College Response to CALEA Reporting Requirements

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Centre College has chosen not to file the report FCC 445 CALEA Monitoring Report for Broadband and VoIP Services. This decision was reached following discussions that involved Stan Campbell – Director of the Library, Shane Wilson – Network Services Coordinator, Jamey Leahey – College Counsel, and Art Moore – Director, Information Technology Services. We used several documents provided by Educause to guide our discussions and subsequent decision.


In making this decision we relied primarily on the Thinking through the CALEA Exempt/Non-Exempt Issue checklist. Specifically,

  • Does the institution support the connection to the ISP (Internet Service Provider)? If no, then the organization is probably exempt and likely need not comply with CALEA. If yes, go to test #2 to determine scope of compliance.


Centre does not support the connection to the ISP based on the principle ‘if the ISP provides the physical connection and the router/multiplexor for the campus, the campus is exempt.' That connection is owned and managed by BellSouth. The routing equipment resides in McReynolds, by necessity, but Centre personnel play absolutely no role in the management of the connection and service. The College is entirely dependent on BellSouth to provide the service and a portion of the monthly ISP fee includes the management of that connectivity.


Even so, test #2 was examined to ensure that we were on solid ground with our decision not to report.

  • Is it a private network?

The decision here is guided by

  • If the network is limited to serving only staff, faculty

and students, it is private.

  • If there is incidental public usage, probably private.


The library does have a policy of providing community members a limited access to the Internet. Access to the College network is limited to serving only staff, faculty, and students, with the very limited exception of occasional use by members of the community through the library. This provision of service is tightly controlled requiring a member of the library staff to log into the Centre network and then monitoring the activity of the guest (in other words, community members are not given their own accounts or passwords) . . The actual library policy is page 2 of this document.


It is possible that the guidelines may be modified in the future and we will have to revisit this issue. For now, Centre has chosen not to file the FCC Form 445 Report.


THE GRACE DOHERTY LIBRARY

COMMUNITY PATRON GUIDELINES

GENERAL


  • Patrons from the Danville community are welcome to use The Grace Doherty Library.
  • There is no charge for using material within the library


CIRCULATION OF LIBRARY MATERIALS

  • Community adult patrons may check out library materials; the library does not circulate material to elementary, middle school, or high school students
  • There is an annual $10.00 charge for community adult patrons who wish to check out library materials; this fee covers the cost of the card and processing.
  • All materials are subject to immediate recall when needed by Centre College students or faculty members.
  • No more than three books may be borrowed at one time.
  • Materials can be renewed only once.
  • If fines over $10.00 accumulate, patrons' borrowing privileges will be revoked.
  • There will be an additional charge for a replacement card.
  • Community patrons may not check out cds or dvds.


INTERLIBRARY LOAN

  • Interlibrary loan and document delivery are not available to community patrons. Please contact the Boyle County Public Library for information on these services.


INTERNET ACCESS

  • Doherty Library can offer only limited access to online services for community adult patrons.
  • Please contact a library staff member about internet services. The staff member will use a College account to log on a patron and access is limited to 30 minutes.
  • Wireless internet service is limited to Centre College faculty, staff, and students.