TABLE OF CONTENTS

Faculty Handbook ........................................................................................ 3

I. University Structure ........................................................................... 3

I.A. Introduction ............................................................................. 3

I.B. The Trustees ............................................................................ 3

I.C. The Central Administration ..................................................... 4

I.D. The Faculties and the Schools ............................................... 5

I.E. General Provisions Concerning a Faculty .............................. 6

I.F. Organization and Responsibilities of Graduate Groups ......... 6

I.G. Policies Concerning Academic and Administrative Ofﬁcers

.......................................................................................................... 7

I.H. The University Council, the Faculty Senate, and University

Committees .................................................................................. 12

I.I. Academic Planning and Budget Committee ......................... 15

I.J. The Ombuds ........................................................................... 16

I.K. Equal Opportunity .................................................................. 16

II. Faculty Policies and Procedures ................................................... 17

II.A. Academic Freedom and Responsibility ............................... 17

II.B. Structure of the Academic Staff ......................................... 17

II.C. Tenure System at the University of Pennsylvania .............. 34

II.D. Appointments and Promotions ............................................ 35

II.E. Terms and Conditions of Faculty Appointments ................ 38

III. Policies and Procedures Concerning Faculty Research .............. 60

III.A. Guidelines for the Conduct of Sponsored Research .......... 60

III.B-C. Policy for Reviewing Alleged Research Misconduct ...... 62

III.D. Policy Relating to Copyrights and Commitment of Effort for

Faculty .......................................................................................... 66

III.E. Patent and Tangible Research Property Policies and

Procedures ................................................................................... 68

III.F. Policy on Conflicts of Interest Related to Research ........... 78

III.G. Consulting and Outside Activities Policies and Procedures

........................................................................................................ 84

III.H. Guidelines for Student Protection and Student Access to

Information Regarding Sources of Financial Support ............... 87

III.I. Policy Concerning the Exclusion of Foreign Nationals from

Speciﬁc Research Areas .............................................................. 87

III.J. Guidelines for Research in the Community ........................ 87

III.K. Human Research Protection Program ............................... 88

III.L. Policy Regarding Human Subject Research in the

Sociobehavioral Sciences ........................................................... 88

III.M. Standard Operating Procedures and Policies of the

University of Pennsylvania Institutional Animal Care and Use

Committee (IACUC) ...................................................................... 91

IV. Procedures Regarding Admission and Instruction of Students

............................................................................................................... 91

IV.A. Guidelines for Admissions Policies and Procedures ......... 91

IV.B. Code of Academic Integrity ................................................ 93

IV.C. Charter of the University of Pennsylvania Student

Disciplinary System ..................................................................... 94

IV.D Faculty Authority to Assign Grades and Academic Integrity

...................................................................................................... 103

IV.E. School Policies and Practices .......................................... 103

IV.F. Rules Governing Final Examinations ................................ 103

IV.G. Reporting of Final Grades ................................................. 104

IV.H. Policy on Secular and Religious Holidays ....................... 104

IV.I. Guidelines for Addressing Academic Issues of Students with

Disabilities .................................................................................. 104

IV.J. Policy on the Conﬁdentiality of Student Records ............ 106

V. Policies Related to Information ................................................... 109

V.A. Guidelines on Open Expression ......................................... 109

V.B. Conﬁdentiality of Employee Records ................................ 113

V.C. Conﬁdentiality of Health Information under HIPAA .......... 115

V.D. Closed Circuit Television Monitoring and Recording of Public

Areas for Safety and Security Purposes .................................. 115

V.E. Relationships Between Members of the University

Community and Intelligence Organizations ............................. 117

V.F. Photocopying for Educational Use .................................... 120

V.G. Protocols for the University Archives and Records Center

...................................................................................................... 121

V.H. Policy on Acceptable Use of Electronic Resources .......... 124

V.I. Policy on Privacy in the Electronic Environment ................ 127

V.J. Policy on Security of Electronic Protected Health Information

(ePHI) .......................................................................................... 128

V.K. Information Systems Security Incident Response Policy

...................................................................................................... 129

V.L. Policy on Unauthorized Copying of Copyrighted Media .... 129

V.M. Conﬁscation of Publications ............................................. 129

V.N. Policy on Computer Disconnection from PennNet ........... 130

VI. Other Policies .............................................................................. 131

VI.A. Use of University Name Policy ......................................... 131

VI.B. Acceptance of Gifts, Grants and Contracts ..................... 132

VI.C. Acceptance of Conditional Gifts ...................................... 132

VI.D. Gift Policy .......................................................................... 132

VI.E-F. Sexual Misconduct Policy, Resource Ofﬁces and

Complaint Procedures ............................................................... 133

VI.G. The University Alcohol and Other Drug Policy ................. 152

VI.H. Drug-Free Workplace Policy ............................................. 157

VI.I. Procedures for the Evaluation and Certiﬁcation of the English

Fluency of Undergraduate Instructional Personnel ................. 158

VI.J. Policy Prohibiting Workplace Violence ............................. 160

VI.K. Social Security Number Policy ......................................... 161

Appendix A ........................................................................................ 164

FAQs .................................................................................................. 166

Index ......................................................................................................... 168

University of Pennsylvania Faculty Handbook

FACULTY HANDBOOK

The Handbook for Faculty and Academic Administrators is a set of

policies governing faculty life at Penn.

Download the Faculty Handbook (PDF) (https://catalog.upenn.edu/pdf/

University of Pennsylvania Faculty Handbook.pdf) - Last Updated August

1, 2025

I. University Structure

•

I.A. Introduction (p. 3)

•

I.B. The Trustees (p. 3)

•

I.C. The Central Administration (p. 4)

•

I.D. The Faculties and the Schools (p. 5)

•

I.E. General Provisions Concerning a Faculty (p. 6)

•

I.F. Organization and Responsibilities of Graduate Groups (p. 6)

•

I.G. Policies Concerning Academic and Administrative Ofﬁcers

(p. 7)

•

I.H. The University Council, the Faculty Senate, and University

Committees (p. 12)

•

I.I. Academic Planning and Budget Committee (p. 15)

•

I.J. The Ombuds (p. 16)

•

I.K. Equal Opportunity (p. 16)

I.A. Introduction

The University of Pennsylvania is a non-proﬁt corporation chartered under

the laws of the Commonwealth of Pennsylvania. Under the Charter, the

Trustees are charged with the ultimate responsibility for the course of

the University. The administrative management of the University, on the

other hand, is delegated by the Trustees to the President. The University’s

faculties participate in the decision-making process through two major

bodies advisory to the President and administration—the University

Council and the Faculty Senate. Non-faculty employees and students

also participate with the faculty in the University’s governance through

their membership in the University Council and in an extensive number of

advisory groups and committees. In addition, the University has a policy

on consultation that articulates procedures for involving faculty, staff and

students in decision-making where the administration has ﬁnal or primary

responsibility.

Organizationally, the University is divided into twelve schools. Each

school is under the direction of a dean. Some schools are further

subdivided into departments.

I.B. The Trustees

(Source: Statutes of the Trustees, 1969; revised, April 28, 1980; revised,

April 15, 1981; revised, June 17, 1983; revised, October 20, 1995; revised,

June 21, 1996; revised,

June 15, 2007

(

https://archives.upenn.edu/

digitized-resources/docs-pubs/trustees-minutes/minutes-2007/june-15/

#Resolutions

); revised,

June 17, 2011

(

https://archives.upenn.edu/

digitized-resources/docs-pubs/trustees-minutes/minutes-2011/june-17/

);

revised, Ofﬁce of the Provost, November 21, 2022)

The Statutes classify the trustees as follows:

Trustees Ex Ofﬁcio

(Non-voting):

The Governor of the Commonwealth

of Pennsylvania and the President of the University during their

respective terms.

Charter Trustees

(Voting):

Up to ten in number, elected to serve until

retirement from among persons who have served as trustees for a

period of not less than ﬁve years.

Term Trustees

(Voting):

Up to thirty in number, elected to serve for

terms of ﬁve years. A term trustee may serve only two terms, which

would ordinarily be successive, for a total of ten years’ service. Prior

service in any other voting class will also be applied toward this ten-

year maximum.

Alumni Trustees

(Voting):

Up to fourteen in number, to include the

President of Penn Alumni during their term of ofﬁce and up to thirteen

trustees elected by the alumni in accordance with rules established

by Penn Alumni with the concurrence of the trustees, to serve for

terms of ﬁve years, from among those persons who have received

degrees from the University. Alumni trustees may not succeed

themselves in ofﬁce, but may be elected in another class.

Trustees Emeriti

(Non-voting):

Charter Trustees shall be designated

as Trustees Emeriti upon attaining the age of seventy (70), or as

early as age sixty-ﬁve (65), if they so choose. Other trustees who

have been elected to two ﬁve-year terms in any class shall be eligible

for election as trustees emeriti upon attaining the age of seventy

(regardless of the age at which their ten-year term of service ends or

the time remaining in their second term if they turn seventy before its

conclusion) or, in rare circumstances, at an earlier age.

Commonwealth Trustees

(Voting):

Four non-elected ofﬁcials

appointed by the following representatives of the Pennsylvania

General Assembly: the President Pro Tempore of the Senate,

the Leader of the Senate, the Minority Speaker of the House

of Representatives, and the Minority Leader of the House of

Representatives, each of whom shall have the power to appoint one

Commonwealth Trustee in accordance with Act No. 1994-25A.

Special Trustees

(Voting):

Up to two in number, to serve for a term

determined by the Chair and approved by the Trustees Executive

Committee, as deﬁned at the time of their election, and whose service

is in the best interests of the University to meet a particular need or

purpose.

The Executive Committee of the Trustees exercises all of the powers

and authority of the trustees, except for those cases where the Statutes

specify action by the full board. The Executive Committee is elected

annually by the trustees and shall normally be comprised of no fewer

than ten voting trustees. The trustees may form such boards and

committees as they see ﬁt for any of the purposes and activities of the

University. The standing committees at present are: Academic Policy;

Audit and Compliance; Budget and Finance; Compensation; Development;

Facilities and Campus Planning; Honorary Degrees and Awards; Local,

National, & Global Engagement; Nominating; and Student Life. There is

also an Investment Board.

The trustees annually elect the chair of the trustees and one or more

vice chairs, who also serve as members of and as chair and vice chairs

of the Executive Committee. The trustees hold two-day meetings three

times a year, normally in the spring, fall, and winter. The meetings consist

primarily of committee sessions and culminate in a stated meeting of

the trustees. The Executive and Budget and Finance Committees are

scheduled to meet at additional times throughout the year, and the other

standing committees may have additional meetings if necessary. In

University of Pennsylvania Faculty Handbook

I.C. The Central Administration

accordance with Pennsylvania law, formal action on resolutions is taken

in stated meetings open to any member of the University community,

subject to space.

Each standing committee is staffed by a University administrator who

assists the chair in planning agendas and preparing background material

for meetings. Six of the standing committees currently have faculty

and student liaisons elected by the Faculty Senate, the Graduate and

Professional Student Assembly, and the Undergraduate Assembly, who

help represent the University community in committee discussions.

Ten of the schools and six University centers have boards of overseers

composed of informed laypersons who act in an advisory capacity to the

trustees, the President, the Provost, and the dean of a school or director

of a center.

Copies of the Statutes and more detailed information about the trustees

are available on the web site of the Secretary of the University (https://

secretary.upenn.edu/).

I.C. The Central Administration

(Source:

Statutes of the Trustees

(

https://secretary.upenn.edu/trustees-

governance/statutes-trustees/

), Article 2, 1969; revised, Article 3, June 19,

1981; revised June 19, 2009; revised, Ofﬁce of the Provost, November 21,

2022)

I.C.1. The Ofﬁcers

The ofﬁcers of the University shall be the President, the Provost, the Vice

Presidents, the Secretary, the Treasurer, the Comptroller, and the General

Counsel.

Subject to the policies of the University, all ofﬁcers except the President

shall be elected by the Trustees upon nomination by the President

and shall be suspended or terminated by the Trustees upon the

recommendation of the President.

The President may appoint a temporary successor or substitute to act

as required because of the death, absence, disability, suspension, or

termination of any ofﬁcer of the University other than the President,

but such temporary appointments shall be effective only until the next

meeting of the Trustees or the Executive Committee, at which time

a successor shall be nominated and elected either on an acting or a

permanent basis.

With the consent of the President and subject to the policies of the

University, ofﬁcers may appoint such associates and assistants and

assign them such duties as they shall deem appropriate.

I.C.2. The President

The President shall hold ofﬁce upon such terms as the Trustees shall

determine.

Functions and Duties of the President

As the Chief Executive Ofﬁcer of the University, the President is its

educational and administrative head. The President is responsible to the

Trustees for the conduct, coordination, and quality of the University’s

programs and for their future development. The President shall have the

authority to perform all acts that are necessary to make effective the

policies and actions of the Trustees unless a resolution of the Trustees

speciﬁcally grants such authority to another person or entity. As a liaison

between the Trustees and the faculty, the President shall inform each

of the views and concerns of the other relating to the programs and

administration of the University.

The President shall hold the academic rank of Professor, shall be a

member of every Faculty of the University, and may at their discretion call

a meeting of any Faculty.

The President is assisted in the management of the University by several

Vice Presidents. The current Vice Presidents who report directly to

the President are: the Executive Vice President; the Executive Vice

President of the University for the Health System; the Senior Vice

President and General Counsel for the University of Pennsylvania and

Penn Medicine; the Vice President and Chief of Staff, Ofﬁce of the

President; the Vice President for Development and Alumni Relations;

the Vice President for Government and Community Affairs; the Vice

President of Institutional Affairs; and the Vice President for University

Communications. Vice Presidents who report to the President through

the Executive Vice President are the Vice President for Budget and

Management Analysis; the Vice President for Business Services; the Vice

President for Facilities and Real Estate Services; the Vice President for

Finance and Treasurer; the Vice President for Human Resources; the

Vice President for Information Systems and Computing, who also reports

to the Provost; the Vice President for the Division of Public Safety; the

Associate Vice President for Audit, Compliance and Privacy; and the Chief

Investment Ofﬁcer.

Election of the President

When it becomes necessary to elect a new President, the Chair of

the Board of Trustees shall convene a Consultative Committee,

composed of trustees, deans, faculty, staff, and students, to advise in the

selection process by identifying priorities, issues, challenges, candidate

qualiﬁcations and other factors important to the constituencies

represented by the members of the Consultative Committee. The Chair

shall also convene a Search Committee, whose members will be selected

primarily from among those of the Consultative Committee, to be

responsible for the identiﬁcation, recruitment, and selection of candidates

for recommendation to the Executive Committee. The composition of

and procedures governing the Consultative Committee and the Search

Committee shall be speciﬁed in a Standing Resolution of the Trustees

and can be found in section I.G.1 of this handbook, Consultation for the

Election of a President.

The Executive Committee shall, at a closed meeting, review the report

of the Search Committee and shall present a ﬁnal nomination of one

candidate to be voted upon by the Trustees.

At least ten days prior to the stated or special meeting of the Trustees at

which the election of the President is proposed, the Secretary shall give

to each trustee notice stating that the election of the President shall be

held at such a meeting and giving the name of the person who has been

nominated by members of the Executive Committee. No such election

shall be valid unless a nominee shall receive the afﬁrmative votes of at

least two-thirds of the number of trustees then in ofﬁce.

Removal of the President

The President may be removed only after consultation with

representatives of the faculty and by the afﬁrmative vote of trustees

actually present at a stated or special meeting equal to at least two-thirds

of the number of trustees then in ofﬁce. Notice of such proposed action

must be included in the notice of the meeting.

The Executive Committee shall appoint a temporary successor or

substitute to act in case of the death, extended absence, disability, or

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University of Pennsylvania Faculty Handbook

removal of the President. The President may appoint an ofﬁcer of the

University to act for him/her during a period of temporary absence.

I.C.3. The Provost

The Provost shall be the ofﬁcer responsible for the conduct, coordination,

and quality of the University’s academic programs and for the planning

of their future development. Hence, the Provost is crucially involved in

the recruitment and maintenance of a faculty of the highest distinction in

research and teaching. The Provost also is concerned with maintaining

a student body of superior quality and thus exercises oversight over

academic program standards and over the admissions process. All deans

report to the Provost, and under the President, the Provost has ultimate

authority for all academic budgets.

The Provost shall hold the academic rank of Professor, shall be a voting

member of every Faculty of the University, and may at their discretion call

a meeting of any Faculty. In the performance of their duties, the Provost

shall consult with representatives of the Faculty.

The Provost is assisted in his role by several administrators with

considerable responsibilities in their areas of expertise. The Vice Provost

for Education has primary responsibility for the oversight of graduate

and undergraduate education and other such educational programs and

policies as the Provost shall designate. The Vice Provost for Faculty

manages the academic personnel process, including recruitment of

faculty, appointments, promotions, tenure cases and grievances. The

Senior Vice Provost for Research is responsible for the development

and implementation of policies and procedures that promote excellence

in research across the University and for the overall operation of the

University’s extensive research enterprise, as well as for the development

and implementation of Penn’s strategy for technology transfer and

entrepreneurial initiatives and the University’s corporate relations

and regional economic development strategy. The Vice Provost for

University Life is responsible for all nonacademic aspects of student

life. This includes addressing a wide array of student concerns in order

to improve the quality of campus life for students and other members

of the University community. The Vice Provost and Director of Libraries

administers the University library system and plays an important role in

the dissemination of information on campus.

(Almanac, May 2, 2017 (https://almanac.upenn.edu/articles/wendell-

pritchett-penns-30th-provost/))

I.C.4 The Secretary

The Secretary of the University shall attend and keep minutes of the

meetings of the Trustees, shall act as secretary of all boards and

committees of the Trustees, and shall be custodian of communications,

reports, and other documents of importance presented to the Trustees.

The Secretary shall give notice to Trustees and to members of boards

and committees of all stated and special meetings. The Secretary

shall have custody of the Seal of the Corporation, shall afﬁx it to such

instruments as require its use, and when so afﬁxed, shall attest it by

signature.

The Secretary shall prepare all diplomas and certiﬁcates of study, shall

have charge of ofﬁcial convocations of the University, and shall have

such other powers and duties as may be conferred from time to time

by the Trustees. Any minute books, documents, and records of the

University not yet deposited in the Archives shall be open at all times to

the inspection of trustee boards and committees, to any trustee, and to

authorized University ofﬁcers.

I.C.5. The Treasurer

The Treasurer shall have custody of all evidences of ownership of real

or personal property owned by the University or pledged to it, other than

those evidences in the custody of the Investment Board. The Treasurer

also shall have custody of all policies of insurance, and shall have the

authority to accept receipt for the same on behalf of the Trustees, and

under their supervision shall arrange for the safekeeping thereof.

The Treasurer shall collect and receive all monies due and payable to

the University and deposit them in the name of the University in such

banking institutions as the Trustees may approve and shall discharge all

debts or other obligations of the University when due and payable. The

Treasurer shall keep a complete set of accounts showing in detail the

ﬁnancial transactions of the Treasurer’s Ofﬁce, and these shall be open

at any time to the inspection of any trustee. The Treasurer shall furnish

such ﬁnancial statements compiled from their accounts as from time to

time may be required by the proper University ofﬁcers, Trustee boards

and committees, or any trustee.

I.C.6. The Comptroller

The Comptroller shall maintain a complete set of accounts, except those

maintained by the Treasurer, showing in detail the business and ﬁnancial

transactions of the University. The Comptroller shall be responsible for

the proper keeping of accounts of every department of the University and

shall have authority to direct the methods, including audit and control, by

which such accounts are kept. The Comptroller shall compile and furnish

such ﬁnancial or statistical reports or information as may be required

by the proper University ofﬁcers, Trustee boards and committees, or

any trustee. The Comptroller shall approve all vouchers before they are

submitted to the Treasurer for payment; such approval shall be evidence

that the charge has been recorded against an approved budget on ﬁle,

and that it is within the appropriation of the budget against which it is

charged.

I.C.7. The General Counsel

The General Counsel shall represent the University in legal matters. All

matters requiring legal advice or legal action shall be referred to the

General Counsel.

I.D. The Faculties and the Schools

(Source: Statutes of the Trustees, Article 7, January, 1956; revised, 1979;

revised, Article 9, June 17, 1983; revised as Article 10, November 2,

2001; revised, February 11, 2005; revised,

September 18, 2008

(

https://

secretary.upenn.edu/trustees-governance/statutes-trustees/#ten

))

There shall be such faculties and such schools as authorized by the

trustees. The Trustees recognize the following (listed in the order of their

origin):

Faculty of Arts and Sciences

The School of Arts and Sciences, including the College of Arts and

Sciences as its undergraduate division, the Graduate Division of Arts

and Sciences, and the College of Liberal and Professional Studies, as its

lifelong learning program.

Faculty of Medicine

The Perelman School of Medicine

Faculty of Law

Penn Carey Law

2026-27 Catalog | Generated 08/03/26

I.E. General Provisions Concerning a Faculty

Faculty of Engineering and Applied Science

The School of Engineering and Applied Science

Faculty of Design

The Stuart Weitzman School of Design

Faculty of Dental Medicine

The School of Dental Medicine

Faculty of the Wharton School

The Wharton School

Faculty of Veterinary Medicine

The School of Veterinary Medicine

Faculty of Education

The Graduate School of Education

Faculty of Social Policy and Practice

The School of Social Policy and Practice

Faculty of Nursing

The School of Nursing

Faculty of Communication

The Annenberg School for Communication

I.E. General Provisions Concerning a

Faculty

(Source: Statutes of the Trustees, Article 7, January, 1956; revised, Article 9,

June 17,1983; became Article 10, November 2, 2001; revised,

June 20, 2003

(

https://secretary.upenn.edu/trustees-governance/statutes-trustees/

#ten

); revised, Ofﬁce of the Provost, November 21, 2022)

The faculty of a school consists of the members of the Standing Faculty,

the Standing Faculty-Clinician-Educator, the Associated Faculty, and

the Academic Support Staff. The voting faculty of a school (hereinafter

referred to as the Faculty) shall consist of the members of the Standing

Faculty and the Standing Faculty-Clinician-Educator and such other

persons who have been granted the right to vote by that faculty. The

Standing Faculty and the Standing Faculty-Clinician-Educator comprise

the core of the academic staff. The term “Standing Faculty,” used alone,

shall refer only to those faculty members with tenure or in tenure-

probationary status.

There shall be a Dean and a Secretary of each Faculty. The Dean shall

be appointed or removed by the Trustees, upon recommendation by the

President and the Provost, and according to policies and procedures

promulgated by the President and the Provost. The Dean shall preside

at meetings of the Faculty; shall sign all diplomas, certiﬁcates, and

other ofﬁcial papers on behalf of their Faculty; and serve as the ofﬁcial

means of communication between the Faculty and the Provost. The

Secretary shall be elected by the Faculty and shall serve for such a time

as determined by the Faculty.

Each Faculty shall meet at stated times and also at the call of its

dean or of the President, the Provost, or other designated ofﬁcer. Each

Faculty shall also adopt provisions governing the call of meetings by

its members. Except for the standing Committee on Academic Freedom

and Responsibility, which shall be elected annually, committees of each

Faculty shall be appointed by the Dean, or elected, as prescribed by the

procedures adopted by each Faculty.

Upon recommendation of the President, the Trustees may authorize the

establishment, merging, or closing of departments, divisions, or similar

entities in schools that do not have departments. The chair of each

department shall be appointed or removed by the President, upon the

recommendation of the Dean with the advice of the Faculty, and with

the approval of the Provost or the Provost's designee. A department

chair shall serve according to policies and procedures established by the

President and the Provost.

Subject to general policies established by the Trustees, the responsibility

for determining the quality of the student body shall rest with the Faculty

of that school. Each Faculty shall articulate the criteria for selection

of applicants for admission and shall establish a written admissions

policy that describes these criteria. Each Faculty shall also monitor

implementation of its admissions policy and amend it when necessary.

Subject to general policies established by the Trustees, and in a manner

consistent with general University policies, each Faculty shall also

set its regulations for instruction of students and requirements for

recommendations for degrees in course and in faculty.

Subject to general policies established by the Trustees, and in a manner

consistent with general University policies, each Faculty shall set its

own procedures for governance and determine the qualiﬁcations for

membership in the Faculty.

I.F. Organization and Responsibilities

of Graduate Groups

(Source: Ofﬁce of the Provost, Almanac, September 29, 1981; revised,

Almanac, March 19, 1996

(

http://www.upenn.edu/almanac/v42/n24/

grad.html

); revised, Ofﬁce of the Provost, November 21, 2022)

I.F.1. Introduction

In the University of Pennsylvania, graduate programs leading to the Ph.D.

and related master’s degrees are carried out by associations of faculty

members called “graduate groups.” Many of these groups are based in

individual departments. In such groups, all members of the Standing

Faculty in that department are

ipso facto

members of the graduate group,

but the group also may include faculty who come from other departments

or schools. There are, in addition, a signiﬁcant number of graduate groups

that are not based in any one department and are composed of faculty

from several departments or schools.

The graduate group structure provides the adaptability necessary to

mount graduate programs in newly developing areas of intellectual

endeavor or to phase out programs in areas of declining vigor, without

disrupting the underlying structure of the traditional departments and

schools. The price paid for this adaptability is continuing vigilance over

the academic quality and vigor of each graduate program, particularly

those that are not based in a single disciplinary department or school.

The purpose of the sections that follow is to outline the organization and

responsibilities of the faculty who are members of graduate groups, and

of the group chairpersons.

I.F.2. Graduate Group Faculty

Only members of the Standing Faculty, the Associated Faculty and

Emeritus Faculty are eligible for membership in graduate groups.

Members of the Academic Support Staff—for example, Instructors,

Lecturers and Research Associates—are not eligible, nor are Visiting

Faculty unless they have an appointment in the Associated Faculty. It

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University of Pennsylvania Faculty Handbook

should be noted that while members of the Research Faculty may serve

on a graduate group, according to a Provostial memorandum dated

August 5, 1983, they may not take responsibility for courses or seminars

nor may they supervise theses or dissertations unless the prior approval

of the Provost is obtained for each such activity.

The fundamental responsibility for the academic quality and

effectiveness of a graduate program rests with the faculty of the

appropriate graduate group. The essential duties of this faculty include:

•

Design of an academic program that meets the requirements of the

student and of the University for depth, breadth and academic quality

of the highest order. Equally important is the continuous adaptation

of this program in response to the challenges by and opportunities for

new developments in its scholarly ﬁeld.

•

Establishment of well deﬁned academic standards and requirements

that are rigorous yet flexible and that ensure quality and encourage

the free development of the scholarly abilities of each student.

students. These standards and requirements must be consistent with

the intellectual style and spirit of the ﬁeld and also with the minimum

requirements of the University, as established by the Graduate

Council of the Faculties.

•

Establishment and operation of graduate admissions programs that

will attract and admit students of the highest quality. Admissions

standards and procedures must be consistent with those established

by the Graduate Council of the Faculties, the Council of Graduate

Deans or the Associate Provost for Education.

•

Wise and intensive counseling of graduate students in matters

both academic and nonacademic, to encourage their rapid progress

toward their academic goals.

•

Active participation in the quest for ﬁnancial resources for support of

graduate students and in the allocation of available resources so as

to optimize the quality of the program and its students.

•

Active assistance in the placement of the program’s graduates in

positions where their abilities and training are utilized to the fullest

degree possible.

At least half of the members of Ph.D. examination and dissertation

committees must be members of the graduate group at the time of

appointment to the committees. Faculty who are not members of the

graduate group may serve only with the written approval of the graduate

group. The authority to approve membership on committees may be

delegated to the graduate chair. The chairs of dissertation committees

and of all examination committees must be members of the Standing

Faculty in the graduate group.

If the chair of a dissertation committee leaves the Standing Faculty

before the dissertation is completed, then a new chair from the Standing

Faculty must be appointed as chair. The dissertation committee chair is

responsible for convening committee meetings, advising the student on

graduate group and university expectations, and assuring the graduate

group chair that the group’s requirements have been met. The committee

chair does not have to be the primary dissertation adviser.

Instructors in courses that satisfy the requirements for the Ph.D. must

hold the Ph.D. degree or be members of the Standing Faculty or the

Associated Faculty. No one may teach a required core course for more

than one semester without becoming a member of the Standing Faculty

or the Associated Faculty.

The selection and appointment of faculty to membership in a graduate

group are the responsibility of the appropriate dean, in consultation

with members of the graduate group and such other faculty groups

or individuals and academic administrators as may be appropriate.

The standards and criteria to be used in selection and appointment of

members of the Standing Faculty or the Associated Faculty to graduate

groups are established by the dean in consultation with the dean's faculty

and include academic excellence and commitment to the academic goals

of the program.

In cases where a graduate group is based in an academic department or

school, appointment to membership in the graduate group accompanies

and is implicit in a primary appointment to the Standing Faculty in

the department or school and is for the same term. In all other cases,

appointment to membership in a graduate group is for a term speciﬁed at

the time of appointment.

All appointments to membership in a graduate group carry full voting

rights in the deliberations of the group unless otherwise speciﬁed at the

time of appointment.

All appointments to membership in a graduate group must be reported to

the Ofﬁce of the Provost at the time of appointment by making a record in

the Faculty Information System.

The procedure for appointment of a faculty member to membership in a

graduate group not based in the faculty member's department or school

differs from and is independent of two other types of intra-university

“linking” appointments:

Interlocking faculty appointments, made by the Provost to facilitate

interaction between the faculties of the several schools.

Secondary faculty appointments, made by the Trustees following

the normal academic appointment process.

These two types of appointments, as well as all appointments to other

than Standing Faculty positions, do not automatically carry with them

appointment to a graduate group.

I.G. Policies Concerning Academic

and Administrative Ofﬁcers

(

Revised, Ofﬁce of the Provost, November 21, 2022)

I.G.1. Consultation Procedures for the

Election of a President

Article 3.2.b. of the Statutes of the University states: “When it becomes

necessary to elect a new President, the Chair of the Board of Trustees

shall convene a Consultative Committee, composed of trustees,

deans, faculty, staff, and students, to advise in the selection process

by identifying priorities, issues, challenges, candidate qualiﬁcations,

and other factors important to the constituencies represented by

the members of the Consultative Committee. The Chair shall also

convene a Search Committee, whose members will be selected primarily

from among those of the Consultative Committee, to be responsible

for the identiﬁcation, recruitment and selection of candidates for

recommendation to the Executive Committee. The composition of and

procedures governing the Consultative Committee and the Search

Committee shall be speciﬁed in a Standing Resolution of the Trustees.

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I.G. Policies Concerning Academic and Administrative Ofﬁcers

The Executive Committee shall, at a closed meeting, review the report

of the Search Committee and shall present a ﬁnal nomination of one

candidate to be voted upon by the Trustees.

At least ten days prior to the stated or special meeting of the Trustees at

which the election of the President is proposed, the Secretary shall give

to each trustee notice stating that the election of the President shall be

held at such a meeting and giving the name of the person who has been

nominated by members of the Executive Committee. No such election

shall be valid unless a nominee shall receive the afﬁrmative votes of at

least two thirds of the number of trustees then in ofﬁce.”

A Consultative Committee to advise the Executive Committee will be

formed, chaired by the Chair of the Board of Trustees (or the Chair's

designee) and comprised of trustees, faculty, deans, undergraduate

students, graduate /professional students, and staff. The size and exact

composition of the Consultative Committee will be determined by the

Executive Committee, provided, however, that the Consultative Committee

shall include in addition to the chair at least four current trustees, four

faculty members, one dean, one undergraduate student, one graduate/

professional student, and one member of the university staff. The faculty

members will be selected by the Faculty Senate Executive Committee in

consultation with the Consultative Committee Chair. All other members of

the committee will be selected by the Chair.

The Chair will charge the Consultative Committee members with the

responsibility for seeking the advice of their respective constituencies

on issues relevant to the search process, such as challenges a new

president might face, strategic priorities, and recommended strengths

and experience for the new President. The Consultative Committee shall

meet to discuss and review the recommendations and will provide a

summary of its ﬁndings to the Chair.

A Search Committee, whose chairman and members will be appointed

by the Chair of the Board of Trustees primarily from among the members

of the Consultative Committee, will be convened to initiate the search

process and review the Consultative Committee’s guidance. The size

of the Search Committee will be determined by the Chair of the Board

of Trustees, but shall include at least two trustees and two faculty

members, and shall not exceed a total of eight members, in addition to

the Committee Chairman. The Search Committee will be responsible

for the identiﬁcation, recruitment and selection of candidates to be

interviewed, will conduct the interviews of the candidates, and will

endeavor to recommend at least three candidates in rank order to the

Executive Committee. The Search Committee will keep the Consultative

Committee apprised of its progress during the interview process, without

disclosing any personal information about particular candidates.

Based on the recommendation of candidates by the Search Committee,

the Executive Committee will then present a ﬁnal nomination of one

candidate to the Board of Trustees for approval.

All proceedings of the Consultative Committee, the Search Committee,

the Executive Committee, and the Board of Trustees will be conﬁdential

and no member of any body will disclose the deliberations to any other

person, except as expressly authorized by the Chair in the course of the

selection process.

I.G.2. Consultation Procedures for the

Appointment and Reappointment of Deans

and University-wide Administrators

(Source: Proposed Consultation Procedures, University Council Steering

Committee, Almanac, February 17, 1981; revised, Ofﬁces of the President

and Provost, Almanac,

September 15, 1981

(

https://almanac.upenn.edu/

archive/v28pdf/n02/091581.pdf

))

The University administration, before recommending the appointment

of certain ofﬁcers, typically seeks the advice of ad hoc committees

composed of faculty and students. The ofﬁces subject to this practice

include all those having a signiﬁcant influence in academic affairs.

While the application of this criterion is clear when positions such as

the Provost and deans are in question, it is difﬁcult to draw a precise

line of demarcation for subordinate positions or for major administrative

posts not directly in academic affairs. This is in part because influence

on academic affairs is not an “either/or” question for many of these

positions, but a matter of degree which, given the changing nature of

the University’s problems, is sometimes difﬁcult to gauge in advance.

Another complication is that new posts with different titles may be

created from time to time.

These procedures take cognizance of these difﬁculties by providing

for consultative input that is graduated according to the degree of

influence that a post seems likely to have in the academic life of the

University. Thus, where the post is one that involves little direct authority

or influence, the consultative process should be informal and should

give great scope to the preferences of the administration. For such a

position, the appointing ofﬁcer may consult faculty and student leaders

individually about a candidate proposed by the appointing ofﬁcer.

For non-academic appointees whose duties have a more substantial

impact on academic affairs or on campus life, consultation may proceed

through a small advisory faculty-student committee, which gives advice

concerning one or more candidates proposed by the administration. For

subordinate academic ofﬁcers, such an advisory committee may both

offer its own suggestions and react to suggestions of the administrator

for whom an aide is being chosen. Finally, where the post is one in

which major academic authority is exercised, more formal consultative

procedures should be followed. In these procedures a consultative

committee is established for the purpose of conducting a search and

drawing up a list of recommended candidates. Such a consultative

committee receives its charge from the President or Provost and may

meet from time to time with one or both of these ofﬁcers during its

deliberations. The committee does not conﬁne itself to suggestions made

by the President or Provost. Both advisory and consultative committees

make their decisions in executive session.

In selecting members for consultative and advisory committees,

consideration should be given to diversity of membership, including

afﬁrmative action concerns, range of interests and rank, as well as

quality of membership. In addition, the afﬁrmative action policy of

the University requires that searches be conducted so as to identify

potential candidates from within the broadest possible pool, including

women and members of minority groups. Acceptance of appointment

to a consultative committee implies a commitment to making such a

search, and no one who does not share this commitment should accept

appointment to the committee.

Spelled out below are speciﬁc consultative procedures for the

appointment and reappointment of deans and certain University-wide

academic ofﬁcers, as well as a mechanism—the University Committee

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University of Pennsylvania Faculty Handbook

on Consultation—for resolving questions regarding the appropriate

level of consultation in doubtful cases. Unless otherwise provided, the

composition of consultative committees should conform to the principle

that “the normal maximum proportion of students on the consultative

committee shall not exceed one-quarter of the membership of the

committee, except in the case of a consultative committee for ofﬁces in

the area of student affairs, in which case, the proportion of students shall

not exceed one-third of the membership.”

University Committee on Consultation

Where doubt exists about the appropriate level of consultation for any

given post that the administration wishes to ﬁll, the President or Provost

should seek the advice of the University Committee on Consultation. This

committee is composed of the Chair, Past Chair and Chair-Elect of the

Faculty Senate and the chairpersons of the Undergraduate Assembly

and the Graduate and Professional Student Assembly. The University

Committee on Consultation shall respond quickly to the President’s or

Provost’s request for an opinion, indicating the nature of the procedure

that it recommends. The President and Provost should err on the side of

inclusiveness in seeking opinions from the committee.

Consultation for University-wide Academic Ofﬁces

Provost

When a vacancy has occurred or is expected to occur in the ofﬁce

of Provost, an ad hoc consultative committee composed of twelve

faculty members, two undergraduate students, and two graduate

or professional students shall be established by the President. The

President shall request from the Senate Executive Committee, through its

chair, nominations of six faculty members. The President shall appoint

to the consultative committee those nominated by the Senate Executive

Committee and shall appoint an equal number of other faculty members.

The committee shall meet with the President and/or the Provost

for the purpose of obtaining information and views concerning the

responsibilities of the position and the qualiﬁcations of the person to

be sought. The committee may develop additional qualiﬁcations in

consultation with the President and/or the Provost. The President and/

or the Provost shall be free to submit names of candidates at the initial

meeting or at any subsequent time prior to the completion of the work

of the consultative committee. In the case of a person from outside

the University, a consideration of academic appointment in a school

and department will normally be appropriate. If this is the case, the

department, school, and administration should act expeditiously.

It is understood that the role of the ad hoc committee shall be an

advisory one; the ﬁnal authority for the appointment rests with the

President and the Trustees. In those cases in which the President

wishes to appoint a person not considered by the ad hoc committee, the

committee shall be asked to review the qualiﬁcations of that person and

determine if they wish to recommend that person for the position.

Deputy, Associate, and Vice Provosts

With respect to the selection of Deputy, Associate, and Vice Provosts,

more flexibility in the consultative arrangements is appropriate,

depending on the particular circumstances at the time the vacancy

exists. It is also necessary to ensure that the Provost have aides in these

posts with whom the Provost can establish a close personal rapport.

Before an ad hoc committee is appointed, the Provost should consult

with the University Committee on Consultation regarding the appropriate

size for the committee, the relative proportion of faculty, undergraduate

and graduate or professional students to serve on the committee, the

extent of the search to be undertaken, the timing of the appointment, and

sponsored programs.

A.1 In accordance with such obligations, the University will use

reasonable efforts to secure an acknowledgment from the authors

of the copyrightable work prior to the commencement of the

sponsored program. Authors who are also principal investigators

and have responsibility for other authors will use reasonable

efforts to secure acknowledgment from said authors prior to the

commencement of the sponsored program.

A.2 The University shall negotiate a license with the sponsor

in accordance with applicable provisions of the sponsored

research agreement. Net revenues realized from said sponsored

research agreements will be distributed in accordance with the

procedures for the distribution of patent royalties described in

Section 2.3 of the Patent and Tangible Research Property Policies

and Procedures, except that the 30 percent research foundation

share will be maintained as a copyright fund share. The copyright

fund will be administered by the Ofﬁce of the Provost to support

the development of pedagogical innovation. When negotiating

sponsored research agreements, to the extent that University

ownership is not necessary to fulﬁll its obligations to a sponsor the

University shall, whenever practicable, make reasonable efforts to

protect the ownership rights of the authors.

B. Works Made for Hire. Exceptions to this custom also arise when

authors create works considered to be "works made for hire." Such works

are the property of the University. For purposes of this policy, "works

for hire" are those works that are prepared by the author pursuant to

the express direction of a supervisor, prepared pursuant to the speciﬁc

provisions incorporated within a position description, or prepared in the

performance of any administrative duty. Works created by authors in the

course of their instructional or research activities shall not be considered

"works made for hire."

B.1 Prior to the preparation of the "work made for hire," the

University may request, and if so the authors shall provide, an

assignment or other declaration of the University's ownership of

that work. Authors who are also principal investigators and have

responsibility for other authors will secure assignments from said

authors prior to the preparation of a "work made for hire." Failure to

secure assignment does not negate the University's ownership of

the work. In the event of subsequent disagreement over ownership

of a "work made for hire," the case shall be referred to the committee

noted in 4.B.

B.2 Net revenues realized from the commercialization of "works

made for hire" will be distributed as in A.2.

B.3 The University will have the authority to waive the "work for

hire" claim where it judges that doing so is in the interest of the

University.

C. Exceptions to this policy arise when the faculty create works

that make substantial use of the services of University non-faculty

employees or University resources. When such support is provided the

works produced shall belong to the University unless there is explicit

agreement otherwise. The faculty member(s) and the units providing

such support shall agree in writing on the ownership of such works

prior to the provision of the support. Notwithstanding the above, the

faculty member(s) may subsequently petition the University to waive its

ownership. The determining ofﬁcial for this action is the Provost, or at

the Provost's designation, the dean of the school in which the faculty

member has their primary appointment(s); or the Provost in the case

where a dean is the creator. In the event of subsequent disagreement

over the use of University resources in the creation of a work, the case

shall be referred to the committee noted in 4.B.

C.1 The reference to "substantial use of the services of University

non-faculty employees or University resources" means the use

of University funds, facilities, equipment, or other resources

signiﬁcantly in excess of the norm for educational and research

purposes in the department or school in which the creator(s)

hold their primary appointment(s). Academic year salary, ofﬁce,

usual library resources, usual secretarial and administrative staff

resources or usual computer equipment, among other things,

are not regarded as constituting "substantial use of services of

University non-faculty employees or University resources." Any

question about what constitutes substantial resources should be

referred to the committee noted in 4.B.

C.2 Net revenues realized from the commercialization of such works

will be distributed as in A.2.

D. A given intellectual property may be protected in some cases

inclusively by United States patent, copyright and trademark laws,

and in some cases by only one or two such intellectual property

laws, with each body of law protecting a different feature of the given

intellectual property. Consequently, deﬁnitions in the Patent and Tangible

Research Property Policies and Procedures and the Copyright Policy

and Procedures will at times overlap. When a single license agreement

incorporates more than one type of intellectual property protection, prior

to the execution of said license agreement, a written agreement shall be

executed by the University and the authors stipulating which University

intellectual property policy is applicable.

2. Commitment of Effort

(See also Conflict

of Interest Policy, II.E.10).

A full-time faculty member's primary commitment in teaching and

research is to the University of Pennsylvania. Any substantial teaching

carried out in another setting, regardless of medium, for which students

receive academic credit, must receive prior approval of the faculty

member's dean. Any teaching, research or other activity in which

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III.E. Patent and Tangible Research Property Policies and Procedures

the faculty member's department or school is actively engaged will

presumptively claim the faculty member's primary effort, and carrying

out these activities in another setting will also require a speciﬁc release

from such commitment by the dean. The dean and faculty of each school

should decide upon those academic activities (currently engaged in

or reasonably likely to be engaged in by the school in the foreseeable

future) other than teaching and research that are subject to the above

restrictions.

3. Audio-Visual Works

Any videotapes or other recordings of classes or courses intended for

students at the University of Pennsylvania belong to the University and

may not be further distributed without permission from the appropriate

school dean. Such audio-visual works may not be used commercially

without the permission of everyone who appears in the ﬁnal program.

A. This policy is not intended to apply to audio-visual works or

recordings that have a speciﬁc short term use such as videotapes

of lectures by job candidates, audio-visual works used to provide

an alternative lecture when students may miss class because of a

religious holiday, or audio-visual works used in teacher development

programs.

B. Net revenues realized from the commercialization of audio-visual

works and recordings using other media will be distributed as in

1.A.2.

4. Procedures for the Administration and

Management of Copyrightable Works

A. Periodic Review of Policy. The Policy Statement on Copyrights

and Commitment of Effort shall be reviewed on a periodic basis

by a review committee appointed by the Provost in consultation

with the Faculty Senate to determine whether it is accomplishing

its intended purposes; is in conformity with federal and state

laws, including intellectual property laws; and, is consistent with

prevailing norms in university-industry relationships. The review

committee shall make recommendations to the Provost who shall

confer with the President.

B. The Provost and Faculty Senate jointly shall annually appoint

a faculty committee to resolve any disputes involving the

interpretation or administration of the Policy Statement on

procedures of its own design, review, mediate, and decide any

such dispute brought before it. The Intellectual Property Ofﬁcer

shall provide staff support for the committee. Any decision of the

committee may be appealed to the Provost, who will make a ﬁnal

decision for the University.

5. Appeal Mechanisms

This policy does not preclude a faculty member's access to appeal

mechanisms, such as the Committee on Academic Freedom and

Responsibility, Faculty Grievance Procedure, or the Provost.

Additional Deﬁnitions

Assignment

In addition to Section 5.0.2 of the Patent and Tangible Research Property

Policies and Procedures, the execution of a formal document that

transfers the right, title and interest of an author of a copyrightable work.

Authors

The University faculty who would be considered authors under copyright

laws of the United States and other jurisdictions, for such works

as books, journals, articles, text, administrative reports, studies or

models, glossaries, bibliographies, study guides, instructional materials,

laboratory manuals, syllabi, tests, proposals, lectures, musical or

dramatic compositions, ﬁlms, ﬁlm strips, charts, transparencies, video or

audio recordings or broadcast, computer software, CD ROMS, circuitry,

microprocessor designs and other works that may be copyrightable

under laws of the United States and other jurisdictions. In the context of

computer software, for purposes of this policy, authorship refers to those

persons who conceive and make signiﬁcant intellectual contributions to

the development of such computer software, as well as to those persons

who author source code, object codes, masks, patterns and the like who

would be considered authors under the copyright laws of the United

States and other jurisdictions.

Copyrightable Work

A work ﬁxed in tangible medium that may be copyrightable under laws of

the United States and other jurisdictions.

Computer Software

The source code and the object code, and related documentation,

of computer programs and designs of computer circuitry and

microprocessor chips.

III.E. Patent and Tangible Research

Property Policies and Procedures

(Source: Resolution of the Trustees, January, 1966; revised, June 18, 1993

and Ofﬁces of the President and Provost, Almanac, March 15, 1994; revised,

Resolution of the Trustees, February 11, 2005 and Ofﬁces of the Provost

and the Faculty Senate, Almanac, February 22, 2005; revised, Ofﬁce of the

Provost, Almanac, February 7, 2006; revised, Resolution of the Trustees, June

18, 2010 and Ofﬁce of the Provost, Almanac, July 13, 2010; revised, Ofﬁce

of the Provost,

Almanac, April 21, 2015

(

https://almanac.upenn.edu/

archive/volumes/v61/n31/pdf/042115-supplement.pdf

); revised, Ofﬁce

of the Provost,

Almanac, February 4, 2020

(

https://almanac.upenn.edu/

uploads/media/Patent_Policy_Supplement.pdf

); revised, Ofﬁce of the

Provost,

Almanac, August 10, 2021

(

https://almanac.upenn.edu/uploads/

media/081021-supplement.pdf

); revised, Ofﬁce of the Provost, December

16, 2022; revised, Ofﬁce of the Provost,

Almanac, October 10, 2023

(

https://

almanac.upenn.edu/volume-70-number-9/#patent-and-tangible-research-

property-policies-and-procedures-of-the-university-of-pennsylvania-

v70-n9

); revised, Ofﬁce of the Provost,

Almanac, June 17, 2025

(

https://

almanac.upenn.edu/#of-record-update-to-the-patent-and-tangible-

research-property-policies-and-procedures

))

The University periodically revises and updates its policies and procedures

regarding patents and tangible research property, to ensure that these

policies and procedures continue to meet the needs of the Penn community.

The updated policy, effective

October 1, 2023

, contains an adjustment to the

distribution of commercialization revenue as described in section 4.0.14:

INITIAL DEDUCTION. This adjustment expands the range of the INITIAL

DEDUCTION of GROSS PCI REVENUES from 5%-25% to 0%-25% and allows

changes to be implemented at any time of the ﬁscal year. A reduction of

the INITIAL DEDUCTION results in increased revenue distributions to the

inventors, schools, and university. The Executive Committee of the Penn

Center for Innovation approved the adjustment, and the Council of Deans and

the Faculty Senate Executive Committee were notiﬁed.

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University of Pennsylvania Faculty Handbook

—John L. Jackson, Jr., Provost

—Dawn Bonnell, Senior Vice Provost for Research

(Note: Words appearing in capital letters are deﬁned in Article 4, unless they

are deﬁned in the document itself.)

Article 1. Preamble

1.0

The Trustees of the University of Pennsylvania (the

University) afﬁrm the following principles as the basis for governing the

intellectual property created by faculty, employees, students, and guest

scholars of the University:

1.1

The mission of the University includes the stimulation of basic and

applied research activities of faculty, employees, and students of the

University and the dissemination of the results of their research for

the purpose of adding to the body of knowledge and serving the public

interest.

1.2

The purpose of this policy is to encourage and enable

faculty, employees and students to translate new knowledge into social

good and provide a framework within which the University can support

and facilitate these actions.

1.3

The University endeavors, where it deems appropriate, to

secure intellectual property protection for the products of such research

and to encourage commercial investment in and development of

University intellectual property for the beneﬁt of the public.

1.4

The community has endowed the University with certain

privileges, resources, and assets in the expectation that no single party

will derive sole beneﬁt or be unjustly enriched from what the community

has endowed to the University.

1.5

The University as a non-proﬁt organization endeavors to marshal its

resources and exploit its assets to serve the public interest and in so

doing reinvests in the research enterprises of its faculty, employees,

and students. Members of the University community share in the

University’s responsibility to serve the public interest and have a duty to

disclose and assign their inventions.

1.6

The University is regularly the recipient of grants from the

government, foundations or commercial enterprises for the support of

research and is subject to legal and contractual obligations imposed by

these entities.

1.7

The University wishes to share the economic beneﬁts of inventions or

other intellectual property with the creators of such works in a way that

is consistent with the research and educational mission of the University

and conforms to the University’s obligations to regulatory authorities,

research sponsors, and licensees.

1.8

In protecting and managing its intellectual property assets,

the University insists that the academic freedom of its faculty and

students be preserved and that collegiality and the open expression

of ideas by and among members of the University community be

encouraged.

Article 2. Policy and Procedures on

Inventions and Patents

2.0 Policy Statement on Inventions and Patents.

It is the policy

of the University that all INVENTIONS, together with associated

MATERIALS, which are conceived or reduced to practice by INVENTORS

in the course of employment at the University, or result from work

directly related to professional or employment responsibilities at the

University, or from work carried out on University time, or at University

expense or with SUBSTANTIAL USE OF UNIVERSITY RESOURCES

under grants or otherwise, are the property of the University, effective

immediately as of the time such INVENTIONS are conceived or reduced

to practice. INVENTORS hereby irrevocably assign to the University

all right, title and interest in and to the INVENTIONS, MATERIALS and

related patent applications and patents, and shall cooperate fully with

the University in the preparation and prosecution of patent applications

and patents. Patents, as they may be available on such INVENTIONS,

may be applied for in any country by the University. The University will

exercise its ownership and management of such INVENTIONS, with

or without economic beneﬁt, with due regard for the principles set

forth in the Preamble (Article 1) of this PATENT POLICY. Procedures for

implementation of this PATENT POLICY, including a PARTICIPATION

AGREEMENT, shall be developed and promulgated by the President of the

University.

2.1 Procedures for the Administration and Management of Inventions and

Patents.

The following procedures have been approved by the President

as of the EFFECTIVE DATE:

2.1.1 Participation Agreement.

All faculty, emeritus faculty, visiting

faculty or other visitors using research facilities (including but not

limited to individuals on sabbatical from another university or research

facility), researchers, adjunct faculty, postdoctoral employees and

trainees, graduate students and undergraduate students participating

in research as employees or otherwise, and all salaried employees, shall

execute a PARTICIPATION AGREEMENT (Appendix A) as a condition of

employment, matriculation, participation in research or use of University

resources. Notwithstanding the above, an individual acknowledges

that they are bound by this PATENT POLICY by accepting or continuing

University employment or by using University resources or facilities, and

acknowledges that they hereby irrevocably assigns all right, title and

interest in and to INVENTIONS, together with associated MATERIALS,

and patent applications and patents which may issue, effective as of

their ﬁrst date of employment, matriculation, participation in research

or use of any University resources, whichever occurs ﬁrst, regardless of

whether they execute or have executed a PARTICIPATION AGREEMENT.

All students shall be advised of the University’s intellectual property

policies and procedures through publication and dissemination in the

Penn Book (https://catalog.upenn.edu/pennbook/) and elsewhere.

2.1.2 Disclosure and Review.

INVENTORS shall ﬁle INVENTION

DISCLOSURES for all INVENTIONS covered by the PATENT POLICY

promptly with the PENN CENTER FOR INNOVATION (PCI) at the

University. PCI shall direct the review and management of the

INVENTIONS under procedures and practices monitored by the

EXECUTIVE COMMITTEE. PCI will undertake the review of the INVENTION

DISCLOSURE within thirty (30) business days after the submission is

completed, or, if requested by one or more INVENTORS, PCI will use

reasonable efforts to undertake the review sooner if necessary to

facilitate an upcoming publication, presentation or other public disclosure

which could adversely affect whether to pursue patent protection.

PCI will convey its determination of whether the University wishes to

retain title to and pursue a patent application on an INVENTION as soon

as practicable, in writing, after completing its review of a completed

INVENTION DISCLOSURE submission and use reasonable efforts to

convey such decision to all INVENTORS within three (3) months after

receiving a complete INVENTION DISCLOSURE submission. If the

University wishes to retain title to an INVENTION, upon the request of the

INTELLECTUAL PROPERTY ADMINISTRATOR (IPA), an INVENTOR shall

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III.E. Patent and Tangible Research Property Policies and Procedures

sign all documents necessary for the University to protect an INVENTION,

ﬁle patent application(s), comply with applicable law in connection with

such INVENTION and conﬁrm in writing the INVENTOR’S prior assignment

to the University of all right, title and interest in and to such INVENTION.

2.1.3 Inventions Outside the PATENT POLICY.

If a faculty member,

emeritus faculty, visiting faculty, other visitor using research facilities,

researcher, adjunct faculty, postdoctoral employee or trainee, graduate

student, undergraduate student, or salaried employee (an INDIVIDUAL)

believes that a given INVENTION was made outside the scope of the

PATENT POLICY, the INDIVIDUAL shall provide the IPA with a written

statement of the circumstances leading to the making of the INVENTION.

If, after reviewing the facts, the IPA determines that the INVENTION falls

outside the scope of the PATENT POLICY, the IPA shall conﬁrm in writing

within thirty (30) days after receiving such written statement that the

University has no right, title and interest to the INVENTION. If the facts

are equivocal, or if the IPA believes that such INVENTION falls under

the PATENT POLICY, the matter of ownership will be referred by the IPA

or the INDIVIDUAL to the APPEALS BOARD, and the APPEALS BOARD

shall make a recommendation to the President concerning ownership.

Nothing in this PATENT POLICY is intended to imply or assume that an

emeritus faculty member is making or has made a SUBSTANTIAL USE OF

UNIVERSITY RESOURCES or imply or assume that an emeritus faculty

member’s invention falls under or outside the scope of this PATENT

POLICY.

If an INDIVIDUAL makes an INVENTION which is outside the scope of

the PATENT POLICY, and the IPA (or, if appealed, the President) agrees

that such INVENTION is outside the scope of the PATENT POLICY,

such INDIVIDUAL may request in writing to use the services of PCI in

connection with the assessment, protection and/or commercialization of

such INVENTION. PCI, in its sole discretion, may decline or may elect to

use its personnel and services with respect to such INVENTION, on the

condition that: (1) the INDIVIDUAL makes ASSIGNMENT to the University

in a writing deemed sufﬁcient by PCI; and (2) the INDIVIDUAL shall be

deemed to be an INVENTOR and such invention shall be deemed to be

an INVENTION within the scope of this PATENT POLICY, for all purposes

(including but not limited to distributions), effective as of the date of

ASSIGNMENT. The use of PCI shall be deemed to be a SUBSTANTIAL

USE OF UNIVERSITY RESOURCES. PCI’s decision to decline shall not be

reviewable by the APPEALS BOARD

2.1.4 Student Inventions.

2.1.4.1

INVENTIONS made by students will remain the property of the

students except:

[a]

when an INVENTION is made in the course of employment at the

University, or

[b]

when an INVENTION results from work directly related to

employment responsibilities at the University, or

[c]

when an INVENTION results from work or research performed under

a grant or other sponsorship where the grant or sponsorship

requires ASSIGNMENT to the University, or

[d]

when an INVENTION is created with another INVENTOR who has a

duty to make or has made ASSIGNMENT to the University.

In such instances, students are hereby deemed to have irrevocably

transferred and assigned all of their right, title and interest in and to such

INVENTION, effective as of the ﬁrst date conceived or reduced to practice,

regardless of whether or when such student executes a PARTICIPATION

AGREEMENT or other written agreement conﬁrming assignment, and

such undergraduate student shall be deemed an INVENTOR for purposes

of sharing in distributions and otherwise pursuant to this PATENT

POLICY.

2.1.4.2

INVENTIONS created by or resulting from research carried

out in University laboratories as part of a post-baccalaureate or

postdoctoral degree or non-degree program shall be subject to this

PATENT POLICY. In such instances, the individual shall be deemed to

have hereby irrevocably made ASSIGNMENT to the University effective

as of the ﬁrst date of matriculation and will be deemed an INVENTOR for

purposes of distributions and otherwise pursuant to this PATENT POLICY,

regardless of whether or when such individual executes or executed a

PARTICIPATION AGREEMENT or other written agreement conﬁrming

assignment.

2.1.5 Return of Inventions.

2.1.5.1 Inventions Made without Outside Sponsorship.

If an INVENTION

is made without sponsorship of the federal government or other sponsor,

and the University does not wish to pursue a patent application in the

United States or other jurisdiction, or elects to abandon a pending

patent application, or does not wish to own an issued patent on a given

INVENTION, the IPA may, after consultation with and subject to the

approval of the Vice Provost for Research, return all of the University’s

right, title and interest to the INVENTION, patent application or issued

patent to the INVENTORS, subject to and upon the terms and conditions

set forth in Section 2.1.5.3.

2.1.5.2 Inventions Made with Outside Sponsorship.

If an INVENTION is

made with sponsorship of the federal government or other sponsor,

and the University does not wish to pursue a patent application in the

United States or other jurisdiction, or elects to abandon a pending

patent application, or does not wish to own an issued patent on a

given INVENTION, and the United States Government or other sponsor

waives ownership rights, if any, the IPA may, after consultation with and

subject to the approval of the Vice Provost for Research, return all of the

University’s right, title and interest to the INVENTION, patent application

or issued patent to the INVENTORS, subject to any other rights retained

by the United States Government or other sponsors and subject to

and upon the terms and conditions set forth in Section 2.1.5.3. If the

INVENTION was made with sponsorship of the federal government, the

INVENTORS are responsible for obtaining written approvals from the

appropriate federal government representatives allowing the University

to transfer the University’s right, title and interest to the INVENTION to

the INVENTORS and providing such written approvals to PCI prior to any

return to the INVENTORS. If the INVENTION was made with sponsorship

of the federal government, to the extent applicable under then-current law,

the INVENTOR shall use reasonable efforts to arrange for development

and commercialization opportunities for the INVENTION, and otherwise

comply with all laws regarding the INVENTION and any additional

requirements imposed by the federal government when approving the

transfer to the INVENTORS.

2.1.5.3 Conditions Regarding Return of Inventions.

Prior to the University

transferring its right, title and interest to an INVENTION and any related

patent(s) and/or patent application(s), each INVENTOR and PCI shall

enter into a written agreement including at least the following terms:

2.1.5.3.1

If the University elects to return an INVENTION made by more

than one INVENTOR, the University will return an undivided interest in

the whole, as deﬁned by prevailing United States patent law, to each

INVENTOR, unless directed otherwise in writing by all INVENTORS.

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2.1.5.3.2

In every case in which an INVENTION is returned to an

INVENTOR, the University hereby reserves a royalty free, non-exclusive,

irrevocable right to practice the INVENTION for research, educational and

clinical care purposes, and to permit other academic institutions and not-

for-proﬁt research institutions to do the same. The University may seek

reimbursement for any INVENTION ASSESSMENT COSTS incurred before

the return from the INVENTOR. After the effective date of the return of

the INVENTION, the University shall not be responsible for paying any

ongoing INVENTION ASSESSMENT COSTS or other costs or expenses

in connection with the returned INVENTION and any patents or patent

applications for the returned INVENTION.

2.1.5.3.3

The INVENTOR or INVENTORS jointly and severally, shall pay

the University ﬁve percent (5%) of all GROSS COMPENSATION and report

non-conﬁdential information at least annually to PCI regarding efforts

to commercialize the returned INVENTION and GROSS COMPENSATION

received.

2.1.5.3.4

Each INVENTOR shall represent and warrant that the INVENTOR

has disclosed to PCI, as part of the INVENTION DISCLOSURE or

otherwise: the best mode contemplated by the INVENTOR for carrying

out the INVENTION; all facts and circumstances relevant to assessing

the INVENTION DISCLOSURE and INVENTION; and has answered each

question or inquiry from PCI about the INVENTION DISCLOSURE and

INVENTION truthfully, to the best of the INVENTOR’s knowledge and

belief.

2.1.5.3.5

INVENTORS have the obligation to disclose to the IPA, and

make ASSIGNMENT of, improvements on returned INVENTIONS at the

time such improvements are conceived or reduced to practice, if such

improvements are conceived or reduced to practice under circumstances

subject to the PATENT POLICY.

2.1.5.3.6

Each INVENTOR shall acknowledge that the transfer of

the University’s interest in the INVENTION may raise issues under

applicable University policies, including without limitation its conflict-

of-interest policies and restrictions on use of University facilities and

assets for private purposes and that the return of an INVENTION does not

constitute a waiver of any term in any University policy or its applicability

to the INVENTOR. The INVENTOR will agree not to use University

resources, personnel, time, facilities or assets to further develop, protect

or commercialize the returned INVENTION, unless permitted after review

by the University’s Conflict of Interest Standing Committee and approved

by the Vice Provost for Research.

2.1.5.3.7

Each INVENTOR will and will cause any licensees or

third persons participating in the development and commercialization

of the INVENTION, to indemnify the University from any claims arising

out of or resulting from or in connection with the INVENTION and its

development and commercialization. The University will transfer its right,

title and interest as is, without warranties.

2.2 Conveyance of Rights to Inventions.

2.2.1 Licensing.

The University may convey rights to its

INVENTIONS through license agreements under the terms of which the

University retains all right, title and interest in and to its INVENTIONS,

while granting to a commercial entity the right to make, use and/or sell

products based on the INVENTION(S).

2.2.1.1

INVENTORS or other University faculty or employees involved in

the licensing of an INVENTION to a prospective licensee shall disclose

any ﬁduciary or ﬁnancial interest in or contractual relationship with

the prospective licensee to their Deans and Chairs, or their relevant

administrative supervisor, in accordance with the applicable University

policy on conflicts of interest. In addition, INVENTORS or other University

faculty or employees involved in the licensing of an INVENTION to a

prospective licensee shall disclose any ﬁduciary or ﬁnancial interest

in that prospective licensee to the IPA, who shall refer consideration of

the matter to the EXECUTIVE COMMITTEE.

2.2.1.2

PCI will use reasonable efforts to notify INVENTORS of

prospective licensees in an early stage of the negotiation process. The

ﬁnal decision on whether to license an INVENTION, to whom to license an

INVENTION, the terms in the agreements and otherwise how to proceed

with the license rests with PCI and is not appealable to the APPEALS

BOARD or otherwise.

2.2.2 Exceptions to Licensing.

Exceptions to the requirement that rights

be conveyed through a license agreement shall be considered only in

extreme or unusual circumstances and shall require approval by the

President of the University.

2.3 Distributions.

(For a hypothetical illustration of the distributions set

forth in Sections 2.3.1 and 2.3.2, see Appendix C. Deﬁnitions for

ADJUSTED PCI REVENUES FOR AN INVENTION, NET PCI INCOME FOR

AN INVENTION and other key deﬁnitions are in Article 4).

2.3.1 Distribution of Adjusted PCI Revenues.

Unless otherwise required

by law or contract, ADJUSTED PCI REVENUES for the

INVENTION (deﬁned in Section 4.0.1, but generally described as the PRO

RATA SHARE of GROSS PCI REVENUES [deﬁned in Section 4.0.13] minus

the INITIAL DEDUCTION [deﬁned in Section 4.0.14]), shall be distributed

as follows:

2.3.1.1

The INVENTORS PERSONAL SHARE shall be thirty percent (30%)

of the ADJUSTED PCI REVENUES for the INVENTION (see Sec. 2.3.4).

2.3.1.2

The INVENTORS RESEARCH ACTIVITY SHARE shall be twelve

and one-half percent (12.5%) of the ADJUSTED PCI REVENUES for the

INVENTION (see Sec. 2.3.5).

2.3.2 Distribution of Net PCI Income.

NET PCI INCOME for the

INVENTION (deﬁned in Section 4.0.23, but generally described as the

amount remaining after distributions in Section 2.3.1, minus the PRO

RATA SHARE of AGGREGATE PCI OPERATING COSTS [deﬁned in Section

4.0.3]) shall be distributed as follows:

2.3.2.1

The SCHOOLS OF INVENTORS SHARE shall be sixty percent (60%)

of the NET PCI INCOME for the INVENTION (see Sec. 2.3.6).

2.3.2.2

The UNIVERSITY RESEARCH SHARE shall be forty percent (40%)

of the NET PCI INCOME for the INVENTION (see Sec. 2.3.7).

2.3.3 Allocation of the EQUITY POOL.

(Procedures governing

licensing transactions for EQUITY are set forth in Appendix B.) Under

license agreements for which the University has negotiated an EQUITY

POOL, where, in accordance with Appendix B.4, EQUITY will be issued

directly to the INVENTOR(S), the INVENTORS shall receive thirty percent

(30%) of the EQUITY POOL, unless one or more INVENTORS receive

EQUITY from the licensee outside of the EQUITY POOL. An INVENTOR

who receives EQUITY from the licensee outside of the EQUITY POOL

shall not receive EQUITY from the EQUITY POOL except with approval

of the University. The IPA shall make a recommendation in this regard

to the Vice Provost for Research, who shall make a determination

in consultation with the relevant Deans. Furthermore, if one or more

INVENTORS receive EQUITY outside of the EQUITY POOL, the portion

of the EQUITY POOL to be received by the other INVENTORS shall be

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reduced in proportion to the contribution to the licensed INVENTIONS, as

determined by PCI, made by the INVENTORS who receive EQUITY outside

of the EQUITY POOL.

2.3.3.1

INVENTORS receiving EQUITY from the EQUITY POOL or outside

the EQUITY POOL may also receive INVENTORS PERSONAL SHARE of

ADJUSTED PCI REVENUES FOR THE INVENTION. An exception to this

may arise in certain circumstances, such as when INVENTORS receive

founders EQUITY, EQUITY for consulting services or other consideration

from the licensee. In such cases, the University may determine that such

INVENTORS shall not receive some or any of the INVENTORS PERSONAL

SHARE of ADJUSTED PCI REVENUES for the INVENTION. The IPA shall

make a recommendation in this regard to the Vice Provost for Research,

who shall make a determination in consultation with the relevant Dean(s).

2.3.3.2 Non-cash Component of License.

Any tangible, noncash

considerations (except EQUITY) in licenses will be distributed by PCI on a

case-by-case basis, in consultation with the INVENTOR(S), Vice Provost

for Research and the relevant Dean(s).

2.3.4 Rules Governing the INVENTORS PERSONAL SHARE

The INVENTORS PERSONAL SHARE of ADJUSTED PCI

REVENUES for the INVENTION, under Section 2.3.1.1, shall be

distributed among all INVENTORS (if more than one), as the

INVENTORS unanimously designate in writing to the IPA. If the

INVENTORS fail to make such unanimous written designation before the

license agreement is executed, the INVENTORS PERSONAL SHARE of

ADJUSTED PCI REVENUES shall be distributed among all INVENTORS as

PCI, in its sole discretion, shall designate, and shall not be appealable to

the APPEALS BOARD. The INVENTORS share of the EQUITY POOL under

Section 2.3.3 shall be distributed among all INVENTORS entitled to share

in the EQUITY POOL (if more than one), as such INVENTORS unanimously

designate in writing to the IPA. If the INVENTORS entitled to share in the

EQUITY POOL fail to make such unanimous written designation before

the license agreement is executed, the INVENTORS share of the EQUITY

POOL shall be distributed among INVENTORS entitled to share in the

EQUITY POOL as PCI, in its sole discretion, shall designate, and shall not

be appealable to the APPEALS BOARD .

2.3.4.1

If an INVENTOR ceases employment at and association with the

University, the INVENTORS designated portion of the INVENTORS

PERSONAL SHARE of ADJUSTED PCI REVENUES under Section 2.3.1.1

and of the INVENTORS share of the EQUITY POOL under Section 2.3.3

shall remain payable to such INVENTOR. If an INVENTOR dies, the

INVENTORS designated portion of the INVENTORS PERSONAL SHARE

shall remain payable to the INVENTOR’s estate.

2.3.5 Rules Governing the Inventors Research Activity Share.

The

INVENTORS RESEARCH ACTIVITY SHARE, when the INVENTORS

are faculty, shall be used only for research purposes approved by the

department chair(s) of the relevant department(s).

2.3.5.1

The INVENTORS RESEARCH ACTIVITY SHARE shall be divided

among the INVENTORS (if more than one) in the same proportion as

the INVENTORS PERSONAL SHARE is divided among the INVENTORS

(the “DESIGNATED PROPORTION”), unless the INVENTORS unanimously

request in writing, and the dean(s) of the relevant school(s) and Vice

Provost for Research approve, some other distribution.

2.3.5.2

If a sole faculty INVENTOR is no longer employed by or

associated with the University, the INVENTORS RESEARCH ACTIVITY

SHARE shall be distributed to the INVENTOR’S school at the University

to support research in the school. If there is more than one faculty

INVENTOR, and one of those INVENTORS is no longer employed by or

associated with the University, that share shall be distributed evenly to

support the research activity of the INVENTORS who remain. If no faculty

INVENTORS remain employed by or associated with the University, the

INVENTORS RESEARCH ACTIVITY SHARE will be distributed to the

INVENTORS school(s) to support research in the school(s).

2.3.5.3

When an INVENTOR is an undergraduate student, the

INVENTORS RESEARCH ACTIVITY SHARE shall be distributed to the

University’s Center for Undergraduate Research and Fellowships

(CURF) or its successor organization, or if no successor organization,

to the Provost’s Ofﬁce to be used to further and support research by

undergraduate students, through a budget approved by the Provost.

When INVENTORS are graduate students or postdoctoral employees

or trainees, the corresponding INVENTORS RESEARCH ACTIVITY

SHARE shall be distributed to the laboratory to which they are primarily

assigned or in which they primarily conducted the research leading to

the INVENTION. If such INVENTORS do not have a primary laboratory

afﬁliation, their corresponding INVENTORS RESEARCH ACTIVITY SHARE

shall be distributed to their school. Amounts so distributed shall be used

to further the education and research activity of the INVENTOR while

at the University and/or for other research purposes through a budget

approved by the department chair(s) of the relevant department(s) or

dean.

2.3.5.4

When an INVENTOR is an emeritus faculty member at the time

of the INVENTION, the INVENTORS RESEARCH ACTIVITY SHARE shall

be distributed to the INVENTOR’S last school before assuming emeritus

status, unless that emeritus faculty INVENTOR, and the emeritus faculty

INVENTOR’s dean, agree in writing upon a different distribution. Such

different distribution may include, without limitation, payment of all or a

portion of such INVENTORS RESEARCH ACTIVITY SHARE to the emeritus

faculty as part of the INVENTORS PERSONAL SHARE. Any such proposed

different distribution of an INVENTORS RESEARCH ACTIVITY SHARE for

an emeritus faculty INVENTOR is subject to review and approval by the

Vice Provost for Research. The emeritus faculty INVENTOR may appeal

the inability to reach an agreement upon a different distribution, or any

disapproval by the Vice Provost for Research, to the APPEALS BOARD.

Amounts received by the school shall be used for research purposes only

through a budget approved by the dean(s) of the relevant school(s)..

2.3.6 Rules Governing the Schools of Inventors Share.

The SCHOOLS OF

INVENTORS SHARE may be used for any research purpose designated

by the dean(s) of the school(s). At the discretion of the dean(s), any

portion of the SCHOOLS OF INVENTORS SHARE may be distributed to

department(s), research centers, and/or research institutes to support

research. The dean(s) will develop a process within each school, that

is reasonably calculated to incentivize units, such as departments, to

support research at various stages of development.

2.3.6.1

If an INVENTION is made by INVENTORS from different schools,

the SCHOOLS OF INVENTORS SHARE shall be divided among the schools

in the DESIGNATED PROPORTION. A school will retain its portion of

SCHOOLS OF INVENTORS SHARE if an INVENTOR from that school is no

longer employed by or associated with the School or the University.

2.3.7 Rules Governing the University Research Share.

The UNIVERSITY

RESEARCH SHARE shall be used for the general support of research at

the University as determined by the Provost. The Provost will release

periodic reports describing the use of these funds.

2.3.8 Periodic Reports of Use of Funds to Support Research.

The deans

of each school that receive funds during the FISCAL YEAR as SCHOOLS

OF INVENTORS SHARES should submit a report to the Vice Provost for

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Research at least once during the subsequent FISCAL YEAR describing

the process to determine the distribution and use of these funds for

research purposes and the support of research.

2.3.9 Invention Revenue Distribution for Non-Academic Inventors.

When

an INVENTOR is other than a faculty member, emeritus faculty, employee

of an academic laboratory, student or postdoctoral employee or trainee,

the distribution of ADJUSTED PCI REVENUES FOR THE INVENTION (other

than the INVENTORS PERSONAL SHARE) and NET PCI INCOME for the

INVENTION shall be determined by the Vice Provost for Research on a

case-by-case basis with a recommendation from the IPA.

2.3.10 INVENTORS with Joint Appointments.

If an INVENTOR has

joint appointments in two or more schools and there is no

primary appointment (for example only, a Penn Integrates Knowledge

professor), the deans shall determine an equitable apportionment of that

INVENTOR’s portion of the INVENTORS RESEARCH ACTIVITY SHARE, and

SCHOOLS OF INVENTORS SHARE, unless the Deans of such schools had

previously agreed on an allocation for such INVENTOR.

2.4 Implementation of Procedures for Distributions.

2.4.1 Inventions Disclosed and Licensed After the Effective

Date.

Distributions from all INVENTIONS disclosed and licensed on

or after the EFFECTIVE DATE shall be governed by the procedures in

Section 2.3.

2.4.2 Inventions Disclosed Before the Effective Date but Licensed After

the Effective Date.

Distribution of income from all INVENTIONS disclosed

before the EFFECTIVE DATE, but not yet subject to a license agreement

as of the EFFECTIVE DATE, shall be governed by the procedures in

Section 2.3.

2.4.3 Inventions Disclosed and Licensed Before the Effective Date.

All

distributions during and after the FISCAL YEAR that the revised PATENT

POLICY becomes effective, including distributions for an INVENTION

whose disclosure or licensing was completed prior to the EFFECTIVE

DATE of the revised PATENT POLICY, will be made according to the

revised PATENT POLICY and shall thus be governed by the procedures in

Section 2.3.

2.5 Administration of Distributions and Reporting.

Distributions, with a

report outlining how the amounts were calculated, shall be made to each

recipient within sixty (60) days after the end of the FISCAL YEAR. PCI will

use reasonable efforts to distribute the INVENTORS PERSONAL SHARE

more frequently than once each year. The University will not pay interest

on amounts received and held by the University pending distribution.

2.6 Use of Outside Facilities.

Faculty members, employees or

students who use research facilities at another institution or a

corporation (including, without limitation, when on sabbatical from the

University or as visiting faculty or visiting researchers) shall contact

the IPA prior to commencing such use, for assistance in evaluating the

policies of the host institution or corporation as appropriate. Graduate

students who are conducting research in commercial research facilities

should obtain a written assurance of their right to publish the results of

their research. Faculty members, employees or students who engage

in outside employment or consulting agreements are referred to the

Consulting and Outside Activities Policies and Procedures of the

University of Pennsylvania (CONSULTING POLICY).

Article 3. Policy and Procedures Relating

to Tangible Research Property

3.0 Policy Statement on Tangible Research Property.

TANGIBLE

RESEARCH PROPERTY made by INVESTIGATORS in the course of

employment at the University, or work or research directly related to

professional, educational or employment responsibilities, or work or

research carried out on University time, or at University expense or

with SUBSTANTIAL USE OF UNIVERSITY RESOURCES under grants or

otherwise, is the property of the University. INVESTIGATORS hereby

irrevocably assign to the University all right, title and interest in and to

the TANGIBLE RESEARCH PROPERTY and shall cooperate fully with

the University in the preparation and prosecution of patents or other

intellectual property protection, if available and applicable. The University

and INVESTIGATORS will endeavor to make such property available to

the research community on a reasonable basis, consistent with other

University policies, procedures and legal obligations and pursuant to a

written agreement in a form approved by the Ofﬁce of General Counsel,

including but not limited to a materials transfer agreement, license

agreement, deposit to a research or data bank repository or other form of

agreement.

3.1 Disclosure to PCI.

INVESTIGATORS shall disclose new TANGIBLE

RESEARCH PROPERTY promptly to PCI.

3.2 Revenues from Transfer of Tangible Research Property.

Unless

otherwise required by law or contract, for TANGIBLE

RESEARCH PROPERTY which is deﬁned as an INVENTION, distributions

will be calculated in accordance with Section 2.3. For TANGIBLE

RESEARCH PROPERTY which is not deﬁned as an INVENTION,

distributions will be calculated as follows, unless otherwise required

by law or contract: PCI shall determine the GROSS PCI REVENUES for

the TANGIBLE RESEARCH PROPERTY. Then, PCI shall determine, in

conjunction with the INVESTIGATORS and the appropriate University

staff, the applicable TANGIBLE RESEARCH PROPERTY DIRECT

GENERATION COSTS. The TANGIBLE RESEARCH PROPERTY DIRECT

GENERATION COSTS shall be reimbursed to the University account(s)

of the INVESTIGATOR(S) and/ or such other school, department or other

accounts from which portions of the TANGIBLE RESEARCH PROPERTY

DIRECT GENERATION COSTS were paid. The amount remaining, if

any, after deducting the TANGIBLE RESEARCH PROPERTY DIRECT

GENERATION COSTS from the GROSS PCI REVENUES for the TANGIBLE

RESEARCH PROPERTY, and after deducting the applicable INITIAL

DEDUCTION, shall be deﬁned as the ADJUSTED PCI REVENUES for such

TANGIBLE RESEARCH PROPERTY. The ADJUSTED PCI REVENUES for the

TANGIBLE RESEARCH PROPERTY or NET PCI INCOME for the TANGIBLE

RESEARCH PROPERTY (as the case may be) shall be distributed in

accordance with Section 2.3 above (substituting the INVESTIGATOR(S)

for the INVENTOR(S) and the TANGIBLE RESEARCH PROPERTY for the

INVENTION, where application in applying this PATENT POLICY):

3.2.1

Thirty percent (30%) of ADJUSTED PCI REVENUES for the

TANGIBLE RESEARCH PROPERTY as the INVESTIGATORS PERSONAL

SHARE (see Sec. 2.3.1.1).

3.2.2

Twelve and one-half percent (12.5%) of ADJUSTED PCI

REVENUES for the TANGIBLE RESEARCH PROPERTY as the

INVESTIGATORS RESEARCH ACTIVITY SHARE (see Sec. 2.3.1.2).

3.2.3

Sixty percent (60%) of NET PCI INCOME for the TANGIBLE

RESEARCH PROPERTY as the SCHOOLS OF INVENTORS SHARE (see

Sec. 2.3.2.1).

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III.E. Patent and Tangible Research Property Policies and Procedures

3.2.4

Forty percent (40%) of NET PCI INCOME for the TANGIBLE

RESEARCH PROPERTY as the UNIVERSITY RESEARCH SHARE (see Sec.

2.3.2.2).

3.3. Program Income and Sponsored Awards.

INVESTIGATORS and PCI

shall report any GROSS PCI REVENUES from TANGIBLE RESEARCH

PROPERTY to the Ofﬁce of Research Services for a determination

whether such revenues must be reported to a funding agency or

sponsor as program income. In those circumstances in which GROSS

PCI REVENUES from the TANGIBLE RESEARCH PROPERTY may be

considered program income under federal law, or grant, award or contract

terms, or where the distribution formula set forth in Section 3.2. would be

prohibited by law or applicable contract, the UNIVERSITY will equitably

share any ADJUSTED PCI REVENUES for such TANGIBLE RESEARCH

PROPERTY, if any, while remaining in compliance with its legal obligation.

Article 4. Deﬁnitions and Miscellaneous

4.0.1 TOTAL ADJUSTED PCI REVENUES

means GROSS PCI REVENUES

minus the INITIAL DEDUCTION.

ADJUSTED PCI REVENUES FOR AN

INVENTION

means the PRO RATA SHARE of the TOTAL ADJUSTED PCI

REVENUES.

4.0.2 ADJUSTED PROCEEDS FOR AN INVENTION

means ADJUSTED

PCI REVENUES FOR AN INVENTION, minus the INVENTORS PERSONAL

SHARE and minus the INVENTORS RESEARCH ACTIVITY SHARE.

4.0.3 AGGREGATE PCI OPERATING COSTS

means all of PCI’s internal or

out-of-pocket expenses to operate PCI, as allocated to and determined

by the University, during a FISCAL YEAR, including, without limitation:

salaries, beneﬁts and other personnel costs; expenses related to

licensing and distribution, and attempts to license and/or distribute,

INVENTIONS, TANGIBLE RESEARCH PROPERTY, copyrightable works,

and trademarks; fees and expenses paid to third persons (excluding

REIMBURSED IP EXPENSES); overhead expense; ﬁnder’s fees or

commissions; EQUITY or other consideration paid or due to patent

management organizations; expenses in connection with the sale,

investment or management of EQUITY or the EQUITY POOL; litigation

or dispute resolution costs and expenses; and consideration paid or

due third persons as a result of settlement of or judgment in a dispute;

applicable taxes (if any) and other operating expenses the University

allocates to PCI. AGGREGATE PCI OPERATING COSTS includes all

UNREIMBURSED IP EXPENSES.

4.0.4 APPEALS BOARD

is empowered to resolve disputes arising from the

interpretation or administration of this PATENT POLICY, as described in

Section 4.2. The APPEALS BOARD comprises nine (9) voting members

(seven [7] standing members and two [2] ad hoc members). The seven

standing members shall be comprised of: one (1) voting chair, appointed

by the Faculty Senate and who shall be a Standing Faculty member; four

(4) administrators (each appointed by the Vice Provost for Research);

and two (2) term faculty appointed by the Faculty Senate. The two (2)

ad hoc members shall be faculty selected for expertise by the dean(s)

of the relevant school(s) or the chair(s) of the relevant departments(s),

except that if one or more of the individuals involved in the appeal is an

emeritus faculty, the two ad hoc voting members selected by the dean(s)

or department chair(s) shall be emeritus faculty and if one or more of the

individuals involved in the appeal is a graduate student, the two ad hoc

voting members selected by the dean(s) or department Chair(s) shall be

graduate students. In addition, the APPEALS BOARD shall include one

nonvoting member ex ofﬁcio, who shall be an attorney from the Ofﬁce of

General Counsel and appointed by the General Counsel. The APPEALS

BOARD shall be staffed by the Ofﬁce of the Vice Provost for Research.

4.0.5 ASSIGNMENT

means the execution of a written agreement by an

INVENTOR assigning all of the INVENTOR’S right, title and interest in and

to an INVENTION or TANGIBLE RESEARCH PROPERTY. INVENTIONS are

deemed automatically and irrevocably assigned, effective as of the time

they are conceived or reduced to practice, regardless of whether or when

such individual executes a PARTICIPATION AGREEMENT or other written

agreement conﬁrming assignment.

4.0.6 PENN CENTER FOR INNOVATION (PCI)

means the administrative

unit, under the direction of the INTELLECTUAL PROPERTY

ADMINISTRATOR, which is responsible for the receipt, review,

management and administration of intellectual property matters of the

University.

4.0.7 EFFECTIVE DATE

means the earlier of October 1, 2023, or the date

this version of this PATENT POLICY was adopted by the Trustees of the

University.

4.0.8 EQUITY

means ownership interests or securities, including but

not limited to shares of stock or securities; stock options; warrants

or any other rights to purchase stock or securities; debt instruments;

partnership interests in a general or limited partnership; or membership

interests in a limited liability company or partnership.

4.0.9 EQUITY POOL

means the total allotment of EQUITY negotiated by

the University as consideration for a license of the University’s interests

in an INVENTION or TANGIBLE RESEARCH PROPERTY.

4.0.10 EXECUTIVE COMMITTEE

provides oversight and steering of the

technology transfer process, including assisting in setting the operating

budget for the PCI. The EXECUTIVE COMMITTEE is appointed by the

Provost in consultation with the Vice Provost for Research and chaired

by the Vice Provost for Research or a Dean designated by the Vice

Provost for Research. The EXECUTIVE COMMITTEE is comprised of the

INTELLECTUAL PROPERTY ADMINISTRATOR, ex ofﬁcio; the Vice Provost

for Research; the dean of the Perelman School of Medicine or the Dean’s

designee; one faculty from each of the School of Arts and Sciences and

the School of Engineering and Applied Science; one at-large faculty;

and an attorney from the Ofﬁce of the General Counsel selected by the

General Counsel, who shall be non-voting and ex ofﬁcio.

4.0.11 FISCAL YEAR

means the period from July 1 through June 30

(or, should the University adjust its ﬁscal year, the same period as

the University’s then-current ﬁscal year for federal tax purposes).

4.0.12 GROSS COMPENSATION

means all cash or other

compensation received or to which someone is entitled due to or arising

out of or related to or in connection with the licensing, sale, development,

commercialization or other exploitation of the INVENTION, including

without limitation royalties, sales receipts, upfront payments, option fees,

milestone payments, equity proceeds, other securities or investments,

infringement or settlement proceeds or other forms of monetization or

compensation.

4.0.13 GROSS PCI REVENUES

means all gross revenues actually received

by PCI during the FISCAL YEAR from all agreements arising out

of or related to or in connection with the licensing, development,

commercialization or other exploitation of an INVENTION or TANGIBLE

RESEARCH PROPERTY, or intellectual property related to an INVENTION

or TANGIBLE RESEARCH PROPERTY, whether involving patents, know-

how, trademarks, copyrights and/or other forms of intellectual property,

but excluding: (1) payments made to the University under sponsored

research agreements or research awards, grants and contracts; (2)

revenues payable to a third party sponsor or funder pursuant to a funding

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agreement, where performance of the sponsored or funded research

directly gave rise to the INVENTION or TANGIBLE RESEARCH PROPERTY;

(3) revenues related to the licensing of a University or Penn Medicine

trademark (e.g., trademark royalties in connection with Penn-branded

apparel, etc.) and unrelated to the licensing, development or other

exploitation of an INVENTION or TANGIBLE RESEARCH PROPERTY; (4)

consideration payable to a university or other third party related to co-

inventor(s) or contributors to INVENTIONS or TANGIBLE RESEARCH

PROPERTY having a duty to assign to such university or other third

party (for example only, revenues payable to another institution due to

joint inventorship or inter-institutional arrangements); and (5) accrued

interest. GROSS PCI REVENUES includes, without limitation: license fees;

license maintenance fees; minimum royalties; sublicense payments;

milestone payments; option fees; royalties on sales of products and

services; proceeds realized from the sale or other disposition of EQUITY

from an EQUITY POOL; dividends and other monetary distributions

related to EQUITY from an EQUITY POOL; and settlements of lawsuits or

intellectual property disputes with third parties related to an INVENTION

DISCLOSURE, INVENTION or TANGIBLE RESEARCH PROPERTY. GROSS

PCI REVENUES does not include REIMBURSED IP EXPENSES.

4.0.14 INITIAL DEDUCTION

means a percentage of GROSS

PCI REVENUES for an INVENTION, and a percentage of GROSS

PCI REVENUES for TANGIBLE RESEARCH PROPERTY which is not

deﬁned as an INVENTION, in each case where such percentage is

approved by the EXECUTIVE COMMITTEE. The percentage amount of

the INITIAL DEDUCTION will be reviewed and may be adjusted, at least

once each ﬁve (5) years, by the EXECUTIVE COMMITTEE. The EXECUTIVE

COMMITTEE may recommend adjusting the INITIAL DEDUCTION

percentage to an amount no greater than twenty ﬁve percent (25%) and

not less than zero percent (0%) for INVENTIONS and/or to an amount no

greater than seven percent (7%) and not less than zero percent (0%) for

TANGIBLE RESEARCH PROPERTY which is not deﬁned as an INVENTION.

Any adjustment to the INITIAL DEDUCTION recommended by the

EXECUTIVE COMMITTEE and approved by the President will take effect

as of the ﬁrst day of the FISCAL YEAR following the President’s approval

and will be announced broadly prior to the start of such FISCAL YEAR,

unless the adjustment beneﬁts the faculty and the schools in which case

the change can be implemented at any time during the FISCAL YEAR.

Effective as of July 1, 2023, INITIAL DEDUCTION means zero percent (0%)

of GROSS PCI REVENUES for an INVENTION, and zero percent (0%) of

GROSS PCI REVENUES for TANGIBLE RESEARCH PROPERTY which is not

deﬁned as an INVENTION.

4.0.15 INTELLECTUAL PROPERTY ADMINISTRATOR (IPA)

means

the Executive Director of PCI (or Executive Director’s successor, as

designated by the Vice Provost for Research).

4.0.16 INVENTION

means and includes discoveries and inventions

and related technical information, trade secrets, developments,

knowhow, methods, techniques, formulae, data and processes; TANGIBLE

RESEARCH PROPERTY upon which a patent has issued, or a patent

application has been ﬁled and is still pending; and other proprietary

matter.

4.0.17 INVENTION DISCLOSURE

means the written submission to the

IPA, on standard invention disclosure forms available from PCI, of a

written description of any INVENTION that an INVENTOR believes the

INVENTOR has made.

4.0.18 INVENTORS

means University faculty, emeritus faculty, visiting

faculty or researchers, adjunct faculty, postdoctoral employees or

trainees, or other employees, or students, or others who individually or

jointly make an INVENTION subject to the PATENT POLICY and who

meet the criteria for inventorship under United States patent laws and

regulations.

4.0.19 INVENTION ASSESSMENT COSTS

means all historic out-of-

pocket costs and expenses related to the review, assessment and

protection of the INVENTION DISCLOSURE and the INVENTION, including

without limitation patent and copyright application costs and expenses,

legal fees, ﬁling fees, search fees, fees for legal opinions, patent fees, IP

EXPENSES, and other out-of-pocket transactional costs attributable to

the INVENTION DISCLOSURE and the INVENTION.

4.0.20 INVESTIGATOR

means any University faculty member, emeritus

faculty, visiting faculty or researcher, adjunct faculty, postdoctoral

employee or trainee, or other employee, or an undergraduate or graduate

student engaged in sponsored or unsponsored research.

4.0.21 IP EXPENSES

means all out-of-pocket expenses incurred

or accrued during the FISCAL YEAR by PCI arising out of or related to or

in connection with the review, assessment, protection, licensing, defense,

enforcement or audit of intellectual property rights related to INVENTION

DISCLOSURES, INVENTIONS, TANGIBLE RESEARCH PROPERTY and

copyrightable works, or the defense, enforcement or audit of licenses or

other agreements related to INVENTION DISCLOSURES, INVENTIONS,

TANGIBLE RESEARCH PROPERTY or copyrightable works, including but

not limited to: outside legal and patent agent fees and expenses; search

fees and expenses; application fees; fees for legal opinions; government

ﬁling and maintenance fees; legal fees to defend or enforce intellectual

property, license agreements, option agreements, conﬁdentiality

agreements, or other agreements related to the INVENTION DISCLOSURE,

INVENTION, TANGIBLE RESEARCH PROPERTY or copyrightable work;

fees and expenses to audit licensees and related agreements; and

other out-of-pocket transactional costs related to patent, copyright,

trademark and other intellectual property protection or licensing

anywhere in the world.

REIMBURSED IP EXPENSES

means IP EXPENSES

for which PCI received or accrued payment or reimbursement from a

licensee, INVENTOR or third person before the end of the FISCAL YEAR.

UNREIMBURSED IP EXPENSES

means all of the IP EXPENSES minus

the REIMBURSED IP EXPENSES at the end of the FISCAL YEAR, as

shown in the accounting records of PCI (excluding accrued payments or

reimbursements).

4.0.22 MATERIALS

means lab notebooks, records, drawings, sketches,

photographs, radiographs or other images, models, biological specimens,

chemical samples or other materials needed to support the preparation,

submission, prosecution, defense or enforcement of a patent in the

United States or other applicable jurisdictions.

4.0.23 NET PCI INCOME FOR AN INVENTION

means the

ADJUSTED PROCEEDS FOR AN INVENTION, minus the PRO RATA SHARE

of the AGGREGATE PCI OPERATING COSTS. If zero or a negative number,

then there is no NET PCI INCOME FOR AN INVENTION. (As an example, if

the ADJUSTED PROCEEDS FOR AN INVENTION equals $273,125, the PRO

RATA SHARE is ﬁve percent (5%), and the AGGREGATE PCI OPERATING

COSTS equals $4,500,000, the NET PCI INCOME FOR AN INVENTION

equals [$273,125 minus (0.05 x $4,500,000)], or $48,125).

4.0.24 PATENT POLICY

means this Patent and Tangible Research

Property Policies and Procedures of the University of Pennsylvania,

with any amendments.

4.0.25 PARTICIPATION AGREEMENT

means a written agreement

substantially in the form of Appendix A to the PATENT POLICY, setting out

rights and responsibilities of University faculty, emeritus faculty, visiting

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III.E. Patent and Tangible Research Property Policies and Procedures

faculty and researchers, adjunct faculty, postdoctoral employees and/

or other salaried employees, students and others under the University’s

policies and procedures, and conﬁrming the automatic assignment of

ownership of INVENTIONS covered under the PATENT POLICY, to the

University.

4.0.26 PRO RATA SHARE

means the ratio (expressed as a percentage) of

the GROSS PCI REVENUES directly generated by and attributable to an

INVENTION and/or TANGIBLE RESEARCH PROPERTY, as determined

by PCI, compared to the entire GROSS PCI REVENUES, during a FISCAL

YEAR. (As an example, if the GROSS PCI REVENUES directly generated by

and attributable to an INVENTION total $600,000 in a FISCAL YEAR and

the GROSS PCI REVENUES total $12,000,000 in a FISCAL YEAR, the PRO

RATA SHARE is ﬁve percent (5%).)

4.0.27 SIGNIFICANT EQUITY INTEREST

means any EQUITY or other

ﬁnancial interest that when aggregated for the individual and the

individual’s spouse and dependent children exceeds $25,000 in value,

as determined through reference to public prices or other reasonable

measures of fair market value and does not represent more than ﬁve

percent (5%) ownership interest in any single entity.

4.0.28 STAKEHOLDERS

means shareholders, owners, members, general

partners, limited partners or other owners or investors in an entity.

4.0.29 SUBSTANTIAL USE OF UNIVERSITY RESOURCES

means the use

of University funds, facilities, equipment, or other resources signiﬁcantly

in excess of the norm for educational or research purposes in the

department or school in which the faculty member(s) holds their primary

appointment(s) or in which a staff member or student is enrolled or

employed. Academic year salary, ofﬁce, usual library resources, usual

secretarial and administrative staff resources or usual computer

equipment, among other things, are not regarded as constituting

“substantial use of University resources.” Any question about what

constitutes substantial use of University resources should be referred to

the Vice Provost for Research.

4.0.30 TANGIBLE RESEARCH PROPERTY

means unique research

products or tools, such as biological materials or chemical moieties,

whether or not patentable or otherwise protectable using intellectual

property laws. Categories of biological material include organisms, cells,

viruses, cell products, cloned DNA, as well as DNA sequences, mapping

information and crystallographic coordinates. Some speciﬁc examples

of biological materials include specialized and/or genetically deﬁned

cells, including normal and diseased human cells; monoclonal cell lines;

hybridoma cell lines; microbial cells and products; viruses and viral

products; recombinant nucleic acid molecules; DNA probes; nucleic acid

and protein sequences; and transgenic mice or other animals. Categories

of chemical moieties or engineered products include sample compounds,

reagents, intermediates, models, sensors, devices, equipment, computer

hardware or ﬁrmware, diagrams or computer media.

4.0.31 TANGIBLE RESEARCH PROPERTY DIRECT GENERATION

COSTS

means all of the documented and veriﬁable direct costs and

expenses attributable or allocated to the generation of the quantities of

TANGIBLE RESEARCH PROPERTY distributed which led to the receipt

of GROSS PCI REVENUES from such TANGIBLE RESEARCH PROPERTY.

As an example, only the costs of raw materials, supplies, reagents,

specialized equipment, and other direct costs and expenses necessary

to generate the quantity of TANGIBLE RESEARCH PROPERTY constitutes

TANGIBLE RESEARCH PROPERTY DIRECT GENERATION COSTS.

Salaries, overhead and equipment which is otherwise used for teaching

or numerous research purposes is not part of TANGIBLE RESEARCH

PROPERTY DIRECT GENERATION COSTS. (Any disagreement among

the INVESTIGATORS and PCI regarding the calculation of TANGIBLE

RESEARCH PROPERTY DIRECT GENERATION COSTS may be appealed to

the APPEALS BOARD).

4.1 Review of Policies and Procedures.

The EXECUTIVE COMMITTEE

together with the Vice Provost for Research shall review the PATENT

POLICY (including Appendix B), from time to time to determine whether

it is accomplishing its intended purposes and is in conformity with

applicable laws and regulations, including intellectual property laws. The

EXECUTIVE COMMITTEE shall make recommendations for amendments

or other changes to the Provost and the Faculty Senate, who shall confer

with the President. The President may amend the PATENT POLICY

including but not limited to an adjustment to the INITIAL DEDUCTION,

upon consultation with the Faculty Senate, and the Vice Provost for

Research.

4.2 Disputes Under Policies and Procedures.

Except as expressly

set forth otherwise in this PATENT POLICY, disputes arising from the

interpretation or administration of the PATENT POLICY may be referred

by any interested party to the Chair of the APPEALS BOARD and the

Ofﬁce of the Vice Provost for Research, who will promptly notify the IPA.

The APPEALS BOARD shall ﬁrst determine whether it has jurisdiction to

hear any such dispute before proceeding. The APPEALS BOARD shall

provide an equitable mechanism for the review and resolution of disputes

brought before it and shall have the authority to make a judgment with

respect to such disputes. The APPEALS BOARD shall use reasonable

efforts to make a judgment with respect to any dispute within thirty

(30) days after having any such dispute referred to it. Any judgment of

the APPEALS BOARD may be appealed by any interested party to the

Vice Provost for Research. The Vice Provost for Research shall consider

the matter de novo and shall use reasonable efforts to review any such

appeal and make a judgment with respect to any appeal, within thirty (30)

days after having any such dispute referred to them. Any judgment of

the Vice Provost for Research may be appealed to the President, who will

make a ﬁnal decision for the University.

4.3 No Change to Relationships.

Nothing in this PATENT POLICY or the

actions taken in connection with INVENTIONS, TANGIBLE RESEARCH

PROPERTY or EQUITY, is intended to or shall be interpreted or deemed to

create a ﬁduciary, trust or agency relationship between the University or

any of its units or personnel, and any faculty, staff, student or INVENTOR.

Appendix A. Participation Agreement

In order that the University may fulﬁll legal and contractual obligations to

sponsors of research, including but not limited to the federal government,

and in consideration of my employment by the University, or my

participation in sponsored research, or my use of funds, facilities, or other

resources provided by the University, I hereby agree as follows:

I have read, and I understand and agree that I am bound by, the

terms of the Patent and Tangible Research Property Policies and

Procedures of the University of Pennsylvania, as well as by the terms

of any revisions or amendments adopted by the President and/or the

Trustees of the University of Pennsylvania (collectively, the “PATENT

POLICY”), effective retroactively to the ﬁrst date of my employment,

appointment or matriculation, and/or participation in sponsored

research and/or SUBSTANTIAL USE OF UNIVERSITY RESOURCES

(“Start Date”). I understand that words appearing as all capitalized

letters in this Agreement are used as deﬁned in the PATENT POLICY.

I agree to promptly and completely report to the INTELLECTUAL

PROPERTY ADMINISTRATOR (“IPA”) any INVENTION which is

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University of Pennsylvania Faculty Handbook

conceived or reduced to practice in the course of my employment

at the University, or from work directly related to professional

or employment responsibilities at the University, or from work

carried out on University time, or at University expense, or with

SUBSTANTIAL USE OF UNIVERSITY RESOURCES under grants

or otherwise.

I hereby irrevocably assign to The Trustees of the

University of Pennsylvania all right, title and interest in and to any

and all such INVENTIONS, effective retroactively to my Start Date.

I acknowledge that any TANGIBLE RESEARCH PROPERTY, whether

or not patentable, which is made in the course of employment at the

University or from work directly related to professional or employment

responsibilities at the University, or from work carried out on

University time, or at University expense, or with SUBSTANTIAL

USE OF UNIVERSITY RESOURCES under grants or otherwise is the

property of the University.

I hereby irrevocably assign to The Trustees

of the University of Pennsylvania all right, title and interest in and

to any and all such TANGIBLE RESEARCH PROPERTY, effective

retroactively to my Start Date.

I understand that the University incurs binding obligations

to sponsors, including the federal government, companies or

foundations, under the terms of sponsored research, or grant

agreements. When I participate in research, I understand that it is

my responsibility to ascertain and abide by the terms of the research

agreement as it relates to me. In particular, when engaged in outside

activity, such as consulting, I recognize my duty to protect the

University’s obligations to its research sponsors and funders and the

University’s rights pursuant to the PATENT POLICY.

I also understand that agreements or grants governing sponsored

programs in which I participate may provide that the sponsor may

acquire rights to copyrightable works produced under the program.

In such cases, the University will own all right, title and interest to

the copyrightable works created under such sponsored program

and

I hereby irrevocably assign to The Trustees of the University of

Pennsylvania all right, title and interest I might otherwise have or

acquire in and to the copyrights in such works.

I will cooperate fully with the University in the preparation, ﬁling

and prosecution of patents, in the registration of copyrights and

in the preparation and execution of all documents necessary or

incidental thereto, including but not limited to any additional written

assignments deemed desirable by the University to further evidence

my legal assignment of ownership or otherwise facilitate protection

of the intellectual property or the establishment of the federal

government’s rights in inventions funded by the federal government.

I accept the provisions for the sharing of amounts and EQUITY in

the PATENT POLICY and, if applicable to me, the then-current Policy

Relating to Copyrights and Commitment of Effort for Faculty (the

“Copyright Policy”).

I am under no obligation to any person, organization, or corporation

with respect to any INVENTION(S), TANGIBLE RESEARCH PROPERTY

or copyrightable materials which are, or could be reasonably be

construed to be, in conflict with this Agreement, except as set forth in

writing in the signed attachment to this letter (if any).

This Agreement and the assignments and obligations are effective

as of my Start Date and apply to any INVENTION(S), TANGIBLE

RESEARCH PROPERTY, and copyrightable materials made during the

time I am employed by the University, hold an appointment, continue

to matriculate, participate in sponsored research, or otherwise make a

SUBSTANTIAL USE OF UNIVERSITY RESOURCES.

Signature: ________________________________________

Printed

Name: _____________________________________

Penn ID: _________________________________________

Date: ____________________________________________

Appendix B. Rules Governing EQUITY

Transactions

B.1 Licenses in Consideration of EQUITY.

The principal purpose of

licensing by the University is to promote the development of technologies

to serve the public interest. If after a diligent effort to identify prospective

licensees, the IPA determines that the public interest is best served by a

license in consideration of EQUITY, the IPA may negotiate such a license

on behalf of the University, following consultation with the Vice Provost

for Research, the INVENTORS, the General Counsel (or the General

Counsel’s designee), the Treasurer (or the Treasurer’s designee) and the

University Conflict of Interest Standing Committee. The IPA should be

satisﬁed that the licensee can demonstrate management and technical

capability and that it has the ﬁnancial resources necessary to meet

its developmental objectives and its obligations to the University. The

IPA may accept EQUITY in the licensee for the University in lieu of or in

addition to license or other fees, provided that the EQUITY represents a

fair valuation for the technology. The IPA shall include in each license

measures of performance that must be met in order to maintain the

license granted by the University.

B.2 Disclosure of EQUITY.

The University will require the prospective

licensee to disclose all EQUITY offered to the University (and other

institutions or individuals which may co-own an INVENTION with the

University) in consideration for the license agreement. In addition, the

prospective licensee will be required to disclose in writing to the IPA

and the Treasurer the speciﬁc terms and conditions associated with

such EQUITY and the current and pro forma capital structure of the

venture. Furthermore, the prospective licensee and the INVENTORS must

disclose to the IPA and the Treasurer in writing the EQUITY to be issued to

INVENTORS for their role as founders, consultants or otherwise.

B.3 Conflicts of Interest in License Agreements Involving

EQUITY.

License agreements involving EQUITY must be structured to

protect the University and faculty members from liability and to avoid

conflicts of interest. Prior to the University executing any agreement,

the INVENTOR(S) shall disclose to the IPA and the University Conflict

of Interest Standing Committee, any existing or proposed consulting

agreement between the INVENTOR(S) and the prospective licensee or any

other consulting agreements with other entities that have potential for

conflicts of interest. Upon the recommendation of the Vice Provost for

Research, the University and the relevant deans may impose limitations

on the proposed license agreement, associated sponsored research

agreement, consulting agreement between the INVENTOR and the

licensee or other agreements. In addition, the University, deans or chairs

may create an oversight mechanism for the relevant INVENTORS.

B.3.1 Board Participation and Fiduciary Roles.

In general, the University

will not accept a position on the board of directors (or other comparable

governing entity) of the licensee but may accept and exercise observer

rights on such boards or comparable governing entities. Exceptions

to this policy require the approval of the Executive Vice President of

the University in consultation with the IPA and the General Counsel.

As a matter of policy, INVENTORS may not serve on the board of

directors (or other comparable governing entity) of the licensee or in any

other ﬁduciary capacity. In general, INVENTORS may accept a seat on

scientiﬁc advisory boards providing that membership on such a board

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III.F. Policy on Conflicts of Interest Related to Research

does not create a ﬁduciary responsibility to the licensee or any of its

STAKEHOLDERS.

B.3.2 Minority Ownership.

The INVENTORS (and members of their

families) together may not be majority STAKEHOLDERS of the venture at

the time that the license agreement is negotiated and thereafter.

B.3.3 Licensee Representation.

In license negotiations with

the University, the prospective licensee must be represented by a party

other than an INVENTOR or a member of the INVENTOR’S family.

B.4 University versus

Direct Personal Ownership of EQUITY.

EQUITY

allocated to INVENTORS from the EQUITY POOL generally will be issued

directly to the University. INVENTORS may request in writing that such

EQUITY be issued directly to them at the time the EQUITY is issued if

reasonably feasible, which will be considered by the IPA in consultation

with the INVENTORS. The INVENTORS will be responsible for retaining

their own business advisors, legal counsel and tax counsel. INVENTORS

are responsible for all ﬁnancial, tax and legal consequences related to

the EQUITY they receive. The University Conflict of Interest Standing

Committee reserves the right to require that any EQUITY issued to

INVENTORS by the licensee be held in a “blind trust” for a deﬁned

period of time. An INVENTOR who receives EQUITY from the EQUITY

POOL or from the licensee outside of the EQUITY POOL generally will

receive a reduced INVENTORS PERSONAL SHARE of ADJUSTED PCI

REVENUES for the INVENTION, pursuant to Section 2.3.3.1 above,

to avoid an unintended incentive to structure transactions whereby

the INVENTORS retain 100% of the proceeds from their share of the

EQUITY POOL and obtain 30% of the proceeds to the University when the

University liquidates EQUITY held by the University. The University may

agree to accept all shares of the EQUITY POOL including INVENTORS

shares, provided that all INVENTORS and other institutions release the

University in writing from any liability associated with the management,

investment and ownership of the EQUITY. When the University accepts

shares of the EQUITY POOL including INVENTORS shares, the Investment

Board of the University will control the EQUITY and make all decisions

regarding the management, investment and ownership of the EQUITY, in

its sole discretion. Any income received by the University from EQUITY

held on behalf of INVENTORS will be distributed among INVENTORS

in accordance with Section 2.3.4 of the Patent and Tangible Research

Policies and Procedures.

B.5 Management of EQUITY.

Any EQUITY received by the University under

a license agreement will be held by the Ofﬁce of the Treasurer until such

time that the University’s Investment Board decides to liquidate such

EQUITY.

Appendix C: Hypothetical Example

GROSS PCI REVENUES

for FY 2022 equals $12,000,000.

GROSS PCI REVENUES

for FY 2022 attributable to the XYZ INVENTION

equals $600,000.

The

PRO RATA SHARE

equals 5% ($600,000 divided into $12,000,000

equals 0.05).

The

INITIAL DEDUCTION

equals 5% of GROSS PCI REVENUES, or

$600,000 (0.05 times $12,000,000 equals $600,000). Thus,

TOTAL

ADJUSTED PCI REVENUES

equals $11,400,000 ($12,000,000 minus

the

INITIAL DEDUCTION

of $600,000 equals $11,400,000).

The

PRO RATA SHARE

of the

INITIAL DEDUCTION

attributable to the XYZ

INVENTION equals $30,000 (0.05 times $600,000 equals $30,000).

Thus, the

ADJUSTED PCI REVENUES for the XYZ INVENTION

equals

$570,000 ($600,000 minus $30,000 equals $570,000).

The

INVENTORS PERSONAL SHARE

equals 30% of ADJUSTED PCI

REVENUES for the XYZ INVENTION,

$171,000 ($570,000 times 0.3

equals $171,000).

The

INVENTORS RESEARCH ACTIVITY SHARE

equals 12.5%

ADJUSTED PCI REVENUES

for the XYZ INVENTION, or $71,250

($570,000 times 0.125 equals $71,250).

The

ADJUSTED PROCEEDS

for the XYZ INVENTION equals $327,750

($570,000 minus $171,000 and minus $71,250).

AGGREGATE PCI OPERATING COSTS

for FY 2022 equals $4,500,000.

The

PRO RATA SHARE

of AGGREGATE PCI OPERATING

COSTS

attributable to the XYZ INVENTION equals $225,000 (0.05 times

$4,500,000 equals $225,000).

Thus, the

NET PCI INCOME

for the XYZ INVENTION equals $102,750

($327,750 minus $225,000).

The

SCHOOLS OF INVENTORS SHARE

equals 60% of the

NET PCI

INCOME

for the XYZ INVENTION, or $61,650 ($102,750 times 0.6 equals

$61,650).

The

UNIVERSITY RESEARCH SHARE

equals 40% of the

NET PCI

INCOME

for the XYZ INVENTION, or $41,100 ($102,750 times 0.4 equals

$41,100).

III.F. Policy on Conflicts of Interest

Related to Research

(Source: Vice Provost for Research,

Almanac, October 17, 2017

(

https://

almanac.upenn.edu/uploads/media/101717-supp.pdf

); revised, Ofﬁce of

the Provost, November 21, 2022)

Introduction

As an institution committed to academic excellence, innovative research,

and the highest quality clinical care, the University of Pennsylvania

consistently generates new knowledge with the potential to link theory

with practice in ways that enhance and transform our society. Penn’s

dedication to excellence, discovery, and collaboration lead our faculty,

students, and staff to opportunities for engaging the world around us.

We support an environment in which faculty and staff are able to pursue

teaching, research, and patient care responsibilities in ways that enrich

their work and further the University’s mission. Faculty involvement with

external entities—in academia, government, the nonproﬁt sector, and

industry—offers many positive beneﬁts consistent with the University’s

goals, including the practical application of new scientiﬁc discoveries and

the ability to obtain research funding.

We must recognize, however, that these opportunities also introduce the

potential for conflicts of interest that could affect one’s responsibilities

and activities as a member of the Penn community. Involvement with

external entities may create the risk that these relationships could

bias the work performed by our faculty. Identifying, understanding,

and responding to conflicts of interest are of primary importance to

protecting the credibility and objectivity of our work, the professional

reputations of our faculty and staff, and respect for the role of the

University as educator, care-giver, and researcher.

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University of Pennsylvania Faculty Handbook

The purpose of this policy is to set forth the framework for identifying,

evaluating, and managing ﬁnancial conflicts of interest related to

University research activities to control their ability to create bias

and to maintain integrity, credibility, and respect for the work of Penn

researchers.

This policy is applicable to all research being conducted under the

University’s auspices, regardless of whether the research is externally

or internally funded, including proposals and applications made by

University researchers to external sponsors, protocols submitted to

the University’s Institutional Review Board or Institutional Animal Care

and Use Committee, research funded by the University’s Centers and

Institutes, material transfer agreements, nonmonetary collaborative

agreements, and similar types of research agreements.

I. Deﬁnitions

As used in this policy, the following terms shall have the meaning

ascribed to them below:

Clinical trial

shall have the same meaning as prescribed from time to time

by the World Health Organization.

Clinical trial intellectual property

means an

Investigator’s

interest in

intellectual property that is the subject of a copyright, issued patent, or

a patent application (regardless of whether the intellectual property has

been patented, licensed, or assigned to the University) if such intellectual

property is being tested, evaluated, or developed in, or if its commercial

value could be affected by, the

Clinical trial

in which the

Investigator

engaged or proposes to engage.

Excluded payer

means a Federal, state, or local government agency, a

United States institution of higher education, an academic teaching

hospital, a medical center, or a research institute that is afﬁliated with

an institution of higher education. By way of example, the University,

the University of Pennsylvania Health System, Children’s Hospital of

Philadelphia, the Philadelphia Veterans Affairs Medical Center, the

Howard Hughes Medical Institute, and Wistar Institute are

Excluded

payers

Family member

means an

Investigator’s

spouse or dependent child,

or persons having such other relationships to the

Investigator

as the

Institutional ofﬁcial

may determine from time to time.

FCOI report

means the University’s report of a ﬁnancial conflict of interest

required by law or otherwise by agreement to be made to a research

sponsor or other oversight agency.

Fiduciary role

means membership on the governing board of an entity,

including service on its board of directors, or having a position of

authority or responsibility to act in the best interest of the entity, including

being an ofﬁcer, manager, partner, or limited liability company member

with management responsibility.

Financial conflict of interest (FCOI)

means a

Signiﬁcant ﬁnancial interest

that could directly and signiﬁcantly affect the design, conduct, or

reporting of the Research.

Financial interest

means anything of monetary value, whether or not the

value is readily ascertainable.

Institutional ofﬁcial

means the Vice Provost for Research or such other

person as the Provost appoints from time to time as the individual within

the University responsible to oversee the University’s compliance with

conflict of interest regulations and policies.

Institutional responsibilities

means an

Investigator’s

professional or

employment-related responsibilities on behalf of the University or any

of its Schools, which may include

Research

consultation,

teaching, professional practice, institutional committee memberships,

and service on panels such as Institutional Review Boards or Data and

Safety Monitoring Boards.

Investigator

means the project director or principal investigator and any

other person, regardless of title or position, who is responsible for the

design, conduct, or reporting of

Research

, whether externally or internally

funded, or proposed for such funding, which may include, for example,

collaborators or consultants.

Outside organization

means any organization other than the University,

University of Pennsylvania Health System and its corporately-owned

entities (e.g., Clinical Care Associates and Clinical Practices of the

University of Pennsylvania) or other

Excluded payer

Research

means a systematic investigation, study or experiment

designed to develop or contribute to generalizable knowledge. The term

encompasses basic and applied research (e.g., a published article, book,

or book chapter) and product development (e.g., of a diagnostic test or

drug).

Senior/key personnel

means the project director or principal investigator

and any other person identiﬁed as senior/key personnel by the University

in a grant application, progress report, or any other report submitted to

the sponsor related to the

Research

Signiﬁcant ﬁnancial interest (SFI)

means one or more of the following of

the Investigator (or the Investigator’s Family member) that reasonably

appear to be related to the

Investigator’s Institutional responsibilities

With regard to any publicly traded

Outside organization

, an SFI exists if

the value of any remuneration received from the

Outside organization

in the 12 months preceding the disclosure plus the value of any

equity interest in the

Outside organization

as of the date of disclosure,

when aggregated, exceeds $5,000. Remuneration includes salary

and any payment for services not otherwise identiﬁed as salary (e.g.,

consulting fees, honoraria, paid authorship); equity interest includes

any stock, stock option, or other ownership interest, as determined

through reference to public prices or other reasonable measures of

fair market value;

ii.

With regard to any non-publicly traded

Outside organization

, an SFI

exists if the value of any remuneration received from the entity in

the 12 months preceding the disclosure, when aggregated, exceeds

$5,000, or if the

Investigator

Family member

holds any equity

interest (e.g., stock, stock option, or other ownership interest);

iii.

Intellectual property rights and interests (e.g., patents, copyrights) not

assigned to the University, upon receipt of any income related to such

rights and interests;

iv.

Clinical trial intellectual property

rights (and royalties or other

remuneration, if any, paid with respect to such rights); or

Any

Fiduciary role

in an O

utside organization

Financial interest

is related to an

Investigator’s Institutional

responsibilities

if, for example, it arises from extramural activities that

derive from the Investigator’s professional standing or that are within

that

Investigator’s

expertise in the Investigator's professional ﬁeld(s) of

discipline, such as consulting, serving on a scientiﬁc advisory board,

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III.F. Policy on Conflicts of Interest Related to Research

providing continuing professional education services, or serving as

an expert witness for an

Outside organization

that, to the best of the

Investigator’s knowledge, conducts or seeks to conduct business

related to the

Investigator’s

ﬁeld of discipline. Moreover, equity in, or

serving in a Fiduciary role for, an Outside organization that, to the

best of the

Investigator’s

knowledge, conducts or seeks to conduct

business related to the Investigator’s ﬁeld of discipline, is related to

the

Investigator’s Institutional responsibilities

Notwithstanding the foregoing, unless arising from the

Investigator’s

Clinical trial intellectual property

, SFI does not include:

•

salary, royalties, or other remuneration paid by the University to the

Investigator

if the

Investigator

is currently employed or otherwise

appointed by the University;

•

rights in intellectual property assigned to the University, including the

right to participate in the University’s royalties or in the University’s

equity pool if the equity interest is held and controlled by the

University under the

Patent and Tangible Research Property Policies and

Procedures of the University of Pennsylvania

, as amended from time to

time;

•

equity in or income from investment vehicles, such as mutual funds

and retirement accounts, as long as the

Investigator

does not directly

control the investment decisions made in these vehicles; or

•

income from seminars, lectures, or teaching engagements sponsored

by, or income from service on advisory committees or review panels

for, an

Excluded payer

II. Investigator’s Duty to Disclose

Signiﬁcant Financial Interests and Travel

Disclosure of Signiﬁcant ﬁnancial interests:

At least annually,

each

Investigator

must submit to designated ofﬁces at the Investigator's

School a disclosure of

Signiﬁcant ﬁnancial interests (SFI)

and such other

information as the

Institutional ofﬁcial

or the

Investigator’s

School shall

require. This disclosure must be updated at the time of submission of a

proposal for sponsored

Research

upon submission of a protocol, upon

being added (in a capacity that meets the deﬁnition of

Investigator

) to an

ongoing Research project, and also within 30 days of the Investigator’s

discovering or acquiring a new

SFI

. The means and format of the

disclosure will be prescribed by the School and University from time

to time and communicated to the University research community

In addition to the disclosure of

SFIs

, the

Investigator

must provide

requested information to assist in the assessment of whether any of

the

Investigator’s SFIs

are related to the

Investigator’s Research

Disclosure of travel:

Investigators

who are funded or proposed to be

funded by the Public Health Service or other sponsor designated from

time to time by the University, must also disclose the occurrence of any

reimbursed or sponsored travel (i.e., travel which is paid on behalf of

the Investigator and not reimbursed to the

Investigator

so that the exact

monetary value may not be readily available), related to the

Investigator’s

Institutional responsibilities

during the previous 12 months, other than

travel reimbursed or sponsored by an

Excluded payer

. Travel disclosures

must include the purpose of the trip, the identity of the trip’s sponsor or

organizer, the trip’s origin and destination, and the duration of the trip.

In addition, the University or

Investigator’s

School may request other

information about the trip as necessary to evaluate whether the travel

may constitute a

Financial conflict of interest (FCOI)

III. Assessment of Disclosures

Review by the School:

Each School shall appoint a Conflict of Interest

(COI) Ofﬁce/Ofﬁcer to review disclosures of SFIs and, where applicable,

travel, and the

Investigator’s

assessment of relatedness of S

FIs

to the

Research

in which the

Investigator

engages or proposes to engage. The

School COI Ofﬁce/Ofﬁcer shall review the disclosures and reasonably

determine whether any of the disclosed

SFIs

or travel payments could

be affected by the

Research

or are in an entity whose

Financial interest

could be affected by the

Research

. The determination of relatedness to

the

Research

will be made based on both the

Investigator’s

assessment

of relatedness and on other facts reasonably deemed relevant by the COI

Ofﬁce/ Ofﬁcer or the

Institutional ofﬁcial

Review by the Institutional ofﬁcial:

The

Institutional ofﬁcial

is responsible

to make the ultimate determination regarding whether a related

SFI

constitutes an

FCOI

and, if so, whether the

FCOI

is amenable to

management. If the School COI Ofﬁce/Ofﬁcer determines that one or

more disclosed SFIs or travel relate to the

Research

, the School shall

direct the

Investigator

to submit information regarding those related

SFIs

to the University’s Ofﬁce of the Vice Provost for Research (OVPR),

using such means of disclosure as prescribed by the OVPR from time

to time and communicated to the University’s research community. The

University may utilize several forms of review to reasonably determine

FCOIs

. The type of review to be utilized and review standards may be

prescribed from time to time through guidance from the

Institutional

ofﬁcial

based generally upon the nature and value of the disclosed

interests, as well as other factors.

Recommendations by the Conflict of Interest Standing Committee:

Conflict of Interest Standing Committee (CISC) shall serve in an advisory

capacity to the

Institutional ofﬁcial

, providing recommendations related to

whether an

SFI

constitutes an

FCOI

, whether the

FCOI

is manageable, and

if so, the management plan. The primary scope of inquiry of the CISC is to

review matters involving

SFIs

and their potential to affect the objectivity

of speciﬁc

Research

. Matters involving other types of conflicts of interest

(

e.g.

, procurement, conflict of commitment) will be referred to the Schools

and/or other University ofﬁces, depending on the nature of the conflict.

The CISC will consist of approximately 10-20 members (or such number

of members as the Institutional ofﬁcial may determine from time to time)

of the standing faculty appointed by the

Institutional ofﬁcial

. Efforts will be

made to have faculty representation on the CISC reflective of the volume

of disclosures submitted by each School. In addition, the

Institutional

ofﬁcial

may from time to time appoint one or more member(s) drawn

from the community external to the University. The external member(s)

shall comply with the same standards of conduct and duties applicable

to participation by University-afﬁliated members of the CISC relative to

their participation on the committee. Only appointed CISC members who

are faculty and the external member(s), if any, shall have voting rights in

CISC decisions.

Ex-ofﬁcio

, non-voting members will include the Associate

Vice Provost for Research; Associate Vice Provost Ofﬁce of Research

Services; the Associate Vice Provost for Research and Executive Director,

Penn Center for Innovation; the Director, Human Research Protections;

and an attorney from the Ofﬁce of the General Counsel. Other non-voting

participants may be appointed at the discretion of the

Institutional ofﬁcial

The recommendations of the CISC require approval by a majority of the

voting members present during the meeting. A member may be present

at a meeting either in person or by electronic means, such as telephone

or internet conferencing, allowing participation in the meeting. A quorum

of six voting members present, or such other quorum requirement as

may be determined from time to time (and applied prospectively) by

2026-27 Catalog | Generated 08/03/26

University of Pennsylvania Faculty Handbook

the

Institutional ofﬁcial

, is required for a meeting. A CISC voting member

shall not vote on a particular case if: the case involves a member of

the same departmental division, or if the department has no divisions

or fewer than six divisions, the same department; the CISC member

has a personal interest because of inter-departmental relationships,

such as collaboration with the faculty member whose case is under

consideration; or the CISC member has a ﬁnancial or other relevant

interest related to the case under discussion. Disclosure of any of

the above conditions must be made by the CISC member prior to the

beginning of the discussion. The Chair has discretion to request that

a CISC member not participate in a discussion based on the above

conditions.

In general, the following types of

SFIs

related to

Research

will be reviewed

by the CISC, as they are likely to constitute an

FCOI

unless there are

factors that would reasonably prevent any direct or signiﬁcant effect on

the design, conduct, or reporting of the

Research

Equity in a privately held

Outside organization

that is actively

conducting or seeking to conduct business related to the

Research

;

ii.

Equity with a value greater than $50,000 or greater than 5% ownership

in a publicly traded

Outside organization

that is actively conducting or

seeking to conduct business related to the

Research

;

iii.

Payments greater than $25,000 in the preceding 12 months from an

Outside organization

;

iv.

Fiduciary role

on behalf of an

Outside organization

that is actively

conducting or seeking to conduct business related to the

Research

;

Intellectual property interest (not assigned to the University or

other

Excluded payer

) if any income has been received from such

intellectual property interest in the preceding 12 months; or

vi.

Clinical trial intellectual property

The

Institutional ofﬁcial

may also choose to submit for CISC review other

types of

SFIs

not listed above or instances where an

Investigator

has more

than one type of

SFI

related to the Research.

Prior to commencement of a

Research

project, review and assessment

FCOIs

shall be conducted within the timeframes required by law or

otherwise by agreement with the sponsor and, where applicable, shall

be concluded prior to the expenditure of funds from the sponsor. During

an ongoing

Research

project, should an Investigator who is new to the

project disclose an SFI or should a current

Investigator

disclose a new

SFI

, the disclosure will be reviewed in the manner described above to

determine whether the

SFI

relates to the

Research

and constitutes an

FCOI

IV. Determination and Management of

FCOI

Whether or not submitted for review by the

CISC

, an

SFI

may be found

by the

Institutional ofﬁcial

to constitute an FCOI and may be subjected

to a requirement that the

FCOI

be managed (including elimination of the

Financial interest

, where appropriate) as a condition to the

Investigator’s

participation in the

Research

to which it is related. The determination of

whether an

FCOI

, including an

FCOI

involving a

Clinical trial

, is manageable

without elimination of the Financial interest should take into account

relevant factors such as the nature and design of the Research; the

magnitude and nature of the

Financial interest

; the extent to which the

Financial interest

could be influenced by the

Research

; the uniqueness

of the

Investigator’s

position with respect to the study (for example,

whether safety or other factors will be diminished if the

Investigator

does

not participate); whether the interest is amenable to management; and

in addition, with respect to Clinical trials, the degree of risk to human

subjects, the role of the

Investigator

in the study, and the degree of the

Investigator’s

influence upon the recruitment and enrollment of subjects

or the results of the study.

Management plan:

Where appropriate, a plan to manage the

FCOI

may be

developed and recommended to the

Institutional ofﬁcial

. The

Institutional

ofﬁcial

will have the authority to accept, modify, or reject the

recommendations or to refer the

FCOI

to the

CISC

for additional

consideration. The

Institutional ofﬁcial

will communicate the ﬁndings and

elements of the management plan to the

Investigator

and other University

personnel as appropriate. The

Investigator

will be granted the opportunity

to review the management plan and must acknowledge in writing their

acceptance of the obligation to abide by the plan.

Reconsideration:

If the

Investigator

objects to the terms of the

management plan, the

Investigator

may submit promptly

to the

Institutional ofﬁcial

a written request for reconsideration, specifying the

basis for the objection. The

Institutional ofﬁcial

has discretion to refer

the matter back to the CISC for further review and recommendations,

but is not required to do so. The

Institutional ofﬁcial

also has the

option to consult with the relevant School ofﬁcials. If the

Investigator

is not satisﬁed with the decision of the

Institutional ofﬁcial

after such

reconsideration, the

Investigator

may appeal to the Provost, whose

determination is ﬁnal.

Reporting:

Once the management plan has been ﬁnalized, OVPR staff

will prepare, if applicable,

FCOI

reports

required to be submitted to the

research sponsor or oversight agency. The

FCOI reports

shall contain

information required by law or otherwise by the sponsor.

The

Investigator

should be aware that information pertaining to

FCOIs

may be disclosed to

sponsors or oversight agencies and, in some cases, to the public and may

contain such details as the value and nature of the

Financial

interest and

elements of the management plan.

Monitoring:

Establishment of a management plan also initiates

responsibility for monitoring compliance with the plan until the

completion of the

Research

project. As part of ﬁnalizing the management

plan, the OVPR,

Investigator’s

School or other designee will establish an

ongoing monitoring program to ensure compliance with requirements of

the management plan.

V. Investigator’s Obligation to Complete

Training

As part of the responsibility for participating in

Research

at the

University,

Investigators

must receive training from the University related

Research

-related

FCOI

prior to engaging in

Research

at the University

and at least every four years thereafter.

Investigators

new to the University

shall undergo training promptly after commencement of employment.

In addition, each

Investigator

must undergo training within a reasonable

period of time following any substantive change to this policy that

affects the requirements for

Investigators

, and must be retrained if it is

determined that the

Investigator

has not complied with this policy or with

a management plan related to their activities. Training shall include a

description of this policy, the

Investigator’s

disclosure responsibilities, an

overview of the relevant Public Health Service regulation, and such other

topics as the

Institutional ofﬁcial

shall determine from time to time.

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III.F. Policy on Conflicts of Interest Related to Research

VI. Investigator’s General Obligation to

Cooperate

The

Investigator

is required to cooperate fully with the University in all

aspects of the administration of this policy. This includes, among other

things, providing all information as required to allow the University

to understand and assess the

Investigator’s

disclosure of

SFI

and the

relatedness of the

SFI

to the

Investigator’s Research

, assisting in the

conduct of retrospective reviews where appropriate, and responding

promptly and appropriately to implementation and monitoring of

management and mitigation plans or corrective action.

VII. Public Accessibility

This policy will be made available to the public via posting on the

University’s website. In addition, to the extent required by law or

otherwise by the terms and conditions of a

Research

award or as

otherwise determined by the

Institutional ofﬁcial

, the University will make

available to the public certain information regarding

FCOIs

Senior/key

personnel

afﬁliated with the University (and to the extent reported to the

University,

Senior/key personnel

at other institutions). In response to a

written request submitted to the OVPR for information related to

FCOIs

held at the time of the request by

Senior/key personnel

of the particular

Research

project speciﬁed in the request, the University will, within ﬁve

business days, provide as to

Senior/key personnel

with

FCOI

related to

such project: the

Investigator’s

title and role with respect to the

Research

project; the name of the entity in which the

SFI

is held; the nature of

the

SFI

; and the approximate value of the

Financial interest

reported in

ranges ($0–$4,999; $5,000–$9,999; $10,000–$19,999; amounts between

$20,000–$100,000 by increments of $20,000; amounts above $100,000

by increments of $50,000) or a statement that the interest is one whose

value cannot be readily determined through reference to reasonable

measures of fair market value.

The written request to the University must identify the project in sufﬁcient

detail to permit identiﬁcation of the speciﬁc grant or contract.

In lieu of response to individual requests as described above, the

Institutional ofﬁcial

may in the future determine to employ postings on

the University’s website as the means of communication of information

regarding

FCOIs

Senior/key personnel

to the public. In the event that the

website is used for that purpose, the website will contain the information

described above and shall be updated with the frequency and maintained

for the periods required by law.

VIII. Response to Non-compliance

Review of untimely disclosures:

Should the University identify an

SFI

that, for any reason, was not disclosed by an

Investigator

within the

required timeline or was not previously reviewed by the University during

an ongoing

Research

project, the

Investigator’s

School and the University

will, within 60 days where required by law or by the terms of the

Research

award and in any event promptly as the circumstances allow, perform

their respective responsibilities to review the

SFI

, determine whether it is

related to the

Research

project, and determine whether an

FCOI

exists. If

the

Institutional ofﬁcial

determines that the

SFI

constitutes an

FCOI

, the

University shall implement a management plan describing the actions

that have been and will be taken to manage the

FCOI

Retrospective review and mitigation:

In addition, if an

FCOI

(including

FCOIs

of subrecipients) is not identiﬁed or managed within the designated

timeframe for any reason, where required by law or by the terms of the

Research

award or otherwise as may be appropriate in the view of the

Investigator’s

School or the University, the University shall direct the

School (or subrecipient, as applicable) to conduct in consultation with

the University a retrospective review of the

Investigator’s

activities and

the

Research

project to determine whether any portion of the

Research

conducted during the time period of the noncompliance was biased in

the design, conduct, or reporting of such Research. This retrospective

review shall be completed within 120 days of the determination of non-

compliance where required by law or by the terms of the

Research

award

and in any event promptly as the circumstances allow.

Documentation of a required retrospective review will include the project

number; project title; project director/principal investigator or contract

project director/principal investigator; name of the

Investigator

with the

FCOI

; name of the entity with which the Investigator has an

FCOI

; the

reason(s) for conducting the retrospective review; detailed description of

the methodology used for the retrospective review; and the ﬁndings and

conclusions of the review.

As appropriate, the University will provide an updated

FCOI report

specifying actions that will be taken to manage the ﬁnancial conflict of

interest going forward. If the retrospective review ﬁnds bias related to

the

Research

project, the University will notify the research sponsor as

appropriate. As required by law or agreement or as otherwise appropriate,

this notiﬁcation shall include a mitigation report including the key

elements documented in the retrospective review above, a description of

the impact of the bias on the

Research

project, and the University’s plan

for eliminating or mitigating the effect of the bias.

Sanctions for violation:

If it is suspected that an

Investigator

has violated

this policy, the

Institutional ofﬁcial

, in conjunction with the applicable

Deans and other administrative ofﬁcials of the University, will make

appropriate inquiry regarding the matter. If after such inquiry a violation is

found, suitable corrective action may be taken. Such action may include

the initiation of proceedings under other University policies, including

the University’s

Procedures Governing Sanctions Against Members of the

Faculty

and relevant Human Resources policies.

If the University determines that an

Investigator

has failed to comply with

this policy or an

FCOI

management plan and that the non-compliance

appears to have biased the design, conduct, or reporting of the

Research

the University shall promptly notify the research sponsor as required

by law or agreement or as otherwise appropriate, of the corrective

action taken or to be taken. Among other actions, in the event that

the Department of Health and Human Services determines that a

clinical

Research

project funded by the Public Health Service (including

the National Institutes of Health) with the purpose of evaluating the

safety or effectiveness of a drug, medical device, or treatment has

been designed, conducted, or reported by an

Investigator

with an

FCOI

that was not managed or reported by the University as required by

Federal regulations, the University shall among other things require the

Investigator involved to disclose the FCOI in each public presentation

of the results of the

Research

and to request an addendum to previously

published presentations.

IX. Responsibilities for Research

Subrecipients

If required under the terms and conditions of a sponsored

Research

project, the University will require any written subaward agreement

with any organization to include terms establishing the applicable

FCOI

policy governing the subrecipient’s work, whether it is the University

of Pennsylvania policy or the policy of the subrecipient institution.

The subrecipient will be required to provide certiﬁcation that its policy

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University of Pennsylvania Faculty Handbook

is established in accord with sponsor requirements or, if unable to

provide such certiﬁcation, the University policy will be applicable to

all subrecipient

Investigators

. (As a rule, the University will require

subrecipient institutions to maintain and administer their own

FCOI

policies and will only in exceptional circumstances assume primary

responsibility for directly soliciting and reviewing subrecipient personnel

disclosures that enable the University to directly identify and manage

identiﬁed

FCOIs

from the

SFI

disclosures of subrecipient personnel.) In

addition, the written subaward agreement will establish timelines and

information requirements that will allow sufﬁcient time for the University

to evaluate, as applicable, subrecipient disclosures or subrecipient

FCOI reports

in order for the University to meet any applicable sponsor

reporting requirements.

X. Record Retention

In general, records related to the identiﬁcation, evaluation, and response

FCOI

Research

shall be retained for three years following the date

that the ﬁnal Research expenditure report has been submitted to the

research sponsor or for a longer period when speciﬁed by applicable

governmental

or University requirements.

XI. Oversight by the Institutional Ofﬁcial

The

Institutional ofﬁcial

is responsible for:

•

communicating the expectations of the University’s

FCOI

policy to the

research community;

•

providing access to appropriate

FCOI

training;

•

designating tools and procedures for

Investigator

disclosure of

SFIs

;

•

creating policies and guidelines for the determination of whether an

FCOI

exists;

•

developing processes for the review of

SFI

disclosures, the evaluation

FCOIs

, and the development and monitoring of management plans;

•

establishing a process for providing

FCOI reports

to the research

sponsor or other oversight agencies as appropriate;

•

implementing a procedure to provide required notiﬁcation to the

research sponsor if bias is found in the design, conduct, or reporting

Research

and to submit any required mitigation plan to the

sponsor;

•

establishing a procedure for notifying research sponsors of non-

compliance with this policy as appropriate;

•

establishing procedures for the maintenance of

FCOI

-related records

in accordance with University and Federal record retention guidelines;

•

establishing appropriate enforcement mechanisms, including actions

to promote

•

Investigator

compliance;

•

establishing procedures to implement that subrecipient agreements

specify the use of University or subrecipient

FCOI

policies;

•

making this policy publicly accessible; and

•

establishing a process for making information related to

FCOIs

held

Senior/key personnel

publicly available, where required, in the

applicable timeframes.

These responsibilities may be delegated to other University or, in

consultation with the applicable Dean, School personnel as necessary

and appropriate to promote adherence with this policy and applicable

sponsor guidelines.

XII. Related Authority

This policy implements the requirements of the Public Health Service,

including the National Institutes of Health as set forth in

Promoting

Objectivity in Research

, 42 CFR 50, Subpart F and

Responsible Prospective

Contractors

, 45 CFR 94, and describes the University’s approach to

meeting the requirements of other sponsors.

This policy was originally adopted as of August 24, 2012 and revised as

of August 14, 2017. When originally adopted in August, 2012, the policy

superseded and replaced two policies:

Financial Disclosure Policy for

Research and Sponsored Projects

, February 6, 2001,

Almanac

, Volume 47,

No. 21, and

Financial Disclosure and Presumptively Prohibited Conflicts for

Investigators Participating in Clinical Trials

, July 17, 2007,

Almanac

, Volume

54, No. 1.

As of the date of this policy, the WHO deﬁnition reads:

…a clinical trial is any research study that prospectively assigns

human participants or groups of humans to one or more health-related

interventions to evaluate the effects on health outcomes. Clinical trials

may also be referred to as interventional trials. Interventions include

but are not restricted to drugs, cells and other biological products,

surgical procedures, radiologic procedures, devices, behavioural

treatments, process-of-care changes, preventive care, etc. This

deﬁnition includes Phase I to Phase IV trials.

Engaging in a trial includes, but is not limited to, serving as a Principal

Investigator, Co-Investigator, regulatory sponsor/IND holder or in any

other role responsible for the design, conduct, or reporting of the trial

(including reporting results to the FDA); performing any other subject-

related activity speciﬁc to the trial, such as the recruitment, selection,

or enrollment of subjects, obtaining informed consent, providing

subject treatment and care speciﬁc to the trial, or performing study

procedures; or collecting, analyzing, or interpreting data.

This includes proposals to transfer existing awards from another

institution in connection with the commencement of an Investigator’s

employment by the University.

As of the time of preparation of this policy, it is anticipated that the

full implementation of the disclosure procedures in this policy will

occur in stages, as necessary software and other resources are

deployed to help support this process. Initial emphasis will be to ﬁrst

assure compliance with federal regulation and thereafter additional

procedures will be phased in. The University will provide notice from

time to time to its research community to advise of the speciﬁc means

by which to submit disclosures.

The foregoing titles may be changed from time to time.

The request for reconsideration must be made with sufﬁcient time to

allow the University to respond to the objection and comply in a timely

manner with reporting requirements under applicable law.

Current Public Health Service regulation requires that such reports be

made prior to the expenditure of funds, within 60 days of identifying a

new FCOI for an existing Investigator or appointing a new Investigator

with an FCOI to the Research project, at least annually and in

conjunction with progress reports or renewals, or when necessary to

update a previously submitted report.

Requests must be submitted in writing to the Ofﬁce of the Vice Provost

for Research, Attention FCOI Request Department, 1 College Hall

Room 118, Philadelphia, PA 19104-6303. FCOI information required to

be furnished under this section shall remain available for the period

required by applicable law.

Including where applicable, 45 CFR 74.53(b) and 92.42, and 48 CFR part

4, subpart 4.7

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III.G. Consulting and Outside Activities Policies and Procedures

III.G. Consulting and Outside

Activities Policies and Procedures

(Source: Resolution of the Trustees, January, 1966; revised, June 18, 1993

and Ofﬁces of the President and Provost, Almanac, March 15, 1994; revised,

Resolution of the Trustees, February 11, 2005 and Ofﬁces of the Provost

and the Faculty Senate, Almanac, February 22, 2005; revised, Ofﬁce of the

Provost, Almanac, February 7, 2006; revised, Resolution of the Trustees, June

18, 2010 and Ofﬁce of the Provost, Almanac, July 13, 2010; revised, Ofﬁce of

the Provost and Resolution of the Trustees, Almanac, April 21, 2015; revised,

Ofﬁce of the Provost,

Almanac, July 12, 2016

(

https://almanac.upenn.edu/

uploads/media/071216-supplement.pdf

); revised, Ofﬁce of the Provost,

November 21, 2022)

Article 1. Preamble

1.0

The Trustees of the University of Pennsylvania afﬁrm the following

principles as the basis for governing the intellectual property created by

faculty, employees, students and guest scholars of the University:

1.1

The mission of the University includes the stimulation of basic and

applied research activities of faculty, employees and students of the

University, and the dissemination of the results of their research for

the purpose of adding to the body of knowledge and serving the public

interest.

1.2

The purpose of this policy is to encourage and enable faculty,

employees and students to translate new knowledge into social good

and provide a framework within which the University can support and

facilitate these actions.

1.3

The University endeavors, where it deems appropriate, to secure in

tellectual property protection for the products of such research and to en

courage commercial investment in and development of University intel

lectual property for the beneﬁt of the public.

1.4

The community has endowed the University with certain privileges,

resources and assets in the expectation that no single party will derive

sole beneﬁt or be unjustly enriched from what the community has

endowed to the University.

1.5

The University as a non-proﬁt organization endeavors to marshal its

resources and exploit its assets to serve the public interest, and in so

doing reinvests in the research enterprises of its faculty, employees and

students. Members of the University community share in the University’s

responsibility to serve the public interest, and have a duty to disclose and

assign their inventions.

1.6

The University is regularly the recipient of grants from the

government, foundations or commercial enterprises for the support of

research, and is subject to legal and contractual obligations imposed by

these entities.

1.7

The University wishes to share the economic beneﬁts of inventions or

other intellectual property with the creators of such works in a way that

is consistent with the research and educational mission of the University,

and conforms to the University’s obligations to regulatory authorities, re

search sponsors and licensees.

1.8

In protecting and managing its intellectual property assets, the Uni

versity insists that the academic freedom of its faculty and students be

preserved, and that collegiality and the open expression of ideas by and

among members of the University community be encouraged.

Article 2. Policy and Procedures Relating

to Consulting and Outside Activities

2.1 Consulting Policy.

As stated in the University policy entitled “Con

flict of Interest Policy for Faculty Members” (Section II.E.10 of the

Hand

book for Faculty and Academic Administrators)

, the University recognizes

the value to the institution and to its faculty of permitting the faculty to

engage in extramural consulting activities. These activities offer the po

tential of strengthening the competence and expertise of the faculty as

scholars, as well as the potential of developing the intellectual property

owned by the University. In all circumstances where consulting activities

may result in the creation of an INVENTION, the following procedures and

principles apply:

2.1.1

To ensure that the consulting activities are consistent with fac

ulty members’ professional obligations to the University, responsibilities

with respect to the avoidance of conflicts of interest, and to their commit

ments for teaching and research, faculty members should comply with

the provisions of Section II.E.10 of the

Handbook

which include both

the prospective disclosure of the potential consulting activities to their

Department Chairs and School Deans, as well as written reports on

such activities as set forth in the

Handbook

, or other related procedures

established by their School or Department.

2.1.2

In any case where the faculty member, Department Chair, or

Dean believes that there is a potential conflict of interest or conflict of

commitment, the matter shall be referred to the University Conflict of

Interest Standing Committee. The Committee shall review the matter

and make recommendations to the Provost, or the Provost's designee,

who has the authority to approve, modify, or disapprove any consulting

arrangement that raises a potential conflict. In determining whether

review by the Conflict of Interest Standing Committee is appropriate, the

faculty member, Department Chair, or Dean may consult with the General

Counsel.

2.1.3

In all consulting relationships, faculty members have the duty to

protect any intellectual property owned by the University and the ability

of the University to fulﬁll its obligations to government funding agencies

and commercial and non-commercial sponsors of research.

2.2 Consulting Agreements.

Except to the extent set forth in Section

3.4 below, faculty members contemplating entering into a consulting

agreement shall ensure that their obligations under the PATENT POL

ICY are not compromised and the University’s rights are protected. Spe

ciﬁcally, faculty members have the responsibility to ensure that the fol

lowing terms are not part of any consulting agreement: (l) conﬁdentiality

provisions that prevent the individual from publishing research or from re

porting results of University research to research sponsors; (2) conﬁden

tiality provisions that prevent the individual from providing TANGIBLE

RESEARCH PROPERTY or other deliverables to a University research

sponsor or other entity as required by federal law, federal regulation, or by

sponsor agreement; (3) intellectual property provisions that preclude the

consultant from assigning any inventions that arise out of the consulting

relationship to the University; and (4) any provisions that are designed to

circumvent University policies and procedures for the disclosure, review

and approval of sponsored research projects or other University policies

concerning intellectual property. Moreover, in the context of academic

research, it may be difﬁcult to avoid commingling of research activity

or resources with services provided under the consulting agreement.

It is the obligation of the faculty member in negotiating the consulting

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University of Pennsylvania Faculty Handbook

agreement to ensure that any consulting relationship entered into

protects against any such commingling of research or resources.

2.2.1

Faculty members may seek the assistance of the IPA in deter

mining whether a proposed agreement conforms to these guidelines.

Such assistance should not be construed to be advice or counsel as to

the faculty member’s personal interests in the consulting agreement.

2.3 Consulting Activity with a Company Providing Sponsored Re

search.

In addition to the procedures set forth above, if a faculty

member contemplates a consulting relationship with a company that

sponsors research for that individual at the University, the proposed

consulting agreement shall be disclosed to the IPA, along with an

explanation of the nature and scope of the individual’s anticipated

activities. The IPA shall refer the matter to the University Conflict of

Interest Standing Committee, with copies of all applicable documentation

to relevant Deans, Department Chairs and the General Counsel, or the

General Counsel's designee, for review. The Committee shall make

recommendations to the Provost, or the Provost's designee, who shall

have the authority to approve, modify or disapprove any such proposed

agreements.

2.4 Exception to the General Consulting Policy.

Notwithstanding the

policies articulated in Article 2.0 above, and in the general consulting

policy set forth above, the University recognizes that faculty members

may seek to undertake consulting engagements, at the direction of a ﬁrm

or entity other than the University, that may require that any resulting

INVENTIONS be assigned to the sponsor of the engagement. While not

providing the University with ownership of the INVENTION, these con

sulting engagements may nevertheless provide signiﬁcant beneﬁts to

faculty members and to the University. For this reason, it is the policy

of the University to authorize a Dean, in the Dean's discretion, to permit

these consulting engagements, without claiming any ownership interest

in the INVENTION for the University, under the follow conditions.

2.4.1 Conditions for Consulting Engagements.

In order for a faculty

member and the faculty member's particular proposed consulting

engagement to be eligible for consideration under this exception to the

consulting policy: (1) The engagement must be consistent with the policy

on “Conflict of Interest Policy for Faculty Members” (

Handbook for Faculty

and Academic Administrators

, II.E.10); (2) no undergraduate or graduate

students may be involved in the engagement; (3) the faculty member

must be compensated in cash, and the compensation must be ﬁxed

and not variable, must reflect the fair market value of the consulting to

be performed, and must not vary according to the perceived value of

INVENTIONS assigned. (The faculty member may not be compensated

with EQUITY or any form of contingent or variable compensation,

including but not limited to options, warrants, royalties, or a payment

that varies based upon the sales, revenues or other perceived success

of an INVENTION or product or service based upon such INVENTION);

(4) the faculty member may not have a SIGNIFICANT EQUITY INTEREST

in the sponsoring entity or an afﬁliate of that entity; (5) performance

of the engagement may not involve the use of any University facilities,

personnel, equipment or assets, except for

de minimus

amounts or uses;

and (6) the terms of the engagement must not conflict with any existing

commitments under sponsored research or otherwise for ownership of

resulting inventions, and shall not make assignment of ownership of

any future INVENTION not conceived and reduced to practice during

the term of, and as a direct and sole result of performing, the consulting

engagement.

2.4.2 Procedures for Disclosing Consulting Engagements.

To qualify

for consideration under Section 3.4 and allow for meaningful advance

review, the speciﬁc terms of the proposed agreement must be disclosed

to the Department Chair and the Dean at a reasonable time prior to the

commencement of the engagement and, in all circumstances, prior to the

faculty member entering into any legally binding agreement to engage

in the engagement. The engagement and its terms must be reported to

the Department Chair and the Dean, in writing, on an annual basis. If the

Dean determines, after consultation with the Department Chair and the

IPA that criteria set forth in Section 3.4.1 have been met, the Dean may

approve the engagement, in the Dean's discretion, but is not required

to approve the engagement. If the Dean determines that the criteria

set forth in Section 3.4.1 have not been met, or otherwise declines to

approve the engagement, the Dean should so notify the faculty member,

who may then seek review of the decision by the APPEALS BOARD. The

Dean should notify the faculty member of the decision promptly, and if

possible, within thirty (30) days of receipt of the disclosure.

2.4.3 Procedures for Waiver of Conditions.

Should a faculty member

seek to undertake a consulting engagement that is neither within the

general consulting policy, nor satisﬁes the criteria of Section 3.4.1, the

faculty member may request a waiver from the Dean to permit the fac

ulty member to enter into the consulting arrangement. In order to request

a waiver, the faculty member must comply with Section 3.4.2 as well as

disclose the proposed consulting engagement to the

Conflict of Interest

Standing Committee

(CISC) as required under the

Policy on Conflicts

of Interest Related to Research

. After the review by CISC, the Dean, in

consultation with the General Counsel, the Provost or the Provost's

designee and the IPA—may grant the waiver. If the Dean determines that,

under the facts and circumstances of the particular case, the waiver

would undermine the principles underlying the PATENT POLICY, violate

any legal or regulatory requirement, present an unmanageable conflict

of interest or otherwise violate University policy, the Dean should deny

the waiver and notify the faculty member. The decision should be made

and communicated to the faculty member as promptly as possible,

generally within ﬁfteen (15) days of receipt of the waiver request. Should

the waiver be denied, the faculty member may appeal the decision to the

APPEALS BOARD. Approval of a waiver under the PATENT POLICY shall

not constitute approval under or waiver of other University policies, such

as the

Policy on Conflicts of Interest Related to Research

Waivers will ordinarily be granted to allow for EQUITY compensation in

cases in which the amount of EQUITY is ﬁxed based on the fair market

value of the consulting services at the time delivered, and it does not

involve a form of contingent or variable compensation, including but

not limited to options, warrants, or a conditional grant of EQUITY that

varies based upon the sales, revenues or other perceived success of an

INVENTION or product or service based upon an INVENTION.

2.4.4 Liability when Consulting.

Faculty members entering into

consulting engagements should understand that they are undertaking

personal responsibilities and may be assuming certain personal risks

of liability. For that reason, all faculty members may wish to seek

personal legal counsel, at their own expense, for the purpose of reviewing

proposed consulting agreements so as to protect their personal interests.

To the extent, however, that faculty members are availing themselves of

this exception to the PATENT POLICY, they are doing so entirely at their

own risk and are not, in any way, protected by the University. For this

reason, faculty members are well advised to seek personal legal advice

before entering into such a consulting relationship.

2.5 Application of the Consulting Policy and Procedures to Ad

ministrators and Staff.

The University recognizes the value to the in

stitution and of permitting administrators and staff, as well as faculty, to

engage in extramural consulting activities, under certain circumstances.

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III.G. Consulting and Outside Activities Policies and Procedures

Except as speciﬁcally set forth below, the above policy applies to admin

istrators and staff who seek to enter into consulting engagements.

2.5.1

Staff and administrators who contemplate entering into consult

ing engagements are subject to the “Guidelines for Extramural

Activities, Associations, and Interest for Staff” (

Human Resources

Policy Manual,

Policy No. 006 (https://www.hr.upenn.edu/policies-and-

procedures/policy-manual/other-policies/guidelines-for-extramural-

activities-associations-and-interest-for-staff/), effective 2/1/1990) and

should follow the procedures for disclosure and clearance of potential

conflict of interest issues set forth in those guidelines.

Article 3. Deﬁnitions and Miscellaneous

3.0.1

The

APPEALS BOARD

is empowered to resolve disputes arising

from the interpretation or administration of this CONSULTING POLICY, as

described in Section 3.2. The APPEALS BOARD comprises nine (9) voting

members (seven [7] standing members and two [2] ad hoc members).

The seven standing members shall be comprised of: one (1) voting Chair,

appointed by the Faculty Senate and who shall be a Standing Faculty

member; four (4) administrators (each appointed by the Vice Provost for

Research); and two (2) term faculty appointed by the Faculty Senate.

The two (2) ad hoc members shall be faculty selected for expertise

by the Dean(s) of the relevant School(s) or the Chair(s) of the relevant

Departments(s), except that if one or more of the individuals involved

in the appeal is an emeritus faculty, the two ad hoc voting members

selected by the Dean(s) or Department Chair(s) shall be emeritus faculty

and if one or more of the individuals involved in the appeal is a graduate

student, the two ad hoc voting members selected by the Dean(s) or

Department Chair(s) shall be graduate students. In addition, the APPEALS

BOARD shall include one nonvoting member ex ofﬁcio, who shall be an

attorney from the Ofﬁce of the General Counsel and appointed by the

General Counsel. The APPEALS BOARD shall be staffed by the Ofﬁce of

the Vice Provost for Research.

3.0.2

CONSULTING POLICY

means this Consulting and Outside Activities

Policies and Procedures of the University of Pennsylvania, with any

amendments.

3.0.3

EQUITY

means ownership interests or securities, including but

not limited to shares of stock or securities; stock options; warrants

or any other rights to purchase stock or securities; debt instruments;

partnership interests in a general or limited partnership; or membership

interests in a limited liability company or partnership.

3.0.4

EXECUTIVE COMMITTEE

provides oversight and steering of the

technology transfer process, including assisting in setting the operating

budget for the PENN CENTER FOR INNOVATION (PCI). The EXECUTIVE

COMMITTEE is appointed by the Provost in consultation with the Vice

Provost for Research and chaired by the Vice Provost for Research. The

EXECUTIVE COMMITTEE is comprised of the INTELLECTUAL PROPERTY

ADMINISTRATOR (IPA), ex ofﬁcio; the Vice Provost for Research; the

Dean of the School of Medicine or his/ her designee; one faculty from

each of the School of Arts and Sciences and the School of Engineering

and Applied Science; one at-large faculty; and an attorney from the Ofﬁce

of the General Counsel selected by the General Counsel, who shall be

nonvoting and ex ofﬁcio.

3.0.5

INTELLECTUAL PROPERTY ADMINISTRATOR

(IPA) means the

Executive Director of PCI (or the Executive Director's successor, as

designated by the Vice Provost for Research).

3.0.6

INVENTION

means and includes discoveries and inventions

and related technical information, trade secrets, developments,

knowhow, methods, techniques, formulae, data and processes;

TANGIBLE RESEARCH PROPERTY upon which a patent has issued

or a patent application has been ﬁled and is still pending; and other

proprietary matter.

3.0.7

INVENTORS

means University faculty, emeritus faculty, visiting

faculty or researchers, adjunct faculty, postdoctoral employees or

trainees, or other employees, or students, or others who individually or

jointly make an INVENTION subject to the PATENT POLICY and who

meet the criteria for inventorship under United States patent laws and

regulations.

3.0.8

PATENT POLICY

means the Patent and Tangible Research Property

Policies and Procedures of the University of Pennsylvania, with any

amendments.

3.0.9

PENN CENTER FOR INNOVATION

(PCI) means the administrative

unit, under the direction of the INTELLECTUAL PROPERTY

ADMINISTRATOR (IPA), which is responsible for the receipt, review,

management and administration of intellectual property matters of the

University.

3.0.10

SIGNIFICANT EQUITY INTEREST

means any EQUITY or other

ﬁnancial interest that when aggregated for the individual and the

individual’s spouse and dependent children exceeds $25,000 in value,

as determined through reference to public prices or other reasonable

measures of fair market value, and does not represent more than ﬁve

percent (5%) ownership interest in any single entity.

3.0.11

TANGIBLE RESEARCH PROPERTY

means unique research

products or tools, such as biological materials or chemical moieties,

whether or not patentable or otherwise protectable using intellectual

property laws. Categories of biological material include organisms, cells,

viruses, cell products, cloned DNA, as well as DNA sequences, mapping

information and crystallographic coordinates. Some speciﬁc examples

of biological materials include specialized and/ or genetically deﬁned

cells, including normal and diseased human cells; monoclonal cell lines;

hybridoma cell lines; microbial cells and products; viruses and viral

products; recombinant nucleic acid molecules; DNA probes; nucleic acid

and protein sequences; and transgenic mice or other animals. Categories

of chemical moieties or engineered products include sample compounds,

reagents, intermediates, models, sensors, devices, equipment, computer

hardware or ﬁrmware, diagrams or computer media.

3.1 Review of Policies and Procedures.

The EXECUTIVE COMMITTEE

together with the Vice Provost for Research shall review the CONSULTING

POLICY, from time to time to determine whether it is accomplishing

its intended purposes and is in conformity with applicable laws and

regulations, including intellectual property laws. The EXECUTIVE

COMMITTEE shall make recommendations for amendments or other

changes to the Provost and the Faculty Senate, who shall confer with the

President.

3.2

Disputes under Policies and Procedures

. Except as expressly set

forth otherwise in this CONSULTING POLICY, disputes arising from the

interpretation or administration of the CONSULTING POLICY may be

referred by any interested party to the Chair of the APPEALS BOARD and

the Ofﬁce of the Vice Provost for Research, who will promptly notify the

IPA. The APPEALS BOARD shall ﬁrst determine whether it has jurisdiction

to hear any such dispute before proceeding. The APPEALS BOARD

shall provide an equitable mechanism for the review and resolution

of disputes brought before it and shall have the authority to make a

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University of Pennsylvania Faculty Handbook

judgment with respect to such disputes. The APPEALS BOARD shall

use reasonable efforts to make a judgment with respect to any dispute

within thirty (30) days after having any such dispute referred to it. Any

judgment of the APPEALS BOARD may be appealed by any interested

party to the Vice Provost for Research. The Vice Provost for Research

shall consider the matter de novo and shall use reasonable efforts to

review any such appeal and make a judgment with respect to any appeal,

within thirty (30) days after having any such dispute referred to the Vice

Provost for Research. Any judgment of the Vice Provost for Research

may be appealed to the President, who will make a ﬁnal decision for the

University.

III.H. Guidelines for Student

Protection and Student Access to

Information Regarding Sources of

Financial Support

(Source: Ofﬁces of the President and Provost,

Almanac, October 21, 1986

(

https://almanac.upenn.edu/archive/v33pdf/n09/102186.pdf

); revised,

Ofﬁce of the Provost, November 21, 2022)

Participation in sponsored research may be an important part of a

student’s undergraduate or graduate education, as well as an important

source of ﬁnancial support. The University recognizes that the student

must be protected in cases where the terms of the research project

conflict with the student’s academic progress, and afﬁrms that the

student has the right to reject such funding if the student chooses to do

so. The University recognizes the sensitivity of these issues, since they

pertain directly to the relationship of personal trust which exists between

a student and the student's faculty sponsor; they are also fundamental

to the development of the student’s intellectual and moral integrity.

Therefore, the University adopts the following policy:

The University recognizes the central role of sponsored research in

fostering educational opportunities for students at all levels and in every

discipline, and encourages the involvement of students in research

projects. On rare occasions, the terms of a research agreement may

contain limitations that may inhibit the participation of students, such

as delays in publication of results that might conflict with a student’s

academic schedule. In such cases, the University requires that careful

consideration be given to the appropriateness of student participation

and that the faculty sponsor or Principal Investigator assure in advance

that students are fully aware of any such restrictions.

The University afﬁrms the student’s right to know the source(s) of

ﬁnancial support for the student's educational and living expenses,

individual research projects, or the research activities of a faculty sponsor

in which the student is involved and from which the student obtains

ﬁnancial support. It is the responsibility of the faculty sponsor to make

this information known to the student.

Should a student choose to reject ﬁnancial assistance, the University

afﬁrms and upholds the student’s right to do so.

(See page 5 - Almanac, October 21, 1986 (https://almanac.upenn.edu/

archive/v33pdf/n09/102186.pdf))

III.I. Policy Concerning the Exclusion

of Foreign Nationals from Speciﬁc

Research Areas

(Source: Ofﬁces of the President and Provost, Almanac, February 23, 1988)

Members of the University research community shall not be subject to

discrimination based on citizenship with respect to their participation

in research activities. While funding agencies may limit their ﬁnancial

support to particular groups (such as U.S. citizens), they may not prohibit

the participation of others in University research.

Where a research contract deviates from this policy an exception may be

granted by the Vice Provost for Research after review by the University

Council Committee on Research.

(See page 6 - Almanac, February 23, 1988 (https://almanac.upenn.edu/

archive/v34pdf/n23/022388.pdf))

III.J. Guidelines for Research in the

Community

(Source: Ofﬁce of the Provost,

Almanac, May 19, 1998

(

https://

almanac.upenn.edu/archive/v44/n34/orresguide.html

))

A signiﬁcant number of Penn faculty and students are engaged in

research that involves the study of the Philadelphia community, and, in

particular, West Philadelphia, or that involves community members as

research subjects. As in all research conducted under the auspices of

the University, such research should adhere to the appropriate protocols

for the protection of human subjects and must be approved by the

University's Institutional Review Board.

Although the Institutional Review Board does an excellent job of

protecting individual subjects, community-based research raises

additional questions about research protocols and approaches. The

populations studied are often Penn's neighbors, and as such, the

approaches undertaken should reflect the importance of that relationship

to Penn, and the values of mutual respect and trust that should guide all

of our collaborative activities with the community. The University also

recognizes that mutual respect and trust are necessary preconditions

for the honest and open exchange of ideas that is essential to genuine

learning and the advancement of academic inquiry.

The University views its relationship with the Philadelphia community

as a partnership. Accordingly, and to the extent possible, Penn faculty

and students should engage the community in helping to plan research

projects. Also, the ﬁndings should be shared with the community so that

all parties can beneﬁt.

As in all research involving human subjects, undertaken under

University auspices, research in the community must be approved by

the Institutional review Board, and meet all of the required protections

of human subjects.

Whenever possible, researchers investigating community

issues should work with community-based organizations to

discuss all aspects of the research process, including problem

deﬁnition, hypothesis generation, study design, data analysis, and

dissemination.

Whenever possible, researchers should have a dissemination plan

that includes distribution or presentation of results to community

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III.K. Human Research Protection Program

members and organizations, particularly those who participated in

the research.

Researchers should determine if other projects are underway in a

community, and whenever possible, coordinate efforts with other

research projects to minimize disruption and maximize positive

impacts on community members and organizations.

In the spirit of mutual learning and beneﬁt, researchers should

consider how study results could be used to the beneﬁt of the

community whenever possible, and should make extra efforts to

communicate those recommendations to appropriate community

members.

III.K. Human Research Protection

Program

(Source: Ofﬁce of the Provost,

Almanac, July 11, 2006

(

https://

almanac.upenn.edu/archive/volumes/v53/n01/or.html

))

The University of Pennsylvania is committed to maintaining a

comprehensive program to protect human subjects engaged in

research conducted or supported by the University and the University of

Pennsylvania Health System.

The institution adheres to the ethical principles and guidelines for the

protection of human subjects in research enumerated in the Belmont

Report, produced by the National Commission for the Protection of

Human Subjects of Biomedical and Behavioral Research (April 1979). The

University has provided the Department of Health and Human Services’

Ofﬁce for Human Research Protections (OHRP) a Federal-wide Assurance

of compliance with the ethical principles and regulations governing

research with human subjects. This Federal-wide Assurance is written

documentation of Penn’s commitment to comply with local and federal

laws and regulations governing human research.

The Vice Provost for Research is empowered by the Board of Trustees

through the Provost to coordinate the overall human research protection

program and has direct authority over the key components of that

program. The responsibilities of the Vice Provost for Research include:

•

Ensuring protection of human research subjects.

•

Ensuring compliance with local, state and federal laws and

regulations.

•

Ensuring the independence of the Institutional Review Boards (IRBs).

•

Ensuring the number of IRBs is appropriate for the volume and types

of human research reviewed, and that reviews are accomplished in a

thorough and timely manner.

•

Responding to allegations of scientiﬁc misconduct.

The Vice Provost for Research has the authority to:

•

Create and approve policies and procedures governing the human

research protection program.

•

Create an annual budget for the human research protection program.

•

Allocate resources within the program.

•

Suspend or terminate research.

•

Place administrative sanctions on investigators for noncompliance,

such as suspension or termination of research privileges; requiring

investigators or research staff to undergo additional training as

a condition of continuing research; and mandating independent

monitors for ongoing research.

The Vice Provost for Research may not approve a study that has been

disapproved by one of the IRBs.

The Vice Provost for Research has established an oversight committee

known as the Human Research Advisory Committee (HRAC). The

HRAC represents all the ofﬁces of the University with interest in the

conduct of human research including the Ofﬁce of Regulatory Affairs;

the Ofﬁce of Research Services; the Ofﬁce of General Counsel; the

Ofﬁce of Audit, Compliance and Privacy; representatives of the schools

conducting research as well as faculty members. This committee advises

the Vice Provost for Research on the need for and implementation of

policies and procedures governing human subject research. Upon the

recommendation of the HRAC, the University shall conduct periodic

reviews of the human research protection program and budget support

for the various components of the program, either through independent

mechanisms or as part of a scheduled accreditation process.

Prior to initiating any research on human subjects, investigators at the

University of Pennsylvania must ﬁrst obtain the approval of one of the

University IRBs through their established policies and procedures. The

University supports eight IRBs through the Ofﬁce of Regulatory Affairs

(ORA). IRB is composed of scientists, nonscientists and members who

are unafﬁliated with the University of Pennsylvania. The Director of the

ORA reports directly to the Vice Provost and informs the Vice Provost for

Research of the IRB actions to approve, withhold approval, disapprove,

terminate or suspend human subject research.

All personnel—faculty, research fellows, students and staff—engaging

in human research must have documented education regarding human

subject protection, in accordance with certiﬁcation standards deﬁned

by the Vice Provost for Research. Training for investigators engaged in

biomedical research is available through a webbased program developed

by the Perelman School of Medicine’s Ofﬁce for Human Research.

Researchers engaged in social and behavioral research are offered web-

based training through the Ofﬁce of the Vice Provost, in cooperation with

the IRB.

In addition, the Perelman School of Medicine Ofﬁce for Human

Research (OHR) maintains high level support for medical researchers

conducting trials including those where the faculty member has a role as

sponsor-investigator. The OHR also provides monitoring of investigator

compliance for the University.

Any individual with questions concerning human research or

noncompliance with regulations may contact the Ofﬁce of Regulatory

Affairs at (215) 898-2614. Allegations of noncompliance may also be

reported to the Ofﬁce of Audit, Compliance and Privacy using 1-888-BEN-

TIPS. All allegations are investigated with appropriate protections of the

rights of the complainant.

This notice shall be published periodically as a reminder to the University

community or when the various components of the human research

program are materially changed.

III.L. Policy Regarding Human

Subject Research in the

Sociobehavioral Sciences

(Source: Ofﬁce of the Provost,

Almanac, October 3, 2006

(

https://

almanac.upenn.edu/archive/volumes/v53/n06/or-hsresearch.html

))

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University of Pennsylvania Faculty Handbook

Scope

This policy is applicable to all employees, students, trainees, faculty,

and other persons working for or in facilities owned and operated by the

University of Pennsylvania and conducting sociobehavioral research. This

policy is meant to apply University-wide to all research involving human

subject data, and inclusive of biomedical research protocols applying

sociobehavioral techniques (e.g., survey research). Depending on the type

of research, other policies (e.g., those pertaining to biomedical research)

may apply as well. Relevance is determined by the involvement of living

human subjects in observational or experimental research, or in the use

of records or specimens that may conceivably place the subjects of these

records at risk, as per the Common Rule.

The term “sociobehavioral sciences” (or the term “social and behavioral

sciences”) must be understood as a shorthand term for the set of

inquiries involving human subjects not otherwise subsumed under the

biomedical sciences. It includes ﬁelds of research speciﬁcally deﬁned

as behavioral and social sciences in federal manpower reports; that

is, “anthropology, demography, the non-clinical ﬁelds of psychology,

sociology, and the speech and hearing sciences.” It also includes human

subject research in economics, business, education, and history, among

others (see the Common Rule). Thus, the proposed policy applies to all

sociobehavioral research irrespective of its institutional setting within the

University or its source of funding. Note that disciplinary predilections—

for example, rejection of the rubric “science”—are insufﬁcient warrant for

self-abstention from the policy promulgated here.

Regulatory Background

In the context of Institutional Review Board (IRB) oversight of human

subject research, the Common Rule speciﬁes three levels of review of

proposed research, which can be summarized as follows:

full board review

—a convened IRB committee must approve the

proposed research, applying criteria set forth in the Common Rule,

before the research can be conducted;

expedited review

—certain kinds of research involving no more than

minimal risk, as well as minor changes in approved research, can be

approved by an administrative mechanism not requiring a convened

IRB committee;

exempt from review

—minimal risk research activities in a number of

speciﬁed categories, involving human subjects not from vulnerable

populations, are exempt from full review as per the Common Rule.

These three levels of review require submission of a research protocol

to the IRB. Speciﬁc submission requirements for each category can be

found at the IRB website.

At the University of Pennsylvania, “expedited review” is typically

performed by Ofﬁce of Regulatory Affairs personnel. The University is

also required to have a mechanism in place for determining whether a

proposed research protocol is “exempt from review.” As per the federal-

wide assurance (FWA) that the University has in place, this determination

is made by an administrative mechanism6 similar to that for “expedited

review.” In addition, there are certain kinds of research not covered by the

Common Rule. Such research does not require any involvement of the

IRB, even at the level of “exempt from review.”

This policy clariﬁes that speciﬁc activities in the social behavioral

sciences do not require IRB involvement. As a category distinct from

“exempt from review,” it is referred to as “

not under the purview of the IRB

.”

Implementation

Implementation of the policy outlined below will be the responsibility

of the Ofﬁce of the Vice Provost for Research. In consultation with the

Schools and their faculty, the Vice Provost will create a training program,

and a certiﬁcation process documenting successful completion of the

training program. Any sociobehavioral research activities involving

human subjects or human subject data will require prior ofﬁcial

certiﬁcation once this policy becomes effective.

Policy

Education and Certiﬁcation

All personnel—faculty, research fellows, students and staff—engaging in

sociobehavioral research must have documented discipline-appropriate

education regarding human subject protection, in accordance with

certiﬁcation standards deﬁned by the Vice Provost for Research.

The training program and certiﬁcation process are to be kept current

under the auspices of the Vice Provost for Research and in consultation

with the Schools and their faculty.

Survey Research

Survey research, which includes face-to-face or telephone interviewing, or

self-administered questionnaires (as through the mail or via the Internet),

generally has a low cost of participation, since it usually requires only

a small amount of subjects’ time. According to the Common Rule, such

research is “exempt from review” and does not require written consent, as

clariﬁed below.

2a. Survey research is exempt from review if the survey is anonymous

or protection of the conﬁdentiality of research subjects is adequately

demonstrated, and if all other applicable criteria for exempt from review

are fulﬁlled (e.g., research must not involve vulnerable populations or put

subjects at more than minimal risk).

2b. For research that is exempt from IRB review, human subjects responding

to a survey are automatically considered to have given informed consent.

In order to qualify for a default waiver of written consent as per policy

item 2b, an exemption form5 must be presented to the IRB showing that:

human subjects will be informed of all applicable elements of

consent prior to responding to the survey; and

ii.

all criteria for “exempt from review” are fulﬁlled.

Secondary Data Analysis

Secondary data analysis is the (usually statistical) investigation of

individual-level data records collected in another study, with the following

characteristics:

no direct contact with or experimental manipulation of human

subjects;

no new data collection; and

no identiﬁcation of individual research subjects. In agreement with

recommendations 1 and 6 of the Draft Recommendations Regarding

Public Use Data Files issued by the National Human Research

Protections Advisory Committee (NHRPAC), this policy states that

such research may either be “exempt from review” or “not under the

purview of the IRB,” as clariﬁed below.

3a. Research on a public-use data ﬁle, which contains only non-

identiﬁable data or data for which a breach of conﬁdentiality is not an

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III.L. Policy Regarding Human Subject Research in the Sociobehavioral Sciences

issue (e.g., public business statements), is not considered human subject

research for the purpose of IRB review and as such is not under the

purview of the IRB.

3b. Research on a non-public-use data ﬁle—that is, non-identiﬁable data

in a non-publicly available or proprietary ﬁle—is exempt from review,

unless vulnerable populations are involved. Non public use data ﬁles may

be submitted by a School to the IRB for approval. If approved, with the

appropriate maintenance of safeguards, studies using these data sets are

no longer human subject research and as such are not under the purview

of the IRB.

Investigators must agree not to attempt to re-identify the human

subjects.

Investigators planning to study non-public-use data ﬁles must

demonstrate to the IRB that conﬁdentiality of research subjects is

protected, by providing direct evidence of protection procedures or by

showing that the data supplier already received IRB approval in which

non-identiﬁability was considered and conﬁrmed. The latter does not

necessarily require submitting to the IRB the survey instrument or

consent form used in the research that yielded the data.

Researchers operating in one of the categories of the Health Insurance

Portability and Accountability Act (HIPAA) should refer to the HIPAA

regulations that contain a deﬁnition of identiﬁability.

Evolving Research

Evolving research is a class of research in the sociobehavioral sciences in

which the questions that are posed evolve in the course of investigation.

An example is ethnography, where research questions may only be

clariﬁed after a period of observation and where current ﬁndings drive

the next steps in the study. This class of research typically involves

studying human behavior in non experimental settings, with or without

active participation by the investigator; but it can also occur in more

structured observational settings (e.g., oral histories, focus groups). In

speciﬁc cases, such research does not pose more than minimal risk to

human subjects and is considered to be “exempt from review,” as stated

below. An approved mechanism is necessary for presenting to the IRB

a research protocol that will evolve in the course of investigation. This

policy institutes such a mechanism via certiﬁcation.

4a. Research involving only non-interventionist observation of behavior

occurring in public (including domains of the Internet clearly intended to

be publicly accessible), for which no identifying information is recorded,

is exempt from review.

4b. Investigators are allowed to use their certiﬁcation, as per policy item

1, as a reference for describing evolving research activities to the IRB in

lieu of a ﬁxed research protocol.

This policy eliminates the need for investigators doing evolving

research to spell out the details of a dynamic research protocol. The

IRB can be assured that the research will be conducted in an ethically

appropriate fashion, with full protection of human subjects, when

certiﬁed investigators attest that their pre-registered research plan will be

conducted within the ethical framework laid out in the training program

for which they are certiﬁed.

Note that different studies by the same investigator(s) must be submitted

to the IRB as separate research protocols. These must not be viewed as a

single study evolving from one investigation into another.

Feasibility Assessment

Feasibility assessment (or exploratory research) is understood to involve

the conceptualization or reﬁnement of a research question through

harmless observation, casual conversation, and browsing of extant data.

The Common Rule applies only to generalizable research. Therefore,

feasibility assessment is “not under the purview of the IRB” if a number of

strict conditions are met, as speciﬁed below.

5. Feasibility assessment is not under the purview of the IRB, if and only if

the following conditions are met:

the assessment involves no more than minimal risk;

the assessment does not involve any vulnerable populations,

including prisoners, minors, pregnant women and fetuses, mentally

impaired or disabled persons, terminally ill patients, the very elderly,

and anyone incapable of self-determination;

the human subjects are not identiﬁable from any of the information

acquired;

the assessment does not involve any deceptions;

the assessment data and results are not disclosed or published;

there is no systematic collection of data, or any systematic data

collection serves only to calibrate a research instrument that involves

no more than minimal risk.

If at any time any of these conditions cannot be satisﬁed, the project

must be submitted to the IRB for review.

Adverse Effects

This policy prescribes the documentation of possible negative effects on

human research subjects and how they can be reversed.

6. For research involving manipulations or deceptions of human subjects

that may cause harmful or undesirable effects, research protocols

submitted to the IRB must speciﬁcally describe the recovery or debrieﬁng

procedures of the study, and address how the effectiveness of these

procedures will be assessed.

When a research study may have foreseeable untoward effects on human

subjects, the investigator must explain in the research protocol how

these effects will be mitigated.

The IRB must be informed of the occurrence of any adverse events that

take place during the research study or as a result of the research study.

For research protocols that are reviewed by the IRB in one of the three

review categories (full board review, expedited review, or exempt from

review), adverse events must be reported for the annual continuing

review. Research protocols “not under the purview of the IRB” require

reporting of any adverse events within a month of occurrence, as such

events may change the review status of the study. Unanticipated events

or effects on human subjects that may change the interpretation of

the risk of the protocol must be reported to the IRB as soon as they are

identiﬁed.

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University of Pennsylvania Faculty Handbook

III.M. Standard Operating Procedures

and Policies of the University of

Pennsylvania Institutional Animal

Care and Use Committee (IACUC)

(Source: Ofﬁce of the Vice Provost for Research, March 9, 2000; revised, May

2002; revised, June 2003; revised, July 2004)

The University of Pennsylvania recognizes the scientiﬁc and ethical

responsibility for the humane care and use of animals involved in

research and education and enjoins all individuals involved to maintain

the highest standards of animal care and consideration. This concern

extends to investigators to protect the animals as well as comply with the

speciﬁc requirements established and regulated by the sponsors of their

research, University Policies and/or federal regulations.

The University of Pennsylvania recognizes and supports fully The

Institutional Animal Care and Use Committee (IACUC), as the agent for

The University of Pennsylvania in its obligations for the humane care and

use of animals.

The University of Pennsylvania and the IACUC shall:

Assure all activities (involving animals) meet the ethical and legal

requirements for the humane care and use of animals

Maintain and promote an open and cooperative relationship with

investigators and faculty, and the greater university community.

Educate the University of Pennsylvania community concerning the

ethical and regulatory considerations for the humane care of animals.

The full text of the University’s Institutional Animal Care and Use

Committee’s standard operating procedures and policies is available

at the following URL: https://iacuc.upenn.edu/node/6 (https://

iacuc.upenn.edu/node/6/)

IV. Procedures Regarding Admission

and Instruction of Students

•

IV.A. Guidelines for Admissions Policies and Procedures (p. 91)

•

IV.B. Code of Academic Integrity (p. 93)

•

IV.C. Charter of the University of Pennsylvania Student Disciplinary

System (p. 94)

•

IV.D Faculty Authority to Assign Grades and Academic Integrity

(p. 103)

•

IV.E. School Policies and Practices (p. 103)

•

IV.F. Rules Governing Final Examinations (p. 103)

•

IV.G. Reporting of Final Grades (p. 104)

•

IV.H. Policy on Secular and Religious Holidays (p. 104)

•

IV.I. Guidelines for Addressing Academic Issues of Students with

Disabilities (p. 104)

•

IV.J. Policy on the Conﬁdentiality of Student Records (p. 106)

IV.A. Guidelines for Admissions

Policies and Procedures

(Source: Ofﬁce of the Provost,

Almanac, February 14, 1980

(

https://

almanac.upenn.edu/archive/v26pdf/n23/021480.pdf

))

Summary of the Guidelines

This document describes the way in which the admissions policies of

the University of Pennsylvania should be formulated and implemented.

It prescribes neither particular policies nor the details of the admissions

process. The purpose of these guidelines is to protect the integrity of the

admissions process.

The admissions function may be divided into three parts. First, the

legislative function

establishes the substantive provisions of an

admissions policy, i.e., standards and goals describing the qualities

of the students sought that can be applied to the applicant pool.

Second, the

administrative function

translates admissions standards

and goals into procedures for attracting a suitable body of qualiﬁed

applicants, for differentiating among them and for persuading those

who best ﬁt the admission criteria to attend the University. Third, the

monitoring function

involves regular evaluation both of the validity of

the norms set in admissions policies and the efﬁcacy of administrative

practices in fulﬁlling the normative standards and goals. Accordingly, the

responsibility for this function rests mainly with the several faculties.

The

legislative function

is essentially a determination of educational

policy. Accordingly, the guidelines place responsibility for this function on

the several faculties after appropriate consultation with administrators

and student groups. Each faculty’s policy is subject to any overriding

University policy.

The

administrative function

is a responsibility of academic administrators.

For graduate and professional schools and programs, the Dean is the

ofﬁcer charged with executing the admissions policy. For the Ph.D.

programs and those master’s degree programs managed by the graduate

groups, the Provost, working with the relevant deans and graduate group

chairpersons, is the responsible ofﬁcer. The Provost is also ultimately

responsible for the administrative function for joint degree programs

in cases where at least one of the degrees of concern is the Ph.D. The

administrative function of other joint degree programs at the graduate

level is the joint responsibility of the relevant deans. In the admission

of undergraduate students, a centralized ofﬁce, reporting to the Provost

and working with the undergraduate deans, serves all the schools and

colleges.

The

monitoring function

is, in major part, a responsibility of each

faculty. Regular review of prior experience provides a basis for possible

amendment of the admissions policy and assures that the prevailing

policy’s standards are being carried out faithfully. The University Council

through its Committee on Academic and Related Affairs also participates

in the monitoring function.

To assure that the various admissions functions are carried out with

integrity, the University relies upon two familiar safeguards. The ﬁrst

is a required

formality

of action. In adopting an admissions policy,

a faculty should endorse by formal resolution a written statement

of its policy that can be publicly disseminated. Administrative staff

members, in developing and evaluating the ﬁles of applicants, should

preserve a written record that includes the source of any item of relevant

information. Though conﬁdentiality is an important element of any

application, the preservation of a written record enables consideration,

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IV.A. Guidelines for Admissions Policies and Procedures

either in the decision-making process or during a monitoring review, of all

actions taken by others.

The second safeguard of the integrity of the process is

collective action

The relevant voting faculty should participate in ﬁnal adoption of any

admissions policy statement. A ﬁnal decision to accept or reject an

applicant should be made by an appropriately constituted group of

persons. Educational values are primary in the establishment of any

admissions policy. Matters of institutional concern may also be reflected

in any admissions policy.

Responsibility of the Legislative Function

The admissions process is integral to the educational mission of the

University. Primary responsibility for that process is vested in the several

faculties of instruction, the bodies best suited to decide matters of

educational concern. For the undergraduate programs, this function lies

with the several undergraduate faculties. For the Ph.D. programs and the

master’s degree programs administered by graduate groups, this function

is carried out by the Council of the Graduate Faculties and the various

graduate groups. For the professional degree programs, this function is

carried out by the faculties of the individual schools. Policies of general

applicability to admissions may be adopted by the Trustees after careful

study by the appropriate faculty bodies and administrative ofﬁces.

The Ofﬁce of the Provost is the primary focus of University-wide actions

to oversee the fulﬁllment of the legislative function of the faculties of

instruction. Accordingly, the Provost should be kept informed of actions

by the faculties; in return he or she will disseminate to the faculties

general University policies on admissions.

General Standards for Faculty’s Policies

While the primary responsibility for developing admissions policies is

delegated to the faculties of instruction, there are certain University-wide

principles or regulations that govern these bodies:

The admissions policy for each school should be consonant with the

overall policies of the University.

The criteria for admission of applicants to a degree program, or

to a non-degree program, should be related to and derived from

the educational mission of the school or college and its cognate

activities.

In determining the admissions policy for a school or college, a faculty

should consider the relationship among the several schools and

colleges and avoid unnecessary parochialism in admissions criteria.

Among the undergraduate schools and colleges, common admissions

policies should be followed. There are also common minimum

standards for admissions to the University’s Ph.D. programs. The

Provost working with the undergraduate deans should provide

coordinating services in the case of undergraduate admissions;

for graduate admissions this function should be carried out by the

Provost working with the graduate deans.

Admissions policies for all schools and colleges should conform to

any obligations or constraints imposed by laws of the United States

or of the Commonwealth of Pennsylvania.

An admissions policy statement should be sufﬁciently complete and

precise that those persons charged with its implementation can carry

out their responsibilities faithfully.

The selection of individuals for admission to any academic program

may not be delegated to any extra-University group.

Procedures for Each Faculty’s Action

An admissions policy statement can be adopted or amended through

formal action by the voting faculty of a school or graduate group.

Assistance may be rendered by staff members, by faculty committees or

by coordinating councils within the University.

The prevailing admissions policy statement for a school or graduate

group should be generally available within the University and, as

appropriate, in the larger community. Upon adopting or amending a

policy statement, a faculty should promptly forward a copy to the Provost

through its dean. The bulletin or other equivalent publication of a school

or college should contain an accurate description of the admissions

policy.

Responsibility for the Administrative

Function

The decentralization of admissions policy to the several faculties

implies concomitant distribution of administrative responsibility. While

the Provost, as chief academic ofﬁcer of the University, oversees the

administration of admissions throughout the University, the deans of

schools and colleges are its primary administrators.

In the undergraduate sector, the Dean of Admissions, who reports to

the Provost, supervises the implementation of admissions policies for

all of the schools. For doctoral program admissions, the Vice Provost

for Education or equivalent University ofﬁcer performs this function.

Professional schools maintain separate admissions ofﬁces.

Procedures for the Administration of

Admissions Programs

In most schools and colleges applications are sufﬁciently numerous that

they cannot be efﬁciently processed without the assistance of a special

staff functioning under the supervision of a dean or the Provost. The

following practices should guide the admissions staff in the processing

of individual applications:

It is the responsibility of the applicant to ensure the completeness of

his or her ﬁle as regards requirements for admission. All applicants

should be assured that whatever the decision on their application,

each will receive full and equitable consideration under the prevailing

admissions policy. All written communications about an applicant

must be placed in the applicant’s ﬁle; a record of oral messages

must also be ﬁled in each case where such messages are taken into

consideration in the admissions decision. Communications from

applicants that require a response should be acknowledged promptly.

Admissions staff members may give applicants a preliminary

estimate of the probable ﬁnal decision on their applications.

The contents of an applicant’s admissions ﬁle are subject to the

University’s guidelines on the conﬁdentiality of student records.

Each dean shall identify in writing those individuals who, under

the guidelines, may have access to admissions ﬁles without the

consent of an applicant; the Provost shall do so in the case of the

undergraduate admissions ofﬁce. All members of a graduate group

have access to the ﬁles of applicants to that group.

The protection of individual privacy does not extend to actions

on behalf of the University in processing applications. Thus ﬁnal

decisions to accept or reject applications, as well as preliminary

estimates of the probable ﬁnal decisions, are matters that can be

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University of Pennsylvania Faculty Handbook

disclosed through the informed discretion of authorized University

personnel without violating the principle of conﬁdentiality.

Persons other than applicants are normally involved in the

completion of an application. When a response is appropriate,

admissions staff members should reply to communications from

these persons promptly and courteously. In all responses to

correspondents about applicants, staff members should be mindful

of the general policy of conﬁdentiality of admissions information.

Examples of several common types of communications follow:

Various persons send letters of appraisal about applicants.

In many instances, admissions procedure requires applicants

to arrange for submissions of this type; in other instances,

individuals may volunteer information about applicants. Both

types of communications must be placed in the applicant’s ﬁle.

University staff members assigned to recruit potential groups of

applicants and to assist them through the admissions process,

regularly communicate with admissions personnel on behalf of

such applicants. These staff members usually act on behalf of

programs for the enrollment of speciﬁc categories of students

identiﬁed by the admissions policy statements. They have

access to applicants’ ﬁles if and only if their names appear on the

approval list for such access. Since they are ﬁlling an advocacy

role, they should be sensitive to the partisan aspect of their

functions.

Persons related to the University often express interest in

the application of a candidate. Communications of this kind

may come from a wide variety of sources. The weight of these

endorsements in the ultimate decisions is determined by the

admissions policy statements. In instances where this seems

appropriate, the admissions staff may notify the Dean or an

appropriate University ofﬁcer of the communication. These

ofﬁcials may respond to queries from such interested outside

parties, but they should avoid taking the initiative in such

interchanges prior to the admissions notiﬁcation.

University ofﬁcials not engaged in the admissions process may

receive inquiries concerning admissions applicants. Ordinarily these

communications can be referred to the appropriate admissions staff

persons for proper response. If the University ofﬁcial concludes that it

is desirable to have additional response by the Dean or by some other

University ofﬁcer, a suggestion to this effect should be made and

acted upon. A response may be transmitted through the University

ofﬁcial initially contacted.

Final decisions on applicants are made in accordance with stated

admissions policies. Whenever possible, two or more individuals

should participate in the evaluation process leading to each

admissions decision. Exceptions may be made for preliminary

screening activity in those schools that receive large numbers of

applications and for ﬁnal decisions in faculties admitting small

numbers of students, such as certain graduate groups. In these

cases, it may be appropriate for a single individual to make the

decision. Participation by faculty members throughout the decision

process can be valuable in assuring conformity with the criteria

adopted by the responsible faculty; each faculty should determine

how faculty members should be selected for this purpose. A

complete record for each application should identify the decision

reached, the persons who participated in that judgment and the basis

for the decision in applicable criteria. No one having any personal

interest in the disposition of an application should take part, directly

or indirectly, in the ﬁnal decision-making process. Persons with

advocacy responsibilities should avoid involvement at this stage.

In all cases, notiﬁcation of the ﬁnal decision on an application must

be sent to the applicant ﬁrst. Thereafter, the dean of a school or

college or other appropriate University ofﬁcer may, in the exercise of

informed discretion, disclose to others the decision reached. When a

disclosure is made, record should be made in an applicant’s ﬁles of

the person authorizing the communication and the person to whom

the information is being given.

The ﬁles of applicants for admission, as of matriculants, should

be retained for at least three years beyond the matriculation date

stated in the application. Conﬁdential letters of appraisal in the

admissions ﬁles of students who have matriculated should not be

merged with records pertaining to those students that are used for

purposes other than admissions. Admissions ﬁles should be available

to representatives of the faculties or to the University ofﬁcial charged

with responsibility for reviewing the implementation of admissions

policies.

Responsibility for the Monitoring Function

Responsibility for assuring that the admissions process is reaching

its goals and operating within the limits set by appropriate authorities

exists at all levels of University governance. Regular procedures should

exist for examination and review of prior actions taken. Through such

auditing, those charged with establishing the content of admissions

policy statements can ascertain that existing policies are valid or that

amendments to admissions policies should be developed. Likewise,

procedures should exist for periodic accounting by those who bear

responsibility for the administrative function. Primarily, oversight of

administrative actions is the responsibility of the respective faculties.

Within the University as a whole, the Ofﬁce of the Provost coordinates

efforts to protect the integrity of the admissions process.

(See page 4 - Almanac, February 14, 1980 (https://almanac.upenn.edu/

archive/v26pdf/n23/021480.pdf))

IV.B. Code of Academic Integrity

(Source: Ofﬁce of the Provost, Almanac, April 25, 1972; revised, Almanac,

December 2, 1980; revised, Almanac, May 4, 1982; revised, Almanac, May 26,

1992; revised,

Almanac, September 10, 1996

(

https://almanac.upenn.edu/

archive/v43/n03/codechar.html

))

Since the University is an academic community, its fundamental purpose

is the pursuit of knowledge. A commitment to the principles of academic

integrity is essential to the success of this educational mission. Every

member of the University community is responsible for upholding the

highest standards of honesty at all times. Students, as members of the

community, are also responsible for adhering to the principles and spirit

of the following Code of Academic Integrity.

Academic Dishonesty Deﬁnitions

Activities that have the effect or intention of interfering with education,

pursuit of knowledge, or fair evaluation of a student’s performance are

prohibited. Examples of such activities include, but are not limited, to the

following deﬁnitions:

Cheating: using or attempting to use unauthorized assistance,

material, or study aids in examinations or other academic work or

preventing, or attempting to prevent, another from using authorized

assistance, material, or study aids. Examples: using a "cheat sheet" in

a quiz or exam, altering a graded exam and resubmitting it for a better

grade.

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IV.C. Charter of the University of Pennsylvania Student Disciplinary System

Plagiarism: using the ideas, data, or language of another without

speciﬁc or proper acknowledgment.

Examples:

copying another

person’s paper, article, or computer work and submitting it for an

assignment; cloning someone else’s ideas without attribution; failing

to use quotation marks where appropriate.

Fabrication: submitting contrived or altered information in any

academic exercise.

Examples:

making up data for an experiment,

fudging data, citing nonexistent articles, contriving sources.

Multiple submission: submitting, without prior permission, any work

submitted to fulﬁll another academic requirement.

Misrepresentation of academic records: misrepresenting or

tampering with or attempting to tamper with any portion of a

student’s transcripts or academic record, either before or after

coming to the University of Pennsylvania.

Examples:

forging a change

of grade slip, tampering with computer records, falsifying academic

information on one’s resume.

Facilitating academic dishonesty: knowingly helping or attempting

to help another violate any provision of the Code.

Example:

working

together on a take-home exam.

Unfair advantage: attempting to gain unauthorized advantage

over fellow students in an academic exercise.

Examples:

gaining or

providing unauthorized access to examination materials, obstructing

or interfering with another student’s efforts in an academic exercise,

lying about a need for an extension for an exam or paper, continuing

to write even when time is up during an exam, destroying or keeping

library materials for one’s own use.

If a student is unsure whether his/her action(s) constitute a violation

of the Code of Academic Integrity, then it is that student’s responsibility

to consult with the instructor to clarify any ambiguities.

IV.C. Charter of the University of

Pennsylvania Student Disciplinary

System

(Source: Ofﬁce of the Provost, Almanac, December 2, 1980; revised,

Almanac, September 4, 1984; revised, Almanac, May 26, 1992; revised,

Almanac, September 10, 1996; revised,

Almanac, April 27, 2010

(

https://

almanac.upenn.edu/archive/volumes/v56/n31/senate.html

); revised,

Almanac,

April 10, 2012

(

http://www.upenn.edu/almanac/volumes/v58/

n29/discipline.html

))

Preamble

In response to increasing concern about sexual assault and its

consequences, the U.S. Department of Education, Ofﬁce for Civil Rights

(OCR) issued a new “guidance” document concerning compliance

with Title IX of the Education Amendments of 1972. Title IX prohibits

discrimination on the basis of sex in educational programs, including

sexual misconduct. In this context, the Ofﬁce of Student Conduct and

the Ofﬁce of the General Counsel, working closely with other University

student affairs professionals, prepared amendments to the Charter of the

Student Disciplinary System. As required by the Charter, the amendments

have been approved by the Council of Deans, the Faculty Senate and the

Provost and are in effect as of April 10, 2012.

Changes

The signiﬁcant points of OCR’s guidance include the following:

•

Once a school knows or reasonably should know of possible sexual

misconduct, it must take immediate and appropriate action to

investigate or otherwise determine what occurred.

•

If sexual misconduct has occurred, a school must take prompt and

effective steps to end the sexual violence, prevent its recurrence, and

address its effects, whether or not the sexual violence is the subject

of criminal investigation.

•

A school must take steps to protect the complainant as necessary,

including interim steps taken prior to the ﬁnal outcome of the

investigation.

•

A school must provide a procedure for students to ﬁle complaints

of sex discrimination, including complaints of sexual misconduct.

These procedures must include an equal opportunity for both parties

to present witnesses and other evidence and the same appeal rights.

•

A school’s procedures must use the preponderance of the evidence

standard to resolve complaints of sexual misconduct.

With the guidance in mind, we developed some special procedures for

handling sexual misconduct cases and added a section in the Charter

describing these. For the full text of these amendments, please refer

to Section II.J. (p.

) of the amended Charter. The amendments also

include other minor clean-up revisions, such as correction of scrivener’s

errors.

U.S. Department of Education, Ofﬁce for Civil Rights, Dear Colleague

Letter: Sexual Violence, Background, Summary and Fast Facts, April 4,

2011

The Charter of the Student Disciplinary System sets forth the procedures

under which alleged violations of the University’s Code of Student

Conduct, Code of Academic Integrity, and other policies, rules, and

regulations are resolved.

The Code of Student Conduct sets forth the responsibility of all students

at the University of Pennsylvania to exhibit responsible behavior

regardless of time or place. This responsibility includes, but is not limited

to, the obligation to comply with all provisions of the Code of Student

Conduct; with all other policies and regulations of the University, its

Schools, and its Departments; and with local, state, and federal laws.

The Code of Academic Integrity, and similar codes adopted by some

of the University’s Schools, set forth the standards of integrity and

honesty that should be adhered to in all student academic activities at

the University of Pennsylvania.

Violations of the Code of Academic Integrity or School regulations are

also violations of the University’s Code of Student Conduct. Further,

violations of local, state, and federal laws may be violations of the Code

of Student Conduct. Therefore, throughout the Charter references to

violation(s) or alleged violation(s) of the Code of Student Conduct include

violations of these other policies and laws.

The University disciplinary process at Penn may involve the following

stages:

•

Bringing a Complaint to the Ofﬁce of Student Conduct

•

Resolving a Complaint by Mediation

•

Investigating a Complaint

•

Filing Charges by the University against a Student

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University of Pennsylvania Faculty Handbook

•

Resolving Charges by Voluntary Agreement to Sanctions

•

Resolving Charges by Disciplinary Hearing

•

Appealing the Decision of a Hearing Panel

•

Imposing Sanctions on a Student

•

Fulﬁlling Sanctions Imposed by the University

Under the University’s Student Disciplinary System, charges are brought

on behalf of the University, not on behalf of the complainant(s) who

brought the matter to the Ofﬁce of Student Conduct (OSC) or the

party(ies) who may have been directly or indirectly harmed by the

alleged violation of University regulations. Therefore, complainants

who wish to maintain greater control over their complaints, such

as is sometimes appropriate in cases involving serious cultural or

communicative differences, or those who wish merely to create a record

of their complaint without necessarily beginning a formal disciplinary

process, may wish to bring their complaint to other University resource

ofﬁces, particularly the Ofﬁce of the Ombudsman, which are equipped

to handle cases in this manner. Such ofﬁces may, when appropriate and

helpful in an individual case, consult with relevant campus communities

or other resource ofﬁces in the process of resolving a complaint and are

able to work closely with both complainants and respondents in resolving

such matters. If such efforts fail to arrive at a satisfactory resolution, the

complainant still has the option of bringing a complaint to the OSC.

Through the University Honor Council, students play a major role in the

Student Disciplinary System by advising the Director of the Ofﬁce of

Student Conduct and the Provost on matters of policy and the operation

of the System and by sitting as members of disciplinary hearing panels.

Students also serve as advisors and mediators within the System.

The System places great emphasis on the mediation of disputes, as is

appropriate in a University Community.

I. The Student Disciplinary System

A. Statement of Purpose

The purpose of the Student Disciplinary System is to further the

educational mission of the University of Pennsylvania by providing a

fair and effective mechanism for investigating and resolving disputes

involving students and alleged violations by students of the University’s

rules, regulations, and policies.

B. Jurisdiction of the Student Disciplinary System

Through the Ofﬁce of Student Conduct (OSC), the Student

Disciplinary System handles complaints from members of the

University community—trustees, faculty, staff or registered students—

about alleged violations of the Code of Student Conduct, the Code of

Academic Integrity, or other University policies. Persons outside the

University community may also bring complaints of alleged violations

of the Code of Student Conduct and other University policies to

OSC. The Director of OSC will make a case-by-case determination

of whether it is appropriate to handle such complaints under the

Student Disciplinary System. Among other factors, the Director will

consider whether the alleged conduct affects a substantial University

interest or whether the conduct may present a threat or danger to the

community. When OSC undertakes to handle such complaints, the

procedures described in this Charter will apply.

Except as provided below, the Student Disciplinary System has

jurisdiction in all disciplinary matters arising under the regulations

of the University against registered students, whether they be

undergraduate, graduate or professional students, or others, including

students who are on unexpired leaves of absence. Approved or

unapproved absence from the University is not a bar to the conduct or

completion of disciplinary proceedings under this Charter.

In general, a student is any individual who has been admitted,

matriculated, enrolled, or registered in any academic program or other

educational activity provided by the Trustees of the University of

Pennsylvania.

The Student Disciplinary System does not handle complaints

against graduate and professional students when such cases lie

within the jurisdiction of a hearing board or other disciplinary body

established by the School of the University in which the student is

enrolled. When such a School-based disciplinary procedure exists,

it should be the recourse of ﬁrst resort for the resolution of an

alleged violation of University or School regulations, unless the OSC

decides, in consultation with the Provost, that it is appropriate in

light of the circumstances for the Student Disciplinary System to

handle the matter. Schools with such procedures are encouraged

to refer disciplinary matters (excluding academic integrity matters)

to the University Mediation Program whenever appropriate. When

an alleged violation of University regulations by a graduate or

professional student is not within the jurisdiction of a disciplinary

system established by the student’s School, the Student Disciplinary

System will have jurisdiction over the matter.

The Student Disciplinary System does not handle alleged violations

of the University’s parking regulations.

Alleged violations of the University’s Residential Living policies

and contracts are ordinarily handled under the procedures of the

Department of Residential Living but, if serious enough to warrant

sanctions beyond those which the Department of Residential Living

is authorized to impose, may be referred by the Director of Residential

Living to the OSC. The fact that proceedings have been held and

sanctions imposed under Residential Living policies does not

preclude proceedings under this Charter.

The Director of the Ofﬁce of Student Conduct decides all questions

of jurisdiction of the Student Disciplinary System arising under

this Charter, consulting with the Provost (or designee) and with the

University’s General Counsel when necessary. When appropriate, the

OSC may refer a complaint to another University ofﬁce or disciplinary

process.

C. General Principles of the Disciplinary System

The University’s Student Disciplinary System is not a legal system,

and University disciplinary proceedings are not civil or criminal

litigation. Thus, they operate under different rules, standards, and

procedures, and seek to achieve ends different from criminal or civil

proceedings.

Any member of the University community may bring a complaint

about student conduct or academic integrity to the attention of the

Ofﬁce of Student Conduct. Doing so in no way limits a complainant’s

rights or obligations to bring such matters to the attention of other

University ofﬁces, ofﬁcers, or resources, including the Ofﬁce of the

Ombudsman and appropriate Deans, or to seek recourse outside the

University through civil or criminal legal proceedings.

In all cases, the University reserves the right to determine how to

process a disciplinary complaint. Once a complaint is brought to the

attention of the Ofﬁce of Student Conduct, the OSC, on behalf of the

University, will decide how the complaint will be handled, including

whether disciplinary charges should be brought against a student.

Complainants in sexual misconduct cases have rights and

responsibilities similar to respondents under this Charter. In addition,

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IV.C. Charter of the University of Pennsylvania Student Disciplinary System

certain special procedures apply in sexual misconduct cases

(see section II.J. (p.

)).

Except as otherwise speciﬁed in this Charter, when appropriate and

if all parties agree, a matter brought to the OSC may be resolved

through mediation and will not result in charges or disciplinary

hearings. Because of their seriousness within an academic

community, alleged violations of the Code of Academic Integrity will

not be referred for mediation. Thus, except in academic integrity

matters and matters that warrant treatment as serious violations

of the Code of Student Conduct or other University policies, the

initial response by the OSC may be to refer the complainant and

respondent to the University’s Mediation Program. If mediation fails

or is inappropriate, the OSC will begin the more formal disciplinary

processes outlined in this Charter.

All members of the University community are required to cooperate

with the Student Disciplinary System. Those individuals who may be

interviewed or called as witnesses in a disciplinary matter (including

respondents and complainants) are obligated to provide honest and

complete statements to the OSC and to the Hearing Panel. While

in some circumstances a respondent may choose not to answer

questions or provide information because of pending civil claims

or criminal charges arising out of the same or other events, the

respondent’s decision not to answer questions or provide information

will not be a reason to delay or defer an investigation or proceedings

under this Charter. A student who fails, without good cause, to

appear for a hearing after receiving notice, or to cooperate with the

investigation conducted by the OSC, may be charged with a violation

of the Code of Student Conduct. Repeated disruption of disciplinary

hearings or the disciplinary process by a student or the student’s

advisor may result in charges against the student of non-cooperation

with the Student Disciplinary System or exclusion of the student

or advisor from disciplinary proceedings, including disciplinary

hearings. Such exclusion is not a bar to the completion of disciplinary

proceedings involving that student.

D. Organization of the Disciplinary System

Ofﬁce of Student Conduct

The Ofﬁce of Student Conduct is the central ofﬁce responsible for

resolving alleged violations of University policies by students. The

duties of the OSC include determining whether complaints warrant

action by the OSC, referring complaints for mediation or resolution

by other University ofﬁces, investigating complaints, determining

whether to charge a student with violations of University policies,

resolving complaints by voluntary agreements to sanctions, bringing

charges of violations to a disciplinary hearing, presenting evidence

at hearings, monitoring and enforcing the fulﬁllment of sanctions

imposed pursuant to voluntary agreements or after disciplinary

hearings, maintaining records of all disciplinary matters, providing

administrative support for all aspects of the disciplinary process

(including hearings), and preparing reports and compiling statistics.

University Mediation Program

The University Mediation Program (UMP) may use the volunteer

services of faculty, students, and staff members who have been

trained in mediation and dispute resolution and may also use

resources available in the University’s Law School, in University

resource ofﬁces such as the Ofﬁce of the Ombudsman, or outside the

University.

University Honor Council

The University Honor Council (UHC) provides independent advice

to the Provost and the OSC regarding the operation of the Student

Disciplinary System in the area of academic integrity and student

conduct, the general handling of academic integrity and conduct

violations, appropriate sanctions for various types of academic

integrity and conduct violations, and the effectiveness and

implementation of the University’s Code of Student Conduct

and Code of Academic Integrity. Members of the UHC also sit

on Disciplinary Hearing Panels. The UHC meets regularly with

the Director of the Ofﬁce of Student Conduct and may also

discuss academic integrity and conduct issues with appropriate

administrators and student, faculty, or administrative groups

or committees. In addition, the UHC initiates and participates

in educational programs about academic integrity and student

conduct and works to help students understand and respect the

academic and behavioral standards of the University community.

The UHC consists of a minimum of 13 undergraduate students,

chosen by current members of the UHC. The UHC is encouraged

to ensure that nominees represent a broad cross-section of

the undergraduate student body. The UHC selects a chair from

among its members by a majority vote of the current members.

Faculty members and graduate students designated by the

Faculty Senate or Graduate and Professional Students Assembly

(GAPSA) to sit on Disciplinary Hearing Panels may participate in

the work of the UHC if the UHC so desires.

Disciplinary Hearing Ofﬁcer

Every two years, the Provost, after consultation with the UHC, and

the chairs of the Faculty Senate, will appoint a tenured member of

the Standing Faculty of the University of Pennsylvania as Disciplinary

Hearing Ofﬁcer (DHO), preferably from among those faculty who

have experience with the Student Disciplinary System. The DHO

(or designee) selects members to serve on Disciplinary Hearing

Panels and determines the time, location, etc., of hearings. The

DHO presides over all disciplinary hearings held under this Charter.

The DHO is responsible for overseeing the procedural integrity of

disciplinary hearings. The DHO will, for example: consider and resolve

pre-hearing challenges to the authority or procedures of a Disciplinary

Hearing Panel; rule on all disqualiﬁcation requests and objections

to individual panel members; assist parties to adhere to the basic

principles of fairness prior to, during, and subsequent to disciplinary

proceedings; and may consult at any time with students, faculty

members, the University’s General Counsel or others about procedural

issues. The DHO also participates in the training of prospective

faculty and student members of Disciplinary Hearing Panels. The

DHO serves and may be reappointed at the discretion of the Provost,

but his or her removal or reappointment may not occur without prior

consultation with the UHC and the chairs of the Faculty Senate.

Disciplinary Appellate Ofﬁcer

Every two years, the Provost, after consultation with the UHC, and

the chairs of the Faculty Senate, will appoint a tenured member

of the Standing Faculty of the University of Pennsylvania as a

Disciplinary Appellate Ofﬁcer (DAO), preferably from among faculty

who have experience with the Student Disciplinary System. The DAO

decides appeals of ﬁndings and recommended sanctions made by

Disciplinary Hearing Panels based on the record of such proceedings

and written submissions from the relevant parties. The DAO serves

and may be reappointed at the discretion of the Provost, but his or her

removal or reappointment may not occur without prior consultation

with the UHC, and the chairs of the Faculty Senate.

Disciplinary Hearing Panels

Disciplinary matters are heard by Disciplinary Hearing Panels of

ﬁve members each. The Disciplinary Hearing Ofﬁcer (or designee)

randomly selects the undergraduate members of Disciplinary

Hearing Panels from the membership of the University Honor

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University of Pennsylvania Faculty Handbook

Council for hearings involving undergraduate respondents.

For hearings involving graduate students, the Disciplinary

Hearing Ofﬁcer (or designee) randomly selects the graduate

and professional student members of Hearing Panels from lists

of 13 or more graduate and professional students provided

annually to the DHO by GAPSA. The Disciplinary Hearing Ofﬁcer

(or designee) randomly selects the faculty members of Hearing

Panels from lists of 13 or more faculty provided annually to the

DHO by the Faculty Senate Executive Committee. GAPSA and the

Faculty Senate Executive Committee are encouraged to ensure

that nominees represent a broad cross-section of graduate and

professional students and faculty, respectively.

In all disciplinary matters, except those involving alleged

violations of the Code of Academic Integrity, the Disciplinary

Hearing Panel is composed of two faculty members and three

students of the same category (undergraduate or graduate)

as the respondent. If a disciplinary matter involves both

undergraduate and graduate respondents, the panel will include

at least one undergraduate and at least one graduate student

and two faculty members; the ﬁfth panel member will be an

undergraduate or graduate student selected by the DHO.

In disciplinary matters involving alleged violations of the Code of

Academic Integrity, the Disciplinary Hearing Panel is composed

of three faculty members and two students of the same category

(undergraduate or graduate) as the respondent. If a disciplinary

matter involves both undergraduate and graduate respondents,

the panel will consist of one undergraduate student, one graduate

student, and three faculty members.

Except for participation on the University Honor Council, no

one designated to serve on Disciplinary Hearing Panels may

serve simultaneously in any other capacity within the Student

Disciplinary System.

If any nominating body chooses fewer than 13 members to

serve on Disciplinary Hearing Panels or cannot make additional

members available when needed, the Provost will make the

necessary appointments to ﬁll the complement of the appropriate

group. If any member is unable to serve for any reason, a

replacement is selected in the same manner that the original

member was chosen.

Student members of Disciplinary Hearing Panels must be in good

academic and disciplinary standing, as deﬁned by their Schools.

The UHC, as appropriate, by a vote of two-thirds of its members,

may remove a member who fails to perform his or her duties.

When a member ceases to be in good standing or is removed by

the UHC, a replacement from the same category will be chosen in

the same manner that the original member was chosen.

Advisors

Advisors help students involved in disciplinary proceedings to

understand the disciplinary process, respect and comply with

the provisions of this Charter, and deal with all aspects of the

process. Any University faculty member, staff member, or student

in good academic and disciplinary standing may serve as an

advisor. The OSC maintains lists of individuals who are willing to

serve as advisors and who have received training in the operation

of the Student Disciplinary System.

Upon receiving notice of a complaint and the accompanying list

of trained advisors, a respondent may select an advisor from this

list or choose any other University faculty member, staff member,

or student in good academic and disciplinary standing to advise

the respondent during the disciplinary process. If criminal

charges are pending against a respondent or, in the judgment of

the Ofﬁce of the University’s General Counsel, are reasonably in

prospect, the respondent’s advisor may be an attorney who is

not a member of the University community. In such instances,

the attorney will be expected to observe the procedures of this

Charter and comply fully and promptly with decisions of the

DHO or other University ofﬁcials or bodies charged with the

administration of this Charter in the same manner expected of

members of the University community.

An advisor may accompany any complainant, witness, or

respondent to, and may participate in, any meeting regarding

a disciplinary complaint. Advisors also may accompany

complainants, respondents, and witnesses to hearings, but

generally may not participate directly in such hearings (except as

provided in section II.F.4.f and g. (p.

) below). Advisors may,

however, quietly provide advice during the hearing and may also

make a brief statement at the conclusion of the hearing, before

the panel begins its deliberations.

Any advisor who fails to observe the procedures of this Charter

or comply fully and promptly with decisions of the DHO may, after

appropriate warning, be disqualiﬁed by the DHO from continuing

to serve. In the event of such disqualiﬁcation, the hearing may

proceed whether or not a replacement advisor is available or it

may be rescheduled at the sole discretion of the DHO. Any person

disqualiﬁed from serving as an advisor will be ineligible to serve

as an advisor for a period of two years. Repeated disruption of

disciplinary hearings or the disciplinary process by an advisor

may result in charges against the advisee of non-cooperation with

the Student Disciplinary System. If the advisor is a member of

the student body, faculty, or staff or the University, disciplinary

charges may be brought against the advisor in the appropriate

forum.

II. The Disciplinary Process

A. Bringing a Complaint to the Ofﬁce of Student Conduct

Any member of the University community, who believes that a

student has violated University rules, regulations or policies may

ﬁle a complaint, which must be in writing, with the OSC. Students,

faculty, staff members and trustees also may consult informally with

the OSC staff to determine whether they wish to ﬁle a complaint.

Others should consult with the Director about whether they may ﬁle a

complaint under the Student Disciplinary System. Complaints made

to other University ofﬁces or personnel also may be referred to the

OSC. A complaint asks the OSC to consider the matter for possible

referral or investigation.

The OSC promptly evaluates each complaint it receives to determine

whether the University’s Code of Student Conduct, Code of Academic

Integrity, or other applicable rules, regulations or policies may have

been violated. When the OSC determines that no such violation

may have occurred, it may dismiss the matter without further

investigation, or it may refer the parties to the University Mediation

Program or elsewhere to resolve their dispute. When the OSC

determines that a violation may have occurred, it may refer the matter

for mediation or undertake an investigation that may lead to the ﬁling

of formal charges against a student or students.

A complaint is not a charge that a student has violated University

regulations. Charges against a student are only made by the

University (not by complainants) following an investigation. Until

there is a determination to the contrary by voluntary agreement to

sanctions or by a Disciplinary Hearing Panel, there is a presumption

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IV.C. Charter of the University of Pennsylvania Student Disciplinary System

that an accused student has not violated University rules, regulations,

or policies.

When a complaint is ﬁled, the OSC promptly gives written notice of

the complaint and its allegations to the student(s) alleged to have

violated University rules. A copy of the Charter will be included with

the notice, as well as a list of potential advisors who have received

training from the OSC.

B. Resolving a Complaint by Mediation

The University encourages informal mediation whenever practical

and appropriate. If the parties agree, at any time the OSC may refer

any disciplinary matter other than an alleged violation of the Code

of Academic Integrity to the University Mediation Program (UMP) or

other resources for mediation. Members of the University community

may also contact the University Mediation Program directly.

It is within the sole discretion of the OSC to determine whether a

disciplinary complaint is suitable for mediation. If mediation fails or

new information comes to light about an unresolved matter then in

mediation, the OSC may proceed with an investigation and the ﬁling

of disciplinary charges. The OSC may also set a date after which it

will begin to investigate the original complaint or ﬁle charges if a

matter has not been successfully mediated.

If the OSC refers a complaint for mediation and both parties to the

dispute agree to participate, the UMP will assign a trained mediator

and advise the complainant(s) and respondent(s) in advance of

the date, time and place set for mediation. In order to resolve a

disciplinary matter by mediation, both the complainant and the

respondent must agree, ﬁrst, to participate in the mediation and,

second, to the proposed resolution.

If a student fails to comply with the terms of a mediation agreement,

the OSC may take steps to enforce the agreement (including use of

a Disciplinary Hold or the ﬁling of new charges under the Code of

Student Conduct) or may investigate the original complaint and bring

disciplinary charges under this Charter.

C. Investigating a Complaint

If, after a preliminary evaluation of a complaint, the OSC determines

that a violation of the Code of Student Conduct may have occurred

and if the complaint is inappropriate for mediation or mediation fails,

the OSC then will investigate the complaint and determine whether to

bring charges of a violation.

In the course of its investigation, the OSC may interview any

witnesses, including the respondent(s) or potential respondent(s).

The OSC will inform each witness that anything they say in such

interviews may be introduced as evidence at a hearing.

Except in extraordinary circumstances, or if the complainant makes

a request of the OSC to delay the investigation based on good cause,

the OSC will make every effort to complete its investigation within 60

days of the ﬁling of the complaint.

D. Filing Charges by the University Against a Student

In light of its investigation of a complaint, the OSC may ﬁle charges

against a student(s) of a violation(s) of the University’s Code of

Student Conduct, Code of Academic Integrity, or other University rules,

regulations, or policies. The OSC also may add charges beyond the scope

of the original complaint, may add additional students as respondents,

or may dismiss the original complaint as unfounded. If the OSC decides

to charge a student with a violation of University regulations, the OSC

must inform the respondent(s) of the charges in writing, identifying the

University rules, regulations, or policies alleged to have been violated. The

OSC will inform both respondent(s) and complainant(s) whether charges

have been ﬁled.

E. Resolving Charges by Voluntary Agreement to

Sanctions

Following the notice that charges have been ﬁled against a student,

the OSC may discuss with the respondent and the respondent’s

advisor what disciplinary sanction(s) would be appropriate to resolve

the matter by voluntary agreement to sanctions. The respondent

may accept, reject, or propose an alternative to the proposed

sanction(s) and may be accompanied and assisted by an advisor,

who may participate in these discussions. Statements made during

discussions about whether a respondent will enter into a voluntary

agreement to sanctions may not be introduced as evidence at any

subsequent hearing, but may provide a basis for further investigation

by the OSC.

A resolution by voluntary agreement to sanctions may be entered

into by written agreement at any time after a complaint has been

ﬁled and prior to a disciplinary hearing. All sanctions allowed under

this Charter are available to the OSC as part of a resolution by

voluntary agreement to sanctions. By agreeing to such a resolution, a

respondent waives further proceedings under this Charter.

Complainants and complainants’ advisors are not parties to voluntary

agreements to sanctions.

If, in the judgment of the OSC, a voluntary agreement to sanctions

is not reasonably in prospect, or if the respondent(s) reject(s) a

proposed sanction, the OSC may bring the disciplinary matter to a

hearing.

F. Resolving Charges by Disciplinary Hearing

Scheduling Disciplinary Hearings

If disciplinary charges are not resolved by a voluntary agreement

to sanctions, the Disciplinary Hearing Ofﬁcer (or designee)

promptly begins the process of scheduling the Disciplinary

Hearing, with due regard for the time required for all parties to

prepare for the hearing. The DHO will provide reasonable advance

notice in writing to the complainant(s), respondent(s), and

witnesses of the date, time, and place of the hearing and of the

names of the panel members assigned to hear the disciplinary

matter.

Hearings normally take place as soon as possible after the ﬁling

of charges, ordinarily within 30 days of the respondent’s request

for a hearing or OSC’s decision to bring the matter to a hearing.

Upon a showing of good cause by a party, the DHO may grant a

reasonable extension of any time limit relating to a disciplinary

hearing set forth in the Charter.

The DHO may expedite a Disciplinary Hearing in appropriate

circumstances, including disciplinary matters involving students

who have been placed on mandatory temporary leave of absence

or conditional attendance, graduating students, or students who

are about to take a leave of absence or to leave campus to study

elsewhere.

Disqualiﬁcation of Hearing Panel Members

Members of the Hearing Panel selected by the DHO (or designee)

should disqualify themselves from hearing a disciplinary matter

if they believe in good faith that their capacity for making

an objective judgment in the disciplinary matter is, or may

reasonably appear to be, impaired. Members should not disqualify

themselves for any other reason.

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The respondent(s) or the OSC may object for speciﬁc cause to

any panel member selected by the DHO. The objection must be

in writing and must be received by the DHO at least 48 hours in

advance of the date and time set for the hearing.

The DHO will rule upon all disqualiﬁcation requests and

objections to panel members. If the DHO decides that a challenge

is valid, or if there is a voluntary disqualiﬁcation, the DHO,

after notifying the respondent(s) and the OSC, will replace the

disqualiﬁed member with another panel member randomly

selected from the same category.

Pre-Hearing Exchanges and Testimony

Within a reasonable time before the hearing or any other time

frame speciﬁed by the DHO, the OSC and the respondent(s) will

exchange among themselves and with the DHO copies of all

exhibits to be presented, the names of witnesses to be called, and

a brief summary of the substance of testimony expected to be

presented to the Hearing Panel.

When the DHO believes that it will contribute to the expedition

and fairness of a Disciplinary Hearing, he or she may (but

need not) ask the OSC to prepare a written statement of its

case against the respondent(s) and give the respondent(s) a

reasonable opportunity to prepare a written response. The OSC

and the respondent(s) may also submit statements at their own

initiative. The statements and any accompanying exhibits may

be considered by the Hearing Panel, in addition to testimony,

arguments, or evidence presented at the actual hearing.

In exceptional circumstances, when a witness or exhibit does not

become known or available until immediately before the hearing,

the DHO may, at her or his discretion, permit the evidence to be

presented or may reschedule the hearing to a later time.

If a respondent or the OSC anticipates that a key witness will be

unavailable for a hearing, they may ask the DHO to preserve the

testimony of the witness on tape and present it as evidence at

the hearing. The OSC and the respondent(s) must be notiﬁed in

advance of the date, time and place of the taping. All parties who

would be permitted to question such a witness at a hearing may

question the witness at the taping.

Conduct of Hearings

Disciplinary hearings are not trials, and they are not constrained

by technical rules of procedure, evidence, or judicial formality.

They are designed to encourage open discussion among the

participants that promotes the Hearing Panel’s understanding

of the facts, the individuals involved, the circumstances under

which the incident occurred, the nature of the conduct, and the

attitudes and experience of those involved. The rules of evidence

applicable to legal proceedings do not apply to disciplinary

hearings. Information, including hearsay evidence, may be

considered if it is relevant, not unduly repetitious, and the sort of

information on which responsible persons are accustomed to rely

in the conduct of serious affairs.

The DHO presides over all hearings and decides all questions

about the admissibility of evidence and the conduct of

hearings. While the DHO may be present for the Hearing Panel’s

discussions to answer procedural questions, the DHO does not

deliberate or vote with the Panel regarding its ﬁndings or its

recommendation of sanctions.

Disciplinary hearings are held in private unless the respondent(s)

and the complainant(s) agree in writing to an open hearing.

The DHO may limit attendance at a hearing to ensure fair and

orderly proceedings. If a hearing is opened in accord with this

procedure, the DHO may, when necessary to maintain order or

to protect the rights of participants, declare the hearing closed

to the public. In a case involving important privacy interests,

the DHO may close a hearing or part of a hearing that has been

opened upon determining that the privacy rights of a participant

may be jeopardized.

Upon a showing that the required notice was provided, the

hearing against a respondent(s) may proceed in her or his

absence.

At the hearing, the OSC presents the results of the OSC’s

investigation of the complaint, calls witnesses to testify and

presents the University’s evidence against the student(s).

Members of the Hearing Panel may also call witnesses to testify

and may question any witness appearing before it. Respondents

may also call witnesses to testify and ask questions of all

witnesses.

A respondent is responsible for presenting his or her own case

before the Hearing Panel. However, at the discretion of the DHO,

the respondent’s advisor may be permitted to question witnesses

on behalf of a respondent or to address the Hearing Panel. The

DHO’s exercise of discretion in this matter will be guided by the

principles that govern disciplinary hearings, speciﬁcally fairness,

the need for orderly procedures, and the Hearing Panel’s duty to

understand the facts and parties in the disciplinary matter.

Complainants may attend the hearing, testify if they wish to do

so, and may be accompanied by an advisor. Except as described

in section II.J. (p.

) of this Charter, neither complainants

nor their advisors may call witnesses or present evidence or

arguments.

At the conclusion of the hearing, the OSC and the respondent(s)

or their advisor(s) may make brief statements. At the discretion

of the Disciplinary Hearing Ofﬁcer, the complainant(s) or their

advisor(s) may be permitted to make a brief statement. The time

allowed for such statements will be set by the DHO.

The OSC will arrange for a verbatim transcript or recording to be

made of all disciplinary hearings. The transcript or recording is

the property of the University of Pennsylvania and becomes part

of the record of the disciplinary proceedings.

Findings and Recommendations of the Hearing Panel

Only evidence presented at the hearing will be considered by the

Hearing Panel. The Hearing Panel will presume a respondent

innocent unless proven responsible for a violation by clear and

convincing evidence. All decisions of the Hearing Panel require a

majority vote.

Following the hearing, the members of the Hearing Panel meet to

discuss in private their ﬁndings, which consist of two parts:

a determination of whether the respondent is responsible for

any violation; and

ii.

if so, a recommendation of sanction(s).

The OSC may recommend to the Hearing Panel a sanction

to be imposed if the Hearing Panel ﬁnds the respondent(s)

responsible for a violation. The respondent(s) may respond to

the OSC’s proposed sanction(s). Before the Hearing Panel makes

its recommendation on sanctions, it will review any previous

disciplinary offenses by and sanctions against the respondent(s)

and sanctions imposed in other similar cases.

If the Hearing Panel determines that the respondent(s) is not

responsible for a violation, no sanction may be recommended

against the respondent(s) and the respondent may not be subject

to further proceedings under this Charter on the same charge(s).

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IV.C. Charter of the University of Pennsylvania Student Disciplinary System

If the Hearing Panel ﬁnds that a student is responsible for a

violation of University rules or regulations, it will recommend to

the Provost appropriate sanctions. Only the Provost (or designee),

acting on behalf of the University, may actually impose a sanction

on a student. The Provost (or designee) will not impose a

sanction until after any appeal of the Hearing Panel’s decision

has been decided by the DAO.

Notice of Hearing Panel Decision

The Hearing Panel will promptly transmit its decision, including its

ﬁndings and recommendation regarding sanctions, in writing to the

DHO, the OSC, the respondent(s) and the Provost as soon as possible

after the end of the hearing.

G. Appealing a Hearing Panel’s Decision

The Disciplinary Appellate Ofﬁcer (DAO) has exclusive jurisdiction

to decide appeals. Appeals are based solely on the record of the

disciplinary hearing and the written submissions and responses of

the respondent(s) and the OSC.

Only respondent(s) may appeal the Hearing Panel’s ﬁndings of

responsibility except where applicable laws or regulations may

extend this right to complainants. Both the respondent(s) and the

OSC may appeal the Hearing Panel’s recommendation of sanction(s).

An appellant must submit any appeal to the DAO in writing within 10

days after the Hearing Panel has rendered its opinion. The appeal

must state in detail the speciﬁc grounds upon which it is based and

must be sent to the OSC and respondent(s), as appropriate.

When the appeal is received, the OSC provides the DAO with a copy

of the respondent’s charge letter, a copy of the Hearing Panel’s

ﬁndings, a verbatim transcript or tape recording of the Disciplinary

Hearing, and any exhibits considered by the panel in reaching its

recommendations. A response to an appeal must be in writing and

must be submitted to the DAO within 10 days from the date the

appeal is ﬁled.

Appellate review is limited to allegations of material and prejudicial

procedural error in the conduct of hearings, error in the interpretation

or application of relevant University regulations, consideration of

new evidence sufﬁcient to alter the Hearing Panel’s ﬁndings or

severity of the recommended sanctions. If the DAO ﬁnds sufﬁcient

basis, he or she may reverse or modify the Hearing Panel’s ﬁndings

or proposed sanctions, or may remand the disciplinary matter for

further investigation by the OSC or a new hearing before a new

Hearing Panel. However, the DAO may not recommend a more

severe sanction(s) unless the OSC has appealed the sanction(s)

recommended by the Hearing Panel.

After considering an appeal, the Disciplinary Appellate Ofﬁcer will

promptly issue his or her decision in writing and will provide copies

to the OSC, the DHO, the Provost, the respondent(s) and other

appropriate parties.

H. Imposing Sanctions on a Student

Sanctions recommended against a respondent by a Hearing Panel or

the DAO are imposed by the Provost (or designee) and may include

any reasonable sanction, including, but not limited to, the following:

•

Warning:

A Warning is a written admonition given by the OSC on

behalf of the University in instances of minor misconduct.

•

Reprimand:

A Reprimand is written censure for violation of the

University’s rules, regulations, or policies, given by the OSC on

behalf of the University, which includes notice to the student

that continued or repeated conduct violations will result in the

imposition of more serious sanctions.

•

Fine:

A monetary Fine may be levied as a disciplinary sanction

and is payable to the Trustees of the University of Pennsylvania.

(Not appropriate in cases of academic integrity violations.)

•

Restitution:

Restitution is reimbursement for the damage, loss,

or misappropriation of University, private or public property or

compensation for injury to individuals. Restitution may take the

form of monetary payment, property, or appropriate service. (Not

appropriate in cases of academic integrity violations.)

•

Disciplinary Probation:

Disciplinary Probation may be imposed

for a speciﬁed period or indeﬁnitely (i.e., for as long as and

whenever a student is a full- or part-time student at the University

of Pennsylvania). Probation may be imposed for a single

instance of misconduct or for repeated minor misconduct. Any

future conduct or academic integrity violation by a student

on Disciplinary Probation, found to have occurred during the

probationary period, may be grounds for suspension or, in

especially serious instances, expulsion from the University.

•

Withdrawal of Privileges:

Withdrawal of Privileges is the denial

of speciﬁed privileges or the ability to participate in speciﬁed

activities for a designated period of time.

•

Suspension:

Suspension is the termination of student status

and separation from the University until a speciﬁed date.

Suspension means the loss of all rights and privileges normally

accompanying student status. While on disciplinary suspension,

students may not obtain academic credit at the University or

elsewhere toward completion of a University of Pennsylvania

degree. Students are eligible to return to the University after the

speciﬁed suspension term has elapsed. Suspension is imposed

in instances of serious misconduct; it is generally the minimum

sanction imposed for a violation of the Code of Academic

Integrity.

•

Indeﬁnite Suspension:

An Indeﬁnite Suspension is termination

of student status and separation from the University for an

unspeciﬁed period, without an automatic right of return to the

University as a student (though speciﬁc conditions for return

as a student may be speciﬁed). When the conditions of an

Indeﬁnite Suspension have been fulﬁlled, the student must make

a formal request, as speciﬁed in the conditions, to return to

student status. Indeﬁnite suspension is imposed in instances

of extremely serious misconduct or in instances of continued

serious misconduct following the imposition of probation or

suspension for a speciﬁed period.

•

Expulsion:

Expulsion is a permanent termination of student

status and permanent separation from the University of

Pennsylvania. Expulsion is imposed in instances of the most

serious misconduct or in instances of continued serious

misconduct following the imposition of probation or suspension.

In addition to the sanctions deﬁned above, students may be required

to perform a designated number of hours of University or other

community service or to utilize University or other educational or

counseling services related to the nature of the misconduct.

Sanctions may be imposed alone or in combination with other

sanctions. The Disciplinary Hearing Panel or the DAO may

recommend whether the sanctions should appear on the transcript of

a respondent and if so, for how long.

After the imposition of sanctions, a faculty member involved in an

academic integrity matter will be informed of the outcome of the

disciplinary proceedings. If the student has been found not to be

responsible for an academic integrity violation, the instructor should

assign a grade (which may differ from the grade originally assigned)

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101

based on the student’s academic performance in the course. If

the student has been found responsible for an academic integrity

violation, the instructor may assign any grade the instructor deems

appropriate. In the event that the student believes the ﬁnal grade

is unfair or fails to take account of the outcome of the disciplinary

proceeding, the student may appeal the grade through the existing

academic grievance procedure for the evaluation of academic work

established by each School and academic department.

I. Fulﬁlling Sanctions Imposed by the University

Under the Code of Student Conduct, students are required to comply

with all disciplinary sanctions. Failure to do so constitutes a violation

of the Code and is itself subject to disciplinary proceedings by the

OSC.

The OSC monitors the implementation and fulﬁllment of sanctions. In

performing this duty, the OSC will have the cooperation of the Division

of University Life, the respondent’s Dean, and other appropriate

University ofﬁces. No sanction will be enforced while an appeal is

pending.

J. Special Procedures for Sexual Misconduct Cases

In sexual misconduct and other sex discrimination cases, the OSC will

follow applicable federal law, including Title IX of the Higher Education

Amendments of 1972, as amended.

The complainants in sexual misconduct cases have rights and

responsibilities similar to the respondents under this Charter. The

time frames set for respondents also apply to complainants and when

notice is required to be provided to the respondent, similar notice will be

provided to the complainant.

Speciﬁed Rights of Complainants in Sexual Misconduct Cases

The complainant will have an opportunity to participate in the

entire disciplinary process, including the opportunity to provide

information and witnesses during the investigation to participate in

the preliminary exchange of information, to attend the disciplinary

hearing, and to present evidence and witnesses at the hearing.

The complainant will have an opportunity equal to the respondent to

have others present during meetings and at the disciplinary hearing.

The complainant will be informed of the outcome of his or her

complaint and any appeal.

Investigation and Pre-Hearing Stages

An OSC staff member will ordinarily meet with the complainant

to hear or clarify his or her account of the incident and to review

the disciplinary process. To initiate a formal complaint, the

complainant must submit a written complaint.

OSC will make every effort to complete its investigation within

60 days from the ﬁling of a formal complaint. In extraordinary

cases, such as when the gathering of information is completely

under the control of law enforcement, OSC’s investigation may

be delayed. In the event of such delay, OSC will advise the

complainant of the reason for the delay. An investigation may

also be delayed upon the complainant’s request based on good

cause.

During the investigation, and until resolution of the matter,

interim restrictions, including restrictions on contact between

the complainant and the respondent, may be imposed by OSC.

Nothing in this Charter precludes other University ofﬁcials from

taking appropriate interim measures before a disciplinary matter

is resolved.

The complainant will be notiﬁed of the outcome of the

investigation. Further, if there is a voluntary agreement to

sanctions, the complainant will be informed of the provisions of

the agreement that directly relate to the complainant.

Subject to any Family Educational Rights and Privacy Act

(FERPA) limitations, the complainant will have a similar

opportunity as the respondent to review evidence to be presented

at the hearing.

Disciplinary Hearings

The complainant will have a similar opportunity as the

respondent to object to panel members for cause. In addition,

the complainant will have an equal opportunity to prepare a

written statement in advance of the hearing and to respond to

any written statement prepared by the respondent or OSC before

the hearing.

The complainant’s advisor (who must be a member of the

University community) may participate in a hearing to the same

extent as the respondent’s advisor. At the discretion of the DHO, a

complainant’s advisor may be permitted to question witnesses.

Alternative testimony options will be offered to complainants,

such as placing a privacy screen in the hearing room or allowing

the complainant to testify from another room via closed circuit

television. Generally, questions between the complainant and the

respondent will be relayed through the DHO, but if both agree,

they can address each other directly. The DHO reserves the right

to exclude questions he/she deems irrelevant or duplicative.

The complainant may call witnesses (including character

witnesses) at the hearing, ask questions of all witnesses, and

present evidence.

The hearing panel will presume the respondent not responsible

unless proven responsible by a preponderance of the evidence.

The complainant may respond to the proposed sanctions OSC

submits to the hearing panel.

Appeal of a Hearing Panel Decision

The complainant may appeal the hearing panel’s ﬁndings and/

or recommended sanctions. In addition, the complainant may

respond to an appeal by the respondent or OSC.

The complainant will be provided with written notice of the

outcome of the appeal at the same time as the respondent.

III. Additional Matters

A. Administration of the Disciplinary System

The Provost is responsible for implementation of this Charter,

administrative oversight of the Student Disciplinary System, including

the OSC, and ensuring that the Student Disciplinary System functions

fairly and in furtherance of the educational mission of the University.

The Provost may instruct the OSC regarding the handling of speciﬁc

cases, but he or she may not so instruct the DHO, the DAO, or the

members of Disciplinary Hearing Panels.

When circumstances warrant, the OSC may take such administrative

steps as may be necessary and feasible to effect the prompt

resolution of a disciplinary matter, including, but not limited to, tape

recording the testimony of witnesses who may be unavailable at

the time of hearing, making special arrangements to ensure the

attendance of complainants, respondents, witnesses, or other

participants at a hearing and scheduling hearings outside of the

normal academic year.

In any disciplinary matter in which a member of the Student

Disciplinary System cannot perform her or his duties under this

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IV.C. Charter of the University of Pennsylvania Student Disciplinary System

Charter, an alternate may be designated by the Provost using the

procedures appropriate to that individual’s position in the system. In

addition, when the Provost determines that circumstances warrant,

such as (but not limited to) when a conflict of interest or a particularly

complex or controversial disciplinary matter arises, the Provost

may appoint a special OSC staff member, a special Disciplinary

Hearing Ofﬁcer, or a special Disciplinary Appellate Ofﬁcer using the

procedures appropriate to the position.

B. Reports to the University Community

Subject to the limitations imposed by law and the University’s policies

on the conﬁdentiality of student records and information, the OSC

and the University Honor Council, in consultation with the Provost,

will make periodic reports to inform the University community about

the character and extent of the work of the Disciplinary System,

including the nature of violations of University rules and regulations

and the sanctions imposed. The reports of the OSC will deal both with

disciplinary matters that go to hearing and with disciplinary matters

that are resolved before hearing, and will include such information as

the total number of disciplinary matters handled during the preceding

year broken down by type of resolution (e.g., mediation, voluntary

agreement to sanctions, hearing, etc.), by type of violation, by type of

sanction(s) imposed, by whether or not the respondent(s) were found

responsible for a violation, and so forth.

With the approval of the Provost, the OSC may also make

extraordinary reports to the University community concerning the

outcome of certain exceptional disciplinary matters, subject to

the limitations imposed by law and the University’s policies on the

conﬁdentiality of student records and information.

C. Disciplinary Holds

At any time after the ﬁling of a complaint, the OSC, after consulting

with the student’s academic dean, may place a “Disciplinary Hold” on

the academic and/or ﬁnancial records of any student for the purpose

of preserving the status quo pending the outcome of proceedings,

enforcing a disciplinary sanction, or ensuring cooperation with the

Student Disciplinary System. A Disciplinary Hold may prevent, among

other things, registration, the release of transcripts, and the awarding of a

degree.

D. Mandatory Leave of Absence and Conditional

Attendance

In extraordinary circumstances, when a student’s presence on campus

is deemed by the University to be a threat to order, health, safety, or

the conduct of the University’s educational mission, the Provost (or

designee), in consultation with the student’s Dean or Associate Dean,

may place the student on a mandatory temporary leave of absence or

impose conditions upon the student’s continued attendance, pending a

hearing of disciplinary charges. When reasonably possible, the student

will be provided with an opportunity to be heard before a decision is made

by the Provost (or designee) to impose a mandatory temporary leave of

absence or conditions on the student’s attendance. At the respondent’s

request, and where feasible, the OSC may expedite the investigation of

a complaint and the disciplinary hearing against a student placed on a

mandatory temporary leave of absence or conditional attendance.

E. Civil or Criminal Proceedings

The University may proceed with disciplinary proceedings against

a student under this Charter regardless of possible or pending civil

claims or criminal charges arising out of the same or other events. The

OSC, with the concurrence of the Provost and after consultation with

the University’s General Counsel, will determine whether to proceed

with charges against a student who also faces related charges in

a civil or criminal tribunal. If the University defers proceeding with

disciplinary charges against a student in light of related charges in a civil

or criminal tribunal, the University may at any subsequent time proceed

with disciplinary proceedings against that student under this Charter

irrespective of the time provisions set forth in this Charter.

F. Disciplinary Records

Maintenance of Records

Except as may be otherwise provided by applicable law, records of

all complaints, disciplinary proceedings, mediations, and voluntary

agreements to sanctions are maintained by the OSC in accordance

with the University’s Protocols for the University Archives and

Records Center and University policies on the conﬁdentiality and

maintenance of student records.

Conﬁdentiality

Except as may be otherwise provided by applicable law, all

disciplinary proceedings, the identity of individuals involved in

particular disciplinary matters, and all disciplinary ﬁles, testimony,

and ﬁndings are conﬁdential, in accordance with University policies

and federal law concerning the conﬁdentiality of student records.

However, no provision of this Charter or the University’s policies on

conﬁdentiality shall be interpreted as preventing a student from

seeking legal advice.

Policy Violation of Conﬁdentiality

Failure to observe the requirement of conﬁdentiality of a disciplinary

hearing by any member of the University community, other than

the respondent, constitutes a violation of University rules and may

subject the individual to the appropriate procedures for dealing

with such violations. The respondent may disclose conﬁdential

information pertaining to him- or herself but may not violate the

conﬁdentiality of others. If the respondent discloses, causes to

be disclosed, or participates in the disclosure of information that

is conﬁdential, any person whose character or integrity might

reasonably be questioned as a result of such disclosure shall have

the right to respond in an appropriate forum, limited to the subject

matter of the initial disclosure.

G.Release of Information on Disciplinary Proceedings

To provide students involved in disciplinary matters with appropriate

liaison with their School ofﬁces in regard to their academic work,

the Dean or appropriate Associate Dean of the School(s) of the

respondent(s) will be conﬁdentially informed when a complaint is

ﬁled, when a sanction is imposed, or when a disciplinary complaint

is otherwise resolved by the Student Disciplinary System. When a

sanction is imposed, the Director of Career Planning and Placement

may be informed by the OSC if the sanction(s) is reportable outside

the University. When a transcript notation is required as part of a

sanction, the University Registrar is also informed and required to

implement the sanction as directed by the OSC on behalf of the

Provost.

As required by law, in disciplinary matters involving allegations of

sexual offenses, the complainant(s) will be informed of the outcome

of the proceeding, including voluntary agreement to sanctions.

H. Reportability of Sanctions

Subject to applicable law and the University’s policies on the

conﬁdentiality of student records and information, any disciplinary

sanction may be reportable outside the University of Pennsylvania,

subject to speciﬁc policies governing the reporting of sanctions

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103

adopted by the Council of Undergraduate Deans for undergraduate

students and the Council of Graduate Deans for graduate and

professional students.

Resolution of disciplinary charges by voluntary agreement to

sanctions is treated like a ﬁnding of responsibility and is reportable

in the same manner as sanctions imposed following a Disciplinary

Hearing.

I. Amendment of the Charter

Amendments to this Charter may be recommended by the UHC, OSC,

University Council, Faculty Senate Executive Committee, or other

appropriate members of the University community and proposed by

the Provost. Amendments take effect upon the approval of the Council

of Deans, except that the Council of Deans may at its discretion refer

proposed amendments to the Deans and faculties of the individual

Schools for approval.

(Source: Almanac, April 10, 2012, Volume 58, No. 12 (http://

www.upenn.edu/almanac/volumes/v58/n29/discipline.html))

IV.D Faculty Authority to Assign

Grades and Academic Integrity

(Source: Ofﬁce of the Provost,

Almanac, September 10, 1996

(

https://

almanac.upenn.edu/archive/v43/n03/codechar.html#faculty

))

The Student Disciplinary Charter is based on the assumption that it is the

obligation and right of faculty members to assign grades for academic

work submitted to them by students under their supervision and that

faculty members should grade student work, using their best judgment

about the quality and propriety of that work, independently of disciplinary

procedures. The present statement makes clear the relationship between

grading and disciplinary action in cases in which a faculty member

believes that a student did not fulﬁll an assignment in accord with the

Code of Academic Integrity.

The Disciplinary Charter rests on the principle that faculty members

have wide authority to judge the academic work of students and have a

general responsibility for the academic progress of students, so much

as lies within the power of faculty. Furthermore, the charter assumes

that violations of the norms of academic integrity fall along a continuum

from minor to major and that not all violations need to be treated as

disciplinary cases. The authority and responsibility of faculty members

require them to judge the relative severity of a violation. Good individual

judgment and institutional practice will help faculty members make the

judgment about when to treat a case as requiring disciplinary action.

The distinction between academic evaluation and disciplinary action is

also important. Faculty members have the authority to make academic

judgments in relation to their students and to make decisions in the

interests of furthering their students’ education. Only the institution,

acting through its formal processes, may discipline a student. Grades

are not sanctions, even if they arise from a judgment that a student

has violated a norm of academic integrity. In such cases, the grade

may reflect the faculty member’s view that a piece of work was done

inappropriately, but it represents a judgment of the quality of the work,

not a record of discipline for the behavior. There are many ways to do

work inappropriately or badly, resulting in low or failing grades. The policy

of the charter is to preserve the faculty member’s right to grade work

on the basis of all of its qualities and to make the decision to pursue

disciplinary action a separate matter.

Students who believe that they have been graded unfairly have recourse

of appeal through the grade appeal procedures established by each

school. The charter explicitly recognizes the right of students to appeal

grades. The appeal of a grade given because a faculty member believed

that the student violated the norms of academic integrity is, for the

purposes of the charter, no different from other grade appeals.

IV.E. School Policies and Practices

Each of the twelve schools of the University has regulations, policies,

and procedures speciﬁc to the undergraduate and graduate students

within that school. These policies are stated in the ofﬁcial bulletins and

announcements issued by each school and are available in the school

and departmental ofﬁces. Faculty members and administrators who

teach in the College of General Studies, in executive education programs

and during the summer sessions should be aware that each of these

divisions issues its own bulletin and that some policies may differ from

those stated in the undergraduate and graduate studies bulletins.

Grading policies are strictly within the province of the faculties of the

several schools. Students who believe that they have been graded

unfairly have recourse of appeal through the grade appeal procedures

established by each school.

IV.F. Rules Governing Final

Examinations

(Source: Provost Memorandum 2-67, April 19, 1967; Ofﬁce of the Provost,

Almanac, May 1, 1979; revised, Almanac, November 21, 1995; revised,

Almanac, November 25, 2003; revised, Almanac, November 22, 2005; revised,

Almanac, November 18, 2008

(

https://almanac.upenn.edu/archive/

volumes/v55/n13/exams.html

); revised,

Almanac, March 31, 2015

)

No instructor may hold a ﬁnal examination nor require the submission

of a take-home ﬁnal exam except during the period in which ﬁnal

examinations are scheduled; when necessary, exceptions to this

policy may be granted for postponed examinations (see 3 and 4

below). No ﬁnal examinations may be scheduled during the last week

of classes or on reading days.

No student may be required to take more than two ﬁnal examinations

on any calendar day during the period in which ﬁnal examinations are

scheduled. If more than two are scheduled, the student may postpone

the middle exam. If a take-home ﬁnal exam is due on a day when

two ﬁnal examinations are scheduled, the take-home exam shall be

postponed by one day.

Examinations that are postponed because of conflicts with other

examinations, or because more than two examinations are scheduled

on the same day, may be taken at another time during the ﬁnal

examinations period if the faculty member and student can agree on

that time. Otherwise, they must be taken during the ofﬁcial period for

postponed examinations.

Examinations that are postponed because of illness, a death in the

family, for religious observance or some other unusual event, may be

taken only during the ofﬁcial periods: the ﬁrst week of the spring and

fall semesters. Students must obtain permission from their Dean’s

ofﬁce to take a postponed exam. Instructors in all courses must

be willing to offer a make-up examination to all students who are

excused from the ﬁnal examination.

No instructor may change the time or date of a ﬁnal exam without

permission from the appropriate Dean.

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104

IV.G. Reporting of Final Grades

No instructor may increase the time allowed for a ﬁnal exam beyond

the scheduled two hours without permission from the appropriate

Dean.

No classes or required class activities may be held during the reading

period.

The ﬁrst examination of the day begins at 9 a.m. and the last

examination concludes by 8 p.m. There will be one hour between

exam time blocks.

All students must be allowed to see their ﬁnal examination. Exams

should be available as soon as possible after being graded with

access ensured for a period of at least one regular semester after

the exam has been given. To help protect student privacy, a student

should have access only to his or her own exam and not the exams of

other students. Therefore, for example, it is not permissible to leave

student exams (or grades or papers) in publicly accessible areas.

10.

Students may not be asked for their Social Security Numbers.

Instructors may not publicly display a student’s Penn ID or any

portion of the Social Security Number, nor use name, initials or

any personally identiﬁable information to post grades. Even when

an identiﬁer is masked or absent, grades may not be posted in

alphabetical order, to protect student privacy.

11.

Final exams for the College of Liberal and Professional Studies (LPS)

courses must be given on the regular class meeting night during the

week of ﬁnal examinations. No change in scheduling is permitted

without unanimous consent of all students in the class and the

director of LPS. LPS ﬁnal exams may not be administered during the

last week of class or on a reading day.

In all matters relating to ﬁnal exams, students with questions should

ﬁrst consult with their Dean’s ofﬁces. Faculty wishing to seek exceptions

to the rules also should consult with their Dean’s ofﬁces. Finally, the

Council of Undergraduate Deans and SCUE urge instructors to see that all

examinations are actively proctored.

IV.G. Reporting of Final Grades

(Source: Provost Memorandum 7-70, April 5, 1970; revised, Ofﬁce of the

Provost, December, 1992)

Grades in each course should be reported to the Registrar and the school

ofﬁces within 72 hours of the last day of exams.

The validity of a grade for any student is determined by the home school

of that student, not the home school of the faculty member teaching

the course. For example, the grade of I (Incomplete) is governed by very

speciﬁc regulations of the faculty in the student’s home school and

may be given to students of those schools only if those conditions are

satisﬁed. If there is any doubt as to the validity of a grade for a particular

student, the Dean’s ofﬁce of that student should be consulted.

IV.H. Policy on Secular and Religious

Holidays

(Source: Provost Memorandum 9-63, September 13, 1963; revised,

Provost’s Memorandum 6-68, September 19, 1968; revised, Ofﬁce of

the Provost, Almanac, May 9, 1989; revised, Almanac, January 15, 1991;

revised, Almanac, March 18, 1997; revised, Almanac, September 4, 2001;

revised, Almanac, September 7, 2010; revised,

Almanac, August 29,2017

(

https://almanac.upenn.edu/articles/policy-on-secular-and-religious-

holidays-2017-08-28/

))

1. The University recognizes/observes the following secular holidays:

Martin Luther King, Jr. Day, Memorial Day, Juneteenth, July 4,

Thanksgiving and the day after, Labor Day, and New Year’s Day.

2. The University also recognizes that there are several secular and

religious holidays that affect large numbers of University community

members, including Christmas, Rosh Hashanah, Yom Kippur, Election

Day in November, the ﬁrst two days of Passover, and Good Friday. In

consideration of their signiﬁcance for many students, no examinations

may be given and no assigned work may be required on these days.

Students who observe these holidays will be given an opportunity to

make up missed work in both laboratories and lecture courses. If an

examination is given on the ﬁrst class day after one of these holidays, it

must not cover material introduced in class on that holiday.

Faculty should realize that Jewish holidays begin at sundown on the

evening before the published date of the holiday. Late afternoon exams

should be avoided on these days. Also, no examinations may be held on

Saturdays or Sundays in the undergraduate schools unless they are also

available on other days. Nor should seminars or other regular classes

be scheduled on Saturdays or Sundays unless they are also available at

other times.

Additionally, no examinations may be given or assignments due on the

days of Fall Break, Thanksgiving Break, Winter Break, or Spring Break

for programs that follow the main University Academic Calendar, with

the exception of clinicals, global experiences, and approved academic

experiences.

3. The University recognizes that there are other holidays, both religious

and secular, which are of importance to some individuals and groups

on campus. Such occasions include, but are not limited to, Sukkot,

the last two days of Passover, Shavuot, Shemini Atzeret and Simchat

Torah, Lunar New Year, the Muslim New Year, Diwali, Navaratri, Rama

Navami, Paryushan, and the Islamic holidays Eid Al-Fitr and Eid Al-

Adha. Students who wish to observe such holidays must inform their

instructors within the ﬁrst two weeks of each semester of their intent to

observe the holiday even when the exact date of the holiday will not be

known until later so that alternative arrangements convenient to both

students and faculty can be made at the earliest opportunity. Students

who make such arrangements will not be required to attend classes or

take examinations on the designated days, and faculty must provide

reasonable opportunities for such students to make up missed work and

examinations. For this reason it is desirable that faculty inform students

of all examination dates at the start of each semester. Exceptions to the

requirement of a make-up examination must be approved in advance by

the undergraduate dean of the school in which the course is offered.

IV.I. Guidelines for Addressing

Academic Issues of Students with

Disabilities

(Source: Provost's Memorandum, Almanac, September 10, 1991; revised,

Ofﬁce of the Provost, Almanac, October 4, 1994; revised,

Almanac, December

7, 1999

(

https://almanac.upenn.edu/archive/v46/n14/ORdisability.html

);

revised, Almanac, July 14, 2015)

The University of Pennsylvania is committed to providing access and

equal educational opportunities to all students, including students

with disabilities. Penn does not discriminate against students with

disabilities. The University provides reasonable accommodation to

a student's known disability in order to afford that student an equal

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105

opportunity to participate in all University-sponsored academic and extra-

curricular programs, activities, and services.

Reason for Policy Guidance

This policy guidance, known as the

Provost's Memorandum

, serves two

purposes:

•

to provide guidance to faculty and staff so that they may reasonably

accommodate and support students with disabilities without

compromising academic standards and requirements

•

to assure students with disabilities that the University will provide

access to all University-sponsored programs, beneﬁts and activities

through reasonable accommodation and program accessibility as

required under the Rehabilitation Act of 1973, and the Americans with

Disabilities Act of 1990, as amended (“ADA”)

Protection from Discrimination

The Rehabilitation Act and the ADA prohibit discrimination against people

with disabilities by institutions like Penn that receive or beneﬁt from

federal ﬁnancial assistance. These and other laws require that reasonable

accommodations be provided to otherwise qualiﬁed individuals with a

disability.

Some Key Deﬁnitions

Disability

–A person with a disability is deﬁned as an individual who

has a physical or mental impairment that substantially limits one or

more major life activities,

has a record of such an impairment, or

is regarded as having such an impairment.

Examples of recognized disabilities include, but are not limited to,

blindness, deafness, paralysis, diabetes, epilepsy, lupus, bipolar disorder,

generalized anxiety disorder, HIV/AIDS, speciﬁc learning disabilities,

autism spectrum disorder and Attention Deﬁcit Hyperactivity Disorder

(ADHD).

Reasonable Accommodation

–A reasonable accommodation is a

modiﬁcation or adjustment that enables an otherwise qualiﬁed individual

with a disability full access to participation in University-sponsored

programs. These modiﬁcations should not fundamentally alter the

purpose or requirements of the course or program. Reasonable

accommodations are determined on an individual basis and take into

account the functional limitations of the impairment. Accommodations

may vary from class to class depending upon course content and format.

They are intended to be effective and reasonable; they may not be exactly

what the student wishes or requests.

Appropriate Documentation

–Appropriate documentation is a written

evaluation or report provided by a clinician in a speciﬁc profession or

area of expertise who is considered qualiﬁed to make the diagnosis.

The documentation must be current, comprehensive, and may

include clinical and social histories from parents, counselors, and

specialists. A diagnosis must be included. Documentation must identify

the student's speciﬁc functional limitations within the academic

setting and must show substantial limitation compared to most

people. The documentation should conform to well-established

practices in the speciﬁc area(s)/ﬁeld(s). For more information, see

Documentation Guidelines (https://www.vpul.upenn.edu/lrc/sds/

ps_documentation_guidelines.php) on the Student Disabilities Services

website.

Responsible University Ofﬁce

Students with disabilities and temporary conditions are served by the

Ofﬁce of Student Disabilities Services (SDS). The ofﬁce is located in

the Weingarten Learning Resources Center (WLRC), a department under

the Ofﬁce of the Vice Provost of University Life. SDS is responsible for

assessing all student requests for accommodations and determining

reasonable accommodations for students with disabilities.

The Ofﬁce of Student Disabilities Services is available to assist faculty

and professional staff with the provision of academic accommodations

and for consultation regarding students with disabilities.

Phone: 215-573-9235

FAX: 215-746-6326

TYY: 215-746-6320

vpul-sdsmail@pobox.upenn.edu

Accommodation Procedures

Responsibilities of Students

Students with disabilities who seek accommodation at Penn are

responsible for self-identifying with SDS. Identiﬁcation may take place

upon admission or at any time during the student's course of study.

Students requesting accommodations are responsible for providing

documentation, at their own expense, according to the guidelines

published on the SDS website: https://www.vpul.upenn.edu/lrc/

sds/ps_documentation_guidelines.php. SDS may request additional

information if the documentation provided does not support the

existence of a disability or the need for the accommodations requested.

The SDS Documentation Review Committee thoroughly reviews the

documentation and accommodations are determined through an

interactive process with input from the student. Consultation with

faculty may be important in determining how to best accommodate a

student in a speciﬁc course. A determination from the Committee may

take four to six weeks, or longer if additional information is needed. For

examples of reasonable accommodations, please see the SDS website at:

http://www.vpul.upenn.edu/lrc/sds/academic_accommodations (http://

www.vpul.upenn.edu/lrc/sds/academic_accommodations/).

Students who are approved for accommodations must authorize SDS to

inform professors about their approved accommodations. They must

also make online requests to SDS for individual exam accommodations

each semester. Students are encouraged to introduce themselves to

professors to initiate a dialogue about their particular needs.

Responsibilities of Faculty and Staff

Faculty and staff are responsible for ensuring equity and access in

their programs and classrooms. The SDS approved accommodations

should not fundamentally alter the academic requirements essential

to a course, program of study, or to licensing prerequisites. It is also

important to recognize that students with disabilities must reach the

same performance standards to fulﬁll degree requirements as their non-

disabled peers. Accommodations provide students with disabilities equal

access, not an unfair advantage.

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106

IV.J. Policy on the Conﬁdentiality of Student Records

Instructors are required to accommodate students only after receiving an

email from SDS indicating the accommodations that have been approved.

A statement about services for students with disabilities should be

included in the syllabus for each course. Below is a sample syllabus

statement:

Sample Syllabus Statement

The University of Pennsylvania provides reasonable accommodations to

students with disabilities who have self-identiﬁed and received approval

from the Ofﬁce of Student Disabilities Services (SDS). If SDS has approved

your request for accommodations, please make an appointment to meet

with me as soon as possible in order to discuss the arrangements for your

accommodations.

If you have not yet contacted Student Disabilities Services, and would like to

request accommodations or have questions, you can make an appointment

by calling 215-573-9235. The ofﬁce is located in the Weingarten Learning

Resources Center at Stouffer Commons, 3702 Spruce Street, Suite 300.

Please visit the SDS website at

http://www.vpul.upenn.edu/lrc/sds/

index.php

(

http://www.vpul.upenn.edu/lrc/sds/

). SDS services are free

and conﬁdential.

Accommodated Exams

In order to effectively manage the logistics of exam accommodations,

instructors are expected to respond promptly to SDS emails requesting

information about exam accommodations. Although the exam may

not be written until shortly before the exam date, other details are

needed by the SDS accommodations staff as early as possible in

order to arrange for exam administration and inform students of the

arrangements. Professors are encouraged to provide SDS with exams

as early as possible prior to the exam to allow SDS time to prepare exam

materials. Exams are locked in a secure location until the exams are

being administered.

In the event that questions arise during the administration of the exam at

SDS, it is important that SDS has contact information for the instructor or

TA (phone, text and/or email).

The

Standards for Accommodating Exams for Students with Disabilities

available on the SDS website at: http://www.vpul.upenn.edu/lrc/sds/

StandardsforAccommodatingExams.php. This document provides

guidelines for accommodated exams that are administered by faculty or

their designees.

Note-taking Announcements

Faculty may be asked to assist SDS by identifying note-takers through an

announcement or email to the class and referring interested note-takers

to SDS. A template for the email will be included when SDS contacts

faculty regarding note-taker accommodations.

Accessibility of Information and Course Materials

Faculty should collaborate with their department ofﬁces and SDS to

ensure that their course materials, presentations, audio-visual materials

and exams are available in an accessible format for students with

sensory and print disabilities.

Conﬁdentiality

All disability documentation provided by the student is conﬁdential and

remains in the Ofﬁce of Student Disabilities Services for the purpose of

determining reasonable accommodations.

Students may not request

accommodations from faculty that have not been approved by SDS. If

documentation is provided to the instructor, it should be returned to the

student and the student should be referred to SDS.

Faculty should refrain from discussing a student's disabilities and

accommodations in front of the class, in the presence of other students,

or to faculty or staff not directly involved in the accommodation process.

Reconsideration Process

Students may request reconsideration of the SDS accommodation

determination through the

SDS Reconsideration Process

found

on the website at: https://www.vpul.upenn.edu/lrc/sds/

reconsiderationprocess.php.

Concerns and Complaints

The Ofﬁce of Equal Opportunity Programs is responsible for overseeing

the University’s implementation of its equal opportunity and

nondiscrimination obligations arising under Federal, Commonwealth, and

local laws. Any concerns or complaints should be addressed to:

The Ofﬁce of Equal Opportunity Programs

Franklin Building

3451 Walnut Street, Room 421

Philadelphia, PA 19104-6205

(215) 898-6993 (voice)

(215) 746-7088 (fax)

https://oeop.upenn.edu/

Additional Information

Related policies and procedures are available on the SDS website (http://

www.vpul.upenn.edu/lrc/sds/) in the section for Faculty and Staff.

IV.J. Policy on the Conﬁdentiality of

Student Records

(Source: Provost’s Memorandum 18-69, December 8, 1969; revised, Ofﬁce

of the Provost, Almanac, February 1, 1977; revised, Almanac, April 29,

1997; revised, Almanac, December 14, 1999; revised,

Almanac, March

16, 2010

(

https://almanac.upenn.edu/archive/volumes/v56/n25/

conﬁdentiality.html

))

I. Statement of Purpose

The purpose of this policy is to describe the rights and responsibilities

of students, faculty and staff regarding the conﬁdentiality of student

records, including as speciﬁed under the Family Educational Rights and

Privacy Act (FERPA).

II. Scope

A. Information

This policy pertains to personally identiﬁable information

contained

in education records. The term “education records” generally includes

records that are directly related to a student and maintained by the

University or a party acting for the University.

Exceptions:

Sole possession of the maker.

This policy does not apply to records

kept in the sole possession of the maker and used only as a personal

memory aid and not accessible to any other individual except a

temporary substitute of the maker of the record.

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107

Peer graded papers.

This policy does not apply to grades on peer-

graded papers/assignments before they are collected and recorded

by a teacher.

Law enforcement records.

This policy does not apply to records

created and maintained by a law enforcement unit, including the Penn

Police, for law enforcement purposes.

Employment records.

This policy does not apply to records relating

exclusively to an individual in his or her capacity as an employee

except for records regarding an individual in attendance who is

employed as a result of his or her status as a student.

Treatment-related records.

This policy does not apply to records

made or maintained by a healthcare professional that are used only

in connection with treatment of the student and disclosed only to

individuals providing treatment.

Other FERPA exceptions.

This policy does not apply to any records or

information speciﬁcally excepted from the term “education records”

under FERPA and its implementing regulations, as they may be

amended.

B. Individuals

Individuals in attendance.

This policy applies to students who are or

have been in attendance at the University.

Alumni.

In general, this policy does not apply to records that contain

only information about an individual after he or she is no longer a

student at the University. However, if the record relates back to the

student’s attendance at the University, it is still an “education record.”

A separate policy protecting the privacy of alumni records may be

found at www.upenn.edu/privacy (http://www.upenn.edu/privacy/).

Deceased individuals.

Neither FERPA nor this policy applies to records

of deceased persons. The person responsible for such records,

however, should exercise informed discretion in responding to

requests for disclosures and should ensure that the person making

the request has a legitimate interest in the information and that the

privacy interests of the deceased and third parties are considered.

Applicants.

This policy does not apply to applicants for admission.

However, the admission-related records of applicants who become

students at the University are subject to the policy.

III. Notice

Penn will annually inform individuals in attendance of their rights

under FERPA, including the right to consent to disclosure of personally

identiﬁable information contained in their education records, the right to

opt out of the disclosure of “directory information,” the right to review and

seek correction of education records, and the right to ﬁle a complaint with

the Department of Education concerning the University’s alleged failure to

comply with FERPA.

IV. Disclosure of Education Records

A. Consent Required

As a general rule, personally identiﬁable information from education

records may not be disclosed to other parties without the student’s prior

written or electronic consent. Such consent shall be signed (on paper or

using an appropriate electronic signature method) and dated and specify

records or information to be disclosed, the purpose(s) of the disclosure,

and the party or class of parties to whom disclosure may be made.

B. Consent Not Required

In certain cases (some of which are described below) personally

identiﬁable information from education records may, and in some cases

must, be disclosed from the records of a student without that individual’s

prior written consent. If such disclosure is made, it should be limited

to that information necessary for the purpose of the disclosure. Note

also that speciﬁc requirements and qualiﬁcations may apply to these

exceptions.

To “school ofﬁcials” with “legitimate educational interests.”

“School ofﬁcials” means employees of the University, including

faculty and staff, as well as certain individuals such as vendors

or contractors, performing work for the University under proper

authorization.

A school ofﬁcial has “legitimate educational interests” in

personally identiﬁable information in the records of a student if

the information in question is required or would be helpful to the

ofﬁcial in the performance of his or her duties.

A contractor, consultant, volunteer, or other party to whom the

University has outsourced services may be considered a school

ofﬁcial provided that the outside party (1) performs a service

for which the University would otherwise use its employees (2)

is under the direct control of the University with respect to the

use and maintenance of education records and (3) is subject

to FERPA requirement governing the use and redisclosure of

personally identiﬁable information from education records.

The University must use reasonable methods to ensure that

school ofﬁcials obtain access to only those education records

in which they have legitimate educational interests. Custodians

of records will establish control procedures to ensure that these

limitations are observed. If the custodian does not use physical or

technological access controls, the custodian must ensure that its

administrative policy for controlling access to education records

is effective.

To another school where the student seeks or intends to enroll or

where the student is already enrolled so long as the disclosure is

for purposes related to the student’s enrollment or transfer and the

University has provided notice of the disclosure or annual notice of its

policy to make such disclosures.

In connection with ﬁnancial aid for which a student has applied,

or which he or she has received, but only for such purposes as

determining eligibility for ﬁnancial aid, the amount of ﬁnancial aid,

and the conditions that will be imposed, or for enforcing the terms or

conditions of ﬁnancial aid.

To comply with a judicial order or lawfully issued subpoena

provided that the University makes a reasonable effort to notify the

student whose records are involved in advance of disclosing the

information. Prior notiﬁcation may be prohibited in certain situations.

All subpoenas and court orders should be directed to the Ofﬁce

of General Counsel and disclosure in response to them must be

approved by that ofﬁce.

In connection with an emergency, to appropriate persons if

knowledge of the information is necessary to protect the health or

safety of the student or other individuals.

To parents as described in Section IV. (c) below.

Regarding directory information as described in Section IV. (d) below.

Other circumstances as authorized by FERPA and its implementing

regulations, as they may be amended or as otherwise required by law.

Questions about legal requirements should be directed to the Ofﬁce

of General Counsel.

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IV.J. Policy on the Conﬁdentiality of Student Records

C. Parental Notiﬁcation—Consent Not Required

The University’s policy regarding disclosure of student information to

parents is based both upon legal requirements and the University’s

philosophy that students should be treated as adults. The University

generally will not share personally identiﬁable information (other than

directory information) from a student’s education records with third

parties, including parents or guardians, without student consent, except

in limited circumstances where such disclosure is permitted under FERPA

(described below) and where the University determines in its discretion

that disclosure is appropriate.

In connection with an emergency if knowledge of the information

is necessary to protect the health or safety of the student or other

individuals.

To the parent or legal guardian of a student under the age of 21,

information regarding the student’s violation of a University policy

governing the use or possession of alcohol or drugs.

To a person who submits a written afﬁrmation that he or she is

the parent or legal guardian of a student and that the student is a

dependent within the meaning of Section 152 of the Internal Revenue

Code of 1954.

In other limited circumstances as allowed under FERPA and its

implementing regulations, as they may be amended.

In cases involving a health or safety emergency or a violation of a

University policy regarding the use or possession of alcohol or drugs,

a decision to notify parents or guardians about information contained

in an education record—and the actual communications to the parents

or guardians—will be made by the Ofﬁce of the Vice Provost for

University Life or another senior student affairs ofﬁcer, in each case

after consultation with the student’s school ofﬁce and other appropriate

ofﬁces. Whenever practicable, a student whose parents or guardians are

to be notiﬁed will be informed before such notiﬁcation occurs and given

an opportunity to initiate contact with his or her parents or guardians.

D. Consent Not Required—Directory Information

“Directory Information” is generally regarded to be less sensitive than

other types of information in a student’s education record. The University

designates as “directory information,” which may be disclosed from

records relating to a student without his or her consent if the student has

not “opted out” of allowing such disclosure, the following categories of

information: a student’s name, address (local, home or electronic mail),

telephone number, date and place of birth, Penn ID number, major ﬁeld

of study, participation in ofﬁcially recognized activities (including social

and honorary fraternities) and sports, weight and height if a member of

an athletic team, dates of attendance, degrees and awards received, and

previous educational institutions attended.

Each year, a notice will be given to students concerning these categories

and their right to refuse to permit the University to make any or all of

them available (i.e., “opt out”). Failure to respond to the annual notice

in certain cases may result in the routine disclosure of one or more of

the designated categories of personally identiﬁable information. The

University will continue to exercise informed discretion in responding to

requests for directory information.

E. Limitation on Redisclosure

As required by FERPA, the University will inform a party to whom a

disclosure of personally identiﬁable information from the records of a

student is made; that disclosure is made only on the condition that the

party will not disclose the information to any other party without the

student’s prior written consent. Exceptions to this requirement include

disclosure of directory information, disclosures to the student, to parents

under appropriate circumstances, to victims of certain disciplinary

matters, and disclosures pursuant to court orders and valid subpoenas.

F. Veriﬁcation of Identity and Authority

Before disclosing personally identiﬁable information from education

records, University employees must take reasonable steps to verify the

identity of the requesting party as well as their authority to have access

to the information.

V. Maintaining a Record of Disclosures

As required by FERPA, the University will maintain a record of requests

for and/or disclosures of personally identiﬁable information from a

student’s education records. The record must include the identities of

the requesters and recipients and the legitimate interests they had in the

information. This record should be maintained with records for as long

as the records themselves are maintained and may be inspected by the

student.

These recordkeeping requirements do not apply to requests from or

disclosures to:

the student;

a school ofﬁcial with a legitimate educational interest;

a person with written consent from the student;

a person seeking directory information; or

a federal grand jury or law enforcement agency in connection with an

order or subpoena requiring

VI. Right to Review Education Records &

Seek Correction

Individuals who are or have been in attendance at the University are

entitled to inspect and review their education records upon a written

request. The request to inspect or review records must be honored within

45 days after the University has received the request. The request should

be directed to the ofﬁce that maintains the record and such ofﬁce may

charge a reasonable fee for copies.

A student does not have a right to inspect or review the following:

Financial records and statements of the student’s parent(s), except

with the written permission of the parent(s).

Conﬁdential letters and statements of recommendation related to

admission to an educational institution, application for employment,

or the receipt of an honor or honorary recognition that were placed in

a student’s records after January 1, 1975, and as to which the student

has executed a written waiver of his or her right to inspect and review;

provided that the University uses the letters and statements only for

the purpose for which they were originally intended and notiﬁes the

student upon request of the names of all individuals providing such

letters and statements.

Other records as to which the student has executed a written waiver

of his or her right to inspect and review. The University may not

require a student to waive his or her rights under FERPA or this policy.

Those portions of records that contain information on other students.

Other exceptions as prescribed by FERPA and its implementing

regulations, as they may be amended.

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C. Opportunity to Seek Correction

A student who believes that information contained in his or her

education records is inaccurate or misleading or violates his or her

privacy rights may request that the University amend them, and the

University will decide whether to do so within a reasonable period of

time.

If the University decides that the information is inaccurate or

misleading or otherwise in violation of the privacy rights of a student,

the University will amend the record and inform the student of the

amendment in writing.

If the University declines to amend the student’s records, it will so

inform the student and inform him or her of the right to request

a hearing to challenge the information believed to be inaccurate,

misleading or in violation of his or her privacy rights. A hearing,

however, may not be requested by a student to contest the

appropriateness of a grade.

The hearing will be conducted by an individual who does not have

a direct interest in the outcome of the hearing and will provide

the student an opportunity to present evidence, relevant to the

request to amend the student’s records. The University will provide a

written decision within a reasonable period of time after the hearing

based on the evidence presented at the hearing. The decision

will include a summary of the evidence and the reasons for the

decision. Additionally, information regarding hearing procedures will

be provided when the student receives notice of his or her rights.

If, after a hearing, the University determines that a student’s

challenge is without merit it will notify the student of the right

to place in his or her records a statement commenting on the

challenged information and/or setting forth reasons for disagreeing

with the University’s decision. The University will maintain such

statement with the student’s record and disclose the statement

whenever it discloses the portion of the record to which the

statement relates.

VII. Right to File Complaint

Students have a right to ﬁle a complaint concerning any alleged failure

by the University to comply with the requirements of FERPA and its

implementing regulations. A complaint may be ﬁled with the federal ofﬁce

that administers FERPA:

Family Policy Compliance Ofﬁce

U.S. Department of Education

400 Maryland Avenue, SW

Washington, DC 20202-5901

A complaint may be ﬁled internally via the University’s Compliance

and Reporting Line by phone at (215) 726-6759 or online at

www.upenn.edu/215pcomply (http://www.upenn.edu/215pcomply/).

VIII. Waiver of Rights

A student may waive any of his or her rights under FERPA and this policy,

provided that the waiver is made in writing and signed by the student.

The University may not require a student to waive his or her rights under

FERPA or this policy.

The term “personally identiﬁable information” includes, but is not

limited to, the name of the student or family member, the address of

the student or family member, identiﬁcation number, biometric record,

indirect identiﬁer (such as date of birth or mother’s maiden name) or

other information that, alone or in combination, is linked to the student

and would allow a reasonable person in the school community, without

personal knowledge of relevant circumstances, to identify the student

with reasonable certainty.

V. Policies Related to Information

•

V.A. Guidelines on Open Expression (p. 109)

•

V.B. Conﬁdentiality of Employee Records (p. 113)

•

V.C. Conﬁdentiality of Health Information under HIPAA (p. 115)

•

V.D. Closed Circuit Television Monitoring and Recording of Public

Areas for Safety and Security Purposes (p. 115)

•

V.E. Relationships Between Members of the University Community

and Intelligence Organizations (p. 117)

•

V.F. Photocopying for Educational Use (p. 120)

•

V.G. Protocols for the University Archives and Records Center

(p. 121)

•

V.H. Policy on Acceptable Use of Electronic Resources (p. 124)

•

V.I. Policy on Privacy in the Electronic Environment (p. 127)

•

V.J. Policy on Security of Electronic Protected Health Information

(ePHI) (p. 128)

•

V.K. Information Systems Security Incident Response Policy

(p. 129)

•

V.L. Policy on Unauthorized Copying of Copyrighted Media (p. 129)

•

V.M. Conﬁscation of Publications (p. 129)

•

V.N. Policy on Computer Disconnection from PennNet (p. 130)

V.A. Guidelines on Open Expression

(Source: Ofﬁces of the President and Provost, 1969; revised, Ofﬁce of the

President, Almanac, May 2, 1978; revised, Almanac, September 8, 1987;

revised, Almanac, December 3, 1991; revised,

Almanac, March 16, 1993

(

https://almanac.upenn.edu/archive/v39pdf/n25/031693.pdf

))

I. Principles

The University of Pennsylvania, as a community of scholars, afﬁrms,

supports and cherishes the concepts of freedom of thought, inquiry,

speech, and lawful assembly. The freedom to experiment, to present

and examine alternative data and theories; the freedom to hear,

express, and debate various views; and the freedom to voice criticism

of existing practices and values are fundamental rights that must be

upheld and practiced by the University in a free society.

Recognizing that the educational processes can include meetings,

demonstrations, and other forms of collective expression, the

University afﬁrms the right of members of the University community

to assemble and demonstrate peaceably in University locations

within the limits of a set of Guidelines on Open Expression and

undertakes to ensure that such rights shall not be infringed. In

keeping with the rights outlined above, the University afﬁrms that the

substance or the nature of the views expressed is not an appropriate

basis for any restriction upon or encouragement of an assembly

or a demonstration. The University also afﬁrms the right of others

to pursue their normal activities within the University and to be

protected from physical injury or property damage. The University

shall attempt to ensure that, at any meeting, event or demonstration

likely to be attended by non-University law enforcement authorities,

the rights provided by these Guidelines are not infringed.

The University shall be vigilant to ensure the continuing openness

and effectiveness of channels of communication among members

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V.A. Guidelines on Open Expression

of the University community on questions of common interest. To

further this purpose, a Committee on Open Expression has been

established as a standing Committee of the University Council. The

Committee on Open Expression has as its major tasks: participating

in the resolution of conflicts that may arise from incidents or

disturbances implicating these Guidelines; mediating among the

parties to prevent conflicts and violations of these Guidelines;

interpreting these Guidelines; advising administrative ofﬁcers when

appropriate; and recommending policies and procedures for the

improvement of all levels of communication.

In case of conflict between the principles of the Guidelines on

Open Expression and other University policies, the principles of the

Guidelines shall take precedence.

II. Deﬁnitions

For the purposes of these guidelines, the "University Community"

shall mean the following individuals:

Persons who are registered as students or who are on an

unexpired ofﬁcial leave of absence.

All persons who are employed by the University.

Trustees and associate trustees of the University and members

of Boards of Boards of Overseers or other bodies advisory to the

University.

For the purposes of these Guidelines, "Meeting" and "Event" designate

a gathering of persons in a University location previously reserved for

that purpose. Unless designated as public, Meetings are considered

to be private. Events are considered to be public. "Demonstration"

designates the presence of one or more persons in a University

location with the intent to express a particular point of view in a

manner that attracts attention, as in protest, rallies, sit-ins, vigils, or

similar forms of expression. "University Location" designates:

The campus of the University;

Any location owned, leased or used by the University, when used

by members of the University community; and

Areas immediately adjacent thereto.

III. Standards

The University, through the President, the Provost, and the Vice

Provost for University Life, shall act to encourage and facilitate free

and open expression within these Guidelines.

The University shall publish these Guidelines at least once each

academic year in a manner that brings them to the attention

of members of the University Community. The University shall

publish the rules adopted pursuant to IV B.1 by the Committee on

Open Expression at least once each academic year in a manner

that brings them to the attention of Members of the University

Community.

The University shall establish standards for the scheduling of

Meetings and Events. This shall involve:

Publishing policies and procedures whereby members of the

University Community, upon suitable request, can reserve and

use designated spaces within University buildings for public

or private Meetings or Events;

Publishing policies and procedures whereby Members of the

University community, upon suitable request, can reserve and

use designated outdoor spaces on the University campus for

public Meetings or Events;

Publishing policies and procedures that speciﬁcally

address requests involving groups composed entirely or

predominantly of persons who are not Members of the

University Community (see Section VI);

Consulting with the Committee on Open Expression with

regard to the substance of the policies and procedures and

the manner of their publication; and, if practicable, consulting

with the Committee on Open Expression before denying a

request for use of a room, facility, or space by an organization

recognized by the University for a reason other than prior

assignment of the room, facility, or space. In any event, any

such denial must be reported promptly to the Committee.

Each Member of the University Community is expected to know and

follow the Guidelines on Open Expression. A person whose conduct

violates the following Standards may be held accountable for that

conduct, whether or not the Vice Provost or delegate has given an

instruction regarding the conduct in question. Any member of the

University community who is in doubt as to the propriety of planned

conduct may obtain an advisory opinion from the Committee on Open

Expression in advance of the event.

Individuals or groups violate these Guidelines if:

They interfere unreasonably with the activities of other

persons. The time of day, size, noise level,* and general tenor

of a Meeting, Event or demonstration are factors that may be

considered in determining whether conduct is reasonable; (*

An "Unreasonable Noise Level" is deﬁned as sound above 85

decibels measured by a calibrated sound-level meter at an "A"

weighting on "slow" response ten feet away from and directly

in front of the source, ampliﬁer or loudspeaker when the latter

is within 50 feet of a building. )

They cause injury to persons or property or threaten to cause

such injury;

They hold meetings, events or demonstrations under

circumstances where health or safety is endangered; or

They knowingly interfere with unimpeded movement in a

University location.

Individuals or groups violate these Guidelines if they hold a

demonstration in the following locations:

Private ofﬁces, research laboratories and associated facilities,

and computer centers; or

Ofﬁces, museums, libraries, and other facilities that

normally contain valuable or sensitive materials, collections,

equipment, records protected by law or by existing University

policy such as educational records, student-related or

personnel-related records, or ﬁnancial records; or

Classrooms, seminar rooms, auditoriums or meeting rooms

in which classes or private meetings are being held or are

immediately scheduled; or

Hospitals, emergency facilities, communication systems,

utilities, or other facilities or services vital to the continued

functioning of the University.

Individuals or groups violate these Guidelines:

If they continue to engage in conduct after the Vice Provost

for University Life or delegate has declared that the conduct

is in violation of the Guidelines and has instructed the

participants to modify or terminate their behavior. Prompt

compliance with the instructions shall be a mitigating factor

in any disciplinary proceedings based upon the immediate

conduct to which the instructions refer, unless the violators

are found to have caused or intended to cause injury to

person or property or to have demonstrated willfully in an

impermissible location.

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If the individuals or groups refuse to comply with the

Vice Provost's or delegate's order, they may challenge

the appropriateness of the order to the judicial system. If

the judiciary ﬁnds that the conduct was protected by the

Guidelines, all charges shall be dismissed.

Individuals or groups complying with the Vice Provost's

or delegate's order may request that the Committee on

Open Expression determine if the Guidelines were properly

interpreted and applied to their conduct.

IV. Committee on Open Expression

A. Composition

The Committee on Open Expression consists of seventeen members:

eight faculty members named by the Faculty Senate Executive

Committee, two representatives of the Penn Professional Staff

Assembly, one representative of the Weekly-Paid Professional

Staff Assembly, and three undergraduate students and three

graduate/professional students selected by the appropriate student

governance organizations (currently the Nominations and Elections

Committee of the Undergraduate Assembly and the Graduate and

Professional Student Assembly).

Members of the Committee are appointed for the following terms:

The faculty and representatives of the Penn Professional Staff

Assembly are appointed to two-year terms, staggered so that in

each year either two or three faculty members are appointed and

one representative of the Penn Professional Staff Assembly is

appointed.

The representative of the Weekly-Paid Professional Staff

Assembly is appointed for a two-year term.

The undergraduate and graduate/professional student members

are appointed to one-year terms.

Vacancies shall be ﬁlled for the unexpired term by the appropriate

nominating body or persons.

The Chair of the Committee shall be selected by the Committee on

Committees from among the members of the Committee on Open

Expression.

B. Jurisdiction

The Committee has competence to act in issues and controversies

involving open expression in accordance with these Guidelines. The

Committee's responsibilities are the following:

Issuing rules to interpret or give more speciﬁc meaning to the

Guidelines. Before adopting a rule, the Committee must hold an open

hearing on the proposed rule and receive the views of individuals or

groups. An afﬁrmative vote of eight members is required for adoption,

modiﬁcation or rescision of a rule to be effective.

Recommending to the University Council proposals to amend or

repeal the Guidelines. An afﬁrmative vote of seven members is

required to make such recommendations.

Giving advisory opinions interpreting the Guidelines at the request of

a member of the University community for the purpose of advising

that person or the University community. Such advice is provided

to guide future action. If the Committee does not give a requested

opinion, it must indicate its reasons for not doing so. The Committee

must respond to such requests as soon as feasible but in any event

not later than within one month of the receipt by the Chair of the

Committee.

Giving advisory opinions interpreting the Guidelines at the request

of administrative ofﬁcials with responsibilities affecting freedom

of expression and communication. Such advice is provided for the

purpose of guiding future action.

Mediating in situations that involve possible violations of the

Guidelines. Those Committee members available at the time may act

on behalf of the Committee. In carrying out the mediation function,

the Committee or those members present may advise the responsible

administrative ofﬁcials and any other person with respect to the

implementation of the Guidelines. Those Committee members who

have acted on behalf of the Committee must report on their activities

to the full Committee.

Reviewing the following administrative decisions for the purpose of

providing advice on future actions.

At the discretion of the Committee, administrative decisions

involving these Guidelines made without consultation with the full

Committee.

All instructions by the Vice Provost or delegate to modify or

terminate behavior under Section III.B.3 of these Guidelines.

Investigating incidents involving the application of these Guidelines

to aid the Committee in its functions of rulemaking, recommending

changes in the Guidelines or issuing advisory opinions. Such

functions provide guidance to the University community for future

action. The results of Committee investigations for these purposes

shall not be a part of the initiation, consideration or disposition of

disciplinary proceedings, if any, arising from the incidents.

Adopting procedures for the functions of the Committee, varied

to suit its several functions, consistent with these Guidelines.

Procedures that are not wholly matters of internal Committee

practice must be made public in advance of implementation. Except

as otherwise provided, the Committee may determine its own voting

procedures.

Submitting an annual report to the Council and the University on the

status of the Committee's work in the University’s journal of record,

Almanac.

C. Procedures

Except as provided with respect to the mediation function in Section

IV.B.5, nine members of the Committee constitute a quorum.

The Committee can authorize subcommittees, selected from its own

members, to act for the Committee in any matter except the issuance

of rules interpreting or implementing the Guidelines or the making of

recommendations to amend or repeal the Guidelines.

The Committee shall respect the privacy of individuals as its general

policy and shall maintain the right to declare the conﬁdentiality of its

proceedings.

If a person appearing before the Committee requests that his/

her testimony or information be kept conﬁdential, the Committee

shall consider such a request. The Committee then shall

determine whether to honor that request and shall inform that

person of its decision before testimony is given.

Minutes of particular Committee meetings may be declared

conﬁdential by the Committee or be so declared at the discretion

of the chair subject to review by the Committee.

All Committee documents containing conﬁdential material, as

determined by the chair, shall be clearly marked "conﬁdential" and

shall carry a warning against unauthorized disclosure.

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V.A. Guidelines on Open Expression

V. Responsibilities for Enforcement

It is the responsibility of the Vice Provost for University Life (hereafter

referred to simply as the "Vice Provost") to protect and maintain the

right of open expression under these Guidelines.

Observation of meetings, events or demonstrations, when deemed

necessary by the Vice Provost to protect and maintain open

expression, shall be the responsibility of the Vice Provost, who may

delegate such responsibility. This delegate shall have full authority to

act in the name of the Vice Provost under these Guidelines.

The observer (Vice Provost or delegate) shall identify himself/

herself to those responsible for the meeting or event or to the

leaders of the demonstration.

The Vice Provost shall attempt to inform the chair of the

Committee on Open Expression of meetings, events or

demonstrations to which an observer will be sent. The chair may

designate a member or members of the Committee to accompany

and advise the observer. Such a Committee representative shall

also be identiﬁed to those responsible for the meeting or event or

to the leaders of the demonstration.

Except in emergencies, the Vice Provost's authority under these

Guidelines shall not be delegated to employees of the University's

Department of Public Safety (“Public Safety”). The role of Public

Safety personnel at a meeting, event or demonstration is deﬁned

below, in Section V.C.3.

Any observer or Committee representative who attends a

meeting, event or demonstration shall respect the privacy of

those involved. If there has been no violation of these Guidelines,

other University regulations, or applicable laws, an observer,

committee representative, or Public Safety employee who

attends a meeting, event or demonstration shall not report on the

presence of any person at such meeting, event or demonstration.

The Vice Provost or delegate is responsible for enforcing Section III.B.

and may instruct anyone whose behavior is violating or threatens

to violate these Guidelines to modify or terminate such behavior.

The instruction shall include notice that failure or refusal to comply

is a further violation according to Section III.B. of these Guidelines.

However, an instruction or warning by the Vice Provost or delegate is

not a prerequisite for a ﬁnding that a violation has occurred.

When the Vice Provost or delegate declares that an individual or a

group has violated the Guidelines, he/she may request to examine

their University identiﬁcation.

Failure to comply with this request is in violation of the

Guidelines.

In the event that any person(s) are deemed by the Vice

Provost or delegate, in consultation with available members

of the Committee on Open Expression, to have violated the

Guidelines and such person(s) refuse to show University

or other identiﬁcation, the Vice Provost or delegate shall

if practicable inquire of other individuals present as to the

identity of the claimed violator(s). Identiﬁcation by two other

individuals shall sufﬁce to establish identity. Should it not

be possible to establish identity in this way, the Vice Provost

or delegate may direct that photographs be taken of the

participant(s) in the claimed violation. The Vice Provost or

delegate must warn the individual(s) that their photographs

will be taken unless identiﬁcation is presented. Photographs

and videotapes obtained without such warning may not be

used as evidence in disciplinary proceedings. It is preferred

that a member of the Committee on Open Expression take

any such photographs; however, if no such person is able or

willing to do so, another member of the University community

may be requested to do so. As soon as safely practicable, all

such photographs shall be turned over to the Vice Provost

or delegate. Any photographs taken (including videotapes

and negatives) shall be used solely by the Ofﬁce of Student

Conduct for the purpose of investigation of alleged violations

and possible identiﬁcation of alleged violators of these

Guidelines. If it is determined that no violation has occurred,

the Vice Provost or delegate shall destroy the photographs.

If a violation is found to have occurred, after identiﬁcation

has been made and the case has been adjudicated, the Vice

Provost or delegate shall destroy the photographs. None

of the photographs shall be published. After each incident

at which photographs are taken, the Committee on Open

Expression shall report on the incident to the University

Council, via the chair of the University Council Steering

Committee, regarding what happened in the incident, which

individuals saw the photographs, and the disposition of the

photographs.

In carrying out this responsibility for safeguarding the right of

open expression, the Vice Provost shall obtain the advice and

recommendation of the representatives of the Committee on

Open Expression whenever feasible.

The Vice Provost or delegate may request members of the

University Police to attend meetings, events or demonstrations to

help protect the open expression of those involved.

Any person acting as an agent of the Division of Public Safety

who attends a meeting, event or demonstration in a University

location shall be clearly identiﬁable as such and in normal

duty uniform. (Arms may be carried if they are part of "normal

duty uniform. ")

Public Safety personnel also may attend meetings, events

or demonstrations when requested to do so by the person

or group responsible for the event, when prominent public

ﬁgures are involved, or when the Vice President for Public

Safety or delegate determines that there exists an imminent

danger of violence at the event.

Terminating a meeting, event or demonstration by force is a most

serious step, as this action may exacerbate existing tensions and

may lead to personal injury and property damage.

Avoidance of injury to persons by the continuation of a

meeting, event or demonstration is a key factor in determining

whether it should be forcibly terminated. Property damage

and signiﬁcant interference with educational processes

are also factors to be considered and may be of sufﬁcient

magnitude to warrant forcible termination.

Whenever possible, the Vice Provost or delegate should

consult with the Committee on Open Expression before

seeking a court injunction against those involved in a

meeting, event or demonstration or calling for police action.

The Vice Provost or delegate shall inform those involved

that he/she intends to seek an injunction or call for police

intervention before he/she does so.

When a meeting, event or demonstration is forcibly

terminated, a full statement of the circumstances leading to

the incident shall be publicized by the Vice Provost within the

University.

Adjudication

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Cases involving undergraduate students are referred to the Ofﬁce

of Student Conduct, which investigates the event and decides

what disciplinary proceedings, if any, to pursue.

Cases involving graduate or professional students are referred to

the Ofﬁce of Student Conduct or to the established disciplinary

body of the school in which the student is enrolled.

Cases involving faculty are referred to the appropriate dean or to

the Provost.

Cases involving University staff or administrators are referred to

that individual's supervisor or any other person with supervisory

responsibility over that individual.

Cases involving trustees and associate trustees of the University

and members of the Boards of Overseers or other bodies advisory

to the University are referred to the Executive Committee of the

Trustees.

The Division of Public Safety shall not collect or maintain information

about members of the University community

, except in connection

with alleged crimes, violations of University regulations, or as

speciﬁcally authorized in writing by the President (to Public Safety

and the Open Expression Committee). This regulation shall not

affect personnel information concerning current, past or prospective

employees of the Division of Public Safety.

VI. Non-University Persons

These Guidelines address themselves explicitly to forms of individual

and collective expression in a University location by members of the

University community. The extent to which the privileges and obligations

of these Guidelines may be made applicable in particular circumstances

to individuals who are not members of the University community shall

be determined by the Vice Provost or delegate. Participants in meetings,

events and demonstrations in a University location are required to

comply with the instructions of the Vice Provost or delegate. (See section

III.A.2.c. of this policy.)

(See page 6-8 - Almanac, March 16, 1993 (https://almanac.upenn.edu/

archive/v39pdf/n25/031693.pdf))

Videotaped or closed circuit television information collected by posted,

ﬁxed location cameras is excluded, as long as it is in conformance with

the rules of the CCTV policy as of January 13, 1999.

V.B. Conﬁdentiality of Employee

Records

(Source: Ofﬁces of the President and Provost, December 5, 1980; revised,

Almanac, October 6, 1981 and Personnel Policy Manual Policy No. 101;

revised, Human Resources Policy Manual Policy No. 201, September 1, 1991

and Almanac, May 18, 1993; revised,

Personnel Policy Manual Policy 201,

March 29, 2005

(

https://www.hr.upenn.edu/policies-and-procedures/

policy-manual/other-policies/conﬁdentiality-of-records/

))

To insure conﬁdentiality, uniformity, and accuracy of personnel

information, it is the responsibility of Division of Human Resources/

Information Management/Records (HR/IM/Records) to handle all

inquiries, other than subpoenas, which require reference to documentary

records concerning past and present staff of the University. Responses

to the subpoenas are handled by the Ofﬁce of the General Counsel.

Inquiries received by other ofﬁces should be referred to HR/IM/Records.

All subpoenas and inquiries from lawyers should be referred to the Ofﬁce

of the General Counsel.

Personnel records, including those established in connection with the

selection process, are University property and are afforded conﬁdential

treatment at all times.

Individually identiﬁable personal information contained in computerized

databases, whether maintained centrally or by schools, departments or

other units, is afforded the same conﬁdential treatment that applies to

written records.

The Provost (or designee) shall administer this policy with respect to the

records of faculty members. The Vice President for Human Resources

(or designee) shall administer the policy with respect to the records

of staff members. Deans and directors shall notify the Provost or the

Vice President for Human Resources, as appropriate, of the name of the

individual who shall serve as custodian for personnel records maintained

in their areas of responsibility.

Exceptions

This policy does not cover disclosures of information that are made on

the basis of personal knowledge or recollection.

This policy does not apply to applicants for employment unless they are

subsequently hired.

Access to Records

Both active and retired members of the faculty and staff shall have the

right of access to their records as described in this policy.

Individuals who are on leave of absence or whose employment has been

terminated for reasons other than retirement with reemployment rights

shall have the right of access.

Legal representatives of deceased faculty and staff members shall have

the right of access for ﬁve years after the death of the individual.

Exceptions to the above may be granted by the Provost or the Vice

President for Human Resources.

Review of Records

An individual may review his/her records by making an appointment

with HR/IM/Records during regular business hours. HR/IM/Records

shall assure that references to others that may be contained in the

ﬁle are deleted for the purpose of the review. (For exceptions please

refer to “Limitations on Review of Records,” which follows later in this

policy.)

The review shall take place in the ofﬁce where the records are

maintained and in the presence of a designated staff member of HR/

IM/Records.

The individual shall sign a log indicating the date of the inspection of

the records.

If necessary, an individual may request copies of his/her records.

There is no charge for copies of records referred to in the

Occupational Health and Safety Act (OSHA) standards for access to

medical records; for other records a reasonable charge may be made

for reproduction costs.

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114

V.B. Conﬁdentiality of Employee Records

Correction of Records

If an individual considers a record to be misleading, if it contains a

statement of fact that can be shown to be erroneous, or if it contains

information that is not relevant, a correction may be requested.

The request must be submitted in writing to HR/IM/Records.

A request for correction of information such as date of birth must be

accompanied by supporting documentation, for example, birth certiﬁcate

or passport. The designated custodian of the records may consult the

Provost (or designee) or the Vice President for Human Resources (or

designee), as appropriate. On the basis of this consultation, the custodian

should make the correction or indicates the reason why the request is

denied.

If a correction is sought on an appropriate ground but is denied, the

individual involved may submit for inclusion in the ﬁle a short statement

explaining the grounds for the request and the correction sought. The

Provost or the Vice President for Human Resources may submit a

counterstatement, a copy of which is sent to the affected individual. Both

statement and counterstatement shall be placed in the Personnel Record.

Limitations on Review of Records

To protect against inappropriate disclosure of conﬁdential information,

certain records, including those containing conﬁdential information

about more than one individual and medical records, are not open to

review by an individual who is a subject of the record. These records are

maintained separately from other beneﬁts records and may be available

under separate policies or practices applicable to all recipients of care

at the Hospital of the University of Pennsylvania or elsewhere at the

University.

Individuals may not review the following:

•

records that contain conﬁdential information about other people;

•

all letters of recommendation relating to the consideration of a

faculty member for appointment, re-appointment, promotion or

tenure, or staff member for employment, unless released by written

consent of the author;

•

documents including records concerning beneﬁts that are being

developed or prepared for use in civil, criminal or grievance

procedures;

•

records relating to the investigation of a possible criminal offense;

•

medical and hospital records.

Records That May Be Disclosed to Third

Parties

Information contained in personnel records may be disclosed by the

University without the written consent of the subject of the record when

the Provost or Vice President for Human Resources concludes that a

constructive purpose would be served or when required by law in the

judgment of the Ofﬁce of the General Counsel.

Unless speciﬁcally excepted from this policy, the content of personnel

records may not be disclosed to third parties without the express written

permission of the individual who is the subject of the record. The written

permission must describe speciﬁcally the records to be disclosed and the

persons to whom they are to be disclosed.

Except for disclosures of directory information and as required by law, the

University shall notify any third party to whom disclosures are made that

disclosures are made under the condition that the party shall not make

any redisclosure of the information without the written consent of the

subject of the record.

Certain substantive categories of information may be disclosed:

Penn makes certain directory information available to its staff,

faculty, and students – and a more limited set of information

available to the general public – so that the ordinary University

business can be conducted. In some cases, individuals may "opt-

out" of having certain data appear. In other cases involving more

personal information, such as home contact information, individuals

may "opt-in" to having their data appear. Also, individuals can often

list organizational contact information, rather than personal contact

information, in their directory entries. For more information on

the levels of control individuals can exercise over their directory

information in disclosures to Penn's faculty, staff and students and to

the general public, see Appendix I., Directory Information Privacy Grid

(https://www.hr.upenn.edu/policies-and-procedures/policy-manual/

other-policies/conﬁdentiality-of-records/directory-information-

privacy-grid/).

Authorized Individuals: Personnel records may be disclosed to

University ofﬁcials, and authorized individuals performing work for

the University who require the information for the performance of

their duties.

Legal Requirements: The University may release personnel records

in response to a lawful subpoena, warrant, or court order or if, in the

opinion of the Ofﬁce of the General Counsel, such records could be

required by law to be produced for any reason, including disclosure to

a government agency. Whenever possible, notice of disclosure shall

be given in advance through the

Almanac

for general categories of

personnel records or by mail for individual records.

Protection of University Interests: The University may disclose

information contained in records to protect its legal interest when it

believes the actions of an individual violate or have violated his/her

conditions of employment or threaten injury to people or property

Collective Bargaining Agreements: Information may be disclosed as

required under the terms of a collective bargaining agreement.

Emergencies: Information may be disclosed if, in the judgment of

the designated custodian of HR/IM/Records, such disclosure is

necessary to protect the health, safety or property of any person.

Exemption to Third Party Disclosure

Policy

The Ofﬁce of Equal Opportunity Programs, Division of Human Resources

and Ofﬁce of the General Counsel are exempted from the above section,

“Records That May be Disclosed to Third Parties.”

Record Retention Requirements

Records shall be maintained for the period speciﬁed by state or federal

law, or longer at the direction of the Provost, the Vice President for

Human Resources, the University Archivist or the General Counsel.

Records

Years

Afﬁrmative Action records

7 years

Information Management/Records

5 years after death

Medical records relating to job

qualiﬁcation

30 years beyond termination date

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University of Pennsylvania Faculty Handbook

115

Records relating to faculty

appointment or promotion

5 years after death

Grievance records

5 years after death

Public Safety Records

5 years after death

Payroll

7 years

Occupational Safety and Health Act

(OSHA) records of exposure to toxic

substances

30 years

Applications (unsuccessful

canidates)

2 years

Payroll, OSHA records and applications are retained according to this

schedule and are not dependent on employment status.

The Department of Public Safety and the Hospital of the University of

Pennsylvania shall develop their own record retention policies for security

records and medical records.

V.C. Conﬁdentiality of Health

Information under HIPAA

(Ofﬁce of Audit, Compliance and Privacy, 2006; revised, 2009)

All faculty members at the University of Pennsylvania should respect

the privacy and security of personal health information. Personal health

information may be used for appropriate patient care, teaching, and

research purposes, consistent with applicable University policy. Further,

faculty should take reasonable steps to safeguard personal health

information from unauthorized access, use, and disclosure.

Under the Health Insurance Portability and Accountability Act (HIPAA),

certain schools and centers within the University must comply with

a number of regulatory requirements that have been incorporated

into speciﬁc policies addressing the privacy and security of health

information. Faculty members within the Perelman School of Medicine,

the School of Dental Medicine, and faculty practicing at the Student

Health Service and Living Independently for Elders (collectively, “HIPAA-

Covered Faculty”) should refer to and follow HIPAA privacy and security

policies and procedures established for their schools and centers.

HIPAA-Covered Faculty must abide by the following HIPAA requirements:

HIPAA-Covered Faculty must receive training on policies and

procedures implementing HIPAA and abide by such policies and

procedures;

In general, HIPAA-Covered Faculty may not use and/or disclose

personal health information without the patient’s signed HIPAA-

compliant authorization, except that:

HIPAA-Covered Faculty may, without patient authorization,

use and/or disclose personal health information for purposes

of treatment, payment, and for the healthcare operations of

the faculty member’s school /center, including but not limited

to management, quality assurance, training programs, and

compliance programs;

HIPAA-Covered Faculty may, without patient authorization, share

personal health information with a patient’s family members and

other relatives or friends that is directly relevant to that person’s

involvement in the patient’s care or payment for care, consistent

with professional judgment unless the patient otherwise objects

to such sharing;

HIPAA-Covered Faculty may, without patient authorization, use

or disclose personal health information for research purposes if

Penn’s Institutional Review Board (IRB) or a similar committee

has waived the requirement for authorization under HIPAA.

However, the faculty member must provide to the designated

institutional ofﬁcial an accounting for all disclosures of that

information in a manner described in the IRB procedures;

HIPAA-Covered Faculty may, without patient authorization,

use and disclose personal health information for designated

priority purposes, including but not limited to reporting to certain

governmental agencies, in emergency circumstances, for judicial

and administrative proceedings, and where disclosure is required

by law, provided that the HIPAA-covered faculty does so in

accordance with speciﬁc conditions set out in school / center

policies and procedures. However, the faculty member must

provide to the designated institutional ofﬁcial an accounting

for all disclosures of that information in a manner described in

school / center policies and procedures;

HIPAA-Covered faculty must limit uses, disclosures, and requests

for personal information to the amount reasonably necessary to

accomplish the purpose, except as related to treatment;

HIPAA-Covered Faculty must permit patients the right to access,

inspect, and copy their personal health information, except in

speciﬁed cases, such as in the course of a clinical trial subject to the

terms of the authorization to use the patient’s health information in

that trial.

HIPAA-Covered Faculty must permit patients the right to request

amendment of their health information;

HIPAA-Covered Faculty must enter into HIPAA business associate

agreements with vendors that create or receive personal health

information on our behalf as described in school / center policies and

procedures;

HIPAA-Covered Faculty must ensure that they provide appropriate

administrative, technical, and physical safeguards to protect

the conﬁdentiality, integrity, and availability of personal health

information; and

HIPAA-covered faculty must report all unauthorized access to

personal health information to school/center privacy ofﬁcials to

the Ofﬁce of Audit, Compliance and Privacy to ensure appropriate

investigation and response.

V.D. Closed Circuit Television

Monitoring and Recording of Public

Areas for Safety and Security

Purposes

(Source: Ofﬁce of the President, Almanac, April 13, 1999; revised, Division

of Public Safety,

Almanac, April 29, 2008

(

https://almanac.upenn.edu/

archive/volumes/v54/n31/cctv.html

))

I. Purpose

The purpose of this policy is to regulate the use of closed circuit

television (CCTV) cameras to monitor and record public areas for the

purposes of safety and security.

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116

V.D. Closed Circuit Television Monitoring and Recording of Public Areas for Safety and Security Purposes

II. Scope

This policy applies to all personnel, UPHS, schools and centers of the

University, in the use of CCTV monitoring and recording. Legitimate uses

of this technology related to research are covered by University policies

governing research with human subjects and, therefore, excluded from

this policy.

III. General Principles

The Division of Public Safety is committed to enhancing the quality

of life of the campus community by integrating the best practices of

public and private policing with state-of-the-art technology. A critical

component of a comprehensive security plan using state-of-the-art

technology is closed circuit television (CCTV).

The purpose of CCTV monitoring of public areas by security

personnel is to deter crime and to assist the Penn police in protecting

the safety and property of the University community. Any diversion

of security technologies and personnel for other purposes (e. g.,

CCTV monitoring of political or religious activities, or employee and/

or student evaluations) would undermine the acceptability of these

resources for critical safety goals and is therefore prohibited by this

policy.

Video monitoring for security purposes shall be conducted in

a professional, ethical and legal manner. Personnel involved in

video monitoring shall be appropriately trained and continuously

supervised in the responsible use of this technology. Violations

of the Code of Procedures for video monitoring referenced in this

policy shall result in disciplinary action consistent with the rules and

regulations governing employees of the University.

Information obtained through video monitoring shall be used

exclusively for security and law enforcement purposes. Information

obtained through video monitoring shall only be released when

authorized by the Vice President of Public Safety according to the

procedures established in this policy.

Video monitoring of public areas for security purposes shall be

conducted in a manner consistent with all existing University policies,

including the Non-Discrimination Policy, the Sexual Harassment

Policy, Open Expression Guidelines and other relevant policies. The

code of practice for video monitoring prohibits monitoring based

on the characteristics and classiﬁcations contained in the Non-

Discrimination Policy (such as, race, gender, sexual orientation,

national origin, and disability)

Video monitoring of public areas for security purposes at the

University is limited to uses that do not violate the reasonable

expectation to privacy as deﬁned by law.

To maintain an informed University community, the Division of Public

Safety shall periodically disseminate written materials describing the

purpose and location of CCTV monitoring and the guidelines for its

use. The location of outdoor CCTV cameras monitored by the Division

of Public safety shall be published in the

Almanac

Information obtained in violation of this Policy may not be used in a

disciplinary proceeding against a member of the University faculty,

staff or student body.

All existing uses of video monitoring and recording must comply with

this policy.

IV. Responsibilities

The Division of Public Safety is the department authorized to

oversee and coordinate the use of CCTV monitoring for safety and

security purposes at the University. All University areas using CCTV

monitoring are responsible for implementing this Policy in their

respective operations. Public Safety has primary responsibility for

disseminating the Policy and assisting other units in implementing

the Policy and related procedures.

The Vice President of Public Safety has the responsibility to

authorize all CCTV monitoring for safety and security purposes at

the University. All new installations shall follow the Division of Public

Safety’s operating principles. All existing CCTV monitoring systems

shall be evaluated for compliance with this policy.

The Division of Public Safety shall monitor new developments in the

relevant law and in security industry practices to ensure that CCTV

monitoring at the University is consistent with the highest standards

and protections.

A CCTV monitoring Panel shall be established to assure that the

Division of Public Safety adheres to established policy and procedure

in the use of CCTV and to review camera locations and request for

release of tapes.

The CCTV monitoring Panel shall consist of seven members who

shall serve for a term of one year:

The Chairperson of the Safety and Security Committee or his/her

designee will serve as chair.

Two faculty members appointed by the Chair of the Faculty

Senate

One member appointed by the President

One student member

One staff member

The University Compliance Ofﬁcer

The CCTV Monitoring Committee will review camera locations to

ensure the perimeter of view of public cameras conforms to this

policy.

The proposed location of permanent CCTV cameras will

be provided to the CCTV Monitoring Committee for review

and published in the

Almanac

before installation. A list of all

University-owned or controlled camera locations will be published

semi-annually in

Almanac

and made available by the Division of

Public Safety to anyone requesting the list.

The locations of temporary cameras to be used for special

events will be reviewed by the CCTV Monitoring Committee for

approval and published in

Almanac

before the event if possible.

(

Note:

“Temporary cameras”—does not include mobile video

equipment or hidden surveillance cameras used for criminal

investigations.)

Included with the list of CCTV camera locations will be a general

description of the technology employed and the capabilities of

the cameras.

Students and staff entering certain sensitive locations

on campus may have an increased concern for privacy or

conﬁdentiality. In order to prevent a possible chilling effect on the

use of service at these locations, concerned persons may petition

the CCTV Monitoring Committee to forgo the installation of a

proposed camera or for the removal of an existing camera. The

CCTV Monitoring Committee will determine the appropriateness

of an installation weighing the concerns of the person(s) making

the requests and the safety and security of the entire community.

In recognizing students may also have an enhanced expectation

of privacy in the hallways and lounges of residence facilities,

CCTV monitoring for safety and security purposes will not

be used in residential hallways and lounges unless the Vice

President of Public Safety determines a speciﬁc safety/security

risk exists.

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University of Pennsylvania Faculty Handbook

117

The CCTV Monitoring Committee will review complaints

regarding camera locations and determine whether the CCTV

Monitoring Policy is being followed. The panel should weigh

whether the potential increment in community security outweighs

any likely infringement of individual privacy.

The CCTV Monitoring Committee, with the Vice President of

Public Safety, will review all requests received by the Division

of Public Safety to release recorded video images obtained

through CCTV monitoring. No releases of recorded video images

will occur without authorization by the Vice President and the

CCTV Monitoring Committee. Excluded from review by the CCTV

Monitoring Committee are releases of recorded video images

directly related to a criminal investigation, arrest or subpoena.

The CCTV Monitoring Committee may also approve release of

recorded video images only for legitimate purposes, such as to

protect the University and its members from harm or liability.

Five afﬁrmative votes are necessary to approve the release of

recorded video images. Any release of recorded video images will

be recorded on a written log.

Any member of the CCTV Monitoring Committee may audit the

Division of Public Safety’s CCTV monitoring operations, including

video storage, at any time without prior notice.

The Chair of University Council’s Committee on Campus &

Community Life will report to the CCTV Monitoring Committee

at least once a year describing all requests for camera locations

and release of recorded video images and disposition of those

requests.

The CCTV Monitoring Committee will review this policy annually

and recommend revisions if needed.

V. Procedures

All operators and supervisors involved in video monitoring of public

areas will perform their duties in accordance with the Code of

Practice consistent with this policy developed by the Division of

Public Safety.

Division of Public Safety Management will assure that responsible

and proper camera monitoring practices by control operators is

continuous.

The Division of Public Safety has posted signage at appropriate

locations. Signage state

This area is subject to Video Monitoring by the

University of Pennsylvania Police Department

The Division of Public Safety will limit camera positions and views of

residential housing. Any view given to the housing will be no greater

than what is available with unaided vision. Furthermore the view

of a residential housing facility must not violate the standard of

“reasonable expectation of privacy.”

The Division of Public Safety Central Monitoring Center and other

central monitoring centers will be conﬁgured to prevent camera

operators tampering with or duplicating recorded video information.

Recorded video will be stored for a period not to exceed 30 days and

will then be erased, unless retained as part of a criminal investigation

or court proceedings (criminal or civil), or other bona ﬁde use as

approved by the Vice President of Public Safety and the CCTV

Monitoring Committee.

Recorded video images will be stored in a secure location with access

by authorized personnel only.

Camera control operators will conduct video observation of areas

only in plain view of others situated in the public area viewable to the

public.

Camera control operators will be trained in the technical, legal and

ethical parameters of appropriate camera use.

Camera control operators will receive a copy of this policy and

provide written acknowledgement that they have read and

understood its contents.

Camera control operators will receive training in cultural

awareness.

Camera control operators will not monitor individuals based

on characteristics of race, gender, ethnicity, sexual orientation,

disability, or other classiﬁcations protected by the University’s Non-

Discrimination Policy. Camera control operators will monitor based on

suspicious behavior, not individual characteristics.

Camera control operators will not spot and continuously view people

becoming intimate in public areas.

Camera control operators will

not

view private rooms or areas through

windows.

Mobile video equipment may be used in criminal investigations.

Mobile video equipment will only be used in non-criminal

investigations in speciﬁc instances creating signiﬁcant risk to public

safety, security, and property as authorized in writing by the President

to the Division of Public Safety and the Open Expression Committee.

Portable hidden cameras with recording equipment will only be used for

criminal investigation by the University Police Detective Unit with the

approval of the Vice President of Public Safety.

Examples of Video Monitoring and Recording of Public

Areas

Legitimate safety and security purposes include, but are not limited to the

following;

Protection of buildings and property

Building perimeter, entrances and exits, lobbies and corridors, receiving

docks, special storage areas, laboratories, cashier locations, etc.

Monitoring of Access Control Systems

Monitor and record restricted access transactions at entrances to

buildings and other areas.

Veriﬁcation of security alarms

Intrusion alarms, exit door controls, hold-up alarms

Video Patrol of Public Areas

Transit Stops, parking lots, public streets (enclosed and unenclosed),

shopping areas and vehicle intersections, etc.

Criminal Investigation

Robbery, burglary, and theft surveillance

Protection of pedestrians

Monitoring of pedestrian and vehicle trafﬁc activity

V.E. Relationships Between Members

of the University Community and

Intelligence Organizations

(Source: University Council Resolution, January 19, 1979 and Ofﬁces of the

President and Provost, 1979 Handbook for Faculty and Administration)

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118

V.E. Relationships Between Members of the University Community and Intelligence Organizations

I. Introduction

The generation, preservation, and dissemination of information and

ideas are primary functions of an academic institution. They are also

primary functions of intelligence organizations. From this functional

congruence have stemmed relationships between the academic and

intelligence communities which in many instances are both proper and

beneﬁcial. There are, however, profound differences between the two

communities which invest such relationships with potential for harm to

the integrity and/or effectiveness of both. Open and unfettered exchange

of information and ideas is the life blood of the academic community. For

the intelligence community, on the other hand, secrecy is an inescapable

fact of life.

Furthermore, reports of questionable activities of intelligence

organizations must influence consideration of relationships between

such organizations and an academic community. It therefore is

appropriate for the University to establish policies regarding issues of

concern in relationships between itself and members of the University

community and intelligence organizations in order to protect its interests

in any such relationships.

In adopting such policies the University recognizes the importance to

the nation of effective intelligence organizations. University policies

regarding issues of concern in relationships between members of the

University community and intelligence organizations must be consistent

with the maintenance of individual rights and freedoms. In addition, the

University recognizes that some of the issues raised by relationships

with intelligence organizations are not speciﬁc to such organizations and

that, therefore, policies designed to govern these issues should be more

broadly based.

These considerations have guided the development of the following

policies that shall govern issues of concern in relationships between the

University of Pennsylvania and members of the University community,

and intelligence organizations.

II. Deﬁnition of Terms as Used in This

Section

University:

The corporate entity formally known as the Trustees of the

University of Pennsylvania.

Intelligence organization:

Any organization or part thereof which has

as its primary function the collection, analysis, or dissemination of

information in aid of the security objectives of a domestic or foreign

government.

University community:

The set of individuals who are employed by, or who

participate in the educational and other activities of, the University, at

times when they are, or may reasonably be thought by others to be, acting

in their capacity as employees or participating in such activities.

Explanatory Note:

The deﬁnition of University community is intended

to reflect the fact that relationships between members of an academic

community and intelligence organizations may pose a threat to the

integrity of that community and to the academic community at large,

even at times when the individuals in question are, in their own minds,

pursuing private interests or conducting personal affairs. In attempting

to achieve a balance between this concern and its concern for individual

rights and freedoms, the committee who wrote this section concluded

that adherence to policies in this area could legitimately be expected

when individuals are conducting University business or participating in

University activities and also when they “may reasonably be thought by

others to be doing so.”

The committee appreciated the difﬁculty of applying the deﬁnition of

University community in some cases but nevertheless believes that it

provides necessary and useful guidance. As an example, consider a

situation in which a University faculty member and an employee of an

intelligence organization ﬁnd themselves participating as members of a

church choir, a patently non-University activity. In terms of our deﬁnition,

the faculty member could not normally be construed to be a member

of the University community in these circumstances. However, if the

employee of the intelligence organization were to take advantage of his

proximity to question the faculty member about a University student or

colleague for intelligence purposes, in the committee’s view the faculty

member should reasonably be thought to be responding as a member

of the University community because the information in question would

normally have been learned at a time when the faculty member was

acting in his capacity as an employee of, or was participating in the

activities of, the University.

III. Research and Technical Service

Agreements

The University may properly enter into an agreement with an intelligence

organization for the conduct of a research program or for the provision

of technical services, provided that the terms and conditions of such

agreement are consistent with the Guidelines for the Conduct of

Sponsored Research and with any other University policies and practices

governing agreements with extramural organizations.

Consultation

Individual members of the University community may properly enter

into an agreement with an intelligence organization to act as a technical

or professional consultant or practitioner, with or without fee, provided

that the general nature of the proposed agreement is reported to the

appropriate dean (for faculty or students) or other administrative ofﬁcer

(for others) prior to the provision of any services thereunder. The dean

or other administrative ofﬁcer shall consider whether the proposed

agreement is consistent with existing University policies, e.g. the Conflict

of Interest Policy for Faculty Members (section II. E. 10) or the Conflict

of Interest Policy for Trustees, Associate Trustees, Ofﬁcers and other

University Employees (adopted by the Trustees, June 19, 1981). The dean

or other administrative ofﬁcer shall also consider whether the proposed

agreement would compromise the individual’s participation in, or the

integrity of, University programs or activities. If the proposed agreement

appears to be in conflict with existing policies or to be inappropriate on

the grounds stated in the preceding sentence, and if the matter cannot be

resolved with the member of the University community, the dean or other

administrative ofﬁcer shall report that fact to the Provost and President

and recommend appropriate action.

Explanatory Note:

Existing University policies require reporting of

extramural consultative and business activities for a fee by full-time

members of the faculty, and reporting of such activities, whether

compensated or not, by administrative and professional staff. Their

purpose is to prevent excessive diversion of effort into extramural

activities and to avoid conflicts of interest. Because recent events

have raised concerns about the potential effect of agreements with

intelligence organizations on an individual’s ability to function properly

in a free and open academic community, the committee believes that

a reporting requirement for such agreements should be extended to all

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119

members of the University community and should apply whether or not a

fee is involved. Such reports are not intended for public release.

The requirement that the dean or other administrative ofﬁcer “consider

whether the proposed agreement would compromise the individual’s

participation in, or the integrity of, University programs or activities”

reflects a standard that is, at least in part, already embodied in the

existing University policies mentioned in this section. However, these

policies presently apply only to Standing Faculty, Standing Faculty-

Clinician-Educators, and full-time members of the Associated Faculty and

the Academic Support Staff contemplating an extramural consultative or

business activity for fee and to administrative and professional staff. The

committee’s intent here is both to extend the standard of existing policies

to all members of the University community in the case of a proposed

relationship with an intelligence organization and to make it clear that in

exceptional cases such a relationship may be objectionable for reasons

not reflected in existing policies.

V. Information Concerning Members of the

University Community

Members of the University Community who provide any factual

information or opinion about other members of the University Community

to extramural organizations or individuals (

e.g.

, in connection with

possible employment) must at all times exercise good judgment and

discretion and distinguish clearly between factual information and

opinion. In addition:

Any member of the University Community who has an agreement

or understanding with an extramural organization or individual to

provide any factual information or opinion about other members of

the University community on a regular basis, for recruiting purposes,

must identify him or herself to the appropriate dean or other

administrative ofﬁcer and to the appropriate University placement

ofﬁcer as a recruiter for the speciﬁed extramural organization or

individuals.

Members of the University Community should require extramural

organizations and individuals soliciting any factual information

or opinion about another member of the University Community to

identify themselves fully and accurately and to indicate the expected

use of the information or opinion.

A member of the University Community who is asked by an

intelligence organization or representative thereof to identify for

recruiting purposes or to provide factual information or opinion

about another member of the University Community should

consider whether the exercise of good judgment and discretion

requires obtaining the prior informed consent of the individual in

question. If the individual in question is a currently enrolled student,

prior informed consent should always be obtained before factual

information (including the individual’s name) is provided.

The requirement of prior informed consent is not applicable where

information is sought by an intelligence organization in connection with

the investigation of alleged speciﬁc criminal activity. The requirement

of prior informed consent shall be deemed to have been satisﬁed if the

person requesting information provides proof that the student has given

written consent (which may be a blanket consent) or, in the case of an

application for employment, proof of such application.

The committee understands that the identity of “recruiters” is a matter of

public record within the University. This record shall include the names of

all recruiters for extramural organizations as deﬁned in that subsection.

The University Guidelines on the Conﬁdentiality of Student Records

(IV.J.), which reflect and elaborate the requirements of federal law, specify

the circumstances in which personally identiﬁable information may

be disclosed from a student’s education records without prior written

consent. Even in such circumstances, the guidelines require the exercise

of informed discretion by the person disclosing the information. The

guidelines do not apply to information that is not part of or derived from

a student’s education records and, although individual departments of

the University have policies regarding the conﬁdentiality of other (e.g.,

employment) records, there is no comprehensive University policy with

respect to such records.

We believe that the standard set forth in this section provides appropriate

guidance for those providing factual information or opinions about any

member of the University community to any extramural organization or

individual. In light of reported abuses in the use of information provided

to intelligence organizations by academic institutions or persons

afﬁliated with them, particularly information about students, we believe

that the requirement for the exercise of good judgment and discretion set

forth in the section above applies with particular force in this context.

The committee notes, for example, that the director of the Central

Intelligence Agency has recently conﬁrmed that the agency currently

has and intends to maintain secret contacts with University personnel

for the purpose of recruitment of students, including foreign students.

For this reason, we believe that a requirement of informed consent prior

to the release of factual information about currently enrolled students

(including students on summer recess or approved leave of absence)

is appropriate. Unless students can be assured that activities of this

sort will not be abetted by other members of the University community,

the atmosphere of trust that is essential to the academic enterprise will

suffer.

In cases where there is doubt about the purpose of an investigation,

members of the University community who are requested to provide

information shall refer the person making the request to the General

Counsel, who shall determine whether a response is appropriate under

these guidelines.

VI. Operational and Other Activities

Members of the University Community may not undertake activities on

behalf of an intelligence organization that are inconsistent with their

normal University activities.

Members of the University Community may not knowingly lend their

efforts, names or positions to the production or dissemination of

information known by them to be false or misleading.

Members of the University Community may not cooperate with an

intelligence organization in obtaining the unwitting services of any other

individual.

VII. Interpretation of These Guidelines

In the ﬁrst instance, the responsibility for interpretation and

implementation of these guidelines rests with the appropriate dean or

other administrative ofﬁcer. If such interpretation is disputed, all parties

to the dispute have the right of appeal to the President of the University,

who has the ultimate responsibility for interpretation of these guidelines.

It is understood that any member of the University Community who

is party to a dispute over interpretation and implementation of these

guidelines may have recourse to one or another of the existing University

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120

V.F. Photocopying for Educational Use

mechanisms for resolution of disputes, e.g. a committee on academic

freedom and responsibility, a grievance procedure or the ofﬁce of the

University Ombudsman.

V.F. Photocopying for Educational

Use

(Source: Ofﬁce of the General Counsel, March 28, 1978 and 1979 Handbook

for Faculty and Administration; reprinted,

Almanac, May 23, 1989

(

https://

almanac.upenn.edu/archive/v35pdf/n36/052389.pdf

))

The enactment of a federal Copyright Act (hereinafter, “the Act”), effective

January 1, 1978, has produced much misunderstanding among teachers

regarding the permissible amount of photocopying for educational

purposes.

Only copyrighted works are protected by the Act. This elemental

point is often overlooked. Court opinions, legislative hearings and

other government documents are not copyrighted, and may be freely

photocopied. The same is true of works for which the copyright

has expired, and of works which prior to January 1978 were sold or

disseminated without proper notice of copyright.

There is a danger, however, of acting unlawfully when one photocopies

without permission works which are covered by the Act. The Act applies

to all “original works of authorship” in written (or other tangible) form,

from the moment the work is created, whether it was created before or

after January 1, 1978 and whether or not it has been published.

But even copyrighted materials may be photocopied without permission

from, or payment to, the copyright owner, if it is a “fair use,” a doctrine

recognized by American courts for nearly a century and a half whose

principal purpose is to protect the public interest in the dissemination

of knowledge. This doctrine is endorsed in the text of the Act, which

explicitly refers to the allowable reproduction of copyrighted works

for purposes such as “criticism, comment, news reporting, teaching

(including multiple copies for classroom use), scholarship, or research.”

Congress appreciated the impossibility of announcing in a statute an

exact quantitative measure that would distinguish copying which is a

fair use from copying which is an infringement. Rather, the Act provides

factors to be considered:

•

The purpose and character of the use, including whether such use is

of a commercial nature or is for non-proﬁt educational purposes;

•

The nature of the copyrighted work;

•

The amount and substantiality of the portion used in relation to the

copyrighted work as a whole; and

•

The effect of the use upon the potential market for or value of the

copyrighted work.

The making of a single copy of copyrighted material for a teacher’s

personal use in teaching, scholarship or research will almost always be

a fair use. More difﬁcult questions arise when multiple copies are made

for distribution to students. Certainly, the risk of infringement increases

in proportion to the amount of copyrighted material that is photocopied

and the extent that the photocopying replaces what would otherwise

be a purchase of copies of the work from trade sources by (or for) the

students. Thus, the making of multiple photocopies of an entire or of a

substantial part of an article will raise serious question as to whether

such a use is “fair,” while the reproduction of ﬁve pages of an article of 25

or 30 pages will generally be regarded as privileged. A teacher should try

to avoid making multiple photocopies of copyrighted material that is not

truly important for that teacher’s pedagogical needs.

In any event, students receiving such photocopied material should be

charged no more than is necessary to cover the cost of photocopying

and processing. During Congressional deliberations on the Act, a group

of educational associations and commercial publishers developed a set

of guidelines that purport to announce the minimum reach of the fair

use doctrine as applied to educational photocopying. The guidelines are

set forth below. In the report by the House committee submitting the

construction of the fair use doctrine. Several misconceptions about these

guidelines have developed and should be dispelled.

Although some have read the guidelines as imposing limits upon

educational photocopying, in fact they prohibit nothing. They purport to

state only the minimum protection of the fair use doctrine and announce

a “safe harbor” within which a teacher is assured of protection against

claims of infringement. The guidelines acknowledge that there may

be allowable photocopying beyond that which is set forth; they do not

purport to state where the fair use privilege ends.

Although some have treated the guidelines as though they have

the status of legislation, that is not true either. The text of the Act,

strengthened in committee deliberations, explicitly refers to “teaching

(including multiple copies for classroom use)” as a classic situation in

which the fair use doctrine applies. This is the statutory text Congress

had before it when it voted, and it is the statutory text that the courts

will construe. The extent to which the privately-developed “guidelines”

will preempt other “reasonable” interpretations of fair use is a judicial

question.

A teacher should consider the potential consequences of an incorrect

decision. If the teacher elects not to photocopy in circumstances

constituting fair use, students must ﬁnd the material in the library or

elsewhere. Techniques for increasing student access to limited materials

will vary; the question of permissible library photocopying for “reserve”

purposes raises issues not addressed here.

If a teacher decides to photocopy for classroom use, the possible legal

sanctions for an incorrect decision must be appreciated. Book publishers

have declared and demonstrated their intention to sue faculty members,

universities, and copy centers for copyright infringement. As a general

rule, a copyright infringer is liable for damages, measured by the loss

of proﬁts to the copyright owner and any additional proﬁts acquired by

the infringer. Since in the academic setting there will not generally be

proﬁts to the teacher or school, damages will be measured by the likely

loss in sales of the copyrighted work, normally an uncertain ﬁgure. For

this reason, the Act permits the copyright owner to sue for “statutory

damages” in lieu of actual damages, and the court is given discretion

to enter an award between $250 and $10,000 (which may be increased

to $50,000 for willful violations). If, however, a teacher had reasonable

grounds to believe that the photocopying was a fair use, he/she is not

liable for statutory damages (although he or she may be liable for actual

damages). In all cases, the court may issue an order against the teacher

or the educational institution barring future infringements.

Without regard to legal implications, a teacher should be sensitive to

the dictates of good practice and courtesy in the use of copyrighted

material. Authors and copyright owners appreciate notiﬁcation that uses

are being made of their work. It is common for the copyright owner to

permit substantial photocopying for educational purposes, provided that

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University of Pennsylvania Faculty Handbook

121

the author and copyright owner are identiﬁed and proper copyright notice

is afﬁxed.

Questions regarding the application of the Copyright Act in speciﬁc

situations should be addressed to the Ofﬁce of the General Counsel.

Guidelines

Single Copying for Teachers. A single copy may be made of any of the

following by or for a teacher at his/her individual request for his/her

scholarly research or use in teaching or preparation to teach a class:

A chapter from a book;

An article from a periodical or newspaper;

A short story, short essay or short poem whether or not from a

collective work;

A chart, graph, diagram, drawing, cartoon or picture from a book,

periodical, or newspaper.

Multiple Copies for Classroom Use. Multiple copies (not to exceed in

any event more than one copy per pupil in a course) may be made by

or for the teacher giving the course for classroom use or discussion

provided that:

The copying meets the tests of brevity and spontaneity as deﬁned

below; and

Meets the cumulative effect test as deﬁned below; and

Each copy includes a notice of copyright.

Deﬁnitions

Brevity

Poetry: (1) A complete poem if less than 250 words and if printed on

not more than two pages, or (2) from a longer poem, an excerpt of not

more than 250 words.

Prose: (1) Either a complete article, story or essay of less than 2,500

words, or (2) an excerpt from any prose work of not more than 1,000

words or ten percent of the work, whichever is less, but in any event a

minimum of 500 words.

Each of the numerical limits stated in “a” and “b” above may be

expanded to permit the completion of an unﬁnished line of a poem or

of an unﬁnished prose paragraph.

Illustration: One chart, graph, diagram, drawing, cartoon or picture per

book or per periodical issue.

“Special” works: Certain works in poetry, prose or in “poetic prose”

that often combine language with illustrations and are intended

sometimes for children and at other times for a more general

audience fall short of 2,500 words in their entirety. Paragraph “b”

above notwithstanding, such “special works” may not be reproduced

in their entirety; however, an excerpt comprising not more than two

of the published pages of such special work and containing not

more than ten percent of the words found in the text thereof may be

reproduced.

Spontaneity

The copying is at the instance and inspiration of the individual

teacher, and

The inspiration and decision to use the work and the moment of its

use for maximum teaching effectiveness are so close in time that

it would be unreasonable to expect a timely reply to a request for

permission.

Cumulative Effect

The copying of the material is for only one course in the school in

which the copies are made.

Not more than one short poem, article, story, essay or two excerpts

may be copied from the same author, nor more than three from the

same collective work or periodical volume during one class term.

There shall not be more than nine instances of such multiple copying

for one course during one class term. [The limitations stated in

“b” and “c” above shall not apply to current news periodicals and

newspapers and current news sections of other periodicals.]

Prohibitions as to the above. Notwithstanding any of the above, the

following shall be prohibited:

Copying shall not be used to create or to replace or substitute for

anthologies, compilations or collective works. Such replacement

or substitution may occur whether copies of various works or

excerpts there from are accumulated or are reproduced and used

separately

There shall be no copying of or from works intended to be

“consumable” in the course of study or of teaching. These include

workbooks, exercises, standardized tests and test booklets and

answer sheets and like consumable material.

Copying shall not:

substitute for the purpose of books, publisher’s reprints or

periodicals;

be directed by higher authority;

be repeated with respect to the same item by the same

teacher from term to term.

No charge shall be made to the student beyond the actual cost of

the photocopying.

(See page 6 - Almanac, May 23, 1989 (https://almanac.upenn.edu/

archive/v35pdf/n36/052389.pdf))

V.G. Protocols for the University

Archives and Records Center

(Source: Ofﬁce of the President, Almanac, January 23, 1990 and

Resolution

of the Trustees, June 22, 1990

(

https://archives.upenn.edu/digitized-

resources/docs-pubs/trustees-minutes/minutes-1990/june-22/

); revised,

Ofﬁce of the Provost, February 2, 2023)

I. Mission

The University of Pennsylvania, acting through its University Archives and

Records Center, recognizes its responsibility to the academic community

and to the public for the orderly retention and disposition of all University

records, both active and inactive, and for the timeless preservation of

historically signiﬁcant documents and other materials which reflect the

University’s origins and development and the activities and achievements

of its ofﬁcers, faculty, students, alumni, and benefactors.

In order to meet this obligation the University Archives and Records

Center has been designated the ofﬁcial repository of all inactive and

historical records of the University’s administrative ofﬁces, academic

departments, committees, and student groups. Documentation is sought

for all aspects of University life. The University Archivist organizes

and supervises the deposit and servicing of inactive records in the

Records Center and the eventual permanent conveyance of historical

materials to the Archives. The purpose of the records management

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122

V.G. Protocols for the University Archives and Records Center

program is to provide records retention and retrieval services which

assist the faculty and administrative staff in the ongoing operation of the

University. The purpose of the archives program is to collect, preserve

and make accessible materials of historical value. Thus it serves scholars

interested in the history of the University, institutions of higher learning

in the United States, American intellectual life, and the Philadelphia

community in which the University lives. In addition to the University’s

administrative records, the Archives and Records Center shall also collect

the personal and professional papers of University ofﬁcers, faculty,

students, alumni, and benefactors and the papers of individuals and

organizations where the subject matter of the collection is particularly

relevant to University history.

The Archives and Records Center shall provide appropriate facilities for

the retention, preservation and servicing of its holdings. Inactive records

remain the property of the ofﬁce of their origin and are made accessible

only to authorized representatives of that ofﬁce. Historical materials

are the property of the Archives and Records Center and are made

accessible to scholars and the community at large in accordance with

University access policy. By making its historical collections accessible,

by encouraging their use for historical research and scholarship and by

entering into cooperative relationships with other archival and records

management agencies and institutions, the Archives and Records Center

shall serve as an educational resource center within the University of

Pennsylvania, a place to stimulate and nourish creative teaching and

learning.

II. Administrative Mandate

The Trustees of the University of Pennsylvania, recognizing the need

for formal archival and records management policy, hereby adopt the

following policy and procedures for the collection, retention, preservation,

and servicing of University records:

Responsibility for assuring that historically signiﬁcant materials

shall be preserved and permanently retained at the University of

Pennsylvania lies with a single administrative unit, the University

Archives and Records Center. The successful collection of all such

records requires that one ofﬁce, with University-wide purview, manage

their progression through the several stages — active, inactive and

archival — of their life cycle. In general, active records are those in

use in the ofﬁce in which they were created; inactive records are

those placed under ﬁnite-term retention at a records center facility,

and archival records are those of historical signiﬁcance retained

permanently in a repository open to research.

Any papers or other records generated or received by the

administrative and academic ofﬁces of the University in the

conduct of their business — including all ofﬁcial printed material,

reports, record books, minutes, committee ﬁles, ﬁnancial records,

correspondence, and associated papers — are the property of the

University and may become archival material. The deﬁnition of

University records shall also extend to forms other than paper, such

as prints, photographs, microﬁlm, motion picture ﬁlm, audio and video

formats, digital, and electronic records.

All administrative ofﬁcers of the University, including those members

of the Faculty who, by virtue of administrative responsibilities either

of a continuing or occasional nature, possess University records

relating to their ofﬁcial duties, are to observe the following policy and

procedures:

Provision shall be made for efﬁcient and economic records

control by all University administrative ofﬁces and the University

Archives and Records Center. Records shall be regularly surveyed,

inventoried and appraised to determine retention value. Active

records shall be retained by the ofﬁce of origin; inactive records

will be transferred to the Records Center and placed on ﬁnite-term

retention schedules. The ofﬁcer in charge of each administrative

or academic ofﬁce, in consultation with the University Archivist,

shall be responsible for deciding how long both active and

inactive papers shall be retained in and under the direct control

of the ofﬁce of origin. Inactive records transferred to the Records

Center shall remain the property of the ofﬁce of origin and shall

be accessible only to authorized representatives of that ofﬁce.

University records may not be destroyed or placed in inactive

storage at a site other than one designated by the Records Center

without the joint approval of the senior ofﬁcer in the ofﬁce of

origin and the University Archivist. Should these individuals

be unable to agree on retention value, disposition shall be

stayed pending review and ﬁnal determination by the Advisory

Committee on the University Archives and Records Center, as

deﬁned in paragraph seven below.

The University Archivist, in accordance with prevailing collections

and access policies, shall be responsible for the appraisal of

inactive University records for their historical signiﬁcance. The

University Archivist shall determine which such materials shall be

permanently retained by the Archives, shall grant and limit access to

the collections and shall establish and administer other public service

policies and procedures as necessary. Historically signiﬁcant records

transferred to the University Archives for permanent retention shall

become the property of the University Archives and Records Center.

The University Archives and Records Center shall be an

administrative department within the Penn Libraries. The University

Archivist is responsible for long-range planning and for hiring, training

and supervising departmental staff. The University Archivist is

accountable for the successful performance of all departmental

services: records management, development of archival collections,

cataloguing and other technical services, access, and other public

services. The University Archivist shall review and have decision

making power over University records which may be offered to or

found in any of the multiple archival repositories at the University.

The University Archivist shall establish intellectual access to all such

repositories through the maintenance of shared collection catalogues

and ﬁnding aids.

The University Archives and Records Center, as the ofﬁcial repository

for all University records, including conﬁdential records, shall provide

appropriate facilities for their retention and preservation. The

University Archives and Records Center shall be provided ﬁnancial

and personnel resources sufﬁcient to maintain services at the level of

comparable university archives and records management operations.

In order to facilitate these protocols an independent Advisory

Committee on the University Archives and Records Center shall be

established and shall have the following responsibilities:

to advise the Penn Libraries or University Archivist on institutional

support and initiatives required to fulﬁll archival and records

management policy;

to advise the University Archivist on the implementation of this

policy; and

in particular, to resolve substantive issues which may arise

regarding access and collections policy and when necessary,

to advise the Penn Libraries or University Archivist on the

modiﬁcation of these policies.

The Committee shall be composed of ten members: one representative

each from the ofﬁces of the President, the Secretary of the University, the

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University of Pennsylvania Faculty Handbook

123

Provost, and the General Counsel; three members of the standing faculty

appointed by the Senate Executive Committee to serve overlapping three-

year terms; and three members of the standing faculty appointed by the

President, also to serve overlapping three-year terms. The President shall

appoint the Committee Chair.

The Committee shall meet at the call of the University Archivist or the

Chair. It shall meet a minimum of once per semester.

III. Collections Policy

The University Archivist and staff of the University Archives and Records

Center shall actively seek, identify and acquire historically signiﬁcant

materials in the following categories:

University administrative records, including, but not limited to:

correspondence, memoranda, minutes, summary ﬁnancial records,

academic research, curriculum, contracts, reports, subject ﬁles,

published materials, photographs, and any other material generated

or received by the administrative and academic ofﬁces of the

University in the conduct of their business. These records shall be

collected in accordance with the University-wide archives and records

management program, in which all records pass through active and

inactive phases prior to appraisal for historical signiﬁcance.

Materials which document the life of the University community,

including student activities, alumni organizations, organizations of

faculty and administrators, and other University related groups. Such

materials are essential complements to ofﬁcial University records.

They may take a variety of physical, digital, and electronic forms,

including books, news clippings, manuscripts, maps and posters,

motion picture ﬁlms, audio and video, and artifacts and objects.

The personal and professional papers of prominent people

associated with the University, including University ofﬁcers, faculty,

students, alumni, and benefactors. These manuscript collections

may include materials relating to issues of historical signiﬁcance

outside higher education as well as professional academic activities,

research and teaching, and educational theories and practices during

the lifetime of the University. This collecting mandate shall also

extend to the papers of individuals and organizations where the

subject matter of the collection is particularly relevant to the history

of the University, institutions of higher learning in the United States,

American intellectual life, and the Philadelphia community in which

the University lives.

The deposit, transfer or donation of records and other materials to the

Archives and Records Center shall follow speciﬁc procedures established

by the University Archivist. In the case of deposit of University records at

the Records Center, the ofﬁce or individual of origin does not relinquish

control of the materials. In the case of transfer of University records for

permanent retention at the Archives, the ofﬁce or individual of origin

relinquishes all rights to the materials. In cases where the materials

are donated to the University, the donor usually relinquishes all rights,

including copyright and literary rights. Donor restrictions are acceptable

in special cases.

IV. Access Policy

The historical collections of the University Archives and Records Center

are open for research to all members of the University community, to

visiting scholars and to the scholarly public. The University encourages

the use of these collections through the dissemination of descriptive

catalogues and the provision of public services at the Archives.

Access to certain classes of records, however, is restricted. Access to

restricted records may be requested by written appeal to the Director of

the University Archivist.

The following types of records generally will be closed:

•

all administrative records of the University for twenty-ﬁve years from

the date of their creation, with certain exceptions, such as those

which must be open in conformance with law;

•

records of a sitting administration;

•

records the disclosure of which might expose the University to legal

liability.

The following types of records will be absolutely closed:

•

individual education records of living students or living former

students, as deﬁned by the Family Educational Rights and Privacy

Act of 1974, as amended, unless the student or former student

grants access in writing (in accordance with the University

“Conﬁdentiality of Student Records (https://catalog.upenn.edu/

pennbook/conﬁdentiality-student-records/)” as published in

the

PennBook

and

Almanac

);

•

individual employment records of living current or former faculty

members, administrators or other staff members, including records

which concern hiring, appointment, promotion, tenure, salary,

performance, termination or other circumstances of employment,

unless the faculty member, administrator, or staff member grants

access in writing (in accordance with University Conﬁdentiality of

Records Policy No. 201 (https://www.hr.upenn.edu/policies-and-

procedures/policy-manual/other-policies/conﬁdentiality-of-records/));

•

other records where usage might constitute an invasion of privacy;

•

records the use of which has been restricted by Deed of Gift.

Requests to photocopy or otherwise reproduce restricted records

generally will be denied.

Appeals to gain access to restricted records shall be conducted in the

following manner:

a researcher seeking access to restricted records shall complete a

“Restricted Records Access Request” form;

the University Archivist shall review each request with the Advisory

Committee on the University Archives and Records Center; the

Advisory Committee is composed of ten members: one representative

each from the ofﬁces of the President, the Secretary of the University,

the Provost and the General Counsel; and six members of the

standing faculty;

the Advisory Committee shall base its decisions on the merits of

each case, weighing the needs of scholarship against the privacy

rights of individuals and the legal interests of the University; the

Committee must be satisﬁed that a researcher seeking access to

restricted records has demonstrated that the records are required

to carry out a legitimate scholarly research project or for other

appropriate use; in all cases, the decision of the Committee shall be

fair and reasonable, permitting the greatest possible access, given

the limitations imposed by legal and ethical considerations;

in order to come to such a decision, the Advisory Committee shall

meet, review the research proposal of the scholar petitioning for

access, examine the materials to which he or she is requesting

access and discuss the case; in cases where the materials are

voluminous, the University Archivist shall review them and summarize

their nature and content for the Committee, presenting individual

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124

V.H. Policy on Acceptable Use of Electronic Resources

documents of particular concern; in cases of requests for innocuous

materials, a less formal review process may be invoked, consisting of

a telephone or electronic poll by the University Archivist;

the Advisory Committee may act as a whole in its review and decision

making or may delegate to a sub-committee of its own members

the power to implement this policy; the decisions of the Advisory

Committee shall be ﬁnal.

V.H. Policy on Acceptable Use of

Electronic Resources

(Source: Ofﬁce of the Provost,

Almanac, April 29, 1997

(

https://

almanac.upenn.edu/archive/v43/n32/accept.html

))

Summary

This policy deﬁnes the boundaries of “acceptable use” of limited

University electronic resources, including computers, networks, electronic

mail services and electronic information sources, as detailed below. It

includes by reference a self-contained compilation of speciﬁc rules that

can be modiﬁed as the electronic information environment evolves.

The policy is based on the principle that the electronic information

environment is provided to support University business and its mission

of education, research and service. Other uses are secondary. Uses

that threaten the integrity of the system; the function of non-University

equipment that can be accessed through the system; the privacy or

actual or perceived safety of others; or that are otherwise illegal are

forbidden.

By using University electronic information systems, you assume personal

responsibility for their appropriate use and agree to comply with this

policy and other applicable University policies, as well as City, State and

Federal laws and regulations, as detailed below.

The policy deﬁnes penalties for infractions, up to and including loss of

system access, employment termination or expulsion. In addition, some

activities may lead to risk of legal liability, both civil and criminal.

Users of electronic information systems are urged in their own interest to

review and understand the contents of this policy.

Purposes

The University of Pennsylvania makes computing resources (including,

but not limited to, computer facilities and services, computers, networks,

electronic mail, electronic information and data, and video and voice

services) available to faculty, students, staff, registered guests, and the

general public to support the educational, research and service missions

of the University.

When demand for computing resources may exceed available capacity,

priorities for their use will be established and enforced. Authorized faculty

and staff may set and alter priorities for exclusively local computing/

networking resources. The priorities for use of University-wide computing

resources are:

Highest:

Uses that directly support the educational, research and service

missions of the University.

Medium:

Other uses that indirectly beneﬁt the education, research and

service missions of the University, as well as and including reasonable

and limited personal communications.

Lowest:

Recreation, including game playing.

Forbidden:

All activities in violation of the General Standards or prohibited

in the

Speciﬁc Rules

interpreting this policy.

The University may enforce these priorities by restricting or limiting

usages of lower priority in circumstances where their demand and

limitations of capacity impact or threaten to impact usages of higher

priority.

Implied consent

Each person with access to the University’s computing resources

is responsible for their appropriate use and by their use agrees to

comply with all applicable University, School, and departmental policies

and regulations, and with applicable City, State and Federal laws and

regulations, as well as with the acceptable use policies of afﬁliated

networks and systems (See Appendices to

Speciﬁc Rules

Open Expression in the Electronic Information Environment:

The rights

to freedom of thought, inquiry and expression, as deﬁned in the

University’s Guidelines on Open Expression (https://catalog.upenn.edu/

pennbook/open-expression/), are paramount values of the University

community. The University’s commitment to the principles of open

expression extends to and includes the electronic information

environment, and interference in the exercise of those rights is a

violation of this policy and of the Guidelines on Open Expression (https://

catalog.upenn.edu/pennbook/open-expression/). As provided in the

Guidelines (https://catalog.upenn.edu/pennbook/open-expression/),

in case of conflict between the principles of the Guidelines on Open

Expression (https://catalog.upenn.edu/pennbook/open-expression/) and

this or other University policies, the principles of the Guidelines (https://

catalog.upenn.edu/pennbook/open-expression/) take precedence.

General Standards for the Acceptable Use of Computer Resources:

Failure

to uphold the following General Standards for the Acceptable Use of

Computer Resources constitutes a violation of this policy and may be

subject to disciplinary action.

The General Standards for the Acceptable Use of Computer Resources

require:

•

Responsible behavior with respect to the electronic information

environment at all times;

•

Behavior consistent with the mission of the University and with

authorized activities of the University or members of the University

community;

•

Respect for the principles of open expression;

•

Compliance with all applicable laws, regulations, and University

policies;

•

Truthfulness and honesty in personal and computer identiﬁcation;

•

Respect for the rights and property of others, including intellectual

property rights;

•

Behavior consistent with the privacy and integrity of electronic

networks, electronic data and information, and electronic

infrastructure and systems; and

•

Respect for the value and intended use of human and electronic

resources.

Enforcement and Penalties for Violation: Any person who violates any

provision of this policy, of the

Speciﬁc Rules

interpreting this policy, of

other relevant University policies, or of applicable City, State, or Federal

laws or regulations may face sanctions up to and including termination or

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University of Pennsylvania Faculty Handbook

125

expulsion. Depending on the nature and severity of the offense, violations

can be subject to disciplinary action through the Student Disciplinary

System or disciplinary procedures applicable to faculty and staff.

It may at times be necessary for authorized systems administrators

to suspend someone’s access to University computing resources

immediately for violations of this policy, pending interim resolution

of the situation (for example by securing a possibly compromised

account and/or making the owner of an account aware in person that an

activity constitutes a violation). In the case of egregious and continuing

violations suspension of access may be extended until ﬁnal resolution by

the appropriate disciplinary body.

System owners, administrators or managers may be required to

investigate violations of this policy and to ensure compliance.

Amendment

Formal amendment of the General Standards of Acceptable Use of

Computing Resources or other aspects of this policy may be promulgated

by the Provost following consultation with the University Council

Committee on Communications, publication “For Comment” in

Almanac

, a

reasonable waiting period, and publication “Of Record” in

Almanac

Interpreting this Policy

As technology evolves, questions will arise about how to interpret

the general standards expressed in this policy. The Vice President for

Information Systems and Computing shall, after consultation with the

University Council Committee on Communications, and subject to the

same waiting period and publication provisions as above, publish speciﬁc

rules interpreting this policy.

Waiver

When restrictions in this policy interfere with the research, educational or

service missions of the University, members of the University community

may request a written waiver from the Vice President for Information

Systems and Computing (http://www.upenn.edu/computing/isc/) (or

designee).

Further Information

For further information about University computing regulations or

Commonwealth of Pennsylvania and Federal computing laws, contact the

University Information Security Ofﬁcer at (215) 898-2172 or send email to:

security@isc.upenn.edu.

Speciﬁc Rules Interpreting the Policy on

Acceptable Use of Electronic Resources

The following speciﬁc rules apply to all uses of University computing

resources. These rules are not an exhaustive list of proscribed behaviors,

but are intended to implement and illustrate the General Standards for

the Acceptable Use of Computer Resources, other relevant University

policies, and applicable laws and regulations. Additional speciﬁc rules

may be promulgated for the acceptable use of individual computer

systems or networks by individual Schools, departments, or system

administrators.

Content of Communications

•

Except as provided by applicable City, State, or Federal laws,

regulations or other University policies, the content of electronic

communications is not by itself a basis for disciplinary action.

•

Unlawful communications, including threats of violence, obscenity,

child pornography, and harassing communications (as deﬁned by

law), are prohibited.

•

The use of University computer resources for private business or

commercial activities (except where such activities are otherwise

permitted or authorized under applicable University policies),

fundraising or advertising on behalf of non-University organizations,

or the reselling of University computer resources to non-University

individuals or organizations, and the unauthorized use of the

University’s name, are prohibited. The Vice President for Information

Systems (or designee) may specify rules and speciﬁc forums where

limited use of University resources for non-recurring exchange and

sale of personal items is permitted.

Identiﬁcation of Users

Anonymous and pseudonymous communications are permitted

except when expressly prohibited by the operating guidelines or stated

purposes of the electronic services to, from, or through which the

communications are sent. However, when investigating alleged violations

of the Guidelines on Open Expression (https://catalog.upenn.edu/

pennbook/open-expression/), the Committee on Open Expression may

direct the University’s Information Security Ofﬁcer, or an authorized

system administrator, to attempt to identify the originator of anonymous/

pseudonymous messages, and may refer such matters to appropriate

disciplinary bodies to prevent further distribution of messages from the

same source.

The following activities and behaviors are prohibited:

•

Misrepresentation (including forgery) of the sender’s identity or an

electronic communication’s source;

•

Acquiring or attempting to acquire passwords of others;

•

Using or attempting to use the computer accounts of others;

•

Alteration of the content of a message originating from another

person or computer with intent to deceive; and

•

The unauthorized deletion of another person’s news group postings.

Access to Computer Resources

The following activities and behaviors are prohibited:

•

The use of restricted-access University computer resources or

electronic information without or beyond one’s level of authorization;

•

The interception or attempted interception of communications by

parties not explicitly intended to receive them;

•

Making University computing resources available to individuals not

afﬁliated with the University of Pennsylvania without approval of an

authorized University ofﬁcial;

•

Making available any materials the possession or distribution of

which is illegal;

•

The unauthorized copying or use of licensed computer software;

•

Unauthorized access, possession, or distribution, by electronic or any

other means, of electronic information or data that is conﬁdential

under the University’s policies regarding privacy or the conﬁdentiality

of student, administrative, personnel, archival, or other records, or as

deﬁned by the cognizant Data Steward;

•

Intentionally compromising the privacy or security of electronic

information; and

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126

V.H. Policy on Acceptable Use of Electronic Resources

•

Intentionally infringing upon the intellectual property rights of others

in computer programs or electronic information (including plagiarism

and unauthorized use or reproduction).

Operational integrity

The following activities and behaviors are prohibited:

•

Interference with or disruption of the computer or network accounts,

services, or equipment of others, including, but not limited to, the

propagation of computer “worms” and “viruses”, the sending of

electronic chain mail, and the inappropriate sending of “broadcast”

messages to large numbers of individuals or hosts;

•

Failure to comply with requests from appropriate University ofﬁcials

to discontinue activities that threaten the operation or integrity of

computers, systems or networks, or otherwise violate this policy;

•

Revealing passwords or otherwise permitting the use by others (by

intent or negligence) of personal accounts for computer and network

access;

•

Altering or attempting to alter ﬁles or systems without authorization;

•

Unauthorized scanning of networks for security vulnerabilities;

•

Attempting to alter any University computing or networking

components (including, but not limited to, bridges, routers, and hubs)

without authorization or beyond one’s level of authorization;

•

Unauthorized wiring, including attempts to create unauthorized

network connections, or any unauthorized extension or re-

transmission of any computer or network services;

•

Intentionally damaging or destroying the integrity of electronic

information;

•

Intentionally disrupting the use of electronic networks or information

systems;

•

Intentionally wasting human or electronic resources; and

•

Negligence leading to the damage of University electronic

information, computing/networking equipment and resources.

Appendices

Relevant University policies

This Acceptable Use Policy incorporates and supersedes the earlier

Policy on Ethical Behavior with Respect to the Electronic Information

Environment. The use of computing resources is also required to conform

to the following University policies:

•

Code of Student Conduct (https://catalog.upenn.edu/pennbook/

code-of-student-conduct/)

•

Guidelines on Open Expression (https://catalog.upenn.edu/

pennbook/open-expression/)

In addition, speciﬁc policies of the University’s Schools, departments,

computer systems and networks, and other general University policies

and regulations are also applicable to the use of computer resources.

These policies include, but are not limited to, the following:

•

Patent Policy (https://catalog.upenn.edu/pennbook/patent-tangible-

research-property-policies-procedures/)

•

Computer Software Policy (http://www.upenn.edu/almanac/v45/n08/

copy.html)

•

Policy on the Uses of University Resources (https://

www.hr.upenn.edu/policies-and-procedures/policy-manual/other-

policies/uses-of-university-resources/)

•

Policy on Conﬁdentiality of Student Records and Information (https://

catalog.upenn.edu/pennbook/conﬁdentiality-student-records/)

•

Policy Regarding Faculty Misconduct in Research (https://

catalog.upenn.edu/faculty-handbook/iii/iii-b/)

•

Policy on Privacy in the Electronic Environment (https://

catalog.upenn.edu/pennbook/policy-privacy-electronic-environment/)

•

Code of Academic Integrity (https://catalog.upenn.edu/pennbook/

code-of-academic-integrity/)

•

Protocols for human subjects research: any research involving

human subjects must be approved by the Committee on Studies

Involving Human Beings

•

Acceptable Use Policies of individual Schools, departments,

computer systems, and networks

•

Guidelines for Administrators of Penn E-mail Systems (https://

provider.www.upenn.edu/computing/email/admin-guidelines.html)

Applicable laws

Computer and network use is also subject to Pennsylvania and Federal

laws and regulations. Suspected violations of applicable law are subject

to investigation by University and law enforcement ofﬁcials. Among the

applicable laws are:

•

Federal Copyright Law:

U.S. copyright law grants authors certain

exclusive rights of reproduction, adaptation, distribution,

performance, display, attribution and integrity to their creations,

including works of literature, photographs, music, software, ﬁlm

and video. Violations of copyright laws include, but are not limited

to, the making of unauthorized copies of any copyrighted material

(such as commercial software, text, graphic images, audio and video

recordings) and distributing copyrighted materials over computer

networks or through other means.

•

Federal Wire Fraud Law:

Federal law prohibits the use of interstate

communications systems (phone, wire, radio, or television

transmissions) to further an illegal scheme or to defraud.

•

Federal Computer Fraud and Abuse Law:

Federal law prohibits

unauthorized access to, or modiﬁcation of information in computers

containing national defense, banking, or ﬁnancial information.

•

Federal and Pennsylvania Child Pornography Laws:

Federal and

Pennsylvania laws prohibit the creation, possession, or distribution

of graphic depictions of minors engaged in sexual activity, including

computer graphics. Computers storing such information can be

seized as evidence.

•

Pennsylvania Computer Crime Law:

Pennsylvania law prohibits access

to any computer system or network with the intent to interrupt an

organization, or to perpetrate a fraud including the intentional and

unauthorized publication of computer passwords.

•

Pyramid Schemes/Chain Letters:

It is a violation of the Federal Postal

Lottery Statute to send chain letters which request sending money

or something of value through the US mail. Solicitations through

electronic messaging are also illegal, if they require use of US mail for

sending money/something of value.

•

Defamation:

Someone may seek civil remedies if they can show that

they were clearly identiﬁed as the subject of defamatory messages

and suffered damages as a consequence. Truth is a defense against

charges of defamation.

•

Common law actions for invasion of privacy:

Someone may take seek

civil remedies for invasion of privacy on several grounds.

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University of Pennsylvania Faculty Handbook

127

•

Public disclosure of private facts:

the widespread disclosure of facts

about a person, even when true, may be deemed harmful enough to

justify a lawsuit.

•

False light:

a person wrongfully attributes views or characteristics to

another person in ways that damage that person’s reputation.

•

Wrongful intrusion

: the law often protects those areas of a person’s life

in which they can reasonably expect they will not be intruded upon.

V.I. Policy on Privacy in the

Electronic Environment

(Source: University Council Resolution, April 26, 2000; Ofﬁce of the Provost,

Almanac, September 19, 2000

(

https://almanac.upenn.edu/archive/v47/

n04/OR-eprivacy.html

))

I. Preliminary Observations

The University afﬁrms that the mutual trust and freedom of thought and

expression essential to the academic mission of a university rest on an

expectation of privacy, and that the privacy of those who work, study,

teach, and conduct research in a university setting will be respected. The

University recognizes that as faculty, staff and students create, use and

store more information in electronic form, there is growing concern that

information the user or creator considers private may be more vulnerable

to invasion than information stored in more traditional media. This policy

is intended to highlight some general principles that should help to deﬁne

the expectations of privacy of those in the University community. While

no document addressing the fluid issue of technology can be exhaustive

or inflexibly dictate outcomes in all circumstances, this policy attempts

to articulate current practices and provide guidance, so that individuals

may make informed and appropriate decisions concerning their various

interactions in the electronic environment.

Before addressing these issues, it should also be noted that in carrying

out their operations, various departments of the University accumulate

information about members of its community, e.g., for purposes of

payroll, employment or enrollment. Data are also created, though not

necessarily compiled or retained on a personally identiﬁable basis, as

an incident to the use of technology, e. g. , the charging of purchases

on Penn Card or the borrowing of library books. The University does not

condone disclosure or release of such personal information stored or

transmitted through University systems, except for legitimate University

purposes as outlined in this policy.

Those responsible for maintaining the University’s computers and

electronic networks have an important and special responsibility to

recognize when they may be dealing with sensitive or private information.

They may access such information without the user’s consent and

without obtaining higher level approval, but only when necessary to fulﬁll

their ofﬁcial responsibilities, and they are expected to carry out their

duties in ways that are not unreasonably intrusive. They will be subject to

disciplinary action if they misuse their access to personally identiﬁable

data or to individuals’ personal ﬁles, e-mail and voice mail or otherwise

knowingly act in ways counter to University policies and applicable laws.

Finally, this policy should be understood in light of the many other

University policies and laws that bear on individuals’ rights to privacy

and the institution’s responsibilities with respect to information in its

possession about individuals.

Examples of applicable laws include the Family Educational Rights

and Privacy Act of 1974 (the “Buckley Amendment”), the Electronic

Communications Privacy Act of 1986, and medical records regulations

promulgated under the Health Insurance Portability and Accountability

Act of 1996. Examples of applicable University policies include the

Acceptable Use Policy for the Electronic Environment, Administrative

Computing Security Policy, Policy for Closed Circuit Television Monitoring

and Recording of Public Areas for Safety and Security Purposes and

policies on Records Conﬁdentiality and Safeguarding University Assets.

II. Policy on Information Created, Stored

or Transmitted Through University

Electronic Media

In General:

The University provides computers, computer and e-mail accounts,

networks and telephone systems to faculty members, staff and

students for the purpose of furthering the University’s academic

mission and conducting University business. While incidental and

occasional personal use of such systems, including e-mail and voice

mail, is permissible, personal communications and ﬁles transmitted

over or stored on University systems are not treated differently from

business communications; there can be no guarantee that such

personal communications will remain private or conﬁdential (see

Appendix at the end of this policy).

As is the case for information in non-electronic form stored in

University facilities, the University’s need for information will be met

in most situations by simply asking the author or custodian for it. The

University reserves the right, consistent with this policy, to access,

review and release electronic information that is transmitted over

or stored in University systems or facilities. When questions arise

about such access, review or release of information, the University

commits to treat electronic information no differently from non-

electronic information. As with paper information, it is often the

case by custom or rule that electronic ﬁles are shared and properly

accessible by multiple parties in ofﬁce settings. Where that is the

case, the special provisions for access and notiﬁcation outlined here

need not be followed. In other cases, properly authorized University

ofﬁcials including the Vice President for Audit and Compliance and

the Information Security Ofﬁcer may access e-mail, voice mail or

computer accounts without the consent of the assigned user when

there is a reasonable basis to believe that such action

Is necessary to comply with legal requirements or process, or

May yield information necessary for the investigation of a

suspected violation of law or regulations, or of a suspected

serious infraction of University policy (for example alleged

research misconduct, plagiarism or harassment), or

Is needed to maintain the integrity of University computing

systems, or

May yield information needed to deal with an emergency, or

In the case of staff, will yield information that is needed for the

ordinary business of the University to proceed.

Except as may otherwise be dictated by legal requirements,

individuals will be notiﬁed of access to, or disclosure of, the

contents of their e-mail, voice mail or their computer accounts

as soon as practicable. In cases where such notiﬁcation might

jeopardize an ongoing investigation of suspected wrongdoing it

may be delayed until the conclusion of the investigation. The Ofﬁce

of General Counsel is responsible for maintaining an ofﬁcial record

of e-mail searches performed by authorized parties.

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128

V.J. Policy on Security of Electronic Protected Health Information (ePHI)

Faculty:

The University has the utmost respect for the freedom of thought

and expression that are at the core of Penn’s academic mission.

Whenever possible, therefore, the University shall resolve any doubts

about the need to access a University computer or other systems in

favor of a faculty member’s privacy interest. Computer ﬁles, e-mail

and voice mail created, stored, transmitted or received by faculty

shall be afforded the same level of privacy as the contents of their

ofﬁces. The Policy on Safeguarding University Assets governs access

to faculty records in connection with investigations carried out

by the University’s Ofﬁce of Audit and Compliance, and provides

for prior consultation with the Provost and Faculty Senate and for

notifying the subject of a search of any ﬁles or materials taken

during an investigation. Except as may otherwise be dictated by legal

requirements, the procedures outlined in that policy shall be followed

with respect to a faculty member’s computer ﬁles, e-mail or voice mail

in connection with other investigations or proceedings.

Staff:

It is generally not University policy to access staff members’

electronically stored information. As noted above, the University’s

need for information shall normally be met by asking an employee

for it. Properly authorized University ofﬁcials, including supervisors

acting with the consent of their management, may, however, access,

review and release the contents of staff computer ﬁles, e-mail or

voice mail transmitted over or stored on University systems when,

for example, an employee is absent or has left the University and the

information is not available elsewhere, or in other situations in which

it is necessary if the ordinary business of the University is to proceed.

In more complicated situations - where, for example, a supervisor

believes University resources are being misused - he/she should

consult with senior administrators, the Division of Human Resources,

or the Ofﬁce of General Counsel.

Students:

Students are provided e-mail and computer accounts for use

primarily in connection with their academic activities. While the

University does not generally monitor or access the contents of

a student’s e-mail or computer accounts, it reserves the right to

do so. However, access to and disclosure of a student’s e-mail

messages and the contents of his/her computer accounts may only

be authorized by any one of the dean of the student’s School or his/

her designate, the Vice Provost for University Life, or the Ofﬁce of

Audit and Compliance, in consultation with the Ofﬁce of General

Counsel.

Multiple Afﬁliations:

Some individuals have multiple University afﬁliations (e. g. students

employed by the University). When the need for access to information

arises from a particular status, the provisions above for that status

shall be applied. In other cases, the provisions for the individual’s

primary status shall be applied.

III. Violations of this Policy

Members of the University community who believe that this policy has

been violated with respect to their privacy should attempt initially to

resolve the issue within their unit or department, if necessary with the

mediation of the leadership of their representative assembly or the

University Ombudsman. Others who become aware of violations of this

policy should report them to the University Information Security Ofﬁcer,

Ofﬁce of General Counsel, Division of Human Resources or the Ofﬁce

of Audit and Compliance. All University ofﬁces that substantiate such

violations should report them to the University Information Security

Ofﬁcer, who will monitor them for repeat instances and patterns. Those

who violate this policy may be subject to disciplinary procedures up to

and including dismissal.

Appendix: Special Note on E-mail Privacy

Despite the best intentions of users and the University or other system

operators, it is difﬁcult, if not impossible, to assure the privacy of e-mail.

E-mail is not a good medium to use for sensitive matters that one would

not want disclosed. There are numerous ways that plain text e-mail may

be disclosed to persons other than the addressee, including:

•

Recipient’s address is mistyped; message is sent to someone else.

•

Recipient forwards e-mail to someone else.

•

Intruders break into e-mail system and read/disclose messages.

•

Despite owner’s belief that he/she deleted it, e-mail continues to

exist on computer hard drive or a copy is archived on tape backup;

disclosure of such copies may be required in connection with judicial

or administrative proceedings or government investigations.

•

E-mail is observed as it travels over public networks like PennNet and

the Internet.

•

In addition, e-mail users may want to consider routinely or periodically

deleting old messages, and encrypting personal messages. Systems

administrators should consider shorter retention of backup tapes,

consistent with data integrity requirements.

V.J. Policy on Security of Electronic

Protected Health Information (ePHI)

(Source: For Comment, Vice President for Information Systems and

Computing, Almanac, February 22, 2005; approved,

Almanac, April 5, 2005

(

https://almanac.upenn.edu/archive/volumes/v51/n27/OR-phi.html

))

HIPAA is a federal law that, among other things, focuses on protecting

the privacy and security of personal health information (protected

health information or PHI). This law affords certain rights to individuals

regarding their PHI and imposes obligations upon many institutions that

maintain such PHI. At Penn, the following entities are responsible for

compliance with HIPAA privacy and security regulations: the University of

Pennsylvania Health System (UPHS), the Perelman School of Medicine,

the School of Dental Medicine, the Living Independently For Elders (LIFE)

program, Student Health Services, and the Employee Health Beneﬁts

Plan, as well as workforce members of other Penn ofﬁces that, while

offering support to these entities, access PHI (workforce members

pertains to anyone assessing ePHI working with the University of

Pennsylvania’s Covered Components and their Shared SupportServices

as an employee, volunteer, student or faculty member.).

While inextricably linked, the HIPAA security regulation is distinguished

from the HIPAA privacy regulation in that it applies to electronic storage

and transmission of PHI (ePHI), compared with the privacy regulation that

applies to all forms of PHI and prescribes more detailed requirements for

securing such data.

The ePHI security policy outlines minimum standards for ensuring

the conﬁdentiality, integrity, and availability of electronic protected

health information received, maintained or transmitted by all University

HIPAA Covered Components (those schools and units listed above),

as well as other ofﬁces which support these entities, listed below as

Support Services. Covered Components shall meet or exceed these

standards by implementing the necessary administrative, physical or

technical safeguards as appropriate based on their assessments of

risk. Compliance by Support Services with these standards is limited to

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University of Pennsylvania Faculty Handbook

129

activities that directly involve the creation or receipt of ePHI in support

of Covered Components and does not pertain to activities related to

services provided to non-covered areas of the University.

Support Services include:

•

Ofﬁce of Regulatory Affairs

•

Institutional Review Board (eight review boards)

•

Ofﬁce of General Counsel

•

Ofﬁce of Audit and Compliance

•

University Archives and Records Center

•

Ofﬁce of Environmental Health and Radiation Services

•

Ofﬁce of Risk Management and Insurance

•

Ofﬁce of the President

•

Ofﬁce of the Provost

•

Ofﬁce of the Executive Vice President

•

Ofﬁce of Student Financial Services

•

Ofﬁce of Development and Alumni Relations

•

Ofﬁce of the Comptroller

•

Ofﬁce of Information Systems and Computing

•

School of Nursing Ofﬁce of Technology and Information Systems,

Center for

•

Nursing Research, and Ofﬁce of Business and Finance

•

VPUL Technical Support

Exclusions

Certain data is speciﬁcally excluded from coverage under HIPAA, most

importantly:

Student records, except for student patient data maintained at

Student Health Service;

Employment records, except for health beneﬁts records; and

Information "de-identiﬁed" under HIPAA standards.

Exceptions

Exceptions to this policy must be documented and submitted for

approval to the University Information Security Ofﬁcer who shall consult

with the Ofﬁce of General Counsel. Appeals of decisions shall be referred

to the Vice President of Information Services and Computing.

For a description of the administrative, physical and technical safeguards

that should be undertaken, a deﬁnition of various terms used in the

policy and a list of related policies, see page 4 - Almanac, February

22, 2005 (https://almanac.upenn.edu/archive/volumes/v51/n22/

pdf_n22/022205.pdf).

V.K. Information Systems Security

Incident Response Policy

(Source: Vice President for Information Systems and Computing and

Associate Vice President for Audit, Compliance and Privacy,

Almanac,

January 16, 2007

(

https://almanac.upenn.edu/archive/volumes/v53/n18/

or.html

))

This policy deﬁnes the steps that personnel must use to ensure that

security incidents are identiﬁed, contained, investigated and remedied.

It also provides a process for documentation, appropriate reporting

internally and externally, and communication so that organizational

learning occurs. Finally, it establishes responsibility and accountability

for all steps in the process of addressing computer security incidents.

Without an effective incident response process, corrective action may

be delayed and harmful effects unnecessarily exacerbated. Further,

proper communication allows the University key learning opportunities to

improve the security of data and networks. Individuals who fail to comply

are subject to sanctions as appropriate under University policies.

This policy applies to all users. It applies to any computing devices

owned or leased by the University of Pennsylvania that experience a

Computer Security Incident. It also applies to any computing device

regardless of ownership, which either is used to store Conﬁdential

University Data, or which, if lost, stolen, or compromised, and based

on its privileged access, could lead to the unauthorized disclosure of

Conﬁdential University Data. Examples of systems in scope include, but

are not limited to, a User’s personally owned home computer that is used

to store Conﬁdential University Data, or that contains passwords that

would give access to Conﬁdential University Data.

This policy does not cover incidents involving the University of

Pennsylvania Health System (UPHS) information systems, which has

a separate incident response policy. ISC Information Security will

coordinate with UPHS as appropriate when UPHS computing devices,

data, or personnel are involved.

For information on identifying and reporting computer security

incidents, the process for handling incidents and documentation,

a list of best practices, compliance, and related University policies

see: www.upenn.edu/almanac/volumes/v53/n18/or.html (http://

www.upenn.edu/almanac/volumes/v53/n18/or.html).

V.L. Policy on Unauthorized Copying

of Copyrighted Media

(Source: Vice President for Information Systems and Computing,

Almanac,

September 15, 1992

(

https://almanac.upenn.edu/archive/v39pdf/

n03/091592.pdf

))

The University of Pennsylvania does not condone or tolerate the

unauthorized copying of copyrighted media by staff, faculty, or students.

The University shall adhere to its contractual responsibilities and shall

comply with all copyright laws, and expects all members of the University

community to do so as well.

Members of the University community who violate this policy may

be subject to discipline through standard University procedures. An

individual or University department engaged in the unauthorized copying

or use of copyrighted materials may also face civil suit, criminal charges,

and/or penalties and ﬁnes. Subject to the facts and circumstances of

each case, such individual or department shall be solely responsible for

its own defense and any resulting liability.

(See page 3 - Almanac, September 15, 1992 (https://almanac.upenn.edu/

archive/v39pdf/n03/091592.pdf))

V.M. Conﬁscation of Publications

(Source: Ofﬁce of the President,

Almanac, July 18, 1989

(

https://

almanac.upenn.edu/archive/v36pdf/n01/071889.pdf

))

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130

V.N. Policy on Computer Disconnection from PennNet

The conﬁscation of publications on campus is inconsistent with the

University’s policies and procedures, and with the ideals of the University.

It is inconsistent with the University’s Guidelines on Open Expression, and

could violate contractual arrangements between the University and other

parties.

Members of the University community who are responsible for

conﬁscating publications should expect to be held accountable.

(See page 4 - Almanac, July 18, 1989 (https://almanac.upenn.edu/

archive/v36pdf/n01/071889.pdf))

V.N. Policy on Computer

Disconnection from PennNet

(Source: Vice President for Systems and Computing,

Almanac, April 20, 1999

(

https://almanac.upenn.edu/archive/v45/n29/communications.html

))

Background:

A well functioning network is critical to the research,

academic and service missions of the University. Information Security

has documented an increasing frequency of computer intrusions that

threaten the integrity of PennNet. The capacity of entire departments to

teach and conduct research has been limited as a result, and sensitive

data have been at risk of unauthorized disclosure. At times, rapid

response is required to protect the integrity of systems, data and those

that rely on them. Inefﬁciency sometimes results because the owners of

the penetrated machines cannot be located. Disagreements arise over

the magnitude and immediacy

of the problems without a formal mechanism for resolving conflicts.

Certain types of misconﬁguration of Penn systems, intentional or

otherwise, can have serious and detrimental consequences. Examples

include using another host’s Internet Protocol address (“IP Spooﬁng”)

or misconﬁgured networking protocols. Normal operation of Penn

computers, and even computers elsewhere on the worldwide Internet,

can be compromised. Networks can become so congested that network

trafﬁc cannot get through.

Purpose:

The goal of this policy is to prevent disruption of the University’s

computers and networks.

Policy:

Information Systems and Computing (ISC) will disconnect from

PennNet any computers that have actually damaged or pose an imminent

threat of harming the integrity of PennNet.

Scope:

This policy only applies to computers and devices attached

directly or indirectly to PennNet, including improper or defective “daisy-

chain” connections and private Local Area Networks with active

networking components connected to PennNet wall plates and hosts.

This policy does not address removing computers from PennNet for

reasons related solely to their content.

Implementation:

Systems administrators must report serious computer

security incidents to the University Information Security Ofﬁcer. Serious

computer security incidents will be deﬁned as those that jeopardize the

integrity, privacy and/or availability of other computers and networks.

Examples of serious computer security incidents include break-ins where

privileged accounts (e. g. UNIX “root” account, or NT “Administrator”

account) are used without authorization, incidents where network

trafﬁc is monitored without authorization, and incidents where Penn

computers or networks are either the source or the target of “denial of

service” attacks. The Information Security Ofﬁcer shall coordinate the

response to computer security incidents, including notifying campus

systems administrators, law enforcement ofﬁcers, external sites, incident

response teams and University ofﬁces as appropriate.

Authorized actions:

If, in the judgment of the Vice President for

Information Systems and Computing or his/her designate, a system

poses a signiﬁcant and immediate threat either to the security of

other Penn computers and networks, or the continued operation of

Penn networks and computers, and the problem cannot be resolved

expeditiously through collaboration between the computer owners and

ISC, then ISC shall notify senior management of the department or unit

and shall require the owners to remove the computer from the network

until the problem is solved.

Absent/Unidentiﬁed Owners:

If ISC is unable, using the Assignments

database, to identify a system owner or Local Support Provider (LSP),

ISC will move unilaterally to protect the network by disconnecting the

threatening system.

Disputes:

In cases where there is persistent disagreement between ISC

and the owner of the perceived threat, ISC must notify the owner and the

LSP of the following information in writing:

•

The reason for the disconnection

•

What steps must be taken for the network connection to be restored

•

How to arrange for the system to be reconnected

•

The process of appealing a decision to disconnect

When the owner of the system has taken the steps necessary to correct

the problem, ISC will restore the PennNet connection as soon as possible.

Appealing a Decision to Disconnect:

The Council Committee on

Communications shall appoint a subcommittee to review appeals of

decisions to disconnect computers.

The subcommittee will consist of:

•

At least four members of the faculty appointed by the Committee on

Communications, one of whom shall serve as chair,

•

The Vice President for Information Systems and Computing or his/her

designate,

•

The University Information Security Ofﬁcer or his/her designate,

•

The Committee on Communications may designate alternates

to serve on the hearings of an appeal when its appointees are

unavailable.

The owner of a disconnected system who believes that the threat that

the system posed is outweighed by the impact of its disconnection on

his/her academic mission may appeal the decision by documenting this

belief in writing to the chair of the subcommittee. The chair or his/her

designate may resolve the dispute amicably; failing this it will be heard

formally by the subcommittee. The subcommittee shall resolve conflicts

as rapidly as possible within the constraints of fairness. It shall establish

and follow its own operating procedures.

If the subcommittee does not begin the proceedings within ﬁve working

days in cases where the issue is a threat and not actual harm, or thirty

working days in cases where ISC can document actual harm, the subject

system must be reconnected. Once the subcommittee has begun the

process, time limits shall not be imposed.

In considering appeals, the subcommittee shall balance the value

of leaving machines connected against the associated risks. Its

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University of Pennsylvania Faculty Handbook

131

decision shall be ﬁnal. The only recourse for faculty whose appeals are

denied shall be to the Senate Committee on Academic Freedom and

Responsibility. ISC may not appeal. However, it may redisconnect the

computer and restart the entire process whenever another trigger event is

detected.

System owners who believe that their freedom of expression has been

unduly infringed may, under the Guidelines for Open Expression, request

that the Committee on Open Expression determine if the Guidelines were

properly interpreted and applied to the disconnection of their system.

For additional information, contact security@isc.upenn.edu.

VI. Other Policies

•

VI.A. Use of University Name Policy (p. 131)

•

VI.B. Acceptance of Gifts, Grants and Contracts (p. 132)

•

VI.C. Acceptance of Conditional Gifts (p. 132)

•

VI.D. Gift Policy (p. 132)

•

VI.E-F. Sexual Misconduct Policy, Resource Ofﬁces and Complaint

Procedures (p. 133)

•

VI.G. The University Alcohol and Other Drug Policy (p. 152)

•

VI.H. Drug-Free Workplace Policy (p. 157)

•

VI.I. Procedures for the Evaluation and Certiﬁcation of the English

Fluency of Undergraduate Instructional Personnel (p. 158)

•

VI.J. Policy Prohibiting Workplace Violence (p. 160)

•

VI.K. Social Security Number Policy (p. 161)

Note on Former Policies:

•

Consensual Sexual Relations Between Faculty and Students

—

Effective on July 1, 2019, the University has a new policy, Consensual

Romantic and Sexual Relations in Workplace and Educational

Settings, which is part of its Sexual Misconduct Policy (p. 133).

The current Policy may be found in the Sexual Misconduct Policy

(p. 133).

•

Sexual Harassment Policy

– Effective on July 1, 2019, the University’s

Sexual Harassment Policy was updated and incorporated into its

new Sexual Misconduct Policy (p. 133). The current Policy may be

found in the Sexual Misconduct Policy (p. 133).

•

Sexual Violence, Relationship Violence, and Stalking Policy

—

Effective on July 1, 2019, the Sexual Violence, Relationship Violence,

and Stalking Policy was incorporated into the Sexual Misconduct

Policy (p. 133). The University’s current Policy may be found in

the Sexual Misconduct Policy (p. 133).

VI.A. Use of University Name Policy

(Source: Ofﬁce of the Secretary, 1969 Handbook for Faculty and

Administration; revised, Almanac, October 14, 1997; revised, Almanac, May

16, 2000; revised,

Almanac, October 24, 2017

(

https://almanac.upenn.edu/

uploads/media/102417.pdf

))

On September 30, 1791, an act conﬁrmed an agreement which united

the University of the State of Pennsylvania with the College, Academy

and Charitable School and provided that the name of the institution

would be “The Trustees of the University of Pennsylvania.”

To facilitate

communication both internally and externally, the institution’s name is

commonly simpliﬁed as the “University of Pennsylvania,” or, more recently,

“Penn.”

The University regulates use of its name, the names of its schools

and programs, its shield and related insignia, trademarks and logos

(“insignia”) to ensure that such use is related to the University’s

educational, service and research missions and promotes its objectives.

Responsibility for overseeing use of the University’s names and insignia

lies with the Secretary of the University.

Ofﬁcial Use

When representing the University in an ofﬁcial capacity, all units of

the University and members of the faculty and administration must

use “University of Pennsylvania” in their publications and documents.

Approved University stationery must be used for ofﬁcial correspondence.

University names and insignia may be used in connection with any

academic University program provided that the program has been

approved in advance by the responsible department chair and dean or

director, and Provost, as appropriate. University units, faculty, staff and

student organizations that wish to use University names or insignia in

connection with any non-academic University program, activity, service or

product must obtain the approval of the Secretary of the University before

proceeding. Requests to use University names or insignia must ﬁrst be

presented to the appropriate department chair and dean, director, or, in

the case of student organizations, to the Vice Provost for University Life,

for review. If approved by the dean, director, or Vice Provost, a request

with supporting information must be submitted to the Secretary for

review. The Secretary will review the proposed use and determine, in

consultation with appropriate colleagues, whether it is properly related to

the University’s missions and whether the beneﬁts of the proposed use

outweighs any risks associated with the use. The Secretary may approve

the proposed use, with or without conditions, or disapprove the proposed

use.

Licensed Uses by Outside Entities

University names or insignia may be used on products or in connection

with services offered by outside entities only under license from the

University. Requests for such licenses are processed jointly through the

Ofﬁce of the Vice President for Business Services (“Business Services”)

and the Penn Center for Innovation (“PCI”), and with guidance from the

Ofﬁce of the University Secretary.

Outside sponsors of University programs or activities often seek to use

University names or insignia in promotional or advertising materials.

While the University is pleased to recognize the contributions of

sponsors, such recognition must not suggest University endorsement of

the sponsor’s activities. Therefore, University names or insignia may not

be used in connection with any outside entity’s name or logo without prior

approval of the Secretary of the University. In general, the Secretary will

approve uses which recognize or acknowledge the sponsor’s contribution

to the University program or activity. Uses which, in the Secretary’s

judgment, may suggest University endorsement or approval of the

sponsor’s goods or services will not be permitted.

Private Use

University faculty, staff and students may refer to their afﬁliation

or status with the University in connection with personal activities,

including consulting, provided that the afﬁliation or status is accurately

represented and any title or position is accurately identiﬁed, and provided

that such use does not imply University endorsement of the activity. In

some cases, a disclaimer of University endorsement may be required.

(See, for example, Handbook for Faculty and Academic Administrators,

section II.E.10 (p. 38)

Use of University insignia in connection with

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132

VI.B. Acceptance of Gifts, Grants and Contracts

personal activities is prohibited. The University’s name must not be used

in any announcement, advertising matter, publication, correspondence, or

report in connection with personal or non-University activities if such use

in any way could be construed as implying University endorsement of or

responsibility for any project, product, or service.

Related Policies

All faculty, staff and students are reminded that University equipment,

stationery, campus mail service, and electronic media are to be used

solely for University business by authorized University personnel and by

ofﬁcially recognized campus organizations. See Human Resources Policy

No. 003

(

https://www.hr.upenn.edu/policies-and-procedures/policy-

manual/other-policies/uses-of-university-resources/

Additional

information on faculty and staff involvement in extramural activities

and organizations can be found in the

Conflict of Interest Policy for

Faculty Members, and Human Resources Policy Nos.

005

(

https://

www.hr.upenn.edu/policies-and-procedures/policy-manual/other-

policies/conflict-of-interest/

) and

006

(

https://www.hr.upenn.edu/policies-

and-procedures/policy-manual/other-policies/guidelines-for-extramural-

activities-associations-and-interest-for-staff/

Statutes of the Trustees of the University of Pennsylvania

, p. 1.

VI.B. Acceptance of Gifts, Grants and

Contracts

(Source: Ofﬁces of the President and Provost, Almanac, March 21, 1978;

revised,

Almanac, May 23, 1978

(

https://almanac.upenn.edu/archive/

v24pdf/n32/052378.pdf

))

The University of Pennsylvania enjoys ﬁnancial support for its programs

of instruction and research from many sources, public and private;

faculty and staff are encouraged to pursue such support with vigor.

Programs undertaken with the aid of external funding must, however, be

fully consonant with the standards, character and responsibilities of the

University. Conditions for the acceptance of gifts, grants and contracts

include:

That the purposes to be served are academically worthy, are in

accord with the needs and priorities of the University, and are not

impediments to the achievement of other academically worthy aims

or programs;

That there are no conditions attached to the gift, grant or contract

that would in any way jeopardize the University’s commitment to the

principles of academic freedom and nondiscrimination;

That any academic appointment supported by such gifts, grants

and contracts be made only in accord with established University

procedures;

That all established University policies fostering the free

dissemination of research results (and otherwise restricting secret

research) are respected; and,

That acceptance of the gift, grant or contract entails no University

ﬁnancial obligations in the present or at any time in the future except

those known and judged to be worth the expenditure or ﬁnancial risk.

(See page 4 - Almanac, May 23, 1978 (https://almanac.upenn.edu/

archive/v24pdf/n32/052378.pdf))

VI.C. Acceptance of Conditional Gifts

(Source: Ofﬁce of the President, Almanac, September 22, 1981 (https://

almanac.upenn.edu/archive/v28pdf/n03/092281.pdf))

All proposals for gifts to the University, including endowments and

similar agreements, will be processed by the Development Ofﬁce.

In the event a proposed gift to the University is conditional, the

conditions must be in writing. The Vice President for Development

and Alumni Relations shall notify the President of all substantial

conditional gifts and all other gifts containing conditions that might

be construed to violate University policies. The President shall then

determine, as a requirement for University acceptance, whether the

conditions violate University policy, including recognized principles

of academic freedom. If the President has doubts in that regard, he/

she shall seek the advice of the chair of the Senate Committee on

Academic Freedom and Responsibility, who will consult with the Chair

of the Senate.

The Chairs of the Senate and the Senate Committee on Academic

Freedom and Responsibility may inspect the terms of any ﬁnal

agreement. Other members of the University community may,

as needed, make requests in writing to the Vice President for

Development and Alumni Relations to see the conditions of such ﬁnal

agreements.

(See page 2 - Almanac, September 22, 1981 (https://almanac.upenn.edu/

archive/v28pdf/n03/092281.pdf))

VI.D. Gift Policy

(Source: Division of Human Resources,

Almanac, July 17, 2007

(

https://

almanac.upenn.edu/archive/volumes/v54/n01/gift-policy.html

))

In order to avoid a conflict of interest or the appearance of a conflict of

interest, at no time should an employee solicit or accept personal gifts

from current or potential vendors, contractors or their agents, local

businesses, University departments, or others with whom there is a

potential or ongoing business or professional relationship. Employees

may accept ordinary business courtesies, such as payment for a modest

meal or event, or gifts which are promotional items without signiﬁcant

value and which are distributed routinely. If the value of the gift is

undetermined, it should be returned.

Gratuities or gifts of money to the employee cannot be accepted at any

time and should be returned immediately to the donor.

All employees are responsible for becoming familiar with and adhering to

this policy. In addition, supervisors are responsible for ensuring that this

policy is known by their employees and that all employees are following

it.

In the decision as to whether or not to accept any gift, employees should

use good judgment and avoid in all cases any actual conflict of interest or

the appearance of any conflict. For example, University ofﬁcials are often

offered goodwill gifts when on a mission abroad, visiting other domestic

institutions, or when ofﬁcials from other institutions visit Penn. Because

a refusal of a gift could offend the hosting ofﬁcials, such gifts can be

accepted. If the gifts are of signiﬁcant value (i.e. greater than $100,

consistent with IRS policy), they become the property of the University

and should be discussed with the head of the department.

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University of Pennsylvania Faculty Handbook

133

Employees who have questions regarding this policy or who are uncertain

as to whether a conflict of interest exists should confer with their

supervisors or the Division of Human Resources.

VI.E-F. Sexual Misconduct Policy,

Resource Ofﬁces and Complaint

Procedures

(Source: Ofﬁce of the President, Almanac, December 6, 1988; revised,

Almanac, November 7, 1995; Ofﬁces of the President and Provost,

revised, Almanac, February 3, 2004; revised,

Almanac, October 18,

2011

(

https://almanac.upenn.edu/archive/volumes/v58/n08/

policy.html

); revised,

Almanac, July 1, 2016

(

https://almanac.upenn.edu/

archive/between/2016/070116-of-record.html

); revised,

Almanac,

April 30, 2019

(

https://almanac.upenn.edu/uploads/media/

OF_RECORD_Sexual_Misconduct_supplement-Web.pdf

), revised

Almanac,

July 19, 2022

(

https://almanac.upenn.edu/uploads/media/071922-

sexual_misconduct_policy_supplement.pdf

))

Effective July 1, 2022

The mission of the University of Pennsylvania is to offer a world-class

education to our students, train future leaders, expand and advance

research and knowledge, serve our community and society both at home

and abroad, and provide the most expert and outstanding healthcare

for our patients. To create and sustain a campus climate in which

members of the University community are able to thrive and achieve their

full potential, the University has established a wide range of policies,

educational programs, resources, support, and reporting systems to

respond to complaints of sexual misconduct made against students,

postdoctoral or other trainees, faculty, and staff. Sexual harassment,

sexual violence, and other forms of sexual misconduct will not be

tolerated. The University’s policies, resources, and complaint procedures

include the following:

I. Sexual Harassment, Sexual Violence, Relationship Violence and

Stalking Policy (p. 134)

II. Consensual Romantic and Sexual Relationships in the Workplace

and Educational Settings Policy (p. 136)

III. Student Disciplinary Procedures for Resolving Complaints of

Sexual Misconduct (p. 137)

IV. Procedures for Resolving Complaints of Sexual Misconduct

Against Faculty (p. 142)

V. Procedures for Resolving Complaints of Sexual Misconduct

Against Staff (p. 146)

As detailed in these policies and procedures, in all cases where a member

of the community, or other person, wishes to initiate a complaint against

a member of the community (student, postdoctoral or other trainee,

faculty, or staff) for sexual misconduct, the complaint should be brought

to the Associate Vice President for Equity and Title IX Ofﬁcer (“AVP”). The

AVP will be responsible for determining the appropriate procedures to be

followed and will be charged with overseeing the process.

Not every act that might be offensive to an individual or a group

necessarily will be considered sexual misconduct and/or a violation of

the University’s standards of conduct. In determining whether an act

violates University policy, the totality of the circumstances surrounding

the conduct must be carefully reviewed. Due consideration must be given

to the protection of individual rights, open expression, and academic

freedom.

Complaints Against Faculty

Any member of the University community, visitor to campus, or a

participant in a University-sponsored activity may bring a complaint

of sexual harassment, sexual violence, relationship violence, stalking

or inappropriate consensual romantic or sexual relationships in the

workplace or educational setting against a faculty member, instructor,

postdoctoral or other trainee, or teaching assistant. The complaint should

be made to the AVP who will meet with the complainant; determine

whether the behavior is covered by the Sexual Misconduct Policy

and, if so, the appropriate process for resolution or investigation; and

oversee that process. If a determination is made that the complaint

involves a possible violation of the Sexual Harassment, Sexual Violence,

Relationship Violence and Stalking Policy, then the AVP will direct the

process in accordance with the Procedures for Resolving Complaints

of Sexual Misconduct Against Faculty. If a determination is made that

the complaint involves a possible violation of the Consensual Romantic

and Sexual Relationships in the Workplace and Educational Settings

Policy, then the AVP will oversee the informal resolution or investigative

process(es). The AVP will advise the Dean of the applicable school

that a complaint has been made and discuss any interim measures

that may be needed. In either case, for Standing Faculty, the Procedure

Governing Sanctions Taken Against Members of the Faculty,

Handbook for

Faculty and Academic Administrators

, Part II.E.16, will be followed where

applicable. Complaints against faculty alleging inappropriate conduct

that do not meet the deﬁnition of sexual harassment, sexual violence, or

relationship violence or stalking under these policies shall be addressed

by the Dean’s Ofﬁce of the school or the Ofﬁce of the Vice Provost for

Faculty, consistent with University policies and procedures.

Complaints Against Staff

Any member of the University community, visitor to campus, or a

participant in a University-sponsored activity may bring a complaint

of sexual harassment, sexual violence, relationship violence, stalking

or inappropriate consensual romantic or sexual relationships in the

workplace or educational setting against a staff member. The complaint

should be made to the AVP who will meet with the complainant and

coordinate with the Ofﬁce of Staff and Labor Relations in the Division

of Human Resources, as appropriate. If a determination is made

that the complaint involves a possible violation of the Consensual

Romantic and Sexual Relationships in the Workplace and Educational

Settings Policy, then the AVP will oversee the informal resolution or

investigative process(es), advising the Dean or Vice President of the

applicable administrative division that a complaint has been made and

discussing any interim measures that may be needed. If a determination

is made that the complaint involves a possible violation of the Sexual

Harassment, Sexual Violence, Relationship Violence and Stalking Policy,

then the AVP will direct the process in accordance with the Procedures

for Resolving Complaints of Sexual Misconduct Against Staff or the

applicable collective bargaining agreement. Complaints against staff

members alleging inappropriate conduct that does not meet the deﬁnition

of sexual harassment, sexual violence, or relationship violence or stalking

under these policies shall be addressed by the Division of Human

Resources and/or the Ofﬁce of Equal Opportunity Programs, consistent

with University policies and procedures.

Complaints Against Enrolled Students

Any member of the University community, visitor to campus, or a

participant in a University-sponsored activity may bring a complaint

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134

VI.E-F. Sexual Misconduct Policy, Resource Ofﬁces and Complaint Procedures

of sexual harassment, sexual violence, relationship violence, stalking

or inappropriate consensual romantic or sexual relationships in

the educational setting or workplace against an enrolled student.

The complaint should be directed to the AVP who will oversee the

investigative and resolution process(es). If a determination is made

that the complaint involves a possible violation of the Consensual

Romantic and Sexual Relationships in the Workplace and Educational

Settings Policy, then the AVP will oversee the informal resolution or

investigative process(es), advising the Dean of the applicable school

that a complaint has been made and discussing any interim measures

that may be needed. If a determination is made that the complaint

involves a possible violation of the Sexual Harassment, Sexual Violence,

Relationship Violence and Stalking Policy, then the AVP will direct the

process in accordance with the Student Disciplinary Procedures for

Resolving Complaints of Sexual Misconduct. Complaints against enrolled

students alleging inappropriate conduct that does not meet the deﬁnition

of sexual harassment, sexual violence, or relationship violence or stalking

under these policies shall be addressed by the Center for Community

Standards and Accountability or the school in which the Respondent is

enrolled, consistent with University and school policies and procedures.

Reporting and Monitoring

The University is committed to ensuring that members of the University

community who share information regarding incidents of sexual

misconduct receive the information, counseling and support that they

need and are aware of the process for making a complaint. The University

is also committed to monitoring reports and complaints of sexual

misconduct so that any patterns or systemic problems revealed by

such reports and complaints can be addressed. Consistent with these

commitments, the AVP should be advised when incidents of sexual

misconduct are reported to any of the University’s resource ofﬁces

(except those identiﬁed as conﬁdential resources), including the Division

of Human Resources (and human resources staff in the schools and

centers); Deans, Vice, Associate, or Assistant Deans in the 12 schools;

Vice, Associate, or Assistant Provosts; Ofﬁce of Equal Opportunity

Programs (EOP); and Division of Recreation and Intercollegiate Athletics

(DRIA). Ofﬁces designated as conﬁdential resources in the Sexual

Misconduct Policy are to provide information to the AVP regarding

possible violations in a manner that protects the identity of the individual

who provided it. However, in all cases in which there is a danger to the

parties or others, that information must be reported immediately to

Wellness Services or the Special Services Department in the Division of

Public Safety. When an incident of sexual misconduct is reported to the

AVP, appropriate steps will be taken to ensure that the individual who

reported the incident has been advised of the available resources and

the process for making a formal complaint. Members of the University

community who have crime statistics reporting obligations under the

Clery Act are obligated to report the matter to the Division of Public

Safety, in addition to the AVP. For additional information about Clery Act

reporting or to make a report, refer to the Clery Act & Crime Reporting

page at https://www.publicsafety.upenn.edu/clery/.

I. Sexual Harassment, Sexual Violence,

Relationship Violence, and Stalking Policy

All forms of sexual harassment, sexual violence, relationship violence and

stalking and attempts to commit such acts are considered to be serious

misconduct and may result in disciplinary action up to and including

expulsion or termination of employment. In addition, such acts may

violate federal, state and local laws and perpetrators of such acts may

be subject to criminal prosecution. This policy, which prohibits behaviors

that are more generally addressed by the University’s Sexual Misconduct

Policy, applies to faculty, postdoctoral and other trainees, students, staff

and visitors to the University campus and facilities.

Sexual Harassment

For the purposes of University policy, the term “sexual

harassment”

refers to any unwanted conduct that is based on an

individual’s sex, sexual orientation, gender identity, or gender expression

and that:

•

Conditions an educational or employment beneﬁt on participation in

unwelcome sexual conduct; or

•

A reasonable person would determine is so severe, pervasive, and/or

objectively offensive that it effectively denies a person equal access

to an educational or employment program or activity.

Sexual violence

includes a range of behaviors in which an act of a sexual

nature is taken against another individual without that person’s consent

or when the individual is unable to consent. There are various types of

sexual violence, including but not limited to sexual assault and rape

(deﬁned below).

Sexual assault

(including but not limited to rape) is deﬁned as having

committed any of the following acts:

•

Any physical sexual contact that involves the use or threat of force

or violence or any other form of coercion or intimidation.

•

Any physical sexual contact with a person who is unable to consent

due to incapacity or mental or physical impairment. “Incapacity” or

“impairment” include but are not limited to being under the influence

of alcohol or drugs or being too young to consent.

Rape

is deﬁned as sexual assault involving an act of penetration (and

includes such assaults when the individuals know one another).

Non-forcible sex acts

include unlawful sex acts where consent is

not relevant, such as sexual contact with an individual under the

statutory age of consent as deﬁned by Pennsylvania law.

Consent

is an afﬁrmative decision to engage in mutually agreed

upon sexual activity and is given by clear words or actions. Consent

may not be inferred from silence, passivity or lack of resistance alone.

Furthermore, consent to one form of sexual activity does not imply

consent to other forms of sexual activity and the existence of a current

or previous dating, marital or sexual relationship is not sufﬁcient

to constitute consent to additional sexual activity. Assent shall not

constitute consent if it is given by a person who, because of youth,

disability, intoxication or other condition, is unable to lawfully consent.

Relationship violence

, also commonly known as dating violence,

is deﬁned as an act or a pattern of abuse committed by a person involved

in a social, sexual or romantic relationship, past or present, with the

victim. Relationship violence can encompass a broad range of behaviors

that may include physical violence, sexual violence, emotional violence

and economic violence.

Domestic violence

is deﬁned as abuse committed against an adult who

is a spouse, former spouse, cohabitant, someone with whom the person

has a child, someone with whom the person has an existing dating or

engagement relationship, or someone with whom the person had a dating

or engagement relationship in the past.

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135

Stalking

means engaging in a course of conduct directed at

speciﬁc person(s) that would cause a reasonable person to fear for their

safety, the safety of others, or to suffer substantial emotional distress.

In determining whether the alleged conduct violates this policy,

consideration will be given to the totality of the circumstances, including

the nature of the conduct and the context in which the alleged incident

occurred. Generally, complaints of sexual harassment, sexual violence,

relationship violence and stalking are made by members of the University

community and those made by individuals who are not students, faculty,

staff, postdoctoral or other trainees, or alumni will be directed to external

resources available to respond to their complaint or provide support and

advice.

The University regards such behavior as a violation of the standards of

conduct required of all members of its community. Accordingly, as noted

in the University’s

Handbook for Faculty and Academic Administrators,

Human Resources Policy Manual, Pennbook

and other publications,

persons engaged in such behavior are subject to the full range of internal

disciplinary actions, including separation from the institution. The same

range of disciplinary actions will be applied in the event of retaliation

against an individual who in good faith makes an allegation of sexual

misconduct, who cooperates in an investigation into such allegations, or

who opposes any act of sexual misconduct as deﬁned in this policy.

Not every act that might be offensive to an individual or a group

necessarily will be considered a violation of the University’s standards of

conduct. In determining whether an act constitutes sexual misconduct,

the totality of the circumstances surrounding the conduct must be

carefully reviewed. Due consideration must be given to the protection of

individual rights, open expression, and academic freedom.

A. Resources

Schools, centers and administrative divisions should make known to

all of their members the available resource ofﬁces for information,

counseling and support, as well as the informal and formal procedures for

resolving complaints of sexual harassment within the appropriate school,

center, division, or at the University level. These resources include the

following:

1. CONFIDENTIAL RESOURCES FOR INFORMATION, COUNSELING

AND SUPPORT

Resource ofﬁces are available to assist members of the Penn community

and visitors to the campus who have been, or know someone who has

been, the victim of sexual violence, relationship violence or stalking. The

staff of these ofﬁces are available to provide counseling and support, as

well as information about and assistance with making a complaint.

Generally, the information shared with conﬁdential resources will

be held in conﬁdence, consistent with the University’s obligation to

address complaints of sexual misconduct, unless the person sharing

the information gives their consent to the disclosure of that information.

Non-identifying information regarding complaints should be provided

to the AVP for purposes of assuring compliance with Title IX and other

applicable laws and regulations. Conﬁdential resources are not obligated

to share identifying information with the AVP when an incident of

sexual misconduct is shared with them. However, the commitment to

conﬁdentiality does not preclude the sharing of information among

University administrators as appropriate to keep members of the

University community safe. In addition, conﬁdential resources should

submit non-identifying information about incidents of sexual misconduct

to the Division of Public Safety for the purpose of crime statistics

reporting under the Clery Act. (For additional information regarding

requirements, see the Clery Act & Crime Reporting page at https://www.

publicsafety.upenn.edu/clery/.) The University’s conﬁdential resources

are:

•

African-American Resource Center (http://www.upenn.edu/

aarc/) (resource for students, staff or faculty)

•

Employee Assistance Program (https://www.hr.upenn.edu/

PennHR/wellness-worklife/counseling-and-employee-assistance-

program/) (resource for staff or faculty)

•

Lesbian Gay Bisexual Transgender Center (http://

www.vpul.upenn.edu/lgbtc/) (resource for students, staff or faculty)

•

Ofﬁce of the University Chaplain (http://www.upenn.edu/

chaplain/) (resource for students, staff, faculty, postdoctoral and

other trainees or visitors)

•

Ofﬁce of the Ombuds (http://www.upenn.edu/ombuds/) (resource for

students, staff, faculty, postdoctoral and other trainees, or visitors)

•

Penn Violence Prevention (https://secure.www.upenn.edu/vpul/

pvp/) (resource for students)

•

Penn Women’s Center (http://www.vpul.upenn.edu/pwc/) (resource

for students, staff or faculty)

•

Special Services Department (https://www.publicsafety.upenn.edu/

about/special-services/), Division of Public Safety (resource for

students, staff, faculty, postdoctoral and other trainees or visitors)

•

Student Health and Counseling (http://www.vpul.upenn.edu/

shs/) (including its Sexual Trauma Treatment Outreach and

Prevention Team, also known as STTOP; resource for students)

2. INFORMAL AND FORMAL MECHANISMS FOR COMPLAINT

RESOLUTION

If both parties agree and the AVP deems it to be an appropriate instance

for an informal resolution of a complaint, the AVP (or the AVP’s designee)

will meet with the parties individually, and others as appropriate, in an

effort to resolve the complaint. When informal resolution is not chosen,

one of the parties is not satisﬁed with the results, or the proposed

resolution is not appropriate, the formal mechanisms described below

should be used.

A formal complaint of sexual misconduct against any member of the

Penn community should be initiated by contacting the AVP. Formal

complaints will be handled in accordance with the applicable procedures

as set forth below.

Complaints Against Faculty

Any member of the University community, visitor to campus or a

participant in a University-sponsored activity may bring a complaint

of sexual harassment, sexual violence, relationship violence, stalking

or inappropriate romantic or sexual relationships in the workplace or

educational setting or workplace against a faculty member, instructor,

postdoctoral or other trainee, or teaching assistant. The complaint should

be made to the AVP, who will meet with the complainant, determine

the appropriate process under University policy for investigation, and

oversee that process. If a determination is made that the complaint

involves a possible violation of the Sexual Harassment, Sexual Violence,

Relationship Violence and Stalking Policy, then the AVP will direct the

process in accordance with the Procedures for Resolving Complaints of

Sexual Misconduct Against Faculty. If a determination is made that the

complaint involves a possible violation of the Consensual Romantic and

Sexual Relationships in the Workplace and Educational Settings Policy,

then the AVP will oversee the formal or informal resolution process(es),

advising the Dean of the applicable school that a complaint has been

made and discussing any interim measured that may be needed. In either

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VI.E-F. Sexual Misconduct Policy, Resource Ofﬁces and Complaint Procedures

case, for Standing Faculty, the Procedure Governing Sanctions Taken

Against Members of the Faculty,

Handbook for Faculty and Academic

Administrators

, Part II.E.16, will be followed where applicable.

Complaints Against Staff

Any member of the University community visitor to campus or a

participant in a University-sponsored activity may bring a complaint

of sexual harassment, sexual violence, relationship violence, stalking

or inappropriate romantic or sexual relationships in the workplace or

educational setting, against a staff member. The complaint should be

made to the AVP who will meet with the complainant and coordinate

with the Ofﬁce of Staff and Labor Relations in the Division of Human

Resources, as appropriate. If a determination is made that the complaint

involves a possible violation of the Sexual Harassment, Sexual Violence,

Relationship Violence and Stalking Policy, then the AVP will direct the

process in accordance with the Procedures for Resolving Complaints of

Sexual Misconduct Against Staff or the applicable collective bargaining

agreement. If a determination is made that the complaint involves a

possible violation of the Consensual Romantic and Sexual Relationships

in the Workplace and Educational Settings Policy, the AVP will oversee

the formal or informal resolution process(es), advising the Dean, Vice

President, or Vice Provost of the applicable administrative division that a

complaint has been made and discussing any interim measured that may

be needed.

Complaints Against Enrolled Students

Any member of the University community, a visitor to campus, or a

participant in a University-sponsored activity may bring a complaint

of sexual harassment, sexual violence, relationship violence, stalking

or inappropriate romantic or sexual relationships in the workplace

or educational setting against an enrolled student. The complaint

should be directed to the AVP who will oversee the investigative and

resolution process(es). If a determination is made that the complaint

involves a possible violation of the Sexual Harassment, Sexual Violence,

Relationship Violence and Stalking Policy, then the AVP will direct the

process in accordance with the Student Disciplinary Procedures for

Resolving Complaints of Sexual Misconduct. If a determination is made

that the complaint involves a possible violation of the Consensual

Romantic and Sexual Relationships in the Workplace and Educational

Settings Policy, then the AVP will oversee the formal or informal

resolution process(es), advising the Dean of the applicable school that a

complaint has been made and discussing any interim measures that may

be needed.

Members of the University community who would like assistance with

making a formal complaint may contact any of the conﬁdential resources

identiﬁed above. As further set forth below, all formal complaints

involving Sexual Misconduct are to be initiated by contacting the

Associate Vice President for Equity and Title IX Ofﬁcer (“AVP”) who will

be responsible for deciding whether the conduct described would violate

the Sexual Misconduct Policy, and if so, which investigative or resolution

process to pursue.

B. Reporting and Monitoring

The University is committed to ensuring that members of the University

community who share information regarding incidents of sexual

misconduct receive the information, counseling and support that they

need and are aware of the process for making a formal complaint. The

University is also committed to monitoring reports and complaints

of sexual misconduct so that any patterns or systemic problems

revealed by such reports and complaints can be addressed. Consistent

with these commitments, AVP should be advised when incidents

of sexual misconduct, including sexual violence, are reported to

any of the University’s resource ofﬁces (except those identiﬁed as

conﬁdential resources), Division of Human Resources (as well as human

resources staff in the schools and centers); Deans, Vice, Associate

or Assistant Deans of the 12 schools; Vice, Associate, and Assistant

Provosts; Ofﬁce of Equal Opportunity Programs (EOP); and Division

of Recreation and Intercollegiate Athletics (DRIA). When an incident

of sexual misconduct is reported to the AVP, appropriate steps will

be taken to ensure that the individual who reported the incident has

been advised of the resources available to them and the process for

making a formal complaint. Members of the University community

who have crime statistics reporting obligations under the Clery Act are

obligated to report the matter to the Division of Public Safety, in addition

to the AVP. For additional information about Clery Act reporting or to

make a report, refer to the Clery Act & Crime Reporting page at https://

www.publicsafety.upenn.edu/clery/.

C. Rights of Complainants and Respondents

Persons who make a complaint and those who are responding to

complaints have the following rights:

•

The option to notify law enforcement;

•

The option to have an advisor, including an attorney the party has

retained, present during interviews that are part of a University

initiated investigation;

•

To be notiﬁed of counseling and support services available; and

•

To be notiﬁed of available options to change academic, living or work

arrangements.

D. Education and Prevention

All members of the University community have a responsibility to aid

in the prevention of sexual misconduct and are encouraged to discuss

concerns with the AVP or another of the University resource ofﬁces listed

in the policy. The AVP will ensure that the policy is publicized regularly

and that educational programs and training are offered to faculty, staff,

postdoctoral and other trainees, and students.

E. Policy Against Retaliation

University policy expressly prohibits retaliation against faculty, staff,

students, postdoctoral or other trainees, and members of the community

who in good faith make reports of violations of this policy. In addition,

knowingly and intentionally making a false report of a violation of

this policy is prohibited. Members of the Penn community who take

adverse action against, intimidate, threaten or otherwise engage in

retaliation against a person because they made a complaint of sexual

misconduct or served as a witness during an investigation are subject to

disciplinary action, up to and including termination of their employment

or expulsion from the University.

II. Consensual Romantic and Sexual

Relationships in the Workplace and

Educational Setting Policy

A. Faculty and Students and Academic Settings

The relationship between faculty member

and student is central to the

academic mission of the University. No non-academic or personal ties

should be allowed to interfere with the integrity of the faculty-student

relationship. Consensual sexual relations between faculty and student

can adversely affect the academic enterprise, distorting judgments, or

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137

appearing to do so to others, and providing incentives or disincentives for

student-faculty contact that are inappropriate.

For these reasons, any sexual relations or dating relationships between a

faculty member and an undergraduate student enrolled at the University

are prohibited. The prohibition extends to all academic advisors and

program directors, including those based in the College Houses and other

University-owned or administered housing. The prohibition also extends

to graduate, professional, or undergraduate student assistants, but, in

their case, only with respect to those undergraduate students over whom

they have academic responsibility.

Although consensual sexual relations or dating relationships between

faculty and graduate or professional students are not categorically

prohibited, the University strongly discourages all sexual relations or

dating relationships between faculty and graduate or professional

students. Further, sexual relations or dating relationships between

a faculty member and a graduate or professional student during the

period of the faculty/student relationship are prohibited. The prohibition

extends to sexual relations or dating between a graduate or professional

student and other students for whom they have some supervisory

academic responsibility, between department chairs and students in

that department, and between graduate group chairs and students in

that graduate group. Likewise, sexual relations and dating relationships

are prohibited between a graduate or professional student and their

academic advisors, program directors, and all others who have any

supervisory responsibility for that student.

B. Workplace and Other Settings

Those entrusted with responsibility for supervising, evaluating, advising,

or mentoring other members of the Penn community are in inherently

unequal positions. Faculty, staff, and others should not evaluate or

supervise those with whom they have a familial, romantic or sexual

relationship because of the potential for conflict of interest, or the

appearance of favoritism, exploitation or bias. As is the case for

faculty, sexual or romantic relationships between staff members

and undergraduate students are prohibited. Although consensual

sexual relations or dating relationships between staff and graduate or

professional students, are not categorically prohibited, the University

strongly discourages all sexual relations or dating relationships between

staff and graduate or professional students.

Consensual sexual or romantic relationships between those employed

by the University as faculty or staff are not in general prohibited by this

policy. However, relationships between employees in which one has

direct or indirect authority over the other are potentially problematic,

including relationships between supervisors and their direct and indirect

reports, between senior faculty and junior faculty, and managers and

those who report to them (directly or indirectly). If such a relationship

develops or exists as a result of a change in employment or academic

status, the person in the position of greater authority or power must

recuse themselves to ensure that they do not exercise any supervisory or

evaluative function over the other person in the relationship. Where such

recusal is required, the recusing party must also notify their department

chair, Dean, supervisor, or manager, so that person can ensure adequate

alternative supervisory or evaluative arrangements are put in place. Such

notiﬁcation is always required where recusal is required. This obligation

to recuse and notify exists for past as well as for current relationships.

Failure to disclose the relationship in a timely fashion will itself be

considered a violation of policy.

It is understood that sexual or romantic relationships may be private

and the University treats such information sensitively and (to the extent

practicable) conﬁdentially. The University has the option to take any

action necessary to ensure compliance with the spirit of this policy,

including transferring either or both employees to minimize disruption of

operations.

MECHANISMS FOR COMPLAINT RESOLUTION

To make a complaint alleging a violation of this policy, the Associate Vice

President for Equity and Title IX Ofﬁcer (“AVP”) should be contacted.

COMPLAINTS AGAINST FACULTY

If a determination is made that the complaint involves a possible

violation of the Consensual Romantic and Sexual Relations in the

Workplace and Educational Settings Policy, (other than sexual

harassment, sexual violence or sexual assault), then the AVP will oversee

the informal resolution or investigative process(es), advising the Dean of

the applicable school that a complaint has been made and discussing

any interim measures that may be needed. In either case, for Standing

Faculty, the Procedure Governing Sanctions Taken Against Members of

the Faculty,

Handbook for Faculty and Academic Administrators

, Part II.E.16,

will be followed where applicable.

COMPLAINTS AGAINST STAFF

If a determination is made that the complaint involves a possible

violation of the Consensual Romantic and Sexual Relations in

the Workplace and Educational Settings Policy (other than sexual

harassment, sexual violence or sexual assault), then the AVP will oversee

the informal resolution or investigative process(es), advising the Dean,

Vice President, or Vice Provost of the applicable administrative division

that a complaint has been made and discussing any interim measures

that may be needed.

COMPLAINTS AGAINST ENROLLED STUDENTS

If a determination is made that the complaint involves a possible

violation of the Consensual Romantic and Sexual Relations in

the Workplace and Educational Settings Policy (other than sexual

harassment, sexual violence or sexual assault), then the AVP will oversee

the informal resolution or investigative process(es), advising the Dean of

the applicable school that a complaint has been made and discussing

any interim measures that may be needed.

C. Policy Against Retaliation

University policy expressly prohibits retaliation against faculty, staff,

students, postdoctoral or other trainees, or members of the community

who in good faith make reports of violations of this policy. In addition,

knowingly and intentionally making a false report of a violation of this

policy is prohibited. Members of the Penn community who take adverse

action against, intimidate, threaten or otherwise engage in retaliation

against a person because they ﬁled a complaint of sexual misconduct

or served as a witness during an investigation are subject to disciplinary

action, up to and including termination of their employment or expulsion

from the University.

III. Student Disciplinary Procedures

for Resolving Complaints of Sexual

Misconduct

A. Introduction

The University of Pennsylvania is committed to providing a safe and

healthy environment, free of gender-based misconduct, to all members

of our community and visitors to our community. As such, sexual

harassment, sexual assault, sexual violence, relationship violence, and

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VI.E-F. Sexual Misconduct Policy, Resource Ofﬁces and Complaint Procedures

stalking will not be tolerated. To ensure the creation of a climate where

students are able to thrive and achieve their full potential, the University

has developed a wide range of policies, educational programs, broad-

based resources, support, and reporting systems. This amendment

to the Student Disciplinary Charter supplements these other policies

and initiatives, addressing the process by which complaints against

an enrolled University student for a violation of the Sexual Misconduct

Policy (which includes its Sexual Harassment, Sexual Violence,

Relationship Violence, and Stalking Policy (“Sexual Harassment Policy”),

and the Consensual Romantic and Sexual Relationships in the Workplace

and Educational Settings Policy will be adjudicated and resolved.

B. Conﬁdentiality

Conﬁdentiality is of critical importance in ensuring that these sensitive

matters are handled appropriately. The University has an obligation

to respond to violations of its Sexual Misconduct Policy as fairly and

expeditiously as possible when a complaint is received. University staff

and faculty may share information with others who have a legitimate

need to know to fairly and effectively address complaints, but the

information should be considered conﬁdential and protected to the extent

possible consistent with legal obligations. Such administrators may

include, for example those in, the Division of University Life, the Ofﬁce

of the Associate Vice President and Title IX Ofﬁcer (AVP), the Division

of Public Safety, the Senior Vice President for Institutional Affairs and

Chief Diversity Ofﬁcer, Ofﬁce of General Counsel, Student Health and

Counseling, and academic advising ofﬁces.

C. Reporting Complaints of Violation of Sexual

Misconduct

1. OFFICE OF THE ASSOCIATE VICE PRESIDENT FOR EQUITY AND

TITLE IX OFFICER (AVP)

The Ofﬁce of the AVP will be responsible for managing all complaints

made against enrolled University students for violations of its Sexual

Misconduct Policy (including sexual harassment and sexual violence).

Complaints should be made to the AVP who will assign the complaint to

a trained investigative ofﬁcer (IO) who will work under the AVP’s direction

and supervision.

Complaints must either be presented in writing or based upon

information provided by the complainant to the AVP or IO who will then

memorialize the allegations in writing and have the allegations conﬁrmed

by the complainant. Complainants may include University students or

others who allege a violation of the Policy by a student enrolled at the

University during the period that student has been enrolled.

2. OFFICE OF THE DISTRICT ATTORNEY AND OFFICE FOR CIVIL

RIGHTS

Complainants may also choose to ﬁle a report with the District Attorney,

the Ofﬁce for Civil Rights of the U.S. Department of Education, or other

external agencies. The University processes and the legal system work

independently of one another and the University has its own interest in,

and responsibility for, ensuring the enforcement of its Sexual Misconduct

Policy.

Therefore, the University will not unilaterally defer its processes

pending the outcome of any criminal process, nor will the outcome of any

legal process be determinative of the University result. The University

will, however, comply with reasonable requests by law enforcement for

cooperation, and upon reasonable request, will temporarily suspend its

fact-ﬁnding process in a sexual misconduct investigation so as not to

impede the law enforcement process.

3. SUPPORT, COUNSELING AND ADVICE

In making a decision about how to proceed with a complaint,

complainants may seek support, counseling, and advice from other

ofﬁces on campus, including the Special Services Department in

the Division of Public Safety, Penn Violence Prevention, Ofﬁce of

the University Chaplain, Penn Women’s Center, Student Health and

Counseling, Ofﬁce of the Ombuds, African-American Resource Center,

or Lesbian Gay Bisexual Transgender Center. A list of these ofﬁces is

provided in Section E below. Should a complainant decide to proceed

with the University’s disciplinary process against an enrolled University

student, the Ofﬁce of the AVP will be the single place to initiate the

process.

4. TIMEFRAME FOR SUBMITTING A COMPLAINT

The University does not limit the timeframe for ﬁling a report of a

violation of the Sexual Misconduct Policy. Reports may be ﬁled at any

time, although the University’s ability to investigate or take any action

may be limited by the passage of time or the matriculation status of the

alleged respondent.

5. COMPLAINANT REQUEST FOR CONFIDENTIALITY

The University is required by Title IX to weigh the complainant’s request

for conﬁdentiality/privacy with the University’s commitment to provide

a reasonably safe and nondiscriminatory environment. In situations

where a complainant requests conﬁdentiality, the University’s ability to

investigate and respond to the allegations may be limited. The AVP or

IO will notify the complainant if the University cannot, in unusual cases,

maintain the complainant’s conﬁdentiality/privacy. The complainant’s

and respondent’s identities will only be revealed to those individuals who

need to know their names to investigate or adjudicate the complaint or

provide interim measures. If the University becomes aware of a pattern of

behavior by one or more respondents, the University will take appropriate

action in an attempt to protect the University community.

D. Investigation and Resolution of Complaints

1. TIMELY RESOLUTION

Where possible, the process of resolving complaints, exclusive of any

appeal, should be completed within 60 business days of the ﬁling of the

written complaint. The appeal should be completed, where possible,

within 30 business days of the ﬁling of the appeal.

In the event that a Hearing Panel is convened, the complainant and the

respondent will both be provided with a copy of the decision of the Panel

and given 10 business days to ﬁle an appeal.

2. RIGHTS AND PROTECTIONS FOR COMPLAINANT AND

RESPONDENT

(a) The complainant and respondent have the right to a process that is

fundamentally fair, and free of bias or prejudice.

(b) The complainant and respondent have the right to be treated with

respect, dignity, sensitivity, and fairness throughout the entire process.

They are both entitled to seek support from the University and to be

informed about the process both before the process is initiated and

throughout the process as it unfolds.

refrain from participation. Failure to participate will not be used as

evidence against either party

, but also will not prevent the process from

proceeding unless the complainant withdraws the complaint and the

University agrees to abide by that request or the respondent withdraws

from the University.

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139

(d) Each party may have a lawyer or other advisor present when being

interviewed by the Investigative Team and the Hearing Panel, but the

lawyer or other advisor will not be permitted to present statements

or seek the production of evidence. The party’s advisor will be able to

direct questions to the other party or witnesses interviewed by the Panel

subject to determinations of relevance and other procedural issues by the

Disciplinary Hearing Ofﬁcer.

(e) Evidence of prior sexual conduct by the complainant or respondent

with other partners will not ordinarily be considered in the process, and

any evidence of a prior sexual relationship between the parties will not be

determinative of the issue of consent.

(f) If there is credible evidence of a pattern of violations of the Sexual

Misconduct Policy, that evidence may be considered by the Hearing Panel

if there is a ﬁnding of responsibility and a sanction is being determined.

(g) While the process is underway, the Division of University Life will work

with the complainant and respondent, ensuring support is made available

to both parties. The Division of University Life will also be responsible

for implementing interim measures to protect the parties, or any of the

witnesses, consistent with principles of fairness, including implementing

measures regarding housing, academic accommodations and scheduling

changes, no contact orders, and any other appropriate actions to protect

the parties or any of the witnesses.

3. PRELIMINARY DETERMINATION

Upon receiving a complaint, the AVP will make a preliminary

determination as to whether the complaint falls within the purview of

a Sexual Misconduct Policy and whether, on its face, there appears

to be a sufﬁcient basis to conduct a full investigation. In making

this determination, the AVP may interview the complainant and the

respondent (after advising the respondent of the allegations in writing)

and conduct whatever preliminary investigation the AVP deems

necessary to determine if the actions alleged in the complaint would, if

true, constitute a violation of the University’s Sexual Misconduct Policy

and there is a reasonable basis for investigating the charges. If the

AVP concludes there is insufﬁcient basis to proceed, the matter will be

concluded, and the parties so advised.

4. INVESTIGATION

If the AVP makes the determination that there is a sufﬁcient basis

to proceed, the AVP will issue a Statement of Charge Letter, based on

the complaint and any preliminary investigation conducted. The Charge

Letter will be provided to the complainant and the respondent. The

respondent will be provided the opportunity to respond in writing to the

Charge, and any response will be shared with the complainant.

The IO will lead a thorough and fair investigation, assisted by one or more

co-investigators who may come from the school of the complainant

or respondent or from elsewhere in the University (the “Investigative

Team”). The co investigator(s) will be University staff or faculty members

or a consultant or attorney appropriately trained to investigate and

handle sexual misconduct cases who are selected for individual

cases by the AVP or IO. The investigation will include interviews of the

complainant, the respondent, and relevant witnesses, as well as a review

of documentation, physical evidence, and any other relevant evidence.

Prior to interviews, the complainant, the respondent, and any relevant

witnesses will be informed by the IO that statements made during the

process may be admissible in concurrent or subsequent civil or criminal

court proceedings, and will accordingly also be informed of their rights

as outlined in Section D.2(c) above. They will also be reminded of the

consequences of making false statements to the IO under the Code

of Student Conduct and the Charter of the University of Pennsylvania

Student Disciplinary System. The complainant and respondent may have

their advisors

and/or or outside counsel present for their interviews, but

the advisors or outside counsel will not be permitted to participate in the

interview other than to provide advice to the student, and they may be

excluded from the interview for disruptive behavior.

In conducting the investigation, the Investigative Team may, as

appropriate, also consult with other campus ofﬁcials including but

not limited to administrators in the relevant school, Division of Public

Safety, the AVP and Title IX Ofﬁcer, Senior Vice President for Institutional

Affairs and Chief Diversity Ofﬁcer, or the Division of University Life. The

Investigative Team may also consult with the Ofﬁce of General Counsel,

who may determine in particular cases to engage outside counsel to

assist the University throughout this process. The Investigative Team

may engage forensic and other experts, as needed.

5. INVESTIGATIVE REPORT

At the conclusion of the investigation, the Investigative Team will prepare

a draft factual investigative report, including assessments of credibility, a

recommended ﬁnding as to responsibility, and recommended sanctions, if

appropriate. In making the responsibility determination, the Investigative

team will use a “preponderance of the evidence” standard. In other words,

to ﬁnd a student responsible for violating the Sexual Misconduct Policy,

the Investigative Team must be convinced that it is more likely than not

that a violation of the Policy has occurred.

(a) Opportunity for Review and Comment

The draft investigative report and related exhibits and evidence will

be provided to both the complainant and respondent for review and

comment, under strict instructions that they are and at all times remains

strictly conﬁdential, and are not to be shared with anyone other than

their families and advisors, and/or outside counsel, as described above

without the expressed consent of the AVP. Sharing of the report by either

party, their families, advisors or outside counsel with any additional

persons is strictly prohibited and anyone with whom the report is shared

must be so advised. The complainant and the respondent will be given

the opportunity to respond to and comment on the draft investigative

report in writing.

(b) Final Report

As a result of the response and comments received, the Investigative

Team may conduct a further investigation and/or amend the draft report,

if the Team determines either action to be warranted. The Investigative

Team will prepare a ﬁnal investigative report, incorporating any changes

they believe are appropriate, and then share it with the complainant and

the respondent. The complainant and respondent may submit formal

objections or comments to the ﬁnal report, which will be appended to the

ﬁnal report of the matter.

6. RESOLUTION WITHOUT A HEARING

The matter may be resolved at this stage if both parties agree to the

recommendations of the Investigative Team with respect to responsibility

and, if applicable, sanctions, or if the parties otherwise reach a mutually

acceptable resolution. The University, however, will not compel either the

complainant or the respondent to engage in face-to face mediation or

to accept the recommendations of the Investigative Team.

7. HEARING PANEL

If the matter is not resolved at this stage in a mutually acceptable

manner, either party may request a Hearing before a Hearing Panel

(Panel) within 10 business days of transmission of the ﬁnal report.

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VI.E-F. Sexual Misconduct Policy, Resource Ofﬁces and Complaint Procedures

(a) Panel Membership

The Panel will be comprised of three (3) faculty members and the

Disciplinary Hearing Ofﬁcer (DHO), who will be a non-voting member. The

DHO will make all decisions about the organization of the Panel, including

decisions regarding the admissibility of evidence, witnesses to appear

before the Panel, or any additional decisions regarding the administration

of the hearing process.

Membership of the Panel, including the DHO, will observe the following

guidelines:

i. Members will be selected from a pool of faculty who have agreed

to serve for a term of one or more years.

ii. Only mixed-gender panels that have received training in

handling complaints involving sexual misconduct will hear sexual

misconduct cases.

iii. Faculty comprising the Panel should be from academic

departments in which neither of the parties is enrolled in a course

of study, and no faculty member should serve on the Panel who has

a mentoring relationship or other personal relationship with either of

the parties.

iv. Faculty asked to serve should recuse themselves or be

dismissed if they have any personal ties to either of the parties or

to individuals with whom the parties are closely associated, or if

they have prior personal knowledge of the alleged incident of sexual

misconduct.

v. The University will train members of the pool to fulﬁll their

responsibilities as adjudicators according to the procedures and

policies outlined here and to ensure compliance with Title IX and

other applicable state and federal guidelines. In addition, the Panel

will be provided with “just in time” training on adjudicating sexual

misconduct cases.

vi. The IO may not serve on the Panel; however, the IO may be

interviewed by the Panel regarding the investigation. The AVP or IO

may assist the DHO as needed in organizational and administrative

matters related to the Panel.

vii. The complainant and respondent will be notiﬁed of the

membership of the Panel in advance of the Hearing. Any challenges

for cause against individual Panel members must be made promptly

so as not to delay the conduct of the Hearing and will be given

serious consideration by the DHO to ensure impartiality of the

proceedings.

viii. All proceedings must be kept strictly conﬁdential among

the parties, witnesses and members of the panel. All individuals

involved in such hearings must agree to such conditions of

conﬁdentiality.

(b) Hearing Procedures

Hearings must be prompt, fair, and impartial, affording the complainant’s

allegations and the respondent’s defenses all due consideration

and protecting the rights of both parties. The Panel will review the

Investigative Team’s ﬁnal report, including any response, objections, or

comments provided by the complainant or respondent. The Panel will

also carefully review the evidentiary record, including witness statements,

documents, and physical evidence.

Hearing Panel Interviews

i. The Panel will interview separately the IO (and co-investigator(s) if the

Panel so chooses), the complainant, and the respondent. The DHO will

provide the complainant and respondent with 10 days advance notice of

the Hearing. If reasonably possible, interviews will be conducted on one

day, but if such scheduling would require an unreasonably long day, or if

such scheduling would unreasonably delay the proceeding, the Hearing

may be scheduled over multiple days.

ii. The Panel may seek additional evidence from the Investigative Team

and interview key witnesses on whom the Investigative Team relied in

drawing conclusions, as well as request additional evidence from the

IO to clarify the evidentiary record, provided that it can do so without

unreasonably delaying the process. In the event that a new witness

comes forward during the Hearing who was not originally interviewed

by the Investigative Team, or new evidence is discovered after the

Investigative Team has issued their report, the DHO may allow that

witness to testify or admit the evidence to the Hearing, but only if the

DHO judges the new witness or evidence to be highly relevant to an

accurate and fair determination of the outcome.

iii. The Hearing will be held in private. Only the person interviewed (and

that person’s advisor or outside counsel, as applicable) will be present

during interviews. The complainant or respondent (and their advisor

or outside counsel, as applicable) will be able to view testimony from

separate rooms via closed-circuit television or similar video transmission.

iv. Subject to the Rights and Protections set forth in Section D.2 above,

the Panel has wide latitude when questioning the complainant, the

respondent, and any witnesses to determine the accuracy of the ﬁnal

report.

v. The complainant and respondent may propose witnesses and provide

speciﬁc questions in advance that they believe important to ask of

other parties or witnesses. The DHO, in consultation with the Panel, will

determine the relevance as well as the appropriateness of witnesses and

questions, and may accordingly place restrictions on, include, or exclude

witnesses or other information.

vi. When the Panel is conducting the interview of the complainant and

respondent, each student will have an advisor or outside counsel with

them to provide advice and support. The advisor or outside counsel

will be permitted to address questions to the other party during the

Hearing subject to determinations of relevancy and other appropriate

considerations. If an advisor’s or outside counsel’s behavior is disruptive,

the Hearing will be adjourned and they may be excluded from the Hearing.

vii. The interviews by the Panel will be recorded (audio only). No

observers will be permitted to make any audio or video recordings.

After the Hearing concludes, the Panel will immediately deliberate in

private to decide whether a preponderance of the evidence shows that

the respondent is responsible for a violation of the University’s Sexual

Misconduct Policy. Preponderance of the evidence means that the Panel

must be convinced based on the evidence that it is more likely than

not that a violation has occurred to ﬁnd a student is responsible for a

violation of the policy. A ﬁnding of responsibility requires a majority vote

of the members of the Panel.

If the respondent is found responsible, the Panel will also determine the

appropriate sanction, by majority vote, based upon the facts of the case

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University of Pennsylvania Faculty Handbook

141

and University precedent, with a presumption in favor of the sanction

recommended by the IO.

The Panel will arrive at its conclusion as expeditiously as possible

and will promptly advise both the complainant and the respondent in

writing of its decision with respect to responsibility and, if applicable,

sanctions. In keeping with guidelines for timely resolution as provided in

Section D1 above, the written decision will be provided as soon after the

conclusion of the proceeding as is possible.

Decisions made by the Panel are considered ﬁnal, subject only to appeal

as outlined below.

(d) Appeal of Hearing Panel Decision

The Panel decision is subject to appeal by either party in writing to a

Disciplinary Appellate Ofﬁcer (DAO), a faculty member with exclusive

jurisdiction to decide appeals. In keeping with guidelines for timely

resolution as provided in Section D1 above, appeals should be submitted

to the AVP within 10 business days after the decision of the Panel.

Letters of appeal should speciﬁcally state whether the objection is to

the judgment of responsibility, the sanction, or both, and explain in detail

the grounds for appeal. The request for an appeal will be shared with

the other party who will have the opportunity to provide a response or

otherwise direct comments to the DAO within 10 business days. Any such

comments or response will be shared with the other party.

The DAO will review the report of the Investigative Team and supporting

evidence, the audio record from the Panel Hearing, and any other material

the DAO deems relevant, in addition to the decision of the Panel to

ensure that the process was consistent with University policy and that

the result was not arbitrary or capricious, that there were no procedural

irregularities, that there was no demonstrated bias or conflict of interest

on the part of any fact-ﬁnder, and that no new evidence has been brought

forward that would alter the outcome of the Hearing.

After considering the appeal, the DAO will promptly issue their decision

in writing and will provide copies to the DHO, the Provost, the Senior

Vice President for Institutional Affairs and Chief Diversity Ofﬁcer, the

complainant, the respondent, and other appropriate parties.

E. Resource Ofﬁces

1. CONFIDENTIAL RESOURCES

Generally, the information shared with conﬁdential resources will

be held in conﬁdence, consistent with the University’s obligation to

address complaints of sexual misconduct, unless the person sharing

the information gives their consent to the disclosure of that information.

Non-identifying information regarding complaints should be provided

to the AVP for purposes of assuring compliance with Title IX and other

applicable laws and regulations. Conﬁdential resources are not obligated

to share identifying information with the AVP when an incident of sexual

misconduct is shared with that resource. However, the commitment

to conﬁdentiality does not preclude the sharing of information among

University administrators as appropriate to keep members of the

University community safe. In addition, conﬁdential resources should

submit non-identifying information about incidents of sexual misconduct

to the Division of Public Safety for the purpose of crime statistics

reporting under the Clery Act. (For additional information regarding

requirements, see the Clery Act & Crime Reporting page at https://www.

publicsafety.upenn.edu/clery/.) The University’s conﬁdential resources

are:

Special Services Department, Division of Public Safety

24-hours/7 days per week: (215) 898-6600

4040 Chestnut Street

http://www.publicsafety.upenn.edu/special-services/

Penn Women’s Center (PWC)

(215) 898-8611 and (215) 898-6500

3643 Locust Walk

https://pwc.vpul.upenn.edu

Student Health and Counseling

Counseling: (215) 898-7021

After-hours emergency number: (215) 349-5490

3624 Market Street, 1st Floor, West

http://caps.wellness.upenn.edu/sttop (http://caps.wellness.upenn.edu/

sttop/)

Sexual Trauma Treatment, Outreach and Prevention (CAPS)

http://caps.wellness.upenn.edu/sttop (http://caps.wellness.upenn.edu/

sttop/)

Medical: (215) 746-3535

Suite 100, 3535 Market Street

http://shs.wellness.upenn.edu

Lesbian Gay Bisexual Transgender Center

(215) 898-5044

3907 Spruce Street

https://lgbtc.vpul.upenn.edu

African-American Resource Center

(215) 898-0104

3643 Locust Walk

http://www.upenn.edu/aarc/

Ofﬁce of the Ombuds

(215) 898-8261

113 Duhring Wing, 236 S. 34th Street

http://www.upenn.edu/ombuds/

Ofﬁce of the University Chaplain

(215) 898-8456

240 Houston Hall, 3417 Spruce Street

http://www.upenn.edu/chaplain/

Penn Violence Prevention

(215) 746-2642

3611 Locust Walk

https://pvp.vpul.upenn.edu

2. OFFICIAL REPORTING OFFICES FOR SEXUAL MISCONDUCT

COMPLAINTS

If reports of sexual misconduct are made with or come to the attention of

the following ofﬁces, they must ensure that appropriate action is taken,

including notifying the University’s AVP and Title IX Ofﬁcer:

Ofﬁce of Equal Opportunity Programs

(215) 898-6993

Suite 421, Franklin Building

http://oeop.upenn.edu

Student Intervention Services, VPUL

(215) 898-6081

(215) 768-6527 Nights/Weekends

3611 Locust Walk

https://sis.vpul.upenn.edu

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142

VI.E-F. Sexual Misconduct Policy, Resource Ofﬁces and Complaint Procedures

Center for Community Standards and Accountability

(215) 898-5651

Suite 400, 3440 Market Street

https://csa.upenn.edu

Ofﬁce of Staff and Labor Relations, Division of Human Resources

(215) 898-6093

Suite 600, Franklin Building

https://www.hr.upenn.edu/workplace-issues/staff-labor-relations

(https://www.hr.upenn.edu/workplace-issues/staff-labor-relations/)

F. Intake and Investigative Ofﬁce for Sexual Misconduct

Complaints

The ofﬁcial ofﬁce for reporting, initiating a formal complaint, and

investigation of violations of the Sexual Misconduct Policy, including

violations of the Sexual Harassment Policy, is the Ofﬁce of the Associate

Vice President for Equity and Title IX Ofﬁcer. The contact information for

that Ofﬁce is:

Associate Vice President for Equity and Title IX Ofﬁcer

3901 Walnut Street, Suite 320

(215) 898-2887

https://titleixofﬁce.upenn.edu/

IV. Procedures for Resolving Complaints

of Sexual Misconduct Against Faculty

A. Introduction

The University of Pennsylvania is committed to providing a safe and

healthy environment, free of gender-based misconduct, to all members of

our community and visitors to our community. As such, sexual assault,

sexual violence, relationship violence and stalking will not be tolerated.

To ensure the creation of a climate where members of the community

are able to thrive and achieve their full potential, the University has

developed a wide range of policies, educational programs, broad-based

resources, support and reporting systems. These procedures supplement

these other policies and initiatives, addressing the process by which

complaints against a University faculty member for a violation of the

Sexual Misconduct Policy (which includes the Sexual Harassment Sexual

Violence, Relationship Violence and Stalking Policy (“Sexual Harassment

Policy”) and the Consensual Romantic and Sexual Relationships in the

Workplace and Educational Settings Policy) will be adjudicated and

resolved.