and substantiality of the portion used in relation to the copyrighted work as a whole; and 4. the effect of the use upon the potential market for or value of the copyrighted work.”

Consider removing the definitions for Library Services (3.F) and Printing Services (3.J). It is not clear that either term needs to be defined. The committee questions whether defining these college units adds clarity or simply restates the names of departments already familiar to SLCC employees.

These definitions have been removed from the policy.

3.H. Open Licensing – The current definition assumes the reader already understands what a “license” is, but the policy never defines license or licensing. This leaves a gap in clarity: users cannot understand open licensing without first understanding licensing. Please consider adding/rewording definitions for License and Open Licensing.

No revision was made based on this comment. Because the policy already defines “Permission” (3.I) as the written terms for how a work may be used, adding a separate definition for “license” would not enhance clarity. Additionally, the definition of “Open Licensing” is consistent with the definition provided in 3.H of the “Copyright Ownership and Intellectual Property” policy.

3.L. Work – This definition is too vague for general users. It does not explain what makes something “capable of copyright protection.” Consider revising to: “A creative product made by a person and expressed in a fixed, tangible form, such as writing, music, artwork, or digital media so that copyright law can protect it from unauthorized copying or use.”

No revision was made based on this comment. The definition of “Work” is consistent with the definition provided in 3.M of the “Copyright Ownership and Intellectual Property” policy.

4.A. General

4.A.1 – Suggestion that the reference to the Copyright Ownership and Intellectual Property Policy should be moved to section 2. References.

Thank you for your suggestion. References are reserved for laws, statutes, and similar requirements; references to internal college documents and policies are not placed in this section. The placement of this reference to the “Copyright Ownership and Intellectual Property” policy is in alignment with the reciprocal mention of this policy (see 4.A.4 of the “Intellectual Property” policy).

4.A.2 – This statement places librarians in a position where they may be expected to interpret copyright law or provide legal guidance, which they cannot do. This creates a circular problem: the policy tells users to ask the librarian, the librarian must direct users to the Office of General Counsel (OGC), and the OGC often refers back to the policies themselves. This loop is confusing and unhelpful to employees seeking clear direction. Consider revising to: “For general information about fair use or limitations on exclusive rights, consult the Copyright Guide or contact Library Services for educational resources. For legal questions or formal interpretation of copyright law, contact the Office of General Counsel.”

This revision has been partially accepted. 4.A.2 has been revised to state, “To learn more about fair use analyses or applicable limitations on exclusive rights for specific uses of copyrighted works, access the Copyright Guide or contact the Library Services Copyright Librarian.” A new section (4.A.3) has been added: “For legal questions, contact the Office of the General Counsel.”

4.A.3 – This AI section is very confusing as written. It doesn’t really provide clear guidance on how we can use or reproduce AI-generated works. What would/wouldn’t be covered by copyright in AI-generated works?

The U.S. Copyright Office has issued several reports on copyright and artificial intelligence. It is outside of this policy’s scope to include all nuances of what may or may not be covered.

4.A.3.a – This statement is overly broad and reflects only one developing area of case law. It oversimplifies a complex and rapidly changing legal question. Additionally, the policy does not acknowledge that prompts written by humans are copyrightable, since they involve human authorship. The current wording risks misleading employees into thinking that all AI-associated content is automatically uncopyrightable, which is not accurate. Consider changing the language to: “Fully autonomous outputs generated by AI systems without meaningful human authorship may not qualify for copyright protection under current interpretations of copyright law. However, human-created inputs, such as prompts, instructions, or edits, may be copyrightable if they reflect original, creative human contribution.”

Thank you for your comment. After consultation with General Counsel, section 4.A.4 “Copying and Artificial Intelligence (AI)” (previously 4.A.3) has been revised to allow for the evolving nature of this content area.

4.B. Reproduction for Academic Use

Why was 4.B.1.b of the original policy removed? This restriction must be in place to comply with the exemptions to the DMCA and 17 U.S.C. § 110(2).

Thank you for your question. As you noted, the original 4.B.1.b access‐restriction statement is a requirement that is reflected in 17 U.S.C. § 110(2). That statement was omitted as the policy does not seek to restate all requirements that accompany the exceptions within the Copyright Act or the DMCA.

4.B – Because the detailed fair use explanation was moved to the Definitions section (3.E), the practical, actionable guidance on applying fair use now feels disconnected from the steps users follow when reproducing works. The committee questions whether fair use guidance belongs in the Procedures section to support operational decision-making.

Thank you for your comment. The fair use factors are included within the definition to clearly indicate that they apply whenever fair use is referenced in the policy. Section 4.B “Reproduction for Academic Use” identifies when a fair use evaluation may be needed for academic use. Section 4.A.2 (“For general information on fair use analyses… access the Copyright Guide…”) is intended to provide the operational decision-making required when performing a fair use evaluation.

4.B.2 – This section requires a fair use analysis when relying on the fair use exception, but without the fair use factors present in the Procedures, this instruction is not helpful. Users are told to conduct an analysis but are not given the tools or criteria they need to do so. This creates confusion and reinforces the misconception that anything used for academic purposes is automatically fair use, which is inaccurate. Consider placing a simplified version of the four factors in this section.

Thank you for your comment. The fair use factors are included within the definition to clearly indicate that they apply whenever fair use is referenced in the policy, including Section 4.B.2. This section is intended to identify when a fair use analysis is necessary rather than provide instructional detail. Your concern about contributing to the misconception that all academic use is automatically fair use is appreciated; the policy’s structure and wording aim to prevent this by requiring a fair use analysis rather than assuming a favorable outcome.

4.B.3 – While this section is legally correct, directing faculty to go read the federal statute is not helpful or practical. Perhaps instead, consider providing faculty with the key questions that Section 110 and fair use require them to consider.

Thank you for this comment. After consultation with General Counsel, this section has been revised to reference applicable laws more broadly. As copyrighted works may be performed or displayed for academic use in a variety of situations, it is not practical to list all the nuances in this policy. These nuances also impact users’ rights to share works, and the goal of this policy is not to unintentionally restrict an individual’s rights.

4.C. Sharing Digital Content for Academic Use

4.C.1 – What does “digitally shared” mean in this context? Sharing digital content in a locked-down Canvas course so students can’t download or retain a copy is different from faculty emailing a file to students.

Thank you for your question. The term “digitally shared” is intentionally broad to better encompass a variety of digital methods for transmitting copyright works for academic use. Regardless of the method or the context for transmitting the work, the user must ensure that their sharing of the work occurs under one of the mechanisms identified in the policy.

4.C.1 – Treats “digital content” as a separate category of work, even though copyright law applies equally to works regardless of format. The procedures do not explain why digital sharing is separated from other types of reproduction, and the distinction may confuse users or imply that digital materials are governed by special rules under copyright law. Consider revising this section so that digital materials follow the same guidance as physical materials unless a true exception applies.

Thank you for this suggestion. To eliminate confusion about digitally versus physically sharing content, this section has been removed. In its place, Section 4.B.1 has been slightly modified to state, “It is permissible to use or reproduce works for academic purposes, including in digital formats, if the sharing or reproduction is done with permission, within the terms of an open license, or adheres to fair use or other limitations on exclusive rights identified in the Copyright Act.” The original Section 4.C.2 regarding ADS accommodations via digital reproductions has been relocated to the “Reproduction for Academic Use” section, now 4.B.4.

4.C.2 – Perhaps you should include links to the actual part of the code (not Cornell) that grants ADS the rights to do this?

Thank you for your suggestion. The rationale and applicable links that grant ADS the right to make digital reproductions for accommodations are provided in the section “Reproduction for Accessibility.”

4.D. Reproduction by College Departments

4.D. – This section includes specific operational procedures for Library Services, Printing Services, and the SLCC Bookstore. These are internal departmental workflows rather than college-wide copyright standards. Consider moving departmental procedures out of the college-wide policy, and replacing it with a general statement that departments must follow copyright law and maintain internal procedures consistent with the policy.

Thank you for your comment. Your concern is understandable. While sections 4.D.1 and 4.D.2, relating to Library Services and Printing Services, respectively, may appear operational, they contextualize departmental functions within the applicable legal requirements. Because these departments routinely reproduce copyrighted materials, maintaining clear and legally precise language at the policy level is valuable for compliance. The inclusion of 4.D.1 “Reproduction by Library Services” follows a similar structure to the “Copying by University Libraries” section of the University of Utah “Copyright Policy: Copying of Copyrighted Works” ( Policy 7-013, Section 3.E).

4.D.1 – This section includes three separate instructions that direct users to “see the Copyright Act” (primarily Sections 108 and 107) for guidance on library reproduction and interlibrary loan. Repeatedly pointing users to federal statutes is not practical or user-friendly. Consider summarizing.

Thank you for your comment. The Copyright Act, specifically Section 108, serves as the legal foundation for why these activities are permissible for qualifying libraries, including Library Services.

4.D.1.a – Does this section refer to anything besides legally obtained copies of materials in the library’s collections?

Thank you for your question. Section 4.C.1 (formerly 4.D.1) is designed to support a variety of activities allowed by Section 108 of the Copyright Act. As such, individual situations may allow for the use of legally-obtained works from a variety of locations.

4.D.1.a – This section essentially says that Library Services may circulate copies of library-owned works provided the reproductions comply with fair use. This restates what libraries already do and does not provide meaningful procedural guidance. The committee feels this section merely states the obvious: that libraries circulate materials. It may be appropriate to delete it.

Thank you for your suggestion. 4.D.1.a has been removed.

4.D.1.b.3 – Is the library not following CONTU guidelines? If so, they may need to review their database contracts to make sure there’s no language requiring them to adopt the CONTU limits.

Thank you for your question. The language in 4.C.1.b (formerly 4.D.1.b) is modeled on the current University of Utah “Copyright Policy: Copying of Copyrighted Works” ( Policy 7-013, Section 3.E) and adheres to the allowances for interlibrary loan provided by Section 108 of the Copyright Act. The suggestion for contract review is appreciated, but evaluating database contracts is outside the scope of this committee.

4.D.1.d.2(b) – This section states that the reproduction “includes a copyright notice” when replacing a damaged, lost, or stolen work. However, §4.D.1.e separately requires that “a copyright notice will accompany all reproduced materials.” Because the global requirement in §4.D.1.e covers all reproductions, the specific instruction in §4.D.1.d.2(b) is redundant and unnecessary.

Thank you for identifying the redundancy. This revision has been accepted and 4.D.1.d.2(b) has been removed from the policy.

4.D.2.b.1 – This section assumes that the SLCC Bookstore is an internal college unit whose staff can verify copyright permissions for materials sent to Printing Services. However, because the bookstore is now third-party owned, it is unclear whether this subsection remains accurate or necessary.

Thank you for your comment. The references dealing with the bookstore’s responsibilities have been removed from the policy, eliminating 4.D.4 “Reproduction for Course Packets,” as it relied on bookstore procedures. 4.D.4’s subpoints dealing with Printing Services and Library Services and instructional materials were also removed due to redundancy with content addressed elsewhere in the policy.

4.D.2.d. – This section directs Printing Services staff to refuse reproduction when they “reasonably believe” the materials may constitute unauthorized copying, concerted reproduction, or a substitute for purchase. This standard effectively requires frontline staff, who are not trained in copyright law, to make legal judgments about whether a reproduction violates federal law. Consider revising as, “Printing Services will reproduce materials only when accompanied by a signed copyright compliance release or documented permission. If the requester cannot provide this documentation, Printing Services will not reproduce the material.”

This revision has been accepted.

4.D.2.d also states that Printing Services “will maintain a notice of copyright on all their copy machines,” raising the question of whether such notices are actually posted and whether this requirement is serving as a mechanism for shifting liability to individual users and staff rather than providing meaningful guidance.

Thank you for your comment. Copyright notices on unsupervised copiers serve as a standard risk-mitigation practice by informing users of their responsibilities. Retaining this requirement in the policy reflects this, is consistent with the University of Utah’s “Copyright Policy: Copying of Copyrighted Works” ( Policy 7-013, Section 3.G.3), and adheres to Section 108(f)(1) of the Copyright Act. The suggestion to verify the placement of notices is appreciated, but it falls within the purview of Printing Services.

4.D.3.c is problematic. You cannot reasonably rely on fair use for showing an entire film or for playing music – especially in a nonacademic setting.

Thank you for sharing your concern. The intent of 4.D.3.c is not to imply that displaying or performing a work will automatically be covered by fair use. To clarify that this point refers to either part or the entirety of a motion picture or audiovisual work, the language has been slightly modified to read: “c. Performing or displaying a work, including all or part of a motion picture or other audiovisual work, for reasons other than academic use, should adhere to fair use or be done with permission, which may include obtaining a performance license.”

4.D.5. addresses reproduction for accessibility and directs readers to follow ADA requirements and Section 121 of the Copyright Act. However, this content duplicates the work of the Accessibility & Disability Services (ADS) office and the existing accessibility policies. Consider striking this section. (Additionally, the procedures in 4.D.5 do not belong within a copyright reproduction policy, because accessibility accommodations are handled centrally through ADS, not through department-level copyright processes.)

Thank you for your comments. The purpose of the “Reproduction for Accessibility” section is to lay out the copyright exceptions and provisions that allow ADS and other relevant campus units to circumvent copyright protections, which are outside of established processes. The existing “Student ADA Access and Reasonable Accommodations” and “Employee ADA Access and Reasonable Accommodations” policies do not address copyright-specific provisions. To better clarify that the reproduction of copyrighted works for accessibility is not a department-level process, this section (4.D.5) will be moved to a main-level header.

4.E. Reproduction for Personal Use

4.E. should be removed because the College has no authority to regulate what individuals do with copyrighted materials in their personal, private capacity. Copyright law governs personal use, not college policy, and SLCC cannot impose enforceable restrictions on behavior occurring outside college property. Consider striking this section entirely.

Thank you for your concern. The use of the phrase “personal use” is misleading for the reasons you stated. This section’s intent is to cover possible uses outside of those encompassed by “academic use,” but still within a user’s institutional role. To clarify this, the language has been modified. 4.E is now labeled “Reproduction for Non-Academic Use,” and states, “Reproductions of works for non-academic uses within a user’s institutional role should be made with permission or constitute fair use.” This change clarifies that all institutional duties involving copyrighted works or reproductions made with college property must comply with copyright law, consistent with the “Code of Student Rights and Responsibilities” ( 3.G), and the “Employee Conduct” ( 4.B.1) and “Acceptable Use of College Computing Resources” ( 4.B.1.c) policies.

4.F. Failure to Comply with Policy

The policy mentions corrective action. Will the college protect an employee’s fair use analysis when the employee is acting on the college’s behalf?

Thank you for this question. Unfortunately, it falls outside this committee’s scope. Please direct this question to the Office of the General Counsel.

4.F. is redundant because all SLCC policies are enforceable, and all employees and students are already subject to institutional discipline when they violate any policy. Consider striking this section.

No revision was made based on this comment. College policies may include “Failure to Comply” sections to clarify to the reader the ramifications of noncompliance. For example, see 4.N of the “Acceptable Use of College Computing Resources” policy.

Comments

Why are the four fair use factors listed in the definition? This doesn’t fit with other definitions, and the four factors seem to be part of the policy process/procedure, not just a definition. Is there a resource we could link to that walks a person through the fair use analysis process? 4.A.3 is very confusing as written. It doesn’t really provide clear guidance on how we can use or reproduce AI-generated works. What would/wouldn’t be covered by copyright in AI-generated works? Why was 4.B.1.b of the original policy removed? This restriction must be in place to comply with the exemptions to the DMCA and 17 U.S.C. § 110. Why does the policy link to Cornell Law School Legal Information Institute instead of the actual laws? Why are there no references to any of the Copyright Office’s circulars? 4.C.1: What does “digitally shared” mean in this context? Sharing digital content in a Canvas course that is locked down so the student can’t download or retain a copy is different from faculty emailing a file to students. 4.C.2: Perhaps you should include links to the actual part of the code (not Cornell) that grants ADS the rights to do this? Does 4.D.1.a refer to anything besides legally obtained copies of materials in the library’s collections? 4.D.3.c is problematic. You cannot reasonably rely on fair use for showing an entire film or for playing music – especially in a nonacademic setting. 4.D.1.b.3: Is the library not following CONTU guidelines? If so, they may need to review their database contracts to make sure there’s no language requiring them to adopt the CONTU limits. The policy mentions corrective action. Will the college protect an employee’s fair use analysis if the employee is acting on behalf of the college? What kind of documentation is required by our legal team for fair use analysis or for playing music in a course, etc.?
References Faculty questions frequently involve who owns instructional materials, which is governed by the Intellectual Property policy, not the Reproduction policy. Making the reference more visible helps direct users to the correct policy and reduces misinterpretation. Consider including reference to the Copyright Ownership and Intellectual Property Policy.
Definitions General Note: This section relies heavily on legal jargon and specialized terminology, making it difficult for non-lawyers to understand. Several definitions are also circular or overly interdependent, reducing clarity and usability for faculty and staff. Simplifying the language and ensuring each definition stands independently would improve accessibility. §3.E. The definition of Fair Use essentially restates the core legal test and now functions as the centerpiece of the entire policy. Because the policy relies so heavily on legal terminology, it is difficult for many employees to understand. Consider instead: Fair use allows limited use of copyrighted material without permission when the use is reasonable and does not harm the market for the original work. To decide whether something qualifies as fair use, four questions are considered together: Why you are using the work (educational and non-commercial uses are more likely to qualify). What kind of work it is (factual works are more flexible than highly creative ones). How much of the work you are using and whether it is an important part of the original. Whether your use could replace the original and reduce its market value. §3.F. The Definitions section includes entries for Library Services (§3.F) and Printing Services (§3.J), but it is not clear that either term needs to be defined. The committee questions whether defining these college units adds clarity or simply restates the names of departments already familiar to SLCC employees. Consider removing these definitions from the policy. §3.H. The current definition of Open Licensing assumes the reader already understands what a “license” is, but the policy never defines license or licensing. This leaves a gap in clarity: users cannot understand open licensing without first understanding licensing. Please consider adding: License: A license is formal permission from the copyright owner that explains how others may use, share, or adapt a work. Open Licensing: Open licensing is a type of copyright license where the creator chooses to give the public advance permission to use, share, or adapt the work, often under specific conditions. §3.L. “Work: a creation that is capable of copyright protection.” This definition is too vague for general users. It does not explain what makes something “capable of copyright protection.” Consider instead: Work: A creative product made by a person and expressed in a fixed, tangible form, such as writing, music, artwork, or digital media so that copyright law can protect it from unauthorized copying or use.
Procedures §4.A.1. currently directs readers to the Copyright Ownership and Intellectual Property Policy for information about works created by faculty, staff, and students. Because this is foundational context, not a procedural step, the committee questions whether this reference belongs within the Procedures section. Consider moving it to References. §4.A.2. instructs users to contact the Library Services Copyright Librarian for assistance with fair use analyses or limitations on exclusive rights. However, this places librarians in a position where they may be expected to interpret copyright law or provide legal guidance, which they cannot do. This creates a circular problem: the policy tells users to ask the librarian, the librarian must direct users to the Office of General Counsel (OGC), and the OGC often refers back to the policies themselves. This loop is confusing and unhelpful to employees seeking clear direction. Consider using language: For general information about fair use or limitations on exclusive rights, consult the Copyright Guide or contact Library Services for educational resources. For legal questions or formal interpretation of copyright law, contact the Office of General Counsel. §4.A.3(a) states that “Works created with AI may not be copyrighted.” This statement is overly broad and reflects only one developing area of case law. It oversimplifies a complex and rapidly changing legal question. Additionally, the policy does not acknowledge that prompts written by humans are copyrightable, since they involve human authorship. The current wording risks misleading employees into thinking that all AI-associated content is automatically uncopyrightable, which is not accurate. Consider changing the language to reflect this: Fully autonomous outputs generated by AI systems without meaningful human authorship may not qualify for copyright protection under current interpretations of copyright law. However, human-created inputs—such as prompts, instructions, or edits—may be copyrightable if they reflect original, creative human contribution. §4.B. currently states that fair use applies when reproduction is done with permission, under an open license, or when a fair use analysis supports the use. However, because the detailed fair use explanation was moved into the Definitions section (§3.E), the practical, actionable guidance on how to apply fair use now feels disconnected from the steps users follow when reproducing works. The committee questions whether fair use guidance belongs in the Procedures section to support operational decision-making. §4.B.2. requires a fair use analysis when relying on the fair use exception, but without the fair use factors present in the Procedures, this instruction is not helpful. Users are told to conduct an analysis but are not given the tools or criteria they need to do so. This creates confusion and reinforces a misunderstanding that anything used for academic purposes is automatically fair use, which is not accurate. Consider placing a simplified version of the four factors in this section: “When you rely on fair use, consider all four factors together: Why you are using the work (educational, nonprofit, or commercial). What type of work it is (creative vs. factual). How much you are using, and whether it is the ‘heart’ of the work. Whether your use could replace the original or harm its market. §4.B.3. currently tells faculty to follow the requirements of Section 110 of the Copyright Act or rely on fair use when performing or displaying works, including motion pictures or audiovisual works. While this is legally correct, directing faculty to go read federal statute is not helpful or practical. Perhaps instead providing faculty with the key questions that Section 110 and fair use require them to consider: Before performing or displaying a work (such as showing a film or presenting an image) for academic purposes, consider the following questions: Is the use directly tied to teaching or learning in the course? Is the copy you are using a lawful copy (not pirated or illegally downloaded)? Is the performance taking place in a classroom or other authorized instructional setting? Are you using only what is necessary to meet the instructional purpose? Could this use replace the need for students to purchase or access the original work? If the answer to these questions is unclear, consult the Office of General Counsel for guidance. §4.C.1. treats “digital content” as a separate category of work, even though copyright law applies equally to works regardless of format. The procedures do not explain why digital sharing is separated from other types of reproduction, and the distinction may confuse users or imply that digital materials are governed by special rules under copyright law (they are not). The only unique digital-specific issue addressed in this section relates to accessibility and ADA accommodations (§4.C.2), not general copyright use. Consider revising this section so that digital materials follow the same guidance as physical materials unless a true exception applies. Works may be shared in any format, including digital, when the use is permitted, within the terms of an open license, or qualifies under limitations such as fair use. §4.D. includes specific operational procedures for Library Services, Printing Services, and the SLCC Bookstore. These are internal departmental workflows rather than college-wide copyright standards. Consider moving departmental procedures out of the college-wide policy, and replacing it with a general statement that departments must follow copyright law and maintain internal procedures consistent with the policy: 4.D. All college departments that reproduce, share, or distribute copyrighted materials must ensure their practices comply with this policy and applicable copyright law. Each department is responsible for developing and maintaining internal procedures that: Ensure that reproductions are made only with permission, under an applicable open license, or in reliance on fair use or other limitations on exclusive rights; Prevent unauthorized or concerted reproduction of copyrighted works; Maintain required copyright notices on reproduced materials; and Provide guidance to employees within the department to support compliance with this policy and federal copyright standards. Departments may establish additional internal workflows or procedures as needed, provided they remain consistent with this policy and do not conflict with the rights and limitations established under federal law. §4.D.1 includes three separate instructions that direct users to “see the Copyright Act” (primarily Sections 108 and 107) for guidance on library reproduction and interlibrary loan. Repeatedly pointing users to federal statutes is not practical or user-friendly. Consider instead summarizing the operational boundaries in more simple language: Library Services may reproduce and share materials only when the use is for research, private study, preservation, or interlibrary loan, and when the reproduction does not substitute for purchasing the work or violate contractual/licensing restrictions. Library Services must maintain required records and avoid repeated requests that suggest a pattern of replacement copying. §4.D.1.a. essentially says that Library Services may circulate copies of library-owned works provided the reproductions comply with fair use. This restates what libraries already do and does not provide meaningful procedural guidance. The committee feels that this section is merely stating the obvious: that libraries circulate materials. It may be appropriate to delete it. §4.D.1.d.2(b) states that the reproduction “includes a copyright notice” when replacing a damaged, lost, or stolen work. However, §4.D.1.e separately requires that “a copyright notice will accompany all reproduced materials.” Because the global requirement in §4.D.1.e covers all reproductions, the specific instruction in §4.D.1.d.2(b) is redundant and unnecessary. §4.D.2.b.1. assumes that the SLCC Bookstore is an internal college unit whose staff can verify copyright permissions for materials sent to Printing Services. However, because the bookstore is now third-party owned, it is unclear whether this subsection remains accurate or necessary. §4.D.2.d. directs Printing Services staff to refuse reproduction when they “reasonably believe” the materials may constitute unauthorized copying, concerted reproduction, or a substitute for purchase. This standard effectively requires frontline staff, who are not trained in copyright law, to make legal judgments about whether a reproduction violates federal law. That expectation is inappropriate and places undue responsibility on rank-and-file employees. Consider removing legal-judgment language: Printing Services will reproduce materials only when accompanied by a signed copyright compliance release or documented permission. If the requester cannot provide this documentation, Printing Services will not reproduce the material. This shifts responsibility for legal compliance from Printing Services staff to the requestor. §4.D.2.d. states that Printing Services “will maintain a notice of copyright on all their copy machines,” raising the question of whether such notices are actually posted and whether this requirement is serving as a mechanism for shifting liability to individual users and staff rather than providing meaningful guidance. §4.D.5. addresses reproduction for accessibility and directs readers to follow ADA requirements and Section 121 of the Copyright Act. However, this content duplicates the work of the Accessibility & Disability Services (ADS) office and the governing accessibility policies already in place. The College does not need a separate copyright policy subsection restating ADS procedures, especially since ADS already has established processes, responsibilities, and legal authority for providing accessible formats. Consider striking this section. Additionally, the procedures in §4.D.5 do not belong within a copyright reproduction policy, because accessibility accommodations are handled centrally through ADS, not through department-level copyright processes. §4.E states that “Reproductions of works for personal use should be made with permission or constitute fair use.” This section should be removed because the College has no authority to regulate what individuals do with copyrighted materials in their personal, private capacity. Copyright law governs personal use, not college policy, and SLCC cannot impose enforceable restrictions on behavior occurring outside college property. Consider striking this section entirely. §4.F. states that “Students and employees who violate this policy are subject to accountability or corrective action.” However, this statement is redundant because all SLCC policies are enforceable, and all employees and students are already subject to institutional discipline when they violate any policy. Consider striking this section.