Effective October 2015
The purpose of this Policy is to help Employees, Student Body and Third Parties understand ANUC's expectations regarding their use of Electronic Communications and Social Media.
SCOPE & APPLICATION
The Policy is enterprise-wide in scope and applies to The All Nations University College, and all:
Wholly-owned subsidiaries of ANUC; and ANUC employees, contingent workers, contractors, temporary workers and other Third Parties, when:1. Using ANUC Electronic Networks,2. Using any Electronic Communication Device or Electronic Network to discuss ANUC Subject Matter.3. Using Electronic Communication Devices:4. Using ANUC issued Assets including ANUC Electronic Communication Devices; 5. Devices as defined under ANUC's Bring Your Own Device (BYOD) Program6. Applications or services which provide access to ANUC Electronic Networks.
POLICY DETAILS & REQUIREMENTS
Employees, Student Body and Third Parties must be familiar with and adhere to this Policy and other related policies and standards when using any ANUC Electronic Communication Devices, or ANUC Electronic Networks, and/or when communicating on any ANUC Subject Matter.
Employees who manage relationships with Third Parties are responsible for informing the Third Parties of this Policy and other relevant ANUC policies, monitoring their compliance with this Policy, and dealing with any incidents of non-compliance.
OWNERSHIP OF ELECTRONIC COMMUNICATIONS
ANUC may provide ANUC Electronic Communication Devices and access to ANUC Electronic Networks to Employees, Student Body and Third Parties to perform their roles and responsibilities for ANUC business. Reasonable and occasional personal use of ANUC Electronic Communication Devices and access to ANUC Electronic Networks by Employees, Student Body and Third Parties is generally permitted, although some business units may prohibit or restrict personal use in whole or in part. In all cases, however, your personal use must adhere to this Policy, and cannot:
Negatively impact your job performance or productivity;Negatively impact the ANUC Electronic Network (e.g., consume excessive network bandwidth or expose ANUC to malicious software like viruses);Extend to political, charitable or religious activities contrary to the Code on Conduct and Ethics; andExtend to outside business activities, including directorships, unless your participation was requested and approved by ANUC in accordance with the Outside Business Activities Guidelines applicable to your business or region.All information created, stored, processed or sent using ANUC Electronic Communication Devices or through ANUC Electronic Networks is the property of ANUC. As such, all of your communications using ANUC Electronic Communication Devices and ANUC Electronic Networks are not private, and these communications will be accessed, stored, recorded, disclosed and used by ANUC for valid business reasons and may be monitored where appropriate Accordingly, there should be no expectation of privacy in such communications including those communications of a personal nature. For purposes of maintaining your own personal privacy, you should be aware that monitoring by ANUC may reveal sensitive personal information about you which could include communications you send and receive and information which you access, store or record.
ANUC reserves the right to block access, either permanently or temporarily, to Internet sites (including Social Media), channels or portals that are considered inappropriate by the nature of their content, where ANUC does not have appropriate controls to monitor compliance with this Policy or regulatory requirements, or that negatively impact (or may negatively impact) the efficiency and security of ANUC Electronic Networks. If your job requires access to sites that are blocked, please request access through your People Manager who will seek approval through the appropriate process.
When conducting ANUC business through Electronic Communications, you must only use ANUC Electronic Networks, or Electronic Networks that ANUC has authorized you to use.
2.1 GENERAL PRINCIPLES
Nothing in this Policy is intended to or shall prevent non-supervisory employees in the Republic of Ghana from engaging in activity or commentary that is protected by Section of the National Labor Relations Act. When you use ANUC Electronic Communication Devices, communicate over ANUC Electronic Networks or discuss ANUC Subject Matter, you must abide by the following:
2.1.1 REPRESENTATIONUnless you are a spokesperson under ANUC’s Disclosure Policy or authorized to do so by Corporate and Public Affairs (“CAPA”) or Digital Marketing and Social Media (“DMSM”), you shall not communicate publicly (including posting on Social Media) on behalf of ANUC. In addition you may not:
Publicly comment, post, or speak on behalf of ANUC or about ANUC Subject Matter such as, ANUC Student Affairs or Employees.Publicly respond to customer questions, student/faculty complaints and/or statements about ANUC.Promote, sell or advertise ANUC products and services using social media platforms.Send electronic communications that include deceptive, misleading or false headers in the subject line or heading of an email.If you make any personal comment about ANUC Subject Matter, you must disclose your connection with ANUC and also make it clear that you are expressing your own personal opinion and not that of ANUC.
2.1.2 RESPECTYour Electronic Communications should be respectful, responsible and professional in tone, and must not violate this Policy, the ANUC Code of Conduct and Ethics or other related policies, standards or guidelines. For example:
You must not create, transmit, post or otherwise publish or access, retrieve, view or store any material that is, or promotes any views or actions that are illegal, unethical, dishonest, discriminatory, defamatory, obscene, threatening, intimidating, violent, harassing or promote hate.You must not create, transmit, post or otherwise publish, or access, retrieve, view or store any material that is not appropriate in a professional environment (including but not limited to gambling-related or pornographic material).You must not knowingly access, download or transmit any damaging or malicious data (e.g., viruses).You must not hack or otherwise gain or attempt to gain, unauthorized access to information or accounts (including email or voicemail accounts of another employee or Third Party), or access material that provides information on or that promotes illegal or questionable access to information systems.
2.1.3 CONFIDENTIALITY AND PRIVACYYou must not disclose any restricted, confidential, internal, proprietary or personal information about or belonging to ANUC, other employees, directors, customers, suppliers or competitors (including for example, internal documents or discussions, presentations, audios/videos and software) other than as protected by law or as required for valid ANUC business purposes.
Similarly, you must not use Electronic Communications or Electronic Communication Devices to collect or use confidential or personal information contrary to the law or ANUC policies. If you are ever in doubt as to whether specific information can/cannot be collected, used or disclosed, do not collect, use or disclose the information and consult with VP COO, Privacy Designate or local Privacy Office.
2.1.4 ACCOUNTABILITY AND RESPONSIBILITYYou are responsible for any information that you communicate. Therefore, unless you are acting in a manner that is protected by law, you should never communicate any information that is damaging to ANUC, its employees, directors, customers, suppliers or competitors; that reflects negatively on yourself; or that violates any laws or the rights of others.
ANUC may remove access to ANUC Electronic Networks or ANUC Electronic Communication Devices, or direct an employee or Third Party to cease using Electronic Communications to discuss ANUC Subject Matter, either temporarily or permanently, if ANUC believes that such an action is necessary or advisable to enforce compliance with this Policy.
2.2 USE OF ANUC ISSUED DEVICESEmployees, Student Body and Third Parties provided with an ANUC issued device are responsible for the safekeeping, care, and custody of the assigned device. If the Device is lost, stolen, or otherwise comprised, they must report it immediately to the office of the COO.
2.3 PERSONAL EMAILEmployees, Student Body and Third Parties must not use personal email accounts to communicate on any topic that relates to ANUC, including, but not limited to, its business (including products, strategies and markets) and the promotion, advertising or marketing of its business or products, corporate matters (including financial results), Admission advice , etc.) or its employees, directors, customers, suppliers and competitors.
MONITORING AND CONTROL
ANUC monitors all communications through ANUC Electronic Networks to watch for unusual, inappropriate or suspicious activities that may indicate a breach of the law or of this Policy or other related ANUC policies including the ANUC Code of Conduct and Ethics. Typically, monitoring occurs on an anonymous basis, meaning that it is only if improper activity is suspected or specified key words are mentioned, that the content of Electronic Communications associated with the employee will be reviewed by ANUC. But, some business segments are required to, and do, monitor and/or record email, business telephone lines and other forms of Electronic Communications for valid business purposes, such as to protect both ANUC and its customers, to enhance customer service, to confirm our discussions with customers, or to fulfill regulatory supervisory responsibilities. ANUC monitors Internet and Social Media sites for posts that are of interest to ANUC, that may constitute a potential breach of ANUC policy and/ or that are potentially damaging to ANUC.
Requests for any exceptions to the Policy must be supported by an executive VP seeking the exception and must be forwarded to the Policy Owner described in the roles and responsibilities table
ROLES AND RESPONSIBILITIES
The President Office, CEO, VP & COO, Senior VP, Technology Solutions - Technology Risk Management and Information Security
The CEO, Senior Vice-President, Technology Solutions, Technology Risk Management and Information Security will approve this policy. They will oversee a committee comprised of the following subject matter experts when approving this Policy and subsequent amendments: • VP, COO, VP Registrar • VP, Student Affairs, Privacy Officer and Social Media Compliance • AVP, Human Resources, Enterprise Regulatory HR Policies
Senior IT Manager, Technology Risk and Control Governance will have primary accountability for monitoring compliance with the Policy. The members of the subject matter expert committee will each designate one or more individuals to support the Senior IT Manager in monitoring, interpreting, applying and enforcing the Policy and Usage Guidelines as it relates to matters within their respective expertise.