1.0 Policy Purpose
This policy governs the development, revision, approval, publication, and management of Brown University policies as they are incorporated into the Comprehensive Policy Review (CPR) Project.
2.0 To Whom the Policy Applies
This policy applies to faculty, staff, students, and any members of the Brown community who develop, revise, review, approve, publish, or manage University policies or who otherwise engage in the University policy process.
3.0 Policy Statement
Brown University policies state the rights and responsibilities of members of the Brown community. A University policy must meet all of the following criteria:
- It has application throughout the University, either in its entirety or within a defined cohort, or is required by regulation or documented industry standards;
- It helps achieve compliance with applicable laws and regulations, promotes operational efficiencies, enhances the University’s mission, or reduces institutional risks; and
- It mandates actions.
University Standard Operating Procedures (SOPs) document multi-step processes that need to be performed consistently.
Information not meeting the above policy criteria or appropriate for an SOP may be documented in other formats, such as website information or professional/industry standard formats.
3.1 Policy Standards
To ensure consistency, policies:
- must be written in accordance with the University’s Policy Template and instructions.
- must be approved by the Corporation, President or Delegated Cabinet Member when issued or materially revised.
- are effective upon approval.
- are effective until rescinded by the Approval Authority (i.e., policies do not end or expire).
- must be posted exclusively on the University Policy Website (UPW); other websites must provide links to the UPW. Attachments will be posted on the Responsible Office’s website and linked to from the UPW.
- must be updated as needed to keep content current and compliant with laws, regulations, and other University policies.
- at a minimum must be reviewed every five (5) years, unless a shorter review cycle is directed by the Policy Owner.
3.2 Approval Authority
The Corporation, the President or a Delegate may approve policies in accordance with the following.
3.2.1 Corporation of Brown University
The Corporation of Brown University or one of its committees acting under authority delegated by the Corporation may establish policies in accordance with The Charter of Brown University and pursuant to its authority delegated by law.
The President may establish a policy:
- under the sole authority of the President.
- to implement a directive of the Corporation.
- to address matters of compliance with fiscal, academic, research, human resources or other requirements imposed by laws, matters not specifically reserved to the Corporation, and matters within the President’s general responsibilities to manage the University.
The President may delegate Approval Authority in writing to a Cabinet Member for policies within their area. Policies requiring Corporation approval cannot be delegated, and Cabinet Members may not subdelegate policy Approval Authority.
3.3 New Policies or Material Revisions to Policies
New policies or Material Revisions to policies will be approved via the University policy approval process, which is managed by University Compliance (UC). Policy Owners, with support from the Responsible Office, will:
- ensure relevant stakeholders are provided the opportunity to provide feedback on a policy.
- submit the policy and supporting information to UC for the approval process.
The policy approval process includes final reviews by UC and the Office of the General Counsel (OGC) prior to the policy being sent to the Approval Authority for approval.
3.4 Non-Material and Nondiscretionary Revisions to Policies
Non-material revisions normally include reformatting, administrative clarifications, and editorial or technical changes that do not materially affect the substance of the policy and do not change the rights or what is expected of the individuals to whom the policy applies. UC will determine if a policy change qualifies as non-material. Non-material changes will be made and documented by UC without going through the process in Section 3.3.
Nondiscretionary revisions based on changes in laws, regulations or other University policies, that do not meet the non-material change standard noted above, may be approved by Policy Owner after review by UC and OGC.
3.5 Policy Publishing
For the purpose of this policy, the terms below have the following definitions:
- Approval Authority:
The Corporation, President or Delegate authorized to approve a policy in accordance with this policy. The Approval Authority applies an institutional perspective to review and approve policies.
- Comprehensive Policy Review (CPR) Project:
Implements this policy across the University by reviewing all policies over a phased, multi-year timeline.
- Delegated Cabinet Member (Delegate):
A Cabinet member with written delegated policy Approval Authority from the President.
- Material Revision:
Changes that materially affect the substance of the policy and/or change the rights or what is expected of the individuals to whom the policy applies.
- Policy Owner:
The Cabinet member responsible for the policy’s content, administration, dissemination, communication and training, compliance monitoring, and timely review and revision.
- Responsible Office:
The office that supports the Policy Owner by performing the required policy-related actions. Responsible Offices can include a department, office, University committee, working group or task force.
- Standard Operating Procedure (SOP):
Provides instructions on how to complete a multi-step, standardized, repeatable, and reliable business process. New and updated SOPs will be approved via the University SOP approval process, which is managed by UC. After approval, SOPs will be published on operating unit, department, or school websites or common drives, as needed; SOP publishing is not centralized.
All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. University supervisors and employees with student oversight duties are responsible for promoting the understanding of this policy and for taking appropriate steps to help ensure and enforce compliance with it.
In addition to responsibilities already assigned in this policy, the following offices will accomplish additional actions.
- University Compliance:
Manage the CPR Project: Perform quality check on new and updated policies; maintain a repository of all policies; authorize policies for publication and manage content on the UPW; advise Policy Owners and Responsible Offices on communication, training, and compliance monitoring, as appropriate; and provide updates as requested by senior management.
- Office of General Counsel:
Perform legal review on new policies and material and non-discretionary revisions to existing policies.
- Office of University Communications:
Provide support to maintain the UPW.
- University Library:
Archive policy versions posted on the UPW.
- Executive Vice President for Planning and Policy:
Provide oversight, direction, and guidance for the CPR Project to implement this policy across the University, and determine if a policy is confidential.
6.0 Consequences for Violating this Policy
Failure to comply with this and related policies is subject to disciplinary action, up to and including suspension without pay, or termination of employment or association with the University, in accordance with applicable (e.g., staff, faculty, student) disciplinary procedures.
7.0 Related Information
Brown University is a community in which employees are encouraged to share workplace concerns with University leadership. Additionally, Brown’s Anonymous Reporting Hotline allows anonymous and confidential reporting on matters of concern online or by phone (877-318-9184).
The following information compliments and supplements this document. The information is intended to help explain this policy and is not an all-inclusive list of policies, procedures, laws and requirements.
7.1 Related Policies:
7.2 Related Procedures: