All staff employees. Faculty are excluded from this Policy.
The purpose of this Policy is to provide expectations and guidelines which define the University’s position on Outside Employment by staff employees.
Conflict of Interest: examples of a conflict of interest that may occur with Outside Employment include, but are not limited to, the following:
Institutional Data: is any information, including Directory Information, Personally Identifiable Information, and Student and Employee Financial Information that can be linked to any individual, including but not limited to, students, employees, or contractors. Institutional Data and all applications storing and transmitting such data, regardless of the media on which they reside, are valuable assets, which the University has an obligation to manage, secure, and protect.
Directory Information: means information contained in an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed. The University designates the following categories of student information as public, or directory information: a student’s name, address, telephone listing, date and place of birth, major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, degrees and awards received, the most recent educational agency or institution attended, electronic mail addresses and photographs. It also states that directory information does not include a student’s social security number or student identification number. “Directory information” however does include, student identification numbers or user identification when such identifiers cannot be used to gain access to education records unless used in conjunction with other factors authenticating the user’s identity.
Employee Financial Information:that information the University has obtained from an employee in the process of offering a benefit or service. Offering a benefit or service includes all University sponsored benefit plans and University financial services such as flexible spending accounts, and personal payroll services. Examples of employee financial information include bank and credit card account numbers, income and credit histories and social security numbers, in both paper and electronic format.
Personally Identifiable Information (“PII”): PII is any information about an individual maintained by an agency, including (1) any information that can be used to distinguish or trace an individual‘s identity that is not been designated as directory information, such as social security number, place of birth, mother’s maiden name, or biometric records; and (2) any other information that is linked or linkable to an individual, such as medical, educational, financial, and employment information relating to an identified or identifiable person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity.
Student Financial Information: that information the University has obtained from a student in the process of offering a financial product or service, or such information provided to the university by another financial institution. Offering a financial product or service includes offering student loans to students, receiving income tax information from a student's parent when offering a financial aid package, and other miscellaneous financial services as defined in 12 CFR § 225.28. Examples of student financial information include bank and credit card account numbers, income and credit histories and social security numbers, in both paper and electronic format.
Outside Employment: any activity unrelated to Thomas More University for which economic benefit is received, including but not limited to, cash payments, non-cash compensation (share of profits, share of stock, equity participation, or other) that may be agreed to by an employee of the University and another entity.
Full-time staff employees (hereinafter “employees” or “employee”) may hold a position with another organization as long as the employee immediately discloses such employment to the employee’s immediate supervisor in writing and only if the Outside Employment does not:
If, in the sole discretion of the employee’s immediate supervisor, it is determined that an employee’s Outside Employment interferes with his/her performance or their ability to meet the requirements of the position or constitutes a Conflict of Interest, the employee may be asked to terminate the Outside Employment if they wish to remain with the University.
During an employee’s work hours at the University, the employee is expected to devote their entire time and the best of their ability to the performance of their duties. As a result, performance of Outside Employment work during an employee’s work hours will be reason for disciplinary action up to and including termination.
Conflict of Interest Policy
Faculty Outside Employment Policy
Staff Corrective Action and Discharge Policy
Staff are required to immediately disclose to their immediate supervisor any Outside Employment. Any potential Conflict of Interest that is created by the Outside Employment must also be submitted to the appropriate persons as set forth in the University’s Conflict of Interest Policy.
All written request and approvals for Outside Employment will be filed in the employee’s personnel file. Outside Employment approvals must be received annually.
This is a new policy, replacing language in the Staff Manual (May 2014).
There are no appendices to this Policy.
Laura Custer, Director of Human Resources
Dr. Kathleen Jagger, Acting President