Policy Framework

Title

University of North Carolina at Chapel Hill Policy Framework

Introduction

Purpose

The Policy Framework sets behavioral expectations across the University. The Policy Framework empowers members of the University community with the knowledge, protection, and flexibility they need to perform their day-to-day roles and responsibilities within certain defined boundaries. The Policy Framework also constrains members of the Carolina community outside of those defined boundaries, thus reducing institutional risk. Finally, the Policy Framework shifts the University to a more proactive policy development and risk management model by formalizing the process by which Policies, Standards, and Procedures are developed, approved, reviewed, published, and communicated; promoting consistency, efficiency, and transparency; and reflecting best practice in higher education.

Scope of Applicability

This Policy applies to all Units of the University of North Carolina at Chapel Hill.

Policy

Policy Statement

Policy Management

Oversight of all Policies at the University rests with the University Chancellor. The Chancellor has delegated the management of University Policies, Standards, and Procedures to the Office of Ethics and Policy.

The Office of Ethics and Policy has established two groups: the Policy Review Committee (PRC), and the Executive Policy Approval Committee (EPAC) to ensure the efficient and effective management of University Policies, Standards, and Procedures according to their scope of applicability, potential impact, and risk to the University. In certain cases, a policy may be elevated to the Chancellor's Cabinet for review. If a University Policy is elevated to the EPAC or Chancellor's Cabinet for review, the issuing Unit responsible for administering the University Policy in question must not implement the Policy until EPAC or the Chancellor's Cabinet has issued their guidance.

The Chancellor retains the right to determine exceptions, appoint permanent or ad-hoc committees for review or approval, or otherwise act to ensure Policies are in keeping with the mission of the University.

Unit Policies, Standards, and Procedures may be developed, reviewed, communicated, and decommissioned in any manner determined by the issuing Unit that is not inconsistent with University, Board of Trustee, or Board of Governor Policies.

Issuing Officers

Policies, Standards, and Procedures may have only one Issuing Officer, even if multiple Units have some interest or stake in the document. If an Issuing Officer changes roles or leaves the University, the Unit responsible for managing the document must immediately select either a new Issuing Officer or an individual in the Unit to manage the document in the interim.

The allowable Issuing Officers for University Policies, Standards, and Procedures are the Provost and the Provost's direct reports, Vice Chancellors, Deans, the Director of Athletics, the Director of Internal Audit, and their designees.

Issuing Officers for Unit Policies, Standards, and Procedures are selected by the issuing Unit and may include the Unit head or their designee.

Role and Authority of the Office of Ethics and Policy

The Office of Ethics and Policy oversees the publication; day-to-day coordination; and review of Policies, Standards, and Procedures in alignment with the Policy Framework. The Office of Ethics and Policy may, at its discretion and with agreement of the appropriate Policy Liaison and Issuing Officer or their designee, change the formatting of documents, including migrating them into the official University templates, without initiating a formal policy review.

The Office of Ethics and Policy prepares briefing materials as needed for the EPAC and the Chancellor's Cabinet.

The Associate Director of the Office of Ethics and Policy serves as the PRC Chair.

Policy Criteria

The decision to write a Policy is ultimately up to the Unit responsible for administering the Policy. Best practice is to write Policies that address "significant organizational problems with reasonably clear causes."1 Organizational problems can be internal (e.g. bad behavior, human error) or external (e.g. regulation, public opinion, or liability).

Policies should be written in response to organizational problems that occur repeatedly and/or are consequential. Policies should not be written "in response to extreme events, to a handful of people, or even to a particular employee."2

Units must not create a Unit policy:

  • when the Unit is prohibited from doing so by an existing UNC System or University policy; or
  • when the proposed Unit policy is inconsistent with, or less restrictive than, Board of Trustees, Board of Governors, UNC System, or University policies.

Policy Development, Approval, and Decommissioning

The development, approval, and decommissioning of University Policies, Standards, and Procedures must follow the University Standard on Policies and the University Procedure for Policy Management.

Policy Format

All University Policies, Standards, and Procedures must be in writing and comply with the University Standard on Policies, unless the Office of Ethics and Policy grants an exception in writing for a specific document. For example, if a document is required by an external legal or regulatory body to be structured a certain way that does not comply with the University templates. Contact the Office of Ethics and Policy if you believe you require an exemption.

Legacy University Policies, Standards, and Procedures must be transitioned into the standardized templates when the content undergoes its next revision, unless the Office of Ethics and Policy grants an exemption per this Policy.

The Office of Ethics and Policy encourages Units to follow similar templates for Unit Policies, Procedures, and Standards, taking care to distinguish them from University-level documents.

Policy Review

Issuing University Officers or their designee(s) must complete a comprehensive review of each of their Policies, Standards, and Procedures at least every three (3) years. The review must include an assessment of the Policy, Standard, or Procedure’s compliance with governing law and regulation and alignment with the key characteristics of an effective Policy outlined in the Policy Criteria section.

Policy Publication

All University Policies, Standards, and Procedures must be hosted by the Office of Ethics and Policy in the electronic University Policy Repository.

Unit Policies, Standards, and Procedures are not required to be published in the electronic University Policy Repository, but may be at the discretion of the issuing Unit.

All written and electronic communications (including but not limited to: websites, emails, social media posts, presentations and printed materials) referring to a Policy, Standard, or Procedure hosted in the electronic University Policy Repository must link to the document hosted in the University Policy Repository so that individuals searching for policy documents always access the latest version.

Sensitive Policies

In rare instances a University or Unit Policy, Standard, or Procedure is considered sensitive (classified as Tier 2 or Tier 3 in the UNC-CH Information Security Classification Standard) and should not be published on a publicly-accessible website. Please contact the Office of Ethics and Policy for additional guidance regarding sensitive University or Unit Policies, Standards, or Procedures.

Expedited Policies

The University Chancellor may approve a University Policy when legal requirements or significant institutional risks exist and there is insufficient time to complete the standard review and approval process before publishing. In such a circumstance, the approved University Policy is effective immediately. A representative of the Chancellor's Office, the Office of University Counsel, the Office of Risk Management Services and Mission Continuity, or other appropriate stakeholder must present the Policy and the context around its creation and approval by the Chancellor at the next PRC meeting following Policy implementation. Subsequent reviews and revisions to the policy must be conducted in a manner consistent with the Standard on Policies and the Procedure for Policy Management.

Exceptions

Academic Policies

Authority to establish Policies, Standards, and Procedures published in the University Catalog and related to the educational activities of and the award of academic degrees by the University of North Carolina at Chapel Hill is governed by The Faculty Code of University Government. The processes for developing and approving the Policies and related Standards and Procedures established under that authority are not intended to be changed by this Policy.

Definitions

EPAC: The Executive Policy Approval Committee, comprised of representative members of Cabinet designated by the Chancellor. Includes, at a minimum: Human Resources and Equal Opportunity and Compliance; Finance and Operations; Office of University Counsel; and Provost representatives. Functions as an authorizing step when Policies are referred to the committee.

Issuing University Officer: Those authorized to issue University Policy. Issuing Officers for University Policies are limited to the Provost, the Provost's direct reports, Vice Chancellors, Deans, the Director of Athletics, the Director of Internal Audit, and their designee(s).

Material Substantive ("Major") Revisions: Changes which alter the purpose or effect of a document.

Non-Substantive ("Minor") Revisions: Changes which do not alter the purpose of effect of a document.

Policy: A Policy is a written statement that mandates, specifies, or prohibits behavior in order to express basic values of the University, enhance the University's mission, ensure coordinated compliance with applicable laws and regulations, promote operational efficiency, and/or reduce institutional risk. A Policy includes criteria as mandated by the Office of Ethics and Policy document templates and must have a single Issuing Officer.

Policy Officer: The Director of the Office of Ethics and Policy, the Policy Officer coordinates Policy organization, coordination, review, approval, and publication.

Policy Liaison: Representatives appointed by heads of administrative units designated by the Policy Officer to perform Policy administration functions both internally for the Unit and collaboratively with the Office of Ethics and Policy

PRC: Policy Review Committee, composed of Policy Liaisons and representatives designated by the Policy Officer. This committee functions as a review step to ensure consistency, quality, and appropriateness of scope for submitted Policies, Standards, and Procedures. All new and Material Substantive Revisions of University policy documents are submitted to the PRC for review. Administrative units may submit other Procedures, Standards, or Unit Policies for review at their discretion. The PRC does not function in an authorization capacity, it is intended to provide feedback and guidance to support effective policymaking.

Procedures: The process(es) required to accomplish an action necessitating specific instructions. Procedures are not intended to be detailed "help guide" documents, but instead higher-level process documents which can then point to specific and detailed instructions maintained by the appropriate Unit. Procedures often pertain to implementing Policy. Procedures may also provide guidance for behavior on issues that are not dictated by Policy. Procedures are created at the Unit level and changes do not go through the same review or approval process as Policies, but Procedures that impact multiple units may need additional review or feedback before being implemented.

Sensitive Policies: Sensitive Policies are defined as those Unit or University Policies, Standards, and/or Procedures which contain Tier 2 or Tier 3 information described in the UNC-CH Information Classification Standard.

Standards: The minimum acceptable limits or rules that may be used to achieve Policy implementation. While Procedures provide specific instructions for units (e.g, how to use specific applications to encrypt data in the HR department), Standards set overarching minimum requirements that must be met by all (e.g., minimum encryption strength for use with sensitive information throughout the University). Standards may be written as standalone documents or may be included in the body of a related policy, at the discretion of the issuing Unit. Standards are created at the unit level and changes are not required to go through the same review or approval process as Policies, but Standards that impact multiple units may need additional review or feedback before being implemented.

Unit: Any administrative organization that is part of the University of North Carolina at Chapel Hill and is headed by a Dean, Vice Chancellor, the Provost, or a direct report to the Provost.

Unit Policy: Has application only within the issuing Unit (e.g. applies only to Unit employees, staff, students and others working for or studying at the Unit). A Unit Policy can create additional specifications, requirements, or restrictions but cannot contradict a University Policy, Procedure, or Standard.

University Policy: Has application throughout the University, informs someone outside the issuing Unit of rights and responsibilities, or regulates the actions of the Unit as it interacts with other units on campus.

Related Requirements

University Policies, Standards, and Procedures

University of North Carolina at Chapel Hill Standard for Policies

University of North Carolina at Chapel Hill Procedure for Policy Management

Contact Information

Policy Contact

Office of Ethics and Policy
123 W. Franklin Street, Chapel Hill, NC 27599
Phone: 919-445-8364
Email: policy@unc.edu
Website

Important Dates

Revised version approved by:

Jen DeNeal January 13, 2021
Associate Director, Office of Ethics and Policy

Revised version approved by:

Kim Strom-Gottfried, PhD June 28, 2019
Director, Office of Ethics Education and Policy Management

Initial approval by:

Kim Strom-Gottfried, PhD January 07, 2017
Director, Office of Ethics Education and Policy Management

References

1. Leisha Dehart-Davis, Creating Effective Rules in Public Sector Organizations (Washington D.C.: Georgetown University Press, 2017). Specifically, see "When to Write a Rule" section on page 107.
2. Ibid, 108.

Details

Article ID: 132080
Created
Thu 4/8/21 9:23 PM
Modified
Thu 7/29/21 4:57 PM
Effective Date
If the date on which this document became/becomes enforceable differs from the Origination or Last Revision, this attribute reflects the date on which it is/was enforcable.
02/19/2021 4:11 PM
Issuing Officer
Name of the document Issuing Officer. This is the individual whose organizational authority covers the policy scope and who is primarily responsible for the policy.
Issuing Officer Title
Title of the person who is primarily responsible for issuing this policy.
Administrative Director
Last Review
Date on which the most recent document review was completed.
02/19/2021 4:11 PM
Last Revised
Date on which the most recent changes to this document were approved.
02/19/2021 4:11 PM
Origination
Date on which the original version of this document was first made official.
01/07/2017 12:00 AM
Responsible Unit
School, Department, or other organizational unit issuing this document.
Ethics and Policy Office