OIAH Privacy Policies

This policy covers all persons working for, volunteering for or doing business with OIAH both during and after: employment; volunteering; and/or when conducting business with OIAH. This policy prohibits confidential information as defined by Federal law or regulation (such as Health Insurance Portability & Accountability Act and Family Education Rights and Privacy Act), State of Ohio law or regulation (such as Board of Regents) and OIAH policy from being accessed, disclosed or released in any format to or by any person/business that does not have a need to know without the proper consent of the individual/student involved and/or OIAH. In addition, this policy applies to certain information considered confidential by OIAH but subject to the State of Ohio or other Accrediting or Regulating agency access, and that should not be released before obtaining specific authorizations from the appropriate level of OIAH management. Formal requests for confidential information should be sent to the Office of the School Director.

Conduct of Personnel:
All individuals are expected to be professional and maintain confidentiality at all times, whether dealing with actual records, projects, or conversations, and abide by the obligations of contractual confidentiality agreements. Situations in violation of this policy include, but are not limited to:

• a) “Loose” talk regarding business information about any student or fellow employee.
• b) Allowing unauthorized access on company computers to confidential student information, financial data, faculty data, or employee personal information.
• c) Sharing of information acquired by persons in the course of their work to others who don’t have a need to have the information; accessing information that the individual doesn’t have the authority to access in the course of their work, or doesn’t have a need to know to carry out their job duties.
• d) Sharing of information relative to confidential Human Resources matters.
• f) Breach of confidentiality obligations regarding the disclosure of confidential information that is subject to a duly signed confidentiality agreement.
• g) Discarding confidential documents in non-secured trash. (Secured shredder bins must be used).

Examples of Types of Information to be Protected:
1. Student Information: Student information must not be accessed, removed, discussed with or disclosed to unauthorized persons, either within or outside of the institution, without the proper consent of the student. All individuals having access to confidential information are bound by strict ethical and legal restrictions on the release of data. No individual therefore may disclose to a third party, including his/her own family, information learned from student records, student accounts, management information systems, or any other confidential sources during the course of his/her work. No individual may access confidential information that they do not have a need to know to carry out their job duties. Employees may not access, release or discuss the information of other employees without proper consent, unless the employee must do so to carry out specific assigned job functions. Employees may not access their own billing or academic information, if also a student.

2. OIAH Information: OIAH information that must be protected includes but is not limited to:

• Confidential commercial or financial information
• Information that is proprietary, e.g., information that allows OIAH to be more competitive in the marketplace. For example: an innovative approach that is described in a grant proposal or other document.
• Ongoing negotiations (labor contracts, leases, purchases)
• Pending litigation and/or investigations This information may not be accessed, removed, altered or disclosed unless OIAH administration has given proper authorization.

3. Individual Matters: This includes personnel, medical, student and other similar files where unauthorized access or release, falsification or destruction of confidential individual records is strictly prohibited.

Other Considerations:

• Disposal of Confidential Documents: Confidential documents must be disposed of utilizing the designated locked containers for shredding.
• Reporting Breach of Confidentiality: Persons must report violations of this policy. Options include reporting to a supervisor or OIAH School Director.
• Disciplinary Action for Non-compliance: Violation of this policy is cause for disciplinary action up to and including dismissal.

Copyright Infringement:
It is the policy of The Ohio Institute of Allied Health, Inc. to follow the United States Copyright Law of 1976, as amended, (Title 17, United States Code, hereinafter, the Copyright Act). Accordingly, all faculty, staff and students of The Ohio Institute of Allied Health should follow these policy guidelines:

Only copyrighted materials are subject to the restrictions in this Policy Statement. Un-copyrighted materials may be copied freely and without restriction. Because a copyright notice is not required for copyright protection of works published on or after March 1, 1989, most works (except those authored by the United States Government) should be presumed to be copyright protected, unless further information from the copyright holder or express notice reveals that the copyright holder intends the work to be in the public domain. Works published prior to March 1, 1989, generally require a copyright notice to be protected.

Copyrighted software may be copied without the copyright owner’s permission only in accordance with the Copyright Act. Section 117 of the Act permits making an archival back-up copy. Most software, however, is licensed to the user and the terms of the license agreement may give the user permission to make copies of the software in excess of the archival copy permitted by the Copyright Act. Each software license agreement is unique. As a result, the user’s rights to copy licensed software beyond that permitted under the Copyright Act may only be determined by reading the user’s license agreement. Any copying or reproduction of copyrighted software on System or component institution computing equipment must be in accordance with the Copyright Act and the pertinent software license agreement. Further, faculty, staff and students may not use unauthorized copies of software on System or component institution owned computers or networks or computers housed in System or component institution facilities.

Copyrighted materials may be copied or otherwise used without the copyright owner’s permission where such copying constitutes fair use under the Copyright Act. In order to copy or otherwise use materials, including software, where (a) the materials are copyrighted, (b) use exceeds what is permitted by license permission should be obtained from the copyright owner.

If permitted by State law and procedures, The Ohio Institute of Allied Health will defend any faculty or staff member against a civil action alleging copyright infringement:

• where the use is in accordance with the provisions of a valid software license agreement
• where the permission of the copyright owner has been obtained, or
• where the Office of General Counsel has assisted in determining that the use was permissible.

Otherwise, the faculty or staff member will be personally responsible for the defense of a civil action for copyright infringement.

Computer Usage:
The use of any Ohio Institute of Allied Health computer which provides access to the Internet is a privilege which may be revoked by instructors, staff, or administrators at any time for abusive or inappropriate conduct. Such conduct would include, but is not limited to, the placing of unlawful information on or through the computer, system, accessing another person’s files or e-mail, and the use of obscene, abusive, or otherwise objectionable language or images in either public or private files or messages.

Because of the potentially large number of individuals who might need to use the computers for Internet as well as personal productivity, student access may be limited to a specified time, as provided by the instructor(s) and/or administration.

Ohio Institute of Allied Health reserves the right to inspect any material stored in files to which users have access and will edit or remove any material which the Ohio Institute of Allied Health staff, in its sole discretion, believes may be objectionable. Users of the computers/Internet will not use their account to obtain, view, download, or otherwise gain access to potentially objectionable materials. This includes text materials, video images, or sound files that may be considered objectionable.

The Ohio Institute of Allied Health’s Internet access is provided primarily for educational purposes under the direction of Ohio Institute of Allied Health staff. Non-educational use may be limited at any time by Ohio Institute of Allied Health staff.

Information services and features contained on the Ohio Institute of Allied Health network are intended for the private use of its patrons. Any commercial or other unauthorized use of those materials, in any form, is expressly forbidden.

Ohio Institute of Allied Health does not warrant that the functions of the system will meet any specific requirements you may have, or that it will be error-free or interrupted; nor shall it be liable for any direct or indirect, incidental, or consequential damages (including lost data, information, or profits) sustained or incurred in connection with the use, operation, or inability to use the system.

Rules and regulations of system usage will be added and posted from time to time by the faculty/administrators of Ohio Institute of Allied Health and/or the network. Users of computers/Internet are subject to these rules and regulations.

The Ohio Institute of Allied Health’s computers/network is intended for the exclusive use of its registered users. As a user, you are responsible for the use of your password and account. Any problems which arise from the use of a user’s account are the responsibility of the account holder. Any misuse will result in suspension of the account privileges.

Deletion, examination, copying, or modification of files and/or data belonging to other users without their prior consent is prohibited.

Commercial software is placed on the computer for the use and convenience of students and staff. Any unlawful use such as the copying of copyrighted material without the express written permission of the owner or the proper license is prohibited.

Any unauthorized, deliberate action which damages or disrupts a computing system (including the willful introduction of computer viruses or other disruptive/destructive programs), alters its normal performance, or causes it to malfunction is prohibited. Intentional attempts to crash network systems or programs are punishable disciplinary offenses.

File Sharing:
All members of the Ohio Institute of Allied Health community are not permitted to illegally share copyrighted material over the company network, including, through the use of e-mail, web pages, and peer-to-peer file sharing software. This applies to OIAH owned computers as well as personally owned computers if they are accessing the company network. Please be sure that you have rights for any material you are making available or sharing on the company network. The unauthorized distribution of copyrighted material, including unauthorized peer-to-peer file sharing, may subject you to disciplinary action as well as civil and criminal liabilities.

Access to the Internet is a wonderful opportunity to interact with the world at large. The opportunity brings with it a number of responsibilities. In order to use the internet services available at the Ohio Institute of Allied Health, you must read the following information and sign the computer/internet agreement that follows.

OIAH strives to provide accurate, honest and clear information in print, online, broadcast media or oral presentations. The college will make every effort to avoid misrepresentation to students and others in communications made in writing, visually, orally, or through other means. Training of employees to avoid any form of misrepresentation as they disseminate communications is a key component of this procedure.

This OIAH policy strives to comply with the U.S. Department Regulatory Citation: 34 CFR § 668.71 through 668.75, regarding the Prohibition of Misrepresentation to students and others.

The current regulations define “misleading statement,” “misrepresentation” and “substantial misrepresentation” as:

• Misleading statement is defined as including any statement that has the likelihood or tendency to deceive or confuse. A statement is any communication made in writing, visually, orally, or through other means.
• Misrepresentation is defined as “any false, erroneous or misleading statement made by an institution, one of its representatives, or any ineligible institution, organization, or person with whom the eligible institution has an agreement to provide educational programs, or to provide marketing, advertising, recruiting, or admissions services, makes directly or indirectly to a student, prospective student, family of either, accrediting agency, state agency, any member of the public, or US Department of Education.” This includes “dissemination of a student endorsement or testimonial made under duress or because the school required the student to provide the endorsement to participate in a program.”
• Substantial Misrepresentation is defined as “any misrepresentation on which the person to whom it was made could reasonably be expected to rely, or has reasonably relied, to that person’s detriment.”
• The revised definition of misrepresentation, misleading statement, and substantial misrepresentation applies to not just written statements, but to “any communication made in writing, visually, orally, or through other means.”

The current regulations provide numerous examples of topics that cannot be misrepresented within each of the four areas covered by statute 20 USC § 1094(c)(3). Those four areas include:

• The nature of the institution’s educational programs.
• The institution’s financial charges.
• The employability of the institution’s graduates.
• Relationship with the Department of Education. A Title IV eligible school may not describe its participation in a way that suggests approval or endorsement by the Department of Education of the quality of its educational programs.

OIAH strives to provide accurate and timely information for faculty and staff at key junctures during the academic year, to conduct training sessions on general school information which is open to all faculty and staff as needed.

In addition, Admissions and Financial Aid periodically provide training opportunities on more focused subject matters to provide clarity on new policy, procedures and regulations.

This policy applies to both oral and written statements from admissions, staff, faculty, and student ambassadors who may represent the college with presentations in high schools and public events.

Maintenance of Records: Records shall be maintained as follows:

• • The School Director maintains electronic copies of all documents submitted for proofing.
  • Electronic and hard copies of every publication created by OIAH are available through the School Director.
  • The Director of Admissions is responsible for the training of personnel regarding misrepresentation of admissions requirements and other college information.
  • The Director of Financial Aid is responsible for the training of personnel regarding misrepresentation of college financial aid information.

Disciplinary Action
Any employee’s action of misrepresentation may result in suspension or depending on severity, termination. All incidents of misrepresentation activity will be and maintained in the employee’s personnel file.