Re: CIPA Questions ? ? ?

["SCHALIP, MICHAEL" <mschalip () CNM EDU>]

Where are the lawyers when you need them......??

I agreed with the earlier suggestion.....pass the info along to Legal - answer their questions to the best of your 
ability - let them make the call.....

M

From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Dan 
Sarazen
Sent: Wednesday, June 13, 2012 11:01 AM
To: SECURITY () LISTSERV EDUCAUSE EDU
Subject: Re: [SECURITY] CIPA Questions ? ? ?

So, does that mean that if Carlos's school does NOT accept funding for Internet access or internal connections from the 
E-rate program, they are off the hook?

From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () 
LISTSERV EDUCAUSE EDU>] On Behalf Of SCHALIP, MICHAEL
Sent: Wednesday, June 13, 2012 12:59 PM
To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
Subject: Re: CIPA Questions ? ? ?

Good question.....the FCC "guide" reads as:  "CIPA imposes certain types of requirements on any school or library that 
receives funding for Internet access or internal connections from the E-rate program..."

The *intent* may have been K-12, but it appears to be written much broader....??

M

From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Dan 
Sarazen
Sent: Wednesday, June 13, 2012 10:44 AM
To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
Subject: Re: [SECURITY] CIPA Questions ? ? ?

Hi,

I thought that law applies only to K-12 schools accepting E Funding.

From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () 
LISTSERV EDUCAUSE EDU>] On Behalf Of SCHALIP, MICHAEL
Sent: Wednesday, June 13, 2012 12:38 PM
To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
Subject: Re: CIPA Questions ? ? ?

Can you mitigate this by including a legal blurb that would have to be signed by parents prior to the students being 
released in to the program?......make it part of the "registration" paperwork?  You could advise the parents (and the 
students) that the use of your networks are subject to your use policies, and "...under age student participants shall 
not...."??

Based on my past experience - most times, the Feds are just looking for folks to demonstrate some level of due 
diligence......and if you can demonstrate that all participants have been apprised of your policies, (and the possible 
consequences for the violation of those policies!), you can usually keep problems to a minimum.....

Just my $.02.....

Michael

From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Carlos 
Lobato
Sent: Wednesday, June 13, 2012 10:26 AM
To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>
Subject: [SECURITY] CIPA Questions ? ? ?

Good Morning Colleagues,

NMSU is hosting some form of "summer camp" for high school (and perhaps younger) students.  The students will be housed 
at NMSU dorms during this time.  They are now asking for Internet access in the dorms.  Of course, NMSU has no 
restrictions on the internet.  Would we need to comply with the Children's Internet Protection Act (CIPA)?  We receive 
federal funding, but based on my reading of CIPA compliance requirements we would not be subject to CIPA.

Just to be cautious... Any thoughts on the risks?  Should we just go ahead and NOT grant them internet access as there 
is that possibility of these minors browsing through inappropriate content?  Please share with me your ideas and/or 
practices.

Carlos S. Lobato, CISA, CIA
IT Compliance Officer

New Mexico State University
Information and Communication Technologies
MSC 3AT PO Box 30001
Las Cruces, NM  88003-8001

Phone: 575-646-5902
Fax: 575-646-5278

Email: clobato () nmsu edu<mailto:clobato () nmsu edu>


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