1.0 Policy Purpose
This policy governs the development, revision, approval, publication, and management of Brown University policies.
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.
Information not meeting the policy criteria above may be documented in other accessible formats, such as website content, professional or industry standard formats, or Standard Operating Procedures.
3.1 Policy Standards
To ensure consistency, policies:
- must be written in accordance with the University 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- are effective until rescinded by the Approval Authority (i.e., policies do not end or expire).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.
- must be updated as needed to keep content current and compliant with laws, regulations, and other University policies.
- must be reviewed at least 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 Delegated Cabinet Member (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. Documents approved by the Corporation, including policy statements or similar, may be published on the University Policy Website even if not adhering to all the policy standards established in this policy. .
3.2.2 President
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, or matters within the President’s general responsibilities to manage the University.
3.2.3 Delegate
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 Delegates may not subdelegate policy Approval Authority.
3.3 New Policies or Material Revisions to Policies
New policies and material revisions to policies must be approved via the University Policy Process. Material revisions are 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 Owners, with support from the Responsible Office, will:
- reasonably ensure relevant Stakeholder Feedback, as defined in Section 4.0, is solicited and adjudicated; and
- submit the finalized policy and supporting information (e.g., cover sheet) to University Compliance (UC) who will manage the approval process.
The approval process includes:
- final review by UC,
- final legal review by the Office of the General Counsel (OGC), and
- review and approval by the Approval Authority, in accordance with Section 3.2.
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 approval process in Section 3.3.
Nondiscretionary revisions are based on changes in laws, regulations, or other University policies and will be made by UC in consultation with the OGC and the Policy Owner.
3.5 Policy Publishing
Policies will be published on the UPW after approval. The Responsible Office is responsible for verifying the policy is posted correctly and alerting UC to any errors.
4.0 Definitions
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.
- Delegated Cabinet Member (Delegate):
-
A Cabinet member with written delegated policy Approval Authority from the President.
- 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, committee, working group, or task force.
- Stakeholder Feedback:
-
Input from relevant individuals and groups who are materially affected by or involved with a policy. This generally includes:
- units (such as schools, departments, offices, committees, working groups, etc.) tasked in the policy,
- units overseeing cohorts of the Brown community covered by the policy, and
- senior leaders whose areas of oversight are connected to the policy's content.
Alternatively or additionally, policy drafts may be made widely and constructively available for a reasonable amount of time to gather broader feedback from the Brown community.
- Standard Operating Procedure (SOP):
-
Provides instructions on how to complete a complex, multi-step, standardized business process that normally impacts multiple units or a large group of stakeholders and must be performed consistently. SOPs requiring approval, as determined by UC, will generally follow the same steps as the approval process detailed in Section 3.3. After approval, SOPs will be returned to the Responsible Office for publication/distribution, as needed; SOP publishing is not centralized.
- University Policy Process:
-
A standardized process for developing, approving, and managing University policies. The process includes policy reviews, quality checks, appropriate approval, and publishing on the UPW. Additionally, it incorporates training, compliance monitoring, and maintaining and archiving a repository of all policies approved via the process.
5.0 Responsibilities
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 University Policy Process and provide updates as requested by senior leaders.
- 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 University Policy Process, 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 individuals are encouraged to share 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:
N/A
7.2 Related Procedures:
N/A
7.3 Related Forms:
- Policy and SOP Templates, Cover sheets, and other Resources
- Delegation of Policy Approval Form (contact UC for guidance on how to complete this form)
7.4 Frequently Asked Questions:
7.5 Other Related Information:
Policy Owner and Contact(s)
Policy Owner: Executive Vice President for Planning and Policy
Policy Approved by: President
Contact Information:
Policy History
Policy Issue Date:
Policy Effective Date:
Policy Update/Review Summary:
Prior policy versions superseded by this policy:
- Policy on Policies, Effective Date: November 6, 2022
- Policy on Policies, Effective Date: November 11, 2019
- Policy on Policies, Effective Date: August 16, 2019
- Policy on Policies, Effective Date: April 1, 2019