Project Sunlight
What is Project Sunlight?
Project Sunlight is a statewide initiative based on the Public Integrity Reform Act of 2011 and omnibus ethics legislation Chapter 399 Part A, §4 of the Laws of 2011. The purpose of the legislation is to increase government transparency and accountability that allows the public to see who interacts with New York State employees with respect to five categories:
- Procurement of a state contract for real property, goods, or services over $25,000,
- Rate Making,
- Regulatory matters,
- Judicial or quasi-judicial proceedings conducted by an agency, or
- Adoptions or repeal of a rule or regulation.
Scope
Interactions covered by Project Sunlight must include an appearance, between covered individuals, and concern one of the five categories listed above. There are several exceptions; see the “Appearance shall not mean” section below.
Given the nature of SUNY Geneseo’s activities, we are most likely to have reportable appearances in the procurement category.
Definitions
Appearance shall mean - An interaction that is an in-person meeting or a video conference between covered individuals, related to one of the five covered categories. The location and formality of the interaction is irrelevant as to whether it constitutes an appearance, and it is irrelevant who initiates the interaction. There can be numerous appearances related to a single matter.
Appearance shall not mean:
- Ministerial or informational appearances, such as communications to schedule meetings or requests for information.
- Written communications such as letters, faxes, or emails.
- Telephonic conversations.
- Appearances regarding legislation or the budget.
- Any appearance related to individuals or matters that deemed by a state entity as confidential pursuant to federal or state statute, rule, or regulation.
- Any appearance that, if disclosed, could endanger the life or safety of any person.
- Participation in meetings which are open to the public, such as conferences or meetings subject to the Open Meetings Law or where a record of the meeting is otherwise publicly available.
- Appearances between a covered individual at a state entity and an agent of the agency, such as a consultant.
- Any appearance that, if disclosed, could subject an individual to a risk of retaliation or adverse employment action.
A covered individual - An individual at the state entity who has the power to exercise agency discretion in one of the five covered categories or advises someone who has such discretion.
A covered individual shall not mean - Outside agents of a state agency or authority, such as retained outside counsel.
A covered individual outside of a state entity shall mean - Appearances by both “external” (e.g., a lobbyist) and “internal” (e.g., a general counsel) representatives of an entity, appearances by an individual appearing on behalf of him/herself, and appearances by advocacy groups or organizations or entities representing the interests or concerns of the organization or entity or of its members.
A covered individual outside of a state entity shall not mean:
- State and local government employees and elected officials as well as those of tribal governments and federal government representatives.
- Judges or employees of the judiciary.
- Individual inmates and parolees and their representatives before state entities regarding their supervision and/or conditions of confinement.
- Representatives of the media.
- People under the age of eighteen.
Covered Individuals at SUNY Geneseo
Campus decision makers (covered individuals), related to this protocol based on title and job function, according to the guidance provided by SUNY are:
- The President
- The Provost
- The Vice President of Finance and Administration
- The Vice President for Student and Campus Life
- The Chief Diversity Officer
- The Dean of Students
- The Associate Vice President for Human Resources
- The Assistant Vice President for Facilities and Planning and Chief Sustainability Officer
- The Controller
- The Athletics Director
- The Director of Planning and Construction
- The Director of Procurement
- The Assistant Director of Procurement
- The Purchasing Assistant
- Other leaders as designated
Each covered individual is notified and provided with training in relation to Project Sunlight requirements.
Campus Compliance
The SUNY Project Sunlight database includes all qualifying appearances between designated state decision makers and the entities and individuals they are interacting with. SUNY Geneseo is complying with Project Sunlight by reporting these appearances within five business days into the public searchable database.
Human Resources has established non-compliance protocol for those state employees who do not comply with Project Sunlight reporting duties.
Reporting Qualified Appearances
To report a qualified appearance, covered individuals will complete the online
and email the completed form to compliance@geneseo.edu within three business days after the appearance. They will follow all instructions for the information required on the form to expedite the process.
If several covered individuals from Geneseo attend the same meeting, only one entry is required. During the meeting, participants should decide who will complete the report. The form allows for the reporting of the names of multiple-covered individuals in attendance at the meeting.
Upon receipt of the form, the Compliance Officer will submit the report into the public searchable database.
Training and Resources
Training is required every two years for covered individuals at SUNY Geneseo. The training will be assigned and must be completed in BizLibrary.
SUNY Project Sunlight Training PowerPoint (link in BizLibrary coming)
Support and Contact Information
Please email the SUNY Geneseo Compliance Office at compliance@geneseo.edu on reporting questions.
Inquiries specifically regarding the Project Sunlight database should be emailed to help@projectsunlight.ny.gov.