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Confidential Information Policy for Employees

It is each employee's responsibility to become familiar with the provisions included in this policy.

The following policy governs the disclosure of confidential information held in any manner by employees of Western Michigan University (the "University"). The purpose of this policy is to protect and safeguard individual and University information used throughout the University.

For purposes of this policy, "confidential information" includes, but is not limited to:

  • student educational information and discipline records;
  • non-public personal information, concerning employees and students including, but not limited to, Western Identification Numbers, information system user IDs and passwords, social security numbers, internal communications, banking or financial information, medical and health information, disability status or special needs, insurance information, and personal benefits information,
  • University-related information which has not been publicly published or released with University authorization, including but not limited to budget, financial, negotiation, bidding, and other information,
  • University research data, information, and findings that are protected by law, contract, or policy,
  • information described as confidential under any other University policy, rule, or directive, and
  • other information and records which the employee is directed under proper authority to not disclose. Confidential information does not include information publicly disclosed by the University or which is required to be disclosed pursuant to law or contract.

All University employees must hold any confidential information in trust and confidence, and not use or disclose it or any embodiment thereof, directly or indirectly, except as may be necessary in the performance of duties for the University, or as otherwise required by law or contract.

University employees may not remove confidential information from a University department/office, or duplicate confidential information, unless authorized by the University to do so. Upon termination of any assignment or as directed by a supervisor, employees shall return all such materials and copies thereof to their proper location in the department/office.

All requests by external entities or persons for the disclosure of confidential University information should be promptly directed to Western Michigan University's Freedom of Information Act Officer, unless the employee has received previous University authority to respond to such a request.

The policy does not prevent or prohibit the internal use of confidential information for the legitimate academic, administrative, and operational purposes and needs of the University as authorized by the University. This policy does not prevent or prohibit employees from good faith disclosures of a violation(s) of law, contract, or policy, either within the University or to the appropriate external body or authority, and such disclosure will not result in adverse employment action against the disclosing employee.

Questions regarding authorized disclosure or use under this policy should be directed to the University employee's supervisor prior to disclosure or use.

University employees who violate this policy will be subject to legal action, including but not limited to disciplinary action up to and including termination of their employment or contractual relationship.

This policy statement is also found in the Employee handbook.