Confidential Information—is any data related to the business of the University including, but not limited to: financial, employee, student, alumni, communication, and physical resources. It includes data maintained at the departmental and office level as well as centrally, regardless of the media on which they reside. Examples include: credit card information; tax identification numbers; payroll information; check requests and associated paperwork; student, parent, and employee tuition, financial aid, and loan accounts information; student educational records as defined by FERPA; photographic images (especially of face or other identifying characteristic), fingerprints, handwriting, or other biometric data (e.g., retina scan, voice signature, facial geometry); medical or financial information for any employee, temporary worker, or student; other personal information to include date of birth, address, phone numbers, maiden names, customer numbers, social security numbers; University contracts; University research data; alumni and donor records; employee records; University financial data; passwords; University proprietary information/data; and any other information for which access, use, or disclosure is not authorized by: a) federal, state, or local law; or b) University policy or operations.
I. Adherence to ethical standards
Members of the University community are expected to conduct themselves at all times ethically, honestly and with integrity in all dealings in accordance with the highest professional and community ethical standards.
In addition, all members of the University community engaged in research are expected to conduct their research with integrity and intellectual honesty at all times and with appropriate regard for human subjects. To protect the rights of human subjects, all research involving human subjects is to be reviewed by the University’s Institutional Review Board. Members of the University community engaged in research are not to: fabricate data or results; change or knowingly omit data or results to misrepresent results in the research record; or intentionally misappropriate the ideas, writings, research, or findings of others. They are also expected to demonstrate accountability for sponsors’ funds and to comply with specific terms and conditions of contracts and grants.
II. Compliance with applicable laws & regulations
Members of the University community are expected to become familiar with the laws and regulations applicable to his or her position or status with the University, and must not act in any way to intentionally breach such laws and regulations, nor should they ask others to do so. Questions and concerns about the legality or propriety of any action or failure to take action by or on behalf of the University should be referred to the Office of General Counsel.
III. Compliance with applicable university policies and procedures
Members of the University community are guided by the mission and goals of the University and are bound by the policies, procedures, and practices set forth in any Lynn University Policy, catalogs, handbooks, and other policy-related document.
Each member of the University community is expected to seek clarification on a policy or other University directive he or she finds to be unclear, outdated or at odds with University objectives. It is not acceptable to ignore or disobey policies if one is not in agreement with them, or to avoid compliance by deliberately seeking loopholes.
In some cases, University employees are also governed by ethical codes or standards of their professions or disciplines. It is expected that those employees will comply with applicable professional standards in addition to laws and regulations.
IV. Conflicts of interest or commitment
Every member of the University community has a duty to avoid conflicts between his or her personal interests and official responsibilities and to comply with University policies for reporting and reviewing actual and potential conflicts of interest and conflicts of commitment. Additionally, a member may not utilize his or her position with the University for his or her personal benefit. Areas of potential conflict include the use of confidential information, college purchases not subject to competitive bids, the acceptance of gifts and, under certain conditions, outside employment. Members of the community are also expected to consider and avoid, not only an actual conflict but also, the appearance of a conflict of interest. In all matters, community members are expected to take appropriate steps, including consultation if issues are unclear, to avoid both conflicts of interest and the appearance of such conflicts.
V. Respect for the rights and dignity of others
Lynn University is committed to a work, academic, and residential environment in which all individuals are treated with respect and dignity. Each individual has the right to work, study, and live in a professional, academic, and residential atmosphere that promotes equal employment and educational opportunities and prohibits discriminatory practices, including harassment. Lynn University prohibits discrimination and harassment and provides equal opportunities for all community members and applicants regardless of race, color, religion, sex, sexual orientation, sexual identity, gender, gender expression, or gender identity, age, national origin, ancestry, citizenship, disability, gender related status, pregnancy, genetic disposition, veteran or military status, marital status, familial status, or any other legally protected characteristic in accordance with federal and Florida State law. Further, romantic or sexual relationships between faculty responsible for academic supervision, evaluation or instruction, and their students are prohibited.
VI. Confidential information
Individuals who have access to confidential, proprietary and private information are expected to be familiar and to comply with applicable laws, University policies, directives and agreements pertaining to access, use, protection, and disclosure of such information. Computer security and privacy are also subject to law and University policy.
VII. Use of university resources
University resources may only be used for activities on behalf of the University. They may not be used for private gain or personal purposes except in limited circumstances permitted by existing policy where incidental personal use does not conflict with and is reasonable in relation to University duties (e.g. telephones). Members of the University community are expected to treat University property with care and to adhere to laws, policies and procedures for the acquisition, use, maintenance, record keeping and disposal of University property.
VIII. Compliance with contractual terms and grant terms and conditions
Every member of the University is expected to maintain access to and to comply strictly with the terms and conditions of each University grant and contract on which he or she is working. All questions or concerns about whether a particular term or condition violates the law or whether the grantor or contractor has breached its obligations to the University should be referred promptly to the Office of General Counsel.
IX. Maintenance and preservation of records
Members of the University are expected to create and maintain records and documentation which fully conform to all applicable laws and professional, and ethical standards. Every member of the University who is involved, directly or indirectly, in the preparation or submission of a bill to any governmental or private payor is expected to use his or her best efforts to ensure the bill addresses only those services rendered and products delivered and in the correct amount, supported by appropriate documentation.
X. Reporting an alleged violation
All trustees, faculty, administrators, staff and students have an obligation to bring suspected violations to the attention of appropriate supervisory personnel in a responsible manner. Generally, the first person to be informed should be either one’s immediate supervisor in the case of employees, or the director of the University office concerned. In those instances in which the immediate supervisor is involved in the alleged violation, the report should be made to the person at the next highest supervisory level. The process for reporting suspected violations of specific policies, such as sexual or gender-based misconduct, is usually explained as part of the policy itself. In addition, individuals may utilize the reporting procedures set forth in the University’s Whistleblower Policy.
Those who report violations in good faith and in an appropriate manner, whether or not further investigation substantiates the claim, will be free from retaliation in any form. The identity of complainants will be protected, within legal limits, and those who retaliate against them will be disciplined.
All reported violations will be investigated promptly in accordance with procedures detailed in the relevant policy.
For more information about this Policy, contact the Office of Compliance.
Policy updated on: Oct. 24, 2018