HEOA Compliance Plan

 

William Paterson University of New Jersey

The Higher Education Opportunity Act (HEOA) includes provisions to reduce the illegal uploading and downloading of copyrighted works through peer-to-peer (P2P) file sharing. Specifically, HEOA requires institutions to:

• make an annual disclosure that informs students that the illegal distribution of copyrighted materials may subject them to criminal and civil penalties and describes the steps that institutions will take to detect and punish illegal distribution of copyrighted materials;

• certify to the Secretary of Education that they have developed plans to “effectively combat” the unauthorized distribution of copyrighted material including "the use of one or more technology-based deterrents";

• offer alternatives to illegal file sharing to the extent practical;

• identify procedures for periodically reviewing the effectiveness of the plans to combat the unauthorized distribution of copyrighted materials.

William Paterson University’s compliance plan with the HEOA act in regard to Copyright infringement includes the following:

 

1. Annual Disclosure

William Paterson University uses a wide variety of methods to inform students about copyright laws:

• The WPUNJ Information Services website provides (http://www.wpunj.edu/is/policies.dot) information and guidelines of copyright laws and fair use to the campus community including specific restrictions on peer to peer software use on the university network.
• All students are required to adhere to the practices stated in University’s IT Policies and Appropriate Use Technology Resources which are bound by federal and state law.  All residential students must are also subject to the terms stated in “Resnet Usage Policy”. Both policies include a section on copyright compliance. The University’s IT policies are included in Student Handbook and posted on University’s website.
•  Each year, the Information Systems office sends out a memo to all students on copyright laws and campus policies related to violating copyright laws. The memo is also posted on University’s website.
• As part of the orientation process all students are informed of the University’s appropriate use policies. These policies are further reinforced in an orientation program for residence hall students.

 

2. Devise a plan to "effectively combat the unauthorized distribution of copyrighted materials" by users of its network

William Paterson University uses several technology-based deterrents to combat the unauthorized distribution of copyrighted materials:

• William Paterson University utilizes Traffic/Packet Shaping (Cisco SCE-1000) that allows the campus to ensure smooth flow of content to and from the Internet with the ability to prioritize traffic based on need or policy. 
• William Paterson University requires user authentication for all network access which requires a local agent (Cisco Clean Access) installed on computers to enforce anti-virus software and provide the ability to restrict specific P2P applications.
• WPUNJ’s policies and procedures effective July 1,2010 regarding the response to Digital Millennium Copyright Act (DMCA) is published on the University website and included in annual notification to students.   If the University receives a complaint that a user is redistributing copyrighted material that user will be notified and given 5 days to respond acknowledging receipt of notice and that appropriate actions have been taken to remove P2P software and unlicensed content.  Failure to comply will result in loss of network access until the complaint is resolved.  The Office of Student Development provides specific disciplinary actions and sanctions for illegal downloading of copyrighted material which are listed HERE and in the Student Handbook.
• Effective July 1, 2010 the WPUNJ network will block all known P2P traffic utilizing an Intrusion Prevention System (Cisco IPS) able to recognize any P2P traffic signature.

 

3. Alternative online sources for copyrighted materials

There are many legal sources for copyrighted material such as music and movies. They have a wide range of business models; some are free and some charge a nominal fee. The Motion Picture Association of America (http://www.mpaa.org/) maintains an up-to-date and comprehensive list of legal sources. In addition, the University will maintain a posting of legal sources for online music and video available on the Information Services website.

 

4. Reviewing Effectiveness

Beginning 2010 academic year and periodically thereafter, we will survey community members to assess the extent to which our anti-piracy messages are reaching them. We will analyze the impact of our technical efforts to combat illegal file sharing, and other aspects of our plans to combat the unauthorized distribution of copyrighted materials.

 

Approved by Executive IT Management Team

May, 2010