Policy 03-002 Meetings and Events

I.   Purpose

The purpose of this policy is to safeguard the privacy, confidentiality, and safety of University of California Education Abroad Program staff and students by prohibiting unauthorized participant recordings of meetings and events, while ensuring compliance with federal and state disability laws, including the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act.

II.  Scope

This policy applies to all UCEAP staff, faculty, contractors, students, and invited participants attending UCEAP-hosted meetings, presentations, trainings, and events, whether conducted in-person or virtually.

III. Definitions

A.  “Recording,” for purposes of this policy, means the creation, storage, reproduction, or other use or processing of audio, imagery, video, or transcripts of a meeting or event, whether through native conferencing software (e.g., Zoom), third-party applications (e.g., Otter.ai), phone camera, or any other means.

B.  “Sensitive Content,” for purposes of this policy, means information designated as confidential, personally identifiable, protected under FERPA, GDPR, or other applicable law, or otherwise identified as sensitive by UCEAP or identified as confidential by UC.

C.  “Reasonable Accommodation” for purposes of this policy, means a modification of a policy, practice, or procedure or the furnishing of an auxiliary aid or service to afford equal access to an individual with a disability, as defined by the ADA and UC nondiscrimination policies.

IV.  Responsibilities

A.  Prohibitions

1. Participants are strictly prohibited from recording UCEAP meetings, presentations, trainings, and events unless prior express permission is granted by the meeting organizer. This prohibition does not apply to organizers of such meetings, presentations, trainings, and events, who may record at their discretion.

B.  Notice

1. Meeting organizers must provide participants advance notice of this prohibition, including a statement that individuals with disabilities may request a reasonable accommodation to record.

C.   Accommodation Requests

1. Initiating Requests – Individuals with a disability-related need to record may request a reasonable accommodation via email or any other appropriate communication channel with UCEAP.
2. Request Management Procedure – Please refer to the Disability Accommodation Request Procedure for guidance on how to provide notice to meeting and event attendees, manage and process accommodation requests, and document disability accommodation activities.
3. Recording Agreement – Where a recording is approved as an accommodation, UCEAP may require the individual to sign an agreement clarifying:
   1. the recording is UC property,
   2. use is limited to the approved purpose, and
   3. redistribution or sharing is strictly prohibited.

D.   Roles

1. Meeting Organizers are responsible for communicating the prohibition, directing requests for accommodations, and ensuring compliance.
2. Data Privacy and Compliance Officer is responsible for policy oversight and annual review.
3. Campus Disability Services Office is responsible for evaluating requests, obtaining documentation as needed, and facilitating agreements.
4. Participants are responsible for adhering to this policy and any signed agreements governing accommodations.

V.  References & Cross-references

Americans with Disabilities Act, 42 U.S.C. § 12101 et seq.
Section 504 of the Rehabilitation Act, 29 U.S.C. § 794
28 C.F.R. § 35.160(b)(2); 28 C.F.R. § 35.164
Dep’t of Justice, Title II Technical Assistance Manual § II-7.1100
UCEAP Disability Accommodation Request Procedure
UCEAP Meeting Recording Frequently Asked Questions (FAQ)
UCEAP Recording Accommodation Agreement (DOCX, PDF)