Skip to Ramapo College Policies, Procedures, Statements site navigationSkip to main content
Ramapo College of New Jersey Home Page

Ramapo College Policies, Procedures, Statements

Policy 402: Intellectual Property

Policy

Ramapo College of New Jersey (the “College”) is committed to an academic environment that fosters creativity, innovation and the free flow of ideas among its faculty, staff and students. The College desires to promote these principles among its constituencies by supporting the development of works and creations through research and scholarship.

Reason for Policy

This Policy establishes the parameters in which intellectual property rights at the College are defined for students, faculty, staff and independent contractors.

To Whom Does the Policy Apply

All College faculty, employees, students and contractors

Supplemental Resources

Contacts

Office of General Counsel

Procedure 402: Intellectual Property

I. Purpose

 The purpose of this procedure is to define the rights of Ramapo College of New Jersey (the “College”) and its faculty, staff, students and contractors concerning intellectual property rights in created works and/or inventions.

II. Definitions

 For purposes of this policy, the following terms shall have the following meanings:

  • “College” shall mean Ramapo College of New Jersey.
  • “Extraordinary Use” shall mean the use of resources (i.e. facilities; financial; administrative technical, etc.) that are above and beyond the resources that are commonly provided to an employee.
  • “Faculty” shall mean the full-time, part-time and adjunct teaching faculty at the College.
  • “Incidental Use” shall mean normal academic use of resources commonly available to an employee such as the use of an employee’s office, computer, internet services, library facilities and/or office equipment.
  • “Invention” shall mean any patentable or non-patentable creation or discovery of a process, technical information, method, technique, data or other proprietary idea or matter.
  • “Marks” shall mean the College’s ownership or proprietary interest in any trademark, service mark, logo, or other distinguishing mark.
  • “Intellectual Property” shall mean, in a collective context, a work or invention in any medium that may be protected by copyright, proprietary right, trade secret protection, patent and/or trademark.
  • “Staff” shall mean all other non-faculty employees at the College, including managers and senior administrators.
  • “Student” shall mean an individual attending the College and taking undergraduate or graduate classes in a matriculated or non-matriculated status.
  • “Work” shall mean an original work of authorship produced through a creative effort that is fixed in a tangible medium of expression from which it can be perceived, reproduced, or otherwise communicated either directly or with the aid of a machine or device.

III.  Intellectual Property Rights of Faculty

A. Ownership of Copyright * 

  1. When a member of the negotiations unit during the course of their employment creates a product that constitutes copyrightable property, the ownership of copyright to such property shall reside as follows:

a. Faculty members shall be the sole owners of the copyright if:

(1) The copyrightable property is embodied in textbooks, manuscripts, scholarly works, works of art or design, musical scores and performances, dramatic works and performances, choreographic works, popular fiction and non-fiction works, poems, or other works of the kind that have historically been deemed in academic communities to be the property of their author, including lecture notes, course outlines, handouts, exercises and tests developed by employees to support their own teaching activities unless covered under b. below; or

(2)  The copyrightable property is embodied in a storage medium such as films, videos, audio recordings, multimedia materials, distance learning materials, and courseware unless covered under (b) below; or

(3)  The copyrightable property has been released by the College to the creator; or

(4)  The copyrightable property is created on sabbatical leave with no more than incidental use of College facilities

(5)  The copyrightable property is exclusively created by the College employee on their own time, unrelated to their job duties and responsibilities and not using any College resources.

b. The College shall be the sole owner of the copyright if:

(1)  The copyrightable property is embodied in a work that is commissioned by the College pursuant to a signed contract; or

(2)  The copyrightable property is embodied in a work that the faculty member is specifically assigned to create; or

(3)  The College indicates, in writing, at the time it grants an alternate assignment within load, that it intends to claim ownership of copyright to any work made possible by the alternate assignment; or

(4)  The copyrightable property is created with more than incidental use of the College facilities or financial support.

c. The ownership rights described in (b) above may be modified by an agreement between the creator and the College.

d. Copyright ownership of any type of recorded synchronous course shall be determined by mutual agreement between the creator and the College. The parties shall enter such agreement prior to the recording of the course.

e. The copyrightable property that is created in the course of research supported by the College which is funded by the College and/or a sponsor pursuant to a grant or research agreement, or which is subject to a materials transfer agreement, confidential disclosure agreement or other legal obligation affecting ownership, will be governed by the terms of such grant or agreement, as approved by the College. The College will ordinarily own copyright to such property.

B. Inventions

  1. The ownership rights of an invention created by a faculty member while employed will be determined based upon an evaluation of the following criteria:

a. Use of incidental or extraordinary College resources by the faculty member in creating the invention;

b. Whether the faculty member was assigned, directed or specifically funded by the College to create the invention; and

c. Whether development of the invention directly resulted from the faculty member’s job duties.

2. Any potential invention by a faculty member shall be disclosed to the Office of the Provost as soon as practicable.

3. In the event there is any potential financial return from an invention, the faculty member and College will stipulate the allocation of net revenues and other related terms in a written agreement mutually agreed upon by the parties.

4. Any invention that is exclusively created by a College faculty member on their own time, unrelated to their job duties and responsibilities and not using any College resources will be owned by the faculty member.

IV. Intellectual Property of Staff

A. Any work or invention that is created by a College staff member during the course of the staff member’s employment, shall be considered a work for hire and such work shall be owned by the College.

B. Any work or invention that is exclusively created by a College staff member on their own time, unrelated to their job duties and responsibilities and not using any College resources will be owned by the staff member.

V. Student Intellectual Property Rights

A. Intellectual property, including copyright in all academic materials (i.e. term papers; projects; presentations; theses; etc.) created and developed by a student while attending the College is owned by the student.

B. Any work or invention that is exclusively created by a student on the student’s own time, unrelated to the student’s academic progression and not using any College resources will be owned by the student.

C. Any work or invention created by a student in the capacity as a student worker or graduate assistant or when a student receives a payment from the College for such work or invention, is owned by the College.

D. Any work or invention that is transferred to the College by means of a written agreement is owned by the College.

E. Intellectual property developed by a student is owned by the College if the student substantially uses College facilities in furtherance of the invention or work.

VI. Copyright with Contractors and Non-Employees of the College

Any ownership of copyright in any work for the College is determined by a written agreement by the contractor/non-employee and the College. Generally, the College considers such work as a work for hire, which gives the College, and not the contractor/non-employee, full and complete ownership of the work.

VII. College-Owned Copyright

A. Any work that is created as a result of a College-paid, assigned duty is owned by the College with the author being granted a limited, no-cost, royalty-free license for non-commercial research and educational purposes.

B. Any work that is created pursuant to a written agreement with the College that specifically provides that the College owns the copyright in the work.

C. Any work that is created pursuant to a sponsored research project and/or receipt of external sponsored funding.

D. Any work created with extraordinary use of College resources.

VIII.  Dispute Procedures

A. For disputes arising under this policy involving faculty, College management and the local collective negotiations unit shall mutually agree upon specific procedures for adjudicating such dispute.

B. If a dispute exists under this policy involving a College student or staff members, the Office of the General Counsel shall appoint a three-member ad hoc committee to adjudicate such dispute. The committee shall consist of:

(i) a member from the Teaching & Learning Core;

(ii) a member from the Fiscal Health Core;

(iii) a member from the Operational & Administrative Integration Core; and

(iv) a member from the Outreach & Engagement Core or Student Well-being Core.

   The decision of the committee shall be final and binding.

IX. Use of College Name and Marks

The College owns various Marks that represent or identify Ramapo College of New Jersey, its programs, or its services, including, but not limited to, the name, seal and logo of the College. Unauthorized use of the College’s Marks is strictly prohibited.

X. Use of Student, Faculty and Staff Likenesses and Images

The College may use the likenesses and/or images of student, faculty and staff, without consent, to the extent such use is not prohibited by law.

XI. Copyright and Posting on the College Web Site and Social Media Pages

The posting of any material to the College’s website, web pages and/or social media pages/accounts that violates the copyright of others, including links to copyrighted material, is strictly prohibited. No copyrighted materials or links to copyrighted material may be posted anywhere on the College’s website, web pages hosted by the College, and/or the College’s social media pages/accounts, without the prior written authorization of the copyright owner.

XIII. Applicability of Policy

This policy is made subject to all applicable federal and state laws, regulations and collective negotiations agreements (master and local). To the extent there is any conflict between the provisions of this policy and any law, regulation or collective negotiations agreement, the applicable law, regulation or collective negotiations agreement shall prevail.

* These provisions for faculty copyright are adopted from the Master Collective Negotiations Agreement by and between the State of New Jersey and the Council of New Jersey State College Locals, AFT, AFL-CIO, dated July 1, 2015- June 30, 2019. As these provisions are not provided for in the subsequent master collective negotiations agreement, the College and the Ramapo Federation of Teachers Local 2274 may negotiate any mandatorily negotiable issues related to intellectual property rights and the same may be incorporated into this policy when finalized between the parties.

Policy 602: Digital Accessibility

Policy

Ramapo College of New Jersey is committed to ensuring its digital environment is accessible to all individuals, including people with disabilities, in accordance with the Americans with Disabilities Act (ADA) of 1990, Section 504 of the Rehabilitation Act of 1973, and other applicable state and federal laws. All electronic content that is generally available to students, College employees, applicants or the general public must be available to those with disabilities in a manner that ensures equal opportunity to that of their non-disabled peers to participate in the College’s programs, benefits and services.

Reason for Policy

Digital accessibility is the shared responsibility of the entire Ramapo College community. This policy enhances access and reduces barriers for members of Ramapo College, supports student and employee success, reduces the need for and costs of required retroactive accommodations, and establishes a framework to guarantee that all web content, mobile applications, and other digital resources are readily accessible for all users.

To Whom Does the Policy Apply

All members of Ramapo College

Supplemental Resources

Contacts

Office of the General Counsel

Procedure 602: Digital Accessibility

*Updates made to reflect the DOJ’s extension of compliance dates for State and local government entities with a total population of 50,000 or more from April 24, 2026, to April 26, 2027. 

I. Scope

This policy applies to all digital content and services developed, procured, maintained, or used by the College for its programs, services, or activities. This includes, but is not limited to:

  •  All public-facing and internal-facing websites, including unit and departmental pages.
  • All web-based applications, software, mobile applications, and learning management systems (e.g., Canvas, Coursedog, etc.).
  • Online course materials, including documents (e.g., PDF, DOCX, PPTX), videos, audio files, and presentations.
  • Official Institutional Communications, including broadcast emails and newsletters.
  • Digital Marketing and Outreach, including recruitment materials and electronic invitations.
  • Official College social media content.
  • Third-party vendor products and services used by the College.

II. Accessibility Standards

To meet the accessibility standards required by this policy, responsible individuals and units must ensure that digital content and information technology allows disabled individuals to independently, privately, and equitably access the same information, engage in the same interactions, and conduct the same transactions with substantially equivalent ease of use, as people without disabilities.

All digital content newly created, redesigned, or modified by the College, any of its units, or any of its faculty on or after April 26, 2027 must adhere to web and mobile app accessibility requirements set by the Department of Justice under the ADA Title II digital accessibility rule using the latest WCAG technical standards.

Additionally, digital content that was published before April 26, 2027 (“legacy digital content”) must be brought into compliance with the same digital accessibility standards applicable to newly created or modified content, unless a specific exemption identified in this policy applies (see Exceptions below). Each College department and unit must establish priorities and timetables for updating legacy digital content. Remediation of legacy digital content shall be prioritized based on the content’s relevance, frequency of use, and its role in critical College business and academic activities – those activities that students, employees, faculty or visitors must access to effectively participate in a program, service, or activity offered by the College.

Digital content specifically requested to be made accessible as part of a formal accommodation request and/or a request by a responsible party on behalf of an individual with a disability shall be made accessible as soon as possible, or an equally effective alternative shall be provided.

Third-party digital content shall also adhere to this policy. This includes videos, social media posts, and other content critical to business and academic activities.

III. Roles and Responsibilities

A.  College Leadership and Administration: Responsible for providing the necessary resources and support for policy implementation, including the allocation of budget, staff, and technology.

B.  ADA Coordinator: The designated central point of contact for all digital accessibility matters. The ADA Coordinator will develop procedures, monitor compliance, and coordinate remediation efforts.

C.  Content Creators (Faculty, Staff, and Administrators): Responsible for creating new digital content that is accessible by design and for remediating existing content under their control. “Existing content” refers to any digital material that was created, posted, or maintained prior to the adoption of this policy, and remains available or in use for instructional or public purposes. This includes ensuring proper use of headings, alternative text for images, captions for videos, and accessible document formats.

D.  Web Developers and IT Staff: Responsible for designing, developing, and maintaining websites and applications to meet accessibility standards and for ensuring that all technological platforms are compliant.

E.  Budget Office/Procurement Officers: Responsible for ensuring that all new contracts for digital products and services, including third-party vendors, explicitly require conformance with this policy and the latest WCAG technical standards.

IV. Exemptions

This policy applies to all College websites, web content, systems, and applications and functionality including those developed by, maintained by, or offered through third-party vendors or open sources, except where doing so would impose a fundamental alteration or undue burden.

Additionally, digital content and information technology are not required to meet the above-described accessibility standard in the limited circumstances set forth below:

A. Archived web content. Web content that meets all of the following requirements:

  • The content was created before the implementation date of the Policy or the content reproduces paper documents or the contents of other physical media (audiotapes, film negatives, and CD-ROMs for example) that were created before the implementation date of the Policy;
  • The content is kept only for reference, research, or recordkeeping;
  • The content is kept in a special area for archived content; and
  • The content has not been changed since it was archived.

B. Individualized documents that are password-protected and the documents meet all of the following requirements:

  • The documents are word processing, presentation, PDF, or spreadsheet files.
  • The documents are about a specific person, incident, or other College business.
  • The documents are password-protected or otherwise secured.

C. Preexisting conventional electronic documents that meet all of the following requirements:

  • The documents were available on the College’s website or mobile applications before the implementation date of the Policy.
  • The documents are word processing, presentation, PDF, or spreadsheet files.
  • The documents are not currently being used to apply for, access, or participate in the College’s services, programs, or activities.

D. Preexisting social media posts that were made before the implementation date of the Policy.

E. Certain content posted by a third-party.

  • Content that is posted by third parties, such as members of the general public, on the College’s website or mobile applications where the third party is not posting due to contractual, licensing, or other arrangements with the College.
  • In circumstances which qualify for an exemption, the responsible individuals or units must, upon receipt of a request from an individual who cannot access the content due to disability, provide a means of effective communication, an accessible alternative format, or an equally effective accommodation to enable equitable access to the digital content and information technology.

Note: the following resources were used to inform this policy and procedure: Rutgers University Digital Accessibility Policy, Montclair State University Digital Accessibility Policy, Accessibility of Digital Content and Information Technology (University of Minnesota)

Policy

Policy Statement
Ramapo College of New Jersey, hereinafter “the College”, recognizes that safeguarding the integrity, confidentiality, and availability of its digital assets and sensitive information is not only essential but also integral to its mission as an institution of higher learning. Cybersecurity is not merely a technical concern; it is a fundamental responsibility that impacts every facet of our college community.

While reliance on technology for teaching, learning, research, administrative operations, and communication offers countless benefits, it also exposes the College to a wide range of cybersecurity threats and vulnerabilities. The consequences of a cybersecurity breach can extend far beyond financial loss; it can affect institutional reputation, compromise the privacy of individuals, and disrupt the academic and administrative functions that are the lifeblood of the College.
Adherence to this policy, procedure, and the confidential Cybersecurity Protocols & Compliance Manual seeks to ensure not only the protection of the College’s digital assets but also the continued growth and success of the College.

Reason for Policy
Sets forth policy and procedures to secure the College’s digital environment, recognizing that cybersecurity is a shared responsibility involving the entire Ramapo College community; provides a structured framework to mitigate risks, protect sensitive data, and establish a culture of vigilance and responsibility among staff, faculty, students, and users; also serves as a guiding document for the community, outlining the principles and practices necessary to create a secure and resilient cybersecurity posture.

To Whom does the Policy Apply
All Ramapo employees, students, and users of Ramapo College’s digital environment and its resources.

Supplemental Resources

Procedure

Procedure 411: Cybersecurity
Procedures to ensure the proper principles, practices, and controls associated with the College’s cybersecurity posture are captured in the User Responsibilities noted below and also in a RCNJ Cybersecurity Protocols & Compliance Manual (CPCM) which is a confidential document.

I. User Responsibilities
Cybersecurity is a shared responsibility. While ITS implements and manages robust security infrastructure, the ultimate protection of our information and systems is a collective effort. Every user is trusted with the duty to safeguard institutional data, protect their credentials, and act as the first line of defense against cyber threats. This includes being vigilant against phishing attempts, practicing strong password management, securing personal devices that connect to the college network, and handling sensitive data with appropriate care. For a complete and detailed outline of your specific obligations, please refer to Policy 604: Acceptable Use for Information and Technological Resources.

II. Cybersecurity Protocols & Compliance Manual (CPCM)
The CPCM shall include, at minimum, the following subjects:

  • Key Objectives
  • Scope
  • Roles and Responsibilities
  • Security Awareness and Training
  • Access Controls
  • Procedures for Encrypting and Protecting Sensitive Data
  • Network Security
  • Incident Response Plan
  • Patch Management
  • Auditing, Security Monitoring, and Logging
  • Vendor Management
  • Compliance and Regulations
  • Physical Security
  • Business Continuity and Disaster Recovery
  • Review and Revision
  • Non-compliance
  • Stressing Everyone’s Role in Maintaining Cybersecurity
  • Communication

The CPCM is reviewed annually by Information Technology Services.

 

Policy

Policy Statement

Ramapo College of New Jersey (hereinafter referred to as the “College”) is committed to supporting research, scholarship, creative work, and other institutional activities through the procurement of external funding, including those from government agencies and private organizations.

Purpose of Policy

The purpose of this policy is to ensure that all sponsored programs for which external funding or internal funding is provided support the College mission and strategic plan, enhance the College’s reputation and standing, and comply with applicable federal, state, and institutional regulations, as well as those of the sponsoring agency.

To Whom Does the Policy Apply

This policy applies to all College employees engaged in sponsored program activities, whether they are externally funded or not. This includes faculty (full-time, part-time/adjunct, lecturers, professional staff who teach), administrators, staff, and persons/parties contracted by the College.

Supplemental Resources

Contact

Office of Grants & Sponsored Programs

Procedure

Procedures to ensure the proper conduct and controls associated with sponsored programs are detailed in the Grants & Sponsored Programs Compliance Manual.

The Grants and Sponsored Programs Compliance Manual shall include, at minimum, the following subjects:

  • Introduction
  • About Sponsored Programs
  • Award Management
  • Award Closeout
  • Audit
  • Regulatory Compliance
  • Appendices

The Manual shall be reviewed annually by the Office of Grants and Sponsored Programs, and, along with the Pre-Award Sponsored Programs Handbook, shall be made available to all College employees engaged in sponsored program activities.

Grants & Sponsored Programs Compliance Manual

Grants & Sponsored Programs Compliance Manual (pdf)

Pre-Award Sponsored Programs Handbook

Pre-Award Sponsored Programs Handbook (pdf)

 

Policy

Policy Statement

Ramapo College of New Jersey (hereinafter referred to as the “College”) is committed to uphold the highest ethical standards in research. This policy is based on the U.S. Department of Health and Human Services Public Health Service Policies on Research Misconduct – Final Rule, Code of Federal Regulations, Vol. 42, Part 93 (Federal Register, Vol. 70, p. 28370 (May 17, 2005, amended Jan. 17, 2025).

Further, for the purposes of research activities that are not sponsored by Health & Human Services, this policy shall be applied and its procedures may only be adjusted as required by the sponsoring agency.

This policy shall be reviewed annually to ensure compliance with governmental regulations.

Purpose of Policy

The purpose of this policy is to communicate the standards expected of faculty, staff, administrators, and academic professionals who participate in sponsored research at or for the College.

The purpose of the procedure is to describe the process followed in those instances in which research misconduct is suspected to have occurred. To the extent permissible, this policy and procedure applies to all sponsored research activity stewarded by the College.

To Whom Does the Policy Apply

This policy applies to all College employees engaged in research activities, whether they are externally funded or not. This includes faculty (full-time, part-time/adjunct, lecturers, professional staff who teach), administrators, staff, as well as individuals contracted by the College to engage in research that is supported by federal, private, or College funds.

Supplemental Resources

Contact

Vice Provost for Academic and Faculty Affairs (in capacity as the Research Integrity Officer at the College)

Procedure

I. Overview & Principles

Allegations of research misconduct are taken very seriously, as are the needs to protect the rights of those who make such complaints in good faith and the rights of those who are accused of research misconduct.

The purpose of this policy and the following procedures are to achieve these goals and to comply with federal regulations including but not limited to:

  • the Department of HHS and the National Science Foundation (NSF) regulationswhich define the responsibilities of PHS and NSF research grant awardees fordealing with and reporting possible misconduct in research efforts (42CFR, Part50, Subpart A and 45CFR, Part 689);
  • the PHS Act, which requires that each agreement for a grant, contract, or cooperative arrangement for the conduct of biomedical or behavioral research must have, as part of it, assurances that the institution has established an administrative process to review reports of scientific misconduct in connection with biomedical and behavioral research conducted at or sponsored by the institution.

In addition, the NSF has similar regulations governing the conduct of researchers supported by NSF grants. Implicit in these requirements is an understanding that the institution reports any investigation of scientific misconduct that appears to be substantiated. The process described below will be followed when an allegation of research misconduct is received by an institutional official. This process is intended to carry out the College’s responsibilities under the PHS Policies on Research Misconduct, 42 CFR Part 93. It does not apply to authorship or collaboration disputes and applies only to allegations of research misconduct that occurred within six (6) years of the date the institution or HHS received the allegation, subject to the subsequent use, health or safety of the public, and grandfather exceptions in 42 CFR § 93.104(b).

Further, for the purposes of research activities that are not sponsored by HHS, these procedures may be adjusted but only as required by the sponsoring agency.

Principle 1. Responsibility

  1. All College employees and students (hereinafter referred to as “institutionalmembers”), are responsible for reporting suspected research misconduct. Institutional members will cooperate with the RIO and other institutional officials in the review of allegations and the conduct of inquiries and investigations.
  2. If an individual is unsure whether a suspected incident falls within the definition of research misconduct, the individual may contact the RIO to discuss a hypothetical scenario without naming individuals. Should the hypothetical scenario fall within the definition of research misconduct, the RIO will counsel the individual to follow the process for alleging research misconduct. Should the hypothetical scenario fall outside the purview of research misconduct yet merits further inquiry, the RIO will refer the individual to the appropriate office or entity on campus, which may include but is not limited to: Provost’s Office/Teaching and Learning Core; Equity, Diversity, Inclusion & Compliance (EDIC); People Operations & Employee Resources (POER); the College Ombudsperson; the Institutional Review Board (IRB); and/or the School Dean care of the Institutional Animal Care & Use Committee (IACUC).
  3. The individual making the allegation is expected to maintain confidentiality of the report, and to cooperate with the entirety of the assessment, inquiry, and/or investigation processes.
  4. If an individual deliberately and knowingly files a false accusation of research misconduct, they will be subject to disciplinary review and possible sanction, in accordance with applicable law/regulation, College policy and/or collective bargaining agreement.

Further, for the purposes of research activities that are not sponsored by HHS, these responsibilities may be adjusted but only as required by the sponsoring agency.

Principle 2. Protections

  1. No institutional member may retaliate against individuals bringing forth allegations, witnesses, or others involved in the allegation or investigation.
  2. Allegations of research misconduct are handled confidentially in accordance with42 CFR § 93.108 as follows: The College will limit disclosure of the identity ofrespondents and complainants to those who need to know in order to carry out acomprehensive, competent, objective, and fair research misconduct proceeding; and the College, except as otherwise prescribed by law, will limit the disclosure of any records or evidence from which research subjects might be identified to those who need to know in order to carry out a research misconduct proceeding.
  3. In accordance with 42 CFR Part 93, respondents may consult with legal counselor a non-attorney personal adviser (who is not a principal or witness in the case) to seek advice, and may bring the legal counsel or personal adviser to interviews or meetings on the case. The College may permit a legal counsel/personal adviser to be present at interviews and meetings; however, the College restricts the legal counsel/personal adviser’s role to advising (as opposed to representing) the respondent.
  4. Throughout the research misconduct proceeding, the RIO will review thematter to determine if there is any threat of harm to public health, federal funds and equipment, or the integrity of the research process. The RIO shall, at any time during a research misconduct proceeding, notify ORI immediately if they have a reason to believe that any of the following conditions exist:
    • Health or safety of the public is at risk, including an immediate need to protect human or animal subjects;
    • HHS resources or interests are threatened;
    • Research activities should be suspended;
    • There is a reasonable indication of possible violations of civil or criminal law;
    • Federal action is required to protect the interests of those involved in the research misconduct proceeding;
    • The research misconduct proceeding may be made public prematurely and HHS action may be necessary to safeguard evidence and protect the rights of those involved; or
    • The research community or public should be informed. In the event of such a threat, the RIO will, in consultation with other College officials and ORI, take appropriate interim action to protect against any such threat.

Further, for the purposes of research activities that are not sponsored by HHS, these protections may be adjusted but only as required by the sponsoring agency.

II. Procedures

Generally, all inquiries and investigations will be carried through to completion and all significant issues will be pursued diligently. The RIO must notify ORI in advance if there are plans to close a case at the inquiry, investigation, or appeal stage on the basis that respondent has admitted responsibility, a settlement with the respondent has been reached, or for any other reason, except:

  • closing of a case at the inquiry stage on the basis that an investigation is not warranted; or
  • a finding of no misconduct at the investigation stage, which must be reported to ORI, as prescribed in this policy and 42 CFR § 93.316.

A. Assessment and Inquiry 
Individuals with concerns regarding potential research misconduct by an institutional member should contact the RIO. Allegations of research misconduct are to be submitted in writing, along with any evidence they have related to the incident, to the RIO.

  1. Upon receipt of the allegation, the RIO will initiate an assessment to determinethe validity of the allegation. The initial assessment should be completed within seven (7) days from the receipt of the allegation and associated evidence. The RIO need not interview the complainant, respondent, or other witnesses, or gather data beyond any that may have been submitted with the allegation, except as necessary to determine whether the allegation is sufficiently credible and specific so that potential evidence of research misconduct may be identified. The RIO shall, on or before the date on which the respondent is notified of the allegation, obtain custody of, inventory, and sequester all research records and evidence needed to conduct the research misconduct proceeding.
  2. If the RIO determines that the criteria for an inquiry are met, they will immediately initiate the inquiry process. The purpose of the inquiry is to conduct an initial review of the available evidence to determine whether to conduct an investigation. An inquiry does not require a full review of all the evidence related to the allegation. Should the inquiry result in no findings or insufficient evidence to substantiate the allegation, the RIO will keep all materials related to the allegation confidentially for six (6) years. Should the inquiry support the allegation, the RIO will proceed to the next step in the process.
  3. Prior to commencing an inquiry, the RIO must make a good faith effort to notifythe respondent in writing. If the inquiry subsequently identifies additional respondents, they must also be notified in writing. On or before the date on which the respondent is notified, or the inquiry begins, whichever is earlier, the RIO must take all reasonable and practicable steps to obtain custody of all the research records and evidence needed to conduct the research misconduct proceeding, inventory the records and evidence and sequester them in a secure manner. Except in instances where the research records or evidence encompass scientific instruments are shared by a number of users, custody may be limited to copies of the data or evidence on such instruments, so long as those copies are substantially equivalent to the evidentiary value of the instruments. The RIO may consult with ORI for advice and assistance in this regard.
  4. The RIO, in consultation with the College Provost/VP for Teaching, Learning, andGrowth, will appoint an inquiry committee and chair as soon after the initiation of the inquiry as is practicable. While the membership of the committee may vary depending on the nature of the allegation, the committee, at minimum, will consist of: a.) the RIO, and b.) three (3) individuals from the College, of which two must have the background related to the allegation.
  5. No member of the committee should have unresolved personal, professional, or financial conflicts of interest with those involved with the inquiry. The respondent may request that the RIO not appoint specific individuals from the College to serve on the committee on the grounds of a conflict of interest.
  6. At the committee’s first meeting, the RIO will review the charge with the committee, discuss the allegations, any related issues, the appropriate procedures for conducting the inquiry, assist the committee with organizing plans for the inquiry, and answer any questions raised by the committee. Specifically, the charge for the inquiry committee:
    • sets forth the time for completion of the inquiry;
    • describes the allegations and any related issues identified during the allegation assessment;
    • states that the purpose of the inquiry is to conduct an initial review of the evidence, including the testimony of the respondent, complainant and key witnesses, to determine whether an investigation is warranted, not to determine whether research misconduct definitely occurred or who was responsible;
    • states that an investigation is warranted if the committee determines:

a. there is a reasonable basis for concluding that the allegation falls within the definition of research misconduct and is within the jurisdictional criteria of 42 CFR § 93.102; and

b.the allegation may have substance, based on the committee’s review during the inquiry.

    • Informs the inquiry committee that they are responsible for preparing or directing the preparation of a written report of the inquiry that meets the requirements of this policy and 42 CFR § 93.309(a).

7. The inquiry committee will normally interview the complainant, the respondent, and key witnesses as well as examining relevant research records and materials. Then the inquiry committee will evaluate the evidence, including the testimony obtained during the inquiry, and submit a draft inquiry report. A written inquiry report must be prepared that includes the following information:

    • the name and position of the respondent;
    • a description of the allegations of research misconduct;
    • the funding support for the research in question, including, for example, grant numbers, grant applications, contracts and publications listing said support; and
    • the basis for recommending or not recommending that the allegations warrant an investigation.

The College’s legal counsel should review the report for legal sufficiency. Modifications should be made as appropriate in consultation with the RIO and the inquiry committee. After consultation with the RIO, the committee members will decide whether an investigation is warranted based on the criteria in this policy and 42 CFR § 93.307.

8. The RIO shall notify the respondent whether the inquiry found an investigation to be warranted, include a copy of the draft inquiry report for comment within 10 calendar days, and include a copy of or refer to 42 CFRPart 93 and the College’s policies and procedures on research misconduct. Any comments that are submitted by the respondent or complainant will be attached to the final inquiry report. Based on the comments, the inquiry committee may revise the draft report as appropriate and prepare it in finalform. The committee will deliver the final report to the RIO, who will then deliver it to the College Provost. The Provost, in consultation with the RIO, will make a decision whether an investigation is warranted.

9. Within 30 calendar days of the Provost’s decision that an investigation iswarranted, the RIO will provide ORI with the Provost’s written decision and acopy of the final inquiry report. The RIO must provide the following information to ORI upon request:

    • the institutional policies and procedures under which the inquiry was conducted;
    • the research records and evidence reviewed, transcripts or recordings of any interviews (if applicable);
    • copies of all relevant documents; and
    • the charges to be considered in the investigation.

10. The inquiry, including preparation of the final inquiry report and the decision of the Provost on whether an investigation is warranted, must be completed within 60 calendar days of initiation of the inquiry, unless the RIO determines that circumstances clearly warrant a longer period.

If the RIO approves an extension, the inquiry record must include documentation of the reasons for exceeding the 60-day period.

If the Provost decides that an investigation is not warranted, the RIO shall secure and maintain for 7 years after the termination of the inquiry sufficiently detailed documentation of the inquiry to permit a later assessment by ORI of the reasons why an investigation was not conducted. These documents must be provided to ORI or other authorized HHS personnel upon request.

Further, for the purposes of research activities that are not sponsored by HHS, these procedures may be adjusted but only as required by the sponsoring agency.

B. Investigation

  1. The investigation must begin within 30 calendar days after the determination by the Provost that an investigation is warranted. The purpose of the investigation is to explore and examine the allegation and evidence to determine whether research misconduct has occurred, by whom, and to what extent. While the investigation will focus on the initial allegation made, should evidence reveal that additional instances of research misconduct may have occurred, the committee may justify broadening the scope of the investigation. If at any point the evidence points to potential harm to human subjects, College students, or the public, the committee must broaden their scope beyond the initial allegation to further investigate this evidence. Under 42CFR § 93.313 the findings of the investigation must be set forth in an investigation report.
  2. On or before the date on which the investigation begins, the RIO must:
    • notify the ORI Director of the decision to begin the investigation and provide ORIa copy of the inquiry report; and
    • notify the respondent in writing of the allegations to be investigated.

The RIO must also give the respondent written notice of any new allegations of research misconduct within a reasonable amount of time of deciding to pursue allegations not addressed during the inquiry or in the initial notice of the investigation. The RIO will, prior to notifying the respondent of the allegations, take all reasonable and practicable steps to obtain custody of and sequester in a secure manner all research records and evidence needed to conduct the research misconduct proceedings that were not previously sequestered during the inquiry.

3. The investigation committee will convene, with members appointed by the RIO in consultation with the Provost. The investigation committee must consist of individuals who do not have unresolved personal, professional, or financial conflicts of interest with those involved with the investigation and should include individuals with the appropriate scientific expertise to evaluate the evidence and issues related to the allegation, interview the respondent and complainant and conduct the investigation. Individuals appointed to the investigation committee may also have served on the inquiry committee.

4. At the first meeting of the investigation committee, the RIO will define the subject matter of the investigation in a written charge to the committee that:

    • Describes the allegations and related issues identified during the inquiry;
    • Identifies the respondent;
    • Informs the committee that it must conduct the investigation;
    • Defines research misconduct;
    • Informs the committee that it must evaluate the evidence and testimony to determine whether, based on a preponderance of the evidence, research misconduct occurred and, if so, the type and extent of it and who was responsible;
    • Informs the committee that in order to determine that the respondent committed research misconduct it must find that a preponderance of the evidence establishes that:

a. research misconduct, as defined in this policy, occurred (respondent hasthe burden of proving by a preponderance of the evidence any affirmativedefenses raised, including honest error or a difference of opinion);

b. the research misconduct is a departure from accepted practices of the relevant research community; and

c. the respondent committed the research misconduct intentionally, knowingly, or recklessly; and

    • Informs the committee that it must prepare or direct the preparation of a written investigation report that meets the requirements of this policy and 42CFR §93.313.

5. The RIO will convene the first meeting of the investigation committee to review the charge, the inquiry report, and the prescribed procedures and standards for the conduct of the investigation, including the necessity for confidentiality and for developing a specific investigation plan. The investigation committee will be provided with a copy of this statement of policy and procedures and 42 CFR Part 93. The RIO will be present or available throughout the investigation to advise the committee as needed.

6. The investigation committee and the RIO must:

    • Use diligent efforts to ensure that the investigation is thorough and sufficiently documented and includes examination of all research records and evidence relevant to reaching a decision on the merits of each allegation;
    • Take reasonable steps to ensure an impartial and unbiased investigation to the maximum extent practicable;
    • Interview each respondent, complainant, and any other available person who has been identified as having information regarding any relevant aspects of the investigation, including witnesses identified by the respondent; record or transcribe each interview; provide the recording or transcript to the interviewee for correction, and include the recording or transcript in the record of the investigation; and
    • pursue diligently all issues and leads discovered that are determined relevant to the investigation, including any evidence of any additional instances of possible research misconduct, and continue the investigation to completion.

7. The investigation is to be completed within 120 days after its commencement, including conducting the investigation, preparing the report of findings, providing the draft report for comment and sending the final report to ORI. However, if the RIO determines that the investigation will not be completed within this 120-day period, they will submit to ORI a written request for an extension, setting forth the reasons for the delay. The RIO will ensure that periodic progress reports are filed with ORI, if ORI grants the request for an extension and directs the filing of such reports.

8. At the conclusion of the investigation, the committee will submit a draft writtenreport to the Provost. This report must include:

a. The individual(s) accused of research misconduct.
b. The nature of the allegation of research misconduct and the specific allegations considered in the investigation. This will include any allegations that were investigated that were beyond the committee’s original scope, as well as the justification for investigating those additional allegations.
c. Identification and summary of research records and evidence reviewed, including any items that were gathered but not reviewed.
d. A statement of the findings for each specific allegation, to include:

      • the type of research misconduct (falsification, fabrication, plagiarism, etc.);
      • the individual(s) who committed it and the time frame;
      • the committee’s assessment of whether the misconduct was committed intentionally, knowingly, or recklessly;
      • the accused individual(s)’ explanations, which may include an argument that the alleged research misconduct is honest error or difference of opinion;
      • any research related to the misconduct, and whether or not it was published/exhibited and if so, when and where;
      • the identification of any and all financial support of the scholarship related to the misconduct, be it federal, private, or College funds; and
      • the identification of any pending applications or proposals for supportrelated to the misconduct.

e. Recommended sanctions to be imposed by the College.

9. The RIO must give the respondent a copy of the draft investigation report for comment and, concurrently, a copy of, or supervised access to, the evidence on which the report is based. The respondent will be allowed 30 days from the date they receive the draft report to submit comments to the RIO. The respondent’s comments must be included and considered in the final report. In distributing the draft report, or portions thereof, to the respondent, the RIO will inform the recipient of the confidentiality under which the draft report is made available.

10. The RIO will assist the investigation committee in completing the final investigation report, including ensuring that the respondent’s comments are included and considered, and transmit the final investigation report to the Provost, who will determine whether or not the finding(s) support the allegation(s) of research misconduct.

Should the report conclude there was no support to the allegations, the Provost will notify the respondent in writing of the results of the committee’s investigation, and keep all materials related to the allegation in the respondent’s confidential personnel file for seven (7) years.

Should the report support the allegations, the Provost will notify the respondent in writing of the finding(s) by sharing the committee’s report less the committee’s recommended sanctions.

The Provost will also notify the respondent in writing that, unless an appeal (see section E below) with evidence is made within 10 days:

    • a report of the finding(s) will be submitted to the granting agencies, journal editors, publishers, or other agencies in receipt of any research related to the allegations,
    • the Committee’s report without the committee’s recommended sanctions will be submitted to the College President or their designee.

The Provost will also submit their recommended sanctions, taking into consideration pertinent institutional policy and/or collectively negotiated agreements, and the committee’s recommendations which may be further developed in consultation with the College’s General Counsel.

The RIO is responsible for ensuring compliance with all notification requirements of funding or sponsoring agencies.

Further, for the purposes of research activities that are not sponsored by HHS, these investigation protocols may be adjusted as required by the sponsoring agency.

C. Appeals

The accused individual(s) have the right to appeal the report and may do so in writing to the Provost within the 10-day period. The appeal must include evidence that disproves the findings of the report.

If an appeal with evidence is filed, the Provost must supply it to the investigation committee for review.

If no appeal is filed; an appeal is filed without evidence; or an appeal with evidence is filed and the evidence is found to be unsubstantiated, the Provost will inform all granting agencies, journal editors, publishers, or other agencies in receipt of any scholarship of the findings.

Further, for the purposes of research activities that are not sponsored by HHS, these appeal procedures may be adjusted but only as required by the sponsoring agency.

D. Final Decision

The Provost will notify the College President or their designee in a report that contains the committee’s report, a copy of the notification to granting agencies, etc., and any recommended sanctions to be imposed by the College.
Upon receipt and review of the Provost’s report, if:

  • no appeal is filed,
  • an appeal is filed without evidence, or
  • an appeal with evidence is filed and the evidence is found to be unsubstantiated,

the President or their designee will issue the sanctions in writing to the accusedindividual(s), and notify the appropriate offices or entities on which the sanctions may have an impact (e.g., Academic Dean for course scheduling; People Operations and Employee Resources Department; etc.).

The investigation concludes with the issuance of sanctions by the President or their designee; there are no further appeals.

Further, for the purposes of research activities that are not sponsored by HHS, this final decision making process may be adjusted but only as required by the sponsoring agency.

III. Reporting of Findings and Actions to ORI

Unless an extension has been granted, the RIO must, within the 120-day period for completing the investigation, submit the following to ORI:

  • a copy of the final investigation report with all attachments, along with any documentation related to an appeal;
  • a statement of whether the College accepts the findings of the investigation report and appeal, if appropriate;
  • a statement of whether the College found misconduct and, if so, who committed the misconduct; and
  • a description of any pending or completed administrative actions against the respondent.

Further, for the purposes of research activities that are not sponsored by HHS, this reporting may be adjusted but only as required by the sponsoring agency.

IV. Records Retention

The RIO must maintain and provide to ORI, upon request, “records of research misconduct proceedings” as that term is defined by 42 CFR § 93.318. Unless custody has been transferred to HHS or ORI has advised in writing that the records no longer need to be retained, records of research misconduct proceedings must be maintained in a secure manner for seven years after completion of the proceeding involving the research misconduct allegation. The RIO is also responsible for providing any information, documentation, research records, evidence or clarification requested by ORI to carry out its review of an allegation of research misconduct or of the institution’s handling of such an allegation. The entirety of the investigation will be kept within the individual’s confidential personnel file.

Further, for the purposes of research activities that are not sponsored by HHS, these retention practices may be adjusted but only as required by the sponsoring agency.

Appendix 301A: Definitions
  • Allegation means a statement or indication of possible research misconductmade to a College official.
  • Authorship means the definition of authorship that varies across academicdisciplines. In general, authorship means the mechanism for allocation of credit tothe individuals for their contribution to the intellectual value of any research orrelated material that is being presented to an audience. Authorship has important academic, social, intellectual property, and financial implications. Authorship also implies responsibility and accountability for the material that is being presented. Disputes of authorship are not considered research misconduct, however, plagiarism (defined below) is considered research misconduct.
  • College means Ramapo College of New Jersey.
  • Complainant means the individual(s) who submits an allegation of research misconduct.
  • Conflict of Interest means the real or apparent interference of an individual’s interest with the interests of another person, where potential bias may occur due to prior or existing personal or professional relationships.
  • Employee means, for the purpose of this policy and procedure only, any individual under the employ of the College, including faculty (full-time, part-time/adjunct, lecturers, professional staff who teach), administrators, and staff, as well as individuals contracted by the College to engage in research that is supported by federal, private, or College funds.
  • Fabrication means the invention/making up of data or results and recording or reporting them.
  • Falsification means the manipulation of research materials, equipment, or processes; the change or omission of data or results such that the research is not accurately represented in the research record.
  • HHS means the U.S. Department of Health and Human Services, the parent agency of the Public Health Service and the National Institutes of Health.
  • Inquiry means the gathering of information and initial fact-finding to determine whether an allegation or apparent reported or observed instance of research misconduct warrants an investigation.
  • Institutional members means employees (staff, faculty, and administrators) of the College.
  • Investigation means the formal examination and evaluation of all relevant facts to determine if research misconduct has occurred and, if so, to determine the responsible individual and the seriousness of the misconduct.
  • ORI means the Office of Research Integrity that oversees research misconduct inquiries and investigations on behalf of the Secretary of Health and Human Services. For the purposes of research activities that are not sponsored by HHS, ORI shall refer to the relevant parent agency’s entity with whom responsibility over research misconduct and investigations is vested.
  • Plagiarism means the appropriation of another person’s ideas, processes, results, or words without acknowledgement of the original author, or assigning appropriate credit.
  • PHS means the U.S. Public Health Service, an operating component of the Department of Health & Human Services.
  • PHS regulation means the Public Health Service regulation establishing standards for institutional inquiries – and investigations into allegations of scientific misconduct, which is set forth at 42 C.F.R. Part 50, Subpart A, entitled “Responsibility of PHS Awardee and Applicant Institutions for Dealing with and Reporting Possible Misconduct in Science.”
  • PHS support means PHS grants, contracts, or cooperative agreements or applications therefor.
  • Research for the purposes of this policy and procedure only, is defined as, according to federal regulations, a systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to generalizable knowledge. The terms scholarship and creative work may also be considered research.
  • RIO means the Research Integrity Officer, whose role is designated in this policy, namely, the Vice Provost for Academic and Faculty Affairs, who will act as the College’s RIO.
  • Research Misconduct means fabrication, falsification, plagiarism, or other practices that seriously deviate from those that are commonly accepted within the scientific community for proposing, performing, or reviewing research or in reporting research results. Research Misconduct does not include honest error or differences of opinion (§93.103, 42 CFR Part 93- June 2005). It also does not include authorship disputes. The College reserves the right to require adherence to other definitions of research misconduct as required by contractual obligations with external sponsors of research. To be considered research misconduct, the action must represent a “significant departure from acceptable practices;” have been “committed intentionally or knowingly or recklessly;” and be “proven by preponderance of evidence.” These are the minimum standards for establishing irresponsible behavior.
  • Research record means any data, document, computer file, or other written or non-written account or object that reasonably may be expected to provide evidence or information regarding the proposed, conducted, or reported research that constitutes the subject of an allegation of research misconduct. A research record includes, but is not limited to, grant or contract applications, whether funded or unfunded; grant or contract progress and other reports; laboratory notebooks; notes; correspondence; videos; photographs; X-ray film; slides; biological materials; computer files and printouts; manuscripts and publications; equipment use logs; laboratory procurement records; animal facility records; human and animal subject protocols; surveys and collected survey responses; consent forms; medical charts; and patient research files.
  • Respondent means the person against whom an allegation of Research Misconduct is directed or who is the subject of a Research Misconduct proceeding.
  • Retaliation means any action that adversely affects the employment or other institutional status of an individual that is taken by an institution or an employee because the individual has, in good faith, made an allegation of research misconduct or of inadequate institutional response thereto or has cooperated in good faith with an investigation of such allegation.
  • Sponsored Research is research activity that is supported by internal or external funding.
Policy

Policy Statement
Ramapo College is committed to protecting the privacy and confidentiality of personal information, including sensitive Personally Identifiable Information (PII), in compliance with applicable laws and regulations such as the Family Educational Rights and Privacy Act (FERPA), New Jersey statute 56:8-161 and Identity Theft Prevention Act, and the Federal Bureau of Investigation (FBI) classifications of PII.

Reason for Policy
Sets forth policy to ensure proper stewardship and safeguarding of personally identifiable information in accordance with the law.

To Whom does the Policy Apply
All Ramapo employees

Supplemental Resources

Procedure

PROCEDURE 410: DATA PROTECTION (PII)

I. Personal Information Definitions
a. High-Risk Personal Information
The following types of information are considered high-risk and must be protected with the highest level of security measures:

  • Social Security number (SSN)
  • Driver’s license number or State/Federal identification card number
  • Account number, credit or debit card number, in combination with any required security code, access code, or password that would permit access to an individual’s financial account
  • User name, email address, or any other account holder identifying information, in combination with any password or security question and answer that would permit access to an online account
  • Biometric data (e.g., fingerprints, iris scans)
  • Medical and health information, as outlined by HIPAA
  • Passport numbers
  • Criminal history records

Access to high-risk data is strictly limited to authorized positions on a need-to-know basis.

The college logs and annually reviews systems with access to high-risk data, implements encryption on servers that store sensitive information, and reviews user access controls within those systems and servers to protect this data from unauthorized access, disclosure, or misuse.

b. Moderate-Risk Personal Information
The following types of information are considered moderate-risk and are protected with security controls:

  • Date of birth
  • Place of birth
  • Mother’s maiden name
  • Home address
  • Email address (when not combined with access information)
  • Telephone number
  • Employment information
  • Educational information
  • R Number (employee/student ID)*

Access to moderate-risk data is limited to authorized positions. Additionally, certain combinations of moderate-risk PII may elevate the overall classification to high-risk. Classification determinations regarding these combinations are the responsibility of ITS leadership.

* An R Number is a unique identifier assigned to each student and employee within the institution, and while it is sensitive, it does not directly reveal personal information. On its own, it is considered moderate risk. The risk level of an R number can increase when combined with other sensitive information.

c. Low-Risk Personal Information
The following types of information are considered low-risk data, but should still be handled with care:

  • Religious beliefs
  • Political affiliations
  • Sexual orientation

While these types of information may be less sensitive, measures are taken to protect them from unauthorized access or disclosure.

II. PII Evaluation, Classification, and Authorization
Evaluation. Ramapo College regularly evaluates PII to determine its confidentiality impact level. Factors considered include:

  • Identifiability: How easily the PII can be used to identify specific individuals.
  • Quantity of PII: Number of individuals affected in case of a breach.
  • Data field sensitivity: Sensitivity of individual PII elements.
  • Context of use: How PII is collected, stored, used, processed, and disclosed.
  • Legal obligations: Compliance requirements for protecting PII.
  • Authorized Access: Positions with access to high- and moderate-risk PII
  • Location: Sources and locations from which PII is accessed and stored.

Classification. When multiple pieces of moderate-risk PII are combined in a way that could lead to identification or cause significant harm if breached, the overall classification may be elevated to high-risk. Classification determinations regarding these combinations are the responsibility of ITS leadership.

Authorization. Positions authorized to access high- and moderate-risk PII are determined by unit heads in collaboration with system functional administrators. ITS implements security measures to safeguard against unauthorized access or disclosure. By default, student positions are not permitted access to moderate or high-risk PII on any campus system. Any exceptions must be formally requested through ITS and approved by the Vice President with oversight of People Operations and Employee Resources.

III. Data Handling and Breach Notification
All college records are considered property of Ramapo College and must be handled in accordance with state law, institutional requirements, and Ramapo College Records Retention Policy. In the event of a security breach involving personally identifiable information, the College will follow the applicable notification procedures outlined in the New Jersey Identity Theft Prevention Act.

IV. Compliance
Units within the College that handle or process high- and moderate-risk PII are responsible for ensuring the security, privacy, and proper management of that PII. At minimum, employees should always password protect documents containing personally Identifiable Information (PII) before sending them via email.

Ramapo College complies with the Family Educational Rights and Privacy Act (FERPA), which protects the privacy of student education records. The College’s FERPA policy is overseen by the Office of the Registrar in accordance with regulations set forth by the U.S. Department of Education.

The Responsible Unit shall annually review this policy to ensure compliance with FERPA, New Jersey Identity Theft Prevention Act, and other applicable laws and regulations.

Any breach disclosure will be discussed in conjunction with both Legal Counsel and the College’s cyber insurer.

Violations of this policy may result in disciplinary action, up to and including termination of employment or expulsion from the College.

Exceptions to this policy may apply to students and employees in the European Union (EU) and in the European Economic Area (EEA) under the General Data Protection Regulation (GDPR).

 

Policy

Policy Statement

Ramapo College of New Jersey (hereafter “RCNJ” ) is committed to the responsible, ethical, and transparent use of Artificial Intelligence (AI) technologies in the workplace. While AI tools may be used to enhance efficiency, decision-making, and innovation; their use must align with RCNJ’s core values of integrity, accountability, fairness, and respect for privacy.

RCNJ employees are required to use AI in ways that: comply with all applicable laws, regulations, and organizational policies; avoid harm, bias, or discrimination; protect confidential and personal information; support—not replace—human judgment in sensitive or high-impact decisions. Further, AI use must be documented, monitored, and periodically reviewed to ensure continued alignment with these standards.

This policy articulates and complies with the security control requirements stated in the National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF) and its supporting NIST Special Publication (SP) 800-171, and applicable laws, regulations, and best security practices.

Reason for Policy

To provide clear guidelines for employees regarding the responsible and ethical use of Artificial Intelligence (AI) technologies, including but not limited to generative AI (also known as GenAI) programs such as ChatGPT, within the College.

To Whom does the Policy Apply

This policy applies to all employees, contractors, and third-party vendors who utilize AI tools and technologies in the course of their work with Ramapo College of New Jersey. Additionally, the policy encompasses all systems and information owned, managed, or processed by RCNJ and its authorized employees for non-instructional, business, or support purposes. It also extends to any external or non-RCNJ systems that interconnect with or exchange data with RCNJ-managed systems.

Supplemental Resources

Procedure

I. Definitions

Employee. For the purposes of this Procedure, the term “employee” refers to all individuals who work for Ramapo College in exchange for financial or other compensation, and the term “employee” includes all part-time and full-time staff, faculty, adjuncts, managers, and student workers.

Artificial Intelligence. As defined by IBM, “Artificial intelligence (AI) is technology that enables computers and machines to simulate human learning, comprehension, problem solving, decision making, creativity, and autonomy.”

II. Scope

a. Controls. This policy and procedure are intended to address the requirements of National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF), its supporting NIST Special Publication (SP) 800-171, and the security controls contained therein. Specifically, this policy addresses compliance with the following NIST CSF categories and subcategories relevant to the responsible use and governance of artificial intelligence systems:

Identify (ID):

    • ID.AM-1: Maintain an inventory of all AI tools and systems used within the institution, documenting ownership, purpose, and associated data.
    • ID.RA-1: Conduct risk assessments to evaluate the potential impact of AI systems on privacy, fairness, and security.
    • ID.BE-4: Ensure alignment of AI system usage with institutional objectives and regulatory requirements.

Protect (PR):

    • PR.AT-1: Conduct security and ethical awareness training for personnel managing AI systems.

Respond (RS):

    • RS.RP-1: Develop and implement incident response plans specifically for AI systems, including handling ethical or student conduct violations.

b. Why These Controls Are Relevant.  Identify (ID) helps educate on AI use cases and their potential risks, ensuring a clear understanding of system dependencies and compliance. Protect (PR) ensures the safeguarding of sensitive data and establishes security baselines for AI tools. Respond (RS) outlines how to mitigate and communicate risks associated with AI use, whether ethical or operational.

c. Educational or Instructional Use. This policy and procedure do NOT apply to, preempt, or supersede any academic policies that apply to faculty or students regarding the educational or instructional use of AI.

d. Exceptions to Policy. All exceptions to this policy must be approved by ITS Leadership and documented accordingly. Exceptions may be granted under the following circumstances:

    • Activities governed by academic or research policies;
    • Instances where compliance conflicts with principles of academic freedom; or
    • Emergency or temporary uses of AI systems.

See Section IV.o. for additional information regarding exceptions.

III. Rules

The following rules must be followed when using AI on College systems or networks:

a. IMPORTANT: Do not upload or input any confidential, proprietary, or sensitive College or student information into any GenAI tool! 

    • Examples include passwords and other credentials, Protected Health Information (PHI), data outlined as moderate or high risk in the RCNJ Policy/Procedure 410: Data Protection (PII), personnel material, information from documents marked Confidential, Sensitive, or Proprietary, or any other nonpublic College information that might be of use to malicious entities or harmful to the College if disclosed. Failure to comply with this policy may breach your or the College’s obligations to keep certain information confidential and secure, risks widespread disclosure, and may cause the College’s rights to that information to be challenged.

b. Verify that any response from a GenAI tool that you intend to rely on or use is accurate, appropriate, not biased, not a violation of any other individual or entity’s intellectual property or privacy, and consistent with RCNJ policies and applicable laws.

c. Do not use GenAI tools to make or help you make personnel decisions about applicants or employees, including recruitment, hiring, retention, promotions, transfers, performance monitoring, discipline, demotion, or terminations.

d. Do not upload or input any personal information (names, addresses, likenesses, etc.) about any person into any GenAI tool.

e. Do not represent work generated by a GenAI tool as being your own original work.

f. Do not integrate any GenAI tool with internal College software without first receiving specific written permission from your supervisor and the ITS Department.

g. If you are unsure if a tool is GenAI, seek the counsel of ITS prior to using it.

IV. Guidelines

The responsible use of AI can significantly enhance organizational capabilities and improve efficiency. By adhering to this policy and procedure, employees contribute to a positive and innovative workplace culture while ensuring that our use of AI aligns with the College’s core values and ethical standards. Guidelines for use include:

a. Appropriate Use of AI. GenAI tools can be valuable for enhancing productivity, streamlining processes, and supporting decision-making; however, they are not a substitute for human judgment and creativity. The output from these tools is often prone to inaccuracies, outdated information, or false responses, making careful human verification essential. Employees must critically evaluate AI-generated suggestions or plans using their knowledge of the College’s values, policies, procedures, and strategies, while also collaborating with colleagues to gain different perspectives and reduce the risk of errors. AI tools should be used to supplement, not replace, traditional methods of problem-solving and decision-making, with appropriate validation such as cross-referencing information, performing tests when feasible, or consulting experts. Additionally, employees must treat any information shared with AI tools as if it could go viral on the Internet and be attributed to them or the College, regardless of tool settings or assurances from its creators. By using AI responsibly and maintaining human oversight, we can optimize its benefits while minimizing risks.

b. Data Privacy and Security. Employees must adhere to all data privacy and security protocols when using AI technologies. This includes ensuring that any data input into AI systems complies with our data protection policies and relevant legal regulations. Sensitive or confidential information, including student data, pre-decisional work, negotiations, personal details, or any data classified as moderate- to high-risk as outlined in RCNJ Policy/Procedure 410: Data Protection (PII), must never be shared with AI tools, as these tools learn and generate content based on the input data. Users should ensure that any data input complies with College policies and legal regulations, preserving data security, intellectual property, and confidentiality. If unsure whether specific information is appropriate to use with the AI tool, employees should consult their supervisor, the ITS department, the College’s internal auditor, or the legal department. Non-compliance with data protection policies and legal regulations may result in disciplinary action.

c. Risk Assessments for AI Usage. In the course of using AI tools, employees should always be aware of the inherent risks these technologies pose. These may include potential inaccuracies or misinterpretations in AI-generated content due to lack of context, legal ambiguities concerning content ownership, and possible breaches of data privacy. As such, a critical attitude towards AI outputs is required at all times. To ensure that risks associated with AI usage are effectively managed, it is the responsibility of management to incorporate AI-specific risk assessments into the College’s broader risk management procedures. This includes continually evaluating and updating protocols to identify, assess, and mitigate potential risks, with considerations for changes in AI technology, its application, and the external risk environment. This also necessitates periodic training and awareness sessions for employees to ensure they stay informed about these risks and the steps needed to mitigate them.

d. Use of Third-Party AI Platforms. Employees should exercise caution when using third-party AI platforms due to the potential for security vulnerabilities and data breaches. Before using any third-party AI tool, employees are required to verify the security of the platform. This can be done by checking for appropriate security certifications, reviewing the vendor’s data handling and privacy policies, and consulting with the College’s ITS cybersecurity team if necessary. Moreover, DRAFTdata shared with third-party platforms must comply with the guidelines outlined in the section on Data Privacy and Security. In situations where employees are unsure about the use of a third-party platform, they should seek guidance from their supervisors or the ITS security team. Employees should not integrate any AI tool with software provided by or maintained by the College without first receiving specific written permission from their supervisor and the ITS Department.

e. Use in Communications. AI tools, when used appropriately, can aid in facilitating efficient internal communication within Ramapo College. This includes drafting emails, automating responses, or creating internal announcements. However, while using AI for these purposes, it is crucial that employees adhere strictly to the College’s policies on ethics, harassment, discrimination, and professional conduct. AI-generated communication should be respectful, professional, and considerate, mirroring the high standards of interpersonal communication expected at Ramapo College. Any misuse of AI tools for communication, including any language or behavior that violates College policies, will be treated as a serious violation and may lead to disciplinary action.

f. Transparency and Accountability. Employees should maintain transparency in their use of AI tools. When AI-generated outputs are utilized in decision-making processes, employees should not represent work generated by an AI tool as being their own original work. Rather, employees should include a footnote in their work indicating which AI tool was used and when it was used. Also, employees must be prepared to explain the rationale behind these decisions and the role AI played in them. Accountability for decisions made with the assistance of AI remains with the employee.

g. Training and Support. The organization will provide training and resources to help employees understand how to effectively and responsibly use AI tools. Use case is an important factor in determining which tools are appropriate, and employees are expected to evaluate whether a given tool fits their intended purpose. In addition to internal resources, employees are encouraged to complete relevant courses – such as those available free online – on AI ethics, data privacy, and secure usage. Employees should seek assistance from their supervisors or the ITS department if they have questions or require support regarding AI technologies.

h. Ethical Considerations. Employees must consider the ethical implications of using AI in their work. This includes assessing AI outputs to detect and avoid bias, considering whether AI outputs would have a negative impact on institutional reputation or integrity, ensuring fairness in decision-making, and being mindful of the potential impact on employees, students, stakeholders (i.e., board members, alumni, etc.), and vendors with whom the College has DRAFTcontractual relationships. Any concerns regarding ethical use should be reported to management.

i. AI Tool Vetting and Inventory. ITS maintains a website which has a list of AI tools that have been vetted for use by employees and students. AI tools used by employees and students on the college’s network or on college-provided computing machines must undergo a formal vetting process to ensure they meet established security requirements. If an employee or student has a mission-related reason to use an AI tool that is not listed on the ITS website, then the employee or student should submit a request to ITS which will assess whether the tool aligns with the college’s security requirements. Approval to use an AI tool not listed on the ITS website must be granted by the Chief Information Officer (CIO), and when appropriate, in consultation with the head of the requesting department (See NIST control ID.AM-1.) (Note: if the AI tool requires purchase, then please refer to the Software Request policy for details about the process to follow in order to procure the tool.)

j. Essential Pre-Use Considerations for New AI Tools. Responsibility for vetting AI tools does not reside solely with ITS. As AI technologies continue to evolve and expand, the campus community shares a role in ensuring responsible use. Employees are encouraged to research any AI tool (not on an approved list or encouraged for use by ITS) prior to use with attention to its purpose, data handling practices, and potential risks. The checklist below highlights key considerations to help evaluate whether an AI platform—if not already vetted by the College—meets acceptable ethical standards and safeguards, and guides users on how to responsibly approach its use:

    1. Handling of Inputted Data. Regardless of any encryption or security measures claimed by the tool, I understand that I should avoid submitting sensitive or personally identifiable information. I also understand that I should not share confidential or valuable intellectual property with the tool.
    2. Purpose and Context. I should use the platform appropriately in alignment with relevant organizational or legal requirements. I understand that not all AI tools are suited for every task, therefore, I should evaluate whether the tool aligns with the specific purpose, intended outcome, and organizational context of the task.
    3. Consideration of Others. I understand that if others (e.g., students, colleagues, etc.) are expected to use the platform, then clear communication, informed consent, and alternatives should be made available.
    4. Data Ownership and Use. The platform should clearly explain who owns the submitted content and how it may be stored, reused, or used for AI training.
    5. Privacy and Security. The platform should provide a transparent privacy policy and describe how it protects data (e.g., via its encryption, access control, and retention policies). The platform also provides users with the option to clear personalized memory from conversations with the tool.
    6. Ethical Use and Risk Awareness. The platform makes it easy to understand ethical considerations and risks, and the platform commits to responsible, safe, and fair AI use.

k. Compliance with Regulations. Employees must comply with all applicable laws and regulations governing the use of AI technologies. This includes intellectual property rights, data protection laws, and industry-specific regulations.

l. Non-Personal Use. AI tools provided by Ramapo College are for business use only and should not be used for personal use. This policy is in place to ensure the maintenance of a professional and productive environment, the preservation of institutional resources, and to prevent potential legal and security risks. Personal use of these tools could potentially involve sharing of inappropriate or sensitive content, misuse of time and resources, and potential breach of data privacy regulations.

m. Monitoring. Ramapo College reserves the right to monitor all employee interactions with AI tools for the purpose of ensuring compliance with this policy and procedure.

n. Non-compliance. Non-compliance with this policy and procedure may result in disciplinary action.

o. Exceptions. Any exceptions to this policy and procedure must be documented by RCNJ ITS with the reason for the exception, and mitigations to reduce risk associated with not fully implementing this policy and procedure. Exceptions may include, but are not limited to, legacy systems or applications that do not permit configuration to the extent required by this policy and procedure, and systems that are not under the direct control of RCNJ, for example.

p. Review and Updates. This policy and procedure will be reviewed annually and updated as necessary to reflect changes in technology, legal requirements, and organizational needs. Employees will be notified of any significant changes to the policy.

Note: The typli AI Text Generator (see https://typli.ai/ai-text-generator) was used on 1/27/2025 to generate an initial draft of this policy statement.

Policy

Policy Statement
Ramapo College of New Jersey is committed to conducting research that is without bias and that conforms to the highest scientific and ethical standards.

Reason for Policy
This policy establishes standards that ensure that design, conduct, and reporting of research performed at the College will be free from bias resulting from financial conflicts of interest.

These guidelines are specific to federal research funded by agencies of the United States federal government. This policy promotes and enforces compliance with requirements of 42 CFR 50, Subpart F, Promoting Objectivity in Research (FCOI Regulation), as implemented in the 2011 Final Rule for grants and cooperative agreements.

To Whom Does the Policy Apply
This policy applies to all faculty, staff, students, and any other members of the College who are responsible for the design, conduct, stewardship, and reporting of research.

Supplemental Resources

Contacts
Office of Grants and Sponsored Programs
(201) 684-7374

Procedure

Procedure 649: Financial Conflict of Interest – Sponsored Research
Date Adopted: June 7, 2022
Date Revised:

A. Definition of Terms
For purposes of this policy, the following terms shall have the following meanings:

  • “College” shall mean Ramapo College of New Jersey.
  • “Animal Use Committee” shall mean the body that oversees and ensures the appropriate review of the use of vertebrate animals in teaching, testing, and research.
  • “College General Counsel” shall mean the College’s General Counsel who serves as the chief legal officer as well as the Ethics Liaison Officer.
  • “FCOI” or “Financial conflict of interest” shall mean any instance when an investigator’s significant financial interest could directly and significantly affect the design, conduct, or reporting of the research.
  • “FCOI Committee” shall mean a committee convened by the Grants Director to evaluate financial conflict of interest. The members of the committee will include the Grants Director, the Investigator’s Dean, the Provost, a representative from the Institutional Review Board (if applicable), and a representative from the Animal Care and Use Committee (if applicable). The College General Counsel shall serve in an advisory capacity to the FCOI Committee.
  • “Institutional Responsibilities” shall mean an Investigator’s professional responsibilities on behalf of the College, which may include for example, activities such as research, research consultation, teaching, professional practice, and institutional committee and panel memberships.
  • “Institutional Review Board” (IRB) shall mean the College’s Institutional Review Board that assures the upholding of the highest ethical standards in research involving human subjects.
  • “Investigator” shall mean 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 including collaborators, consultants and sub awardees. For purposes of the regulatory requirements relating to financial interests, the term “Investigator” includes the Investigator’s family including spouse, dependent children and other individuals and relationships that may create, or may be perceived to create a conflict of interest.
  • “Management plan (FCOI)” shall mean a written plan instituted by the College to manage, reduce, or eliminate to the fullest extent possible any financial conflict of interest.
  • “NIH” shall mean the National Institutes of Health.
  • “NSF” shall mean the National Science Foundation.
  • “OGSP” shall mean the College’s Office of Grants and Sponsored Programs.
  • “PHS” shall mean Public Health Service.
  • “HHS” shall mean the United States Department of Health and Human Services, which oversees 11 operating divisions that offer competitive grants, including: the National Institutes of Health; the Health Resources and Services Administration; the Substance Abuse and Mental Health Services Administration, and eight (8) others.
  • “SFI” or “significant financial interest” shall mean anything of monetary value that reasonably appears to be related to an Investigator’s institutional responsibilities. Additional guidance can be found in the NIH FCOI regulation and FAQs.

SFI may include:

    • Salary or other payments for services (e.g., consulting fees, honoraria)
    • Equity interests (e.g. stock, stock options, ownership interests)
    • Intellectual property rights (e.g., patents, copyrights and royalties from such rights)
    • Certain travel related to the sponsored research

SFI does not include:

    • Salary, royalties, or other remuneration from the applicant institution
    • Income from investment vehicles in which the Investigator does not directly control the investment decisions made in these vehicles
    • Income from seminars, lectures, or teaching engagements
    • Income from service on advisory committees or review panels
  • “Sponsored research” shall mean activities funded by an external agency such as one of the divisions of the HHS, or the National Science Foundation.

B. Training
OGSP has established the following process to train investigators on financial conflict of interest.

The OGSP will hold a financial conflict of interest information session with each Investigator before grant approvals are sought from the Dean and Provost. The OGSP will hold the session within two weeks of a grant proposal being submitted for Dean’s approval. Any Investigator recently hired to work on sponsored research will also be required to attend the FCOI information session. For Investigators whose research is funded, the information session will be held every four years.

Investigators will undergo training again when a change has been made to FCOI policy or procedures, or when the Investigator has been found to be noncompliant with an FCOI management plan or College FCOI policy.

The information session will train Investigators on the federal FCOI regulation, inform the Investigator of Ramapo College’s FCOI policy, the Investigator’s responsibility to disclose significant financial interests, and actions that may be taken when noncompliance is found.

The OGSP will indicate that an Investigator has completed the financial conflict of interest information session by checking the box on the grant approval form, which is completed before a proposal is submitted. The checked box indicates that the Investigator(s) and any applicable subawardees and contractors have completed a significant financial interest disclosure form.

C. Disclosure, Review, and Monitoring
During the grant period, existing Investigators or Investigators who are new participants to the research project must complete the significant financial interest disclosure form annually. The SFI disclosure form must also be completed within 30 days of any change in an SFI (e.g., through purchase, marriage, or inheritance), or within 30 days of discovery of an incidence of SFI.

The form will be reviewed by the Investigator’s Dean, the Institutional Review Board (as appropriate), the Institutional Animal Care and Use Committee (as appropriate), and the Director of the Office of Grants and Sponsored Programs (“OGSP Director”), in consultation with the College General Counsel.

If no significant financial interest is disclosed, no further action is required.

If a significant financial interest that is related to PHS-funded research is found to violate this policy, or that biases the design, conduct, or reporting of the sponsored research, the OGSP Director will take the following actions:

  • Immediately inform the Investigator’s Dean, the Provost, and the College General Counsel, and begin gathering further information and supporting documentation from the Investigator and others as applicable. All such documentation and subsequent discussions will be confidential to the extent permitted by applicable law.
  • The OGSP Director, Dean, and Provost, in consultation with the College General Counsel, will review the documentation and within 60 days determine if corrective action is necessary.
  • The OGSP will notify the funding agency within 60 days if corrective action is necessary.
  • Corrective action may include a FCOI management plan that specifies the actions to be taken to manage a financial conflict of interest. Compliance with any corrective actions/management plan will be under the direction of the Investigator’s Dean and the Provost.
  • The Director of Grants will promptly notify the funding agency and submit a mitigation report that includes the impact of the bias on the research project and the plan to eliminate or mitigate the bias.

In the event the College identifies an SFI that was not disclosed or managed in a timely manner, the Director of Grants will complete a retrospective review (see section F.iii.).

D. Reporting to NIH
The OGSP Director will submit significant financial interest disclosure forms to the NIH:

  • Prior to the expenditure of funds.
  • Annually during the grant period.
  • Within 60 days of the addition of a new Investigator.
  • In the case of the discovery of a new financial conflict of interest, within 60 days of the creation of a FCOI management plan; when corrective action is implemented; and annually until the matter is resolved, or the grant period ends.
  • Following a retrospective review to update a previously submitted report.

The College will notify the funding agency and take corrective action if an Investigator fails to comply with this policy or a FCOI management plan appears to have biased the design, conduct, or reporting of the research.

E. Maintenance of Records
All records of FCOI disclosure and the College’s review, response, and action related to the disclosure will be maintained in the OGSP. These records will be maintained for three (3) years from the date of submission of the final expenditures report, or where applicable, from other dates specified in 45 C.F.R. 75.361 (see FAQ A.11) for different situations.

F. Enforcement Mechanisms, Remedies, and Noncompliance

i. Corrective Actions
If a financial conflict of interest is found, actions will be taken to manage, reduce, or eliminate the conflict. These corrective actions will be determined by the FCOI Committee. Corrective actions may include:

  • Public disclosure of the significant financial interest (e.g. when presenting or publishing research, to staff working on the project, to the College’s IRB or Animal Use Committee. etc.)
  • Removal of an investigator from the portion of the research affected by the SFI
  • Disclosure of the significant financial interest to research participants
  • Appointment of an independent monitor capable of protecting the research from bias resulting from the FCOI
  • Modification of the research plan
  • Change of personnel or personnel responsibilities
  • Reduction or elimination of the financial interest
  • Severance of relationships that create financial conflicts
  • Other actions as appropriate

If HHS determines that a clinical research project evaluating the safety or effectiveness of a drug, medical device, or treatment is managed by an Investigator in violation of this policy or related regulations, the Investigator will be required to 1) disclose the financial conflict of interest in each public presentation of the results of the research, and 2) request an addendum to previously published presentations.

The OGSP Director will notify the Investigator of the committee’s decision and of any corrective action, including a FCOI Management Plan.

ii. Appeal Process
If the Investigator does not agree with the committee’s corrective actions, the Investigator can appeal in writing to the OGSP Director within ten (10) days after receipt of notification. The appeal must describe why such conditions and restrictions are inappropriate. The OGSP Director will consult with the President to determine whether a modification is necessary, and their decision will be final.

iii. Retrospective Reviews
If FCOI is not identified or managed in a timely manner, the Director of Grants will convene the FCOI Committee and complete a retrospective review. Retrospective reviews will be completed within 120 days of the determination of non-compliance. The documentation for the retrospective review shall include:

  • The funding agency project number and project title,
  • Project PD/PI contact information,
  • Name of the Investigator with the FCOI,
  • Name of the entity with which the Investigator has an FCOI,
  • Reason(s) for the retrospective review,
  • Methodology used for the retrospective review,
  • Findings of the review, and
  • Conclusions of the review.

If bias is found, the Director of Grants will notify the funding agency and promptly submit a mitigation report. This report will include information from the retrospective review and FCOI management plan. The report will be submitted annually.

iv. FCOI Management Plan
The FCOI Committee may conduct factual inquiries, consultations, and recommendations as appropriate in order to formulate a financial conflict of interest management plan. The terms of the plan shall be consistent with all applicable legal and regulatory requirements, and the requirements of this policy.

The Management Plan will include at a minimum:

  • The role and principal duties of the conflicted Investigator in the research project;
  • Conditions of the Management Plan, which may include one or more of the actions described under section F.i. Corrective Actions above;
  • How the Management Plan is designed to safeguard objectivity in the research project;
  • Confirmation of the Investigator’s agreement to the Management Plan, and
  • How the Management Plan will be monitored to insure Investigator compliance.

G. Subrecipients
Before a research proposal is submitted, or a subaward agreement is issued, the College shall secure written assurance that the proposed subrecipient agrees to comply with all applicable PHS, NIH, and/or NSF policies on financial conflict of interest. If the proposed subrecipient has a publicly posted FCOI policy in compliance with PHS, NIH, and/or NSF policy, the subrecipient will provide a certification to the College that such FCOI policy complies with all applicable regulations. To the extent that the subrecipient does not have a compliant FCOI policy, the subrecipient will be required to comply with the College’s FCOI policy.

Subrecipients will be required to report FCOI to the College’s Director of Grants, prior to the expenditure of any funds, and within 45 days of discovering any FCOI. FCOI reported by a subrecipient Investigator will be reported to the PHS and/or NSF by the College on the subrecipient’s behalf.

H. Public Accessibility
Information concerning any FCOI related to an externally-funded research project that has been disclosed to the OGSP will be made publicly accessible. The OGSP web site will list the contact information where the public may request this information, and will respond to any request within five (5) business days. The response will include:

  • The Investigator’s name, title, and role in the research project,
  • The name of the entity giving rise to the SFI and FCOI,
  • The nature of the FCOI, and
  • The approximate dollar value of the FCOI.

Policy

Policy Statement

This policy advances standards for the awarding and administration of graduate assistantships at Ramapo College of New Jersey (“Ramapo College” or “College”). It is intended that this policy adhere to other relevant policies of the College, some of which are referenced below.

Reason for Policy

To promulgate standards for the awarding and administration of graduate assistantships at Ramapo College of New Jersey.

To Whom Does the Policy Apply

All Hiring Managers

Related Resources

Procedure 481: Graduate Assistants

Appendix 481A: Graduate Assistant Template Contract

Contacts

People Operations and Employee Resources Department

(201) 684-7500

Procedure

Adopted: June 30, 2021

Revised: January 4, 2023

 I. Purpose

The purpose of this procedure is to promulgate standards for the awarding and administration of graduate assistantships at Ramapo College of New Jersey (“Ramapo College” or “College”).

Graduate assistantships are positions where Ramapo Graduate students work a set number of hours in exchange for tuition reimbursement. These positions are intended to compliment the students’ academic growth.

Positions not fitting these requirements are not considered for Graduate Assistantships.  Please contact the Cahill Center for hourly student aides (for Ramapo students) or Human Resources for part-time positions (non-Ramapo Students).

II. Categories of Employment Status

A. Graduate Assistant (Academic)

A graduate student whose primary focus is assisting in an Academic program and performing such functions as research and/or teaching. An academic graduate assistant works a maximum of 20 hours per week, is paid a stipend consistent with College guidelines, and is eligible for tuition remission.

B. Graduate Assistant (Administrative)

A graduate student whose primary focus is assisting with administrative support functions within the needs of a department, including student facing units. An administrative graduate assistant works a maximum of 20 hours per week, is paid a stipend consistent with College guidelines, and is eligible for tuition remission.

C. Graduate Assistant (Residence Life)

A graduate student who assists with the administrative support functions for the Office of Residence Life. The Graduate Residence Assistant works maximum of 20 hours per week plus On-Call Administrator rotation, is paid a stipend consistent with College guidelines, and is eligible for tuition remission.  As part of the On-Call Administrator rotation, Graduate Assistant receives campus housing and food allowance. These positions are usually awarded to students who have had previous residence life employment experience.

III. Requirements for Graduate Assistantships

The following Academic requirements apply to all graduate assistantships at the College:

  • Graduate Assistant must be matriculated and enrolled in a graduate program at Ramapo College, and make satisfactory academic progress towards degree completion.
  • If after advertising the position, no Ramapo College student is identified for the graduate assistantship, a student from another university/college may be selected.
  • Enrollment in a minimum of six (6) credit hours per semester or two (2) courses per semester, whichever is greater, during the academic year (fall and spring semesters).
  • Graduate Assistant shall maintain a minimum grade point average of 3.0 or higher and be in good academic standing as defined by the College or other college/university in which the Graduate Assistant is enrolled.

No person will be permitted to apply and keep a Graduate Assistantship at the College if these criteria are not met.

IV. Compensation:

  • Academic and Administrative Graduate Assistants
    • Tuition: Tuition remission of up to $4,000 per semester or up to $8,000 per academic year (spring and fall semesters), towards their Ramapo College graduate student tuition or graduate student tuition at another university/college; and
    • Stipend: $10,000.00 for an academic year (10 months – September 1st to June 30th).
  • Residence Life Graduate Assistants
    • Tuition: Tuition remission of up to $4,000 per semester or up to $8,000.00 per academic year (spring and fall semesters), towards their Ramapo College graduate student tuition or graduate student tuition at another university/college; and,
    • Stipend: $8,000 for an academic year (10 months – September 1st to June 30th); and
    • Room & Board: Paid housing and food allowance as part of the GAs On-Call Administrator duties.
  • Taxable Income on Tuition Remission
    • Administrative and Residence Life Graduate Assistant tuition remission is taxable under the Internal Revenue Service (IRS) Code §127. $5,250 per calendar year in tuition remission associated with Graduate Assistants are excluded from taxable income. If the annual (January to December) amount of remission exceeds $5,250, the excess is deemed taxable income under IRS Code and is taxed accordingly.
    • Academic Graduate Assistant tuition remission is exempt under IRS Code §117.

V. Proof of Academic Progress

  • Graduate Assistants must achieve active and satisfactory academic progress towards the completion of a graduate degree in an approved graduate (Master’s) program.
  • Proof of class enrollment and good academic standing must be provided each semester to the Graduate Assistant’s Supervisors must then forward such proof to Human Resources for final review and recordkeeping.
  • Students who do not maintain the minimum grade point average and/or provide proof of academic progress may be terminated from their Graduate Assistant position.

VI. Payment Terms

  • Tuition remission is eligible only for graduate level courses as part of the Ramapo College student graduate program requirements.
  • Tuition for non-Ramapo College students will be paid at the beginning of each semester once a bill has been provided to the College with proper supporting documentation. An Accounts Payable (A/P) voucher must be prepared by the Graduate Assistant’s supervisor along with a copy of the tuition invoice and be provided to Accounts Payable for direct payment to the institution. If payment was made by the Graduate Assistant directly to the institution a copy of the paid tuition invoice must be provided along with the A/P voucher for reimbursement to the Graduate Assistant.
  • Stipends are paid in bi-weekly installments for the term of the contract. Applicable federal and state taxes will be withheld.
  • The stipend terminates effective the date of resignation. In addition, any housing privileges will be revoked as of the date of resignation.
  • While tuition benefits are paid on behalf of the Graduate Assistant up front, if the Graduate Assistant’s contract is not completed as noted, the Graduate Assistant will owe a pro-rated portion of the tuition benefit to the College.
  • If a Graduate Assistant withdraws from a course and this generates a refund, such refund must be paid back to the College.
  • Tuition remission is to be posted to the student account as a financial aid award and will reduce the balance due on the account. The Graduate Assistant’s supervisor must provide information to both the Financial Aid Office and Office of Student including the student name, ID number, amount of the award, semester of the award, and the FOAP requested to be charged. Supervisors must submit this information upon receiving the signed contract to ensure timely posting to the student account. Any overpayment on the account resulting from the tuition remission award will reduce the award accordingly.
  • Once the financial aid award is disbursed to the student account, if the total amount awarded for the calendar year (January to December) exceeds $5,250, the Payroll Office is notified and the amount above $5,250 will be included in your taxable income. The tax withholding will begin on the next pay period.

VII. Available Benefits/Limitation on Benefits

  • Graduate Assistants are not eligible to travel and/or receive travel reimbursements, except when the Graduate Assistant’s job description requires the Graduate Assistant to accompany undergraduate students as part of a College program.
  • Graduate Assistants are entitled to Workers’ Compensation benefits in the event of a workplace injury.
  • All students follow the medical insurance requirements as set forth by the College.
  • Graduate Assistants are not eligible for pension benefits.
  • There is no accrual of leave time or pay for time not worked.
  • There are no entitlements to benefits or pay for hours not worked with exception of paid sick entitlements.

VIII. Employment Requirements:

  • All graduate assistant appointments terminate at the end of the appointment period (September 1st – June 30th) and there is no commitment to reappoint the same student at a later time.
  • Units requiring additional weeks of service beyond the 10 month graduate assistant contract, must contact Human Resources. Students will be paid hourly, up to 20 hours per week for any work outside of the 10 month contract.  No student will be allowed to work during the 2 additional months at hourly pay without a separate contract.
  • Since the Graduate Assistant is in a part-time, temporary position, the Graduate Assistant is an at-will employee who can be terminated by the College at any time without notice or severance pay.
  • Ongoing employment is contingent upon satisfactory performance as well as availability of funding and other policy considerations.
  • Graduate Assistants may need to be absent for personal reasons or illness; while every effort will be made to accommodate occasional absences, such absences must not interfere with or cause neglect of duties, and must not exceed reasonable limits.
  • Graduate Assistants who are not able to fulfill the requirements of their assistantship due to illness or other reason will be terminated, and a pro-rated portion of the stipend will be paid up to the date of termination. A pro-rated bill for the tuition benefit will be issued by the College and the Graduate Assistant shall pay such amount to the College.
  • Graduate Assistants who must resign during or prior to their period of appointment must provide written notice to the College. Every effort shall be made for the Graduate Assistant to provide adequate notice for a replacement to be hired.  If the resignation takes place at the end of a semester, the tuition benefit for that semester remains in place; if the resignation takes effect during a semester, a pro-rated bill will be issued to the Graduate Assistant who shall pay the amount owed to the College.  The stipend terminates effective the date of resignation.  In addition, any housing privileges will be revoked as of the date of resignation.

IX. Contracts

  • Graduate Assistants must be provided with contracts detailing the terms and conditions of the graduate assistantship.
  • A template contract is attached hereto as Appendix A. Any changes to the template contract must be approved by the College’s Office of General Counsel.

X. Compliance with Applicable College Policies

  • All Graduate Assistants are governed by College Policies as applicable, including but not limited to policies outlined within the Student Code of Conduct and Student Handbook or/and the Employee Handbook.

XI. Hiring Process

  • Human Resources and Vice President/Provost approval of all Graduate Assistant positions is required.
  • Open positions shall have a job description and be advertised in Hiretouch.
  • Positions should be communicated to the Associate Director of Graduate Admissions.
  • Signed Graduate Assistantship contracts must be received by the College prior to work commencement.

XII.  General Procedures for Processing Graduate Assistantships

  • All open graduate assistantship positions for the upcoming academic year shall be posted on the College’s website (Hiretouch).
  • Students shall submit a Graduate Assistantship Application for the academic year or semester in response to a posted position. Applicants must apply through the College’s online job portal.
  • Graduate assistantships are normally awarded for a full academic year, but may be awarded for a semester. Individual units or departments are responsible for the selection of a Graduate Assistant.
  • An offer of a graduate assistantship should be made to the candidate along with a contract and job description for the position.
  • Required documentation for Graduate Assistants includes: Social Security Card; student ID or photo driver’s license; completed W-4 and I-9 forms; written evidence of health insurance coverage; and, other documents/forms as may be required by Human Resources.
  • Reappointments must follow the policy of initial hiring (application, approval and contract signing). The student shall also satisfy all of the criteria for a Graduate Assistant.

Policy

Policy

The College will facilitate the resolution of complaints arising from employment with the College.

Reason for Policy

To provide due process for administrative, professional, supervisory and confidential staff not included in a Collective Bargaining Unit.

To Whom Does the Policy Apply

Administrative, professional, supervisory and confidential staff not included in a Collective Bargaining Unit

Related Documents

  • Procedure

Contacts

Office of Human Resources
(201) 684-7506

Procedure

Employee Complaint Filing Procedures  

The College facilitates the resolution of complaints arising from employment at the College.  Employees (see eligibility below) can use the following procedure to file a complaint about an alleged violation of College policies, the misconduct of a person or persons affiliated with the College (student, employee, contractor of the College, or visitor), administrative regulations or statutes with respect to conditions of employment, or for appealing disciplinary actions.

This policy and procedure shall constitute the full and exclusive right and remedy for any and all such claims by eligible employees at the College.  This procedure may not be used to grieve the reduction or expiration of grants, or the expiration of individually negotiated contracts.

Eligibility

This procedure applies to full-time, permanent managerial or confidential employees and persons appointed under grants and/or contracts if those grants and/or contracts make no alternative provision concerning employment “due process”.  The procedure applies to employees covered by a collective bargaining agreement (American Federation of Teachers (AFT), Communications Workers of America (CWA), International Federation of Professional, Technical Engineers (IFPTE), probationary or temporary employees, in so far as the contract does not take precedence over violations of laws, codes, and policies promulgated at the Federal and State levels.  Student employees are covered by the policy “Student Complaints of a Non-Academic Nature”.

Resolution Processes

Before filing complaints, affected employees should carefully evaluate the nature of their concerns which may fall under separate College policies and procedures and may be adjudicated by different offices.

These concerns may include alleged violations of the:

  1. Laws of the State of New Jersey (i.e. criminal, traffic, domestic violence laws). Employees should file these concerns with the Public Safety Department, which may refer them to the Mahwah Police Department.
  1. State of New Jersey Uniform Ethics Code. Employees should file these concerns in the Office of Employee Relations or the Office of the General Counsel.
  1. State of New Jersey Policy Prohibiting Discrimination in the Workplace. Employees should file these concerns with the Office of Affirmative Action and Workplace Compliance.
  1. Violence in the Workplace. Employees should file these concerns with the People Operations and Employee Resources Department or with the Public Safety Department.
  1. College Policies and Procedures. Employees should file these concerns with the People Operations and Employee Resources Department, the Office of Employee Relations, or the Office of the Ombudsperson.
  1. Misconduct of a person or persons affiliated with the College (student, employee, contractor of the College, or visitor). Employees are encouraged, whenever appropriate and feasible, to resolve those concerns directly with the individuals involved.  If that is not possible, employees should file their complaint with the People Operations and Employee Resources Department (if the complaint involves misconduct of non-AFT professional staff or faculty), with the Office of Employee Relations (if the complaint involves misconduct by AFT professional staff or faculty), Office of the Ombudsperson, or the Public Safety Department (which may forward the complaint to the appropriate department).
  1. Administrative regulations or statutes with respect to conditions of employment. Managerial or confidential employees and persons appointed under grants should file their concerns with the People Operations and Employee Resources Department.  Employees covered by a collective bargaining agreement should file their concerns with their respective union representative.
  1. Concerns about the way offices conduct business that cannot be resolved directly with the individuals involved. Employees should file these complaints with the managers of the relevant units. If employees have cause for not directing their complaints to those managers, they may file their complaints with the People Operations and Employee Resources Department or the Office of the Ombudsperson.
  1. Misuse of College funds or other resources/Whistleblower Policy). Employees should file their concerns with the Office of the Internal Auditor.
  1. Outcomes of disability-related accommodation. Employees should file their concerns with the Office of the Title IX/ADA Coordinator.
  1. Outcomes of Disciplinary actions. Managerial or confidential employees and persons appointed under grants should file their concerns with the Office of Human Resources.  Employees covered by a bargaining agreement should file their concerns with their respective union representative.

Once employees contact these offices, they may be guided to follow separate procedures for filing complaints of an alleged violation cited above.

Tabular View of Alleged Concerns, Complaints, Violations and Responsible Offices

       Alleged Concerns/          Complaints/Violations

                File Complaint with. . .
Laws of the State of New Jersey Public Safety Department
Ethical Misconduct of Employees State of New Jersey Uniform Ethics Code Office of Employee Relations or the Office of the General Counsel
Workplace Violence People Operations and Employee Resources Department or Public Safety Department

 
New Jersey State Policy Prohibiting Discrimination in the Workplace Office of the Director of Affirmative Action and Workplace Compliance
College Policies and Procedures People Operations and Employee Resources Department, the Office of Employee Relations, Office of the Ombudsperson
Misconduct of persons affiliated with the College (student, employee, contractor  of the College, or visitor) Whenever appropriate and feasible, resolve concerns directly with the individual(s) involved.  If not appropriate and feasible, file complaint with the relevant manager, or People Operations and Employee Resources Department (non- AFT faculty/ professional staff), Office of Employee Relations (AFT faculty/professional staff), Office of the Ombudsperson, or  Public Safety Department
Administrative regulations or statutes with respect to conditions of employment People Operations and Employee Resources Department, Union Representative
Concerns about the way offices conduct business Whenever appropriate and feasible, resolve concerns directly with the individual(s) involved.  If not appropriate and feasible, file complaint with the relevant manager, People Operations and Employee Resources Department, or Office of the Ombudsperson
Misuse of College funds or other College resources/Whistleblower Policy) Office of the Internal Auditor
Outcomes of disability-related accommodation requests Office of the Title IX/ADA Coordinator
Outcomes of Disciplinary actions People Operations and Employee Resources Department, Office of Employee Relations, Union Representative
Ramapo College Logo

505 Ramapo Valley Road
Mahwah, NJ 07430

p: 201-684-7500
e: information@ramapo.edu

Copyright ©2026 Ramapo College Of New Jersey | Statements And Policies | Accessibility | Contact Webmaster.