Policies

Privacy & Security Policy
Web Accessibility Policy
Link Policy
Fraud Detection Policy
Social Media Policy

Privacy & Security Policy

Privacy Statement
As a public service, TVC allows website users to electronically submit to the Commission certain forms and materials that may contain personal information. With a few exceptions, Texas privacy laws and the Public Information Act entitle persons who submit personal information to ask TVC about the information collected on such forms, to receive and review their personal information, and to request that TVC correct any inaccuracies in the personal information. TVC’s procedures for requesting corrections are in Title 1 of the Texas Administrative Code, sections 351.17 through 351.23.

Security Policy
For site security purposes and to ensure that the site remains available to all users, TVC uses software to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. Except for authorized law enforcement investigations, no other attempts are made to identify individual users or their usage habits. Raw data logs are used for no other purposes. Unauthorized attempts to upload information or change information on this site are strictly prohibited and may be punishable under the Texas Penal Code Chapters 33 (Computer Crimes) or 33A (Telecommunications Crimes).

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Web Accessibility Policy

Texas Veterans Commission is committed to making its Web sites accessible to all users, and we are committed to making our Web site/Web pages compliant with Texas Adminstrative Code 213.

We have included several features designed to improve accessibility for users with disabilities. Some of these features are described below:

• Images on the site contain 'alt tags' with descriptions of the image, which aid users who listen to the content of the site by using a screen reader, rather than reading the site. Text transcripts accompany audio clips of speeches and remarks.
• A 'skip to' link provides users with a method for bypassing the header and going directly to the main content each time a page is accessed.
• Major reports and other special publications that are made available on our Web site are generally available in html. In some cases we may publish a document using Adobe Portable Document Format (PDF). When posting PDF files, we follow the "How to Create Accessible Adobe PDF Files" and may post the document with two links.
• To improve the accessibility of our Web site we test any major redesign with screen readers, use the W3C validators for html, and Cascading Style Sheets (CSS). We welcome comments on how to improve the site's accessibility for users with disabilities.
• If you use assistive technology and the format of any material on our Web sites interfere with your ability to access the information, please use the following point(s) of contact for assistance. To enable us to respond in a manner most helpful to you, please indicate the nature of your accessibility problem, the preferred format in which to receive the material, the Web address of the requested material, and your contact information.

Voice (512) 463-6564

Fax (512) 475-2395

Email info@tvc.state.tx.us

Additional information about accessibility programs in Texas is available from the Governor's Committee on People with Disabilities at http://www.governor.state.tx.us/disabilities/.

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Link Policy

Texas Veterans Commission (TVC) encourages organizations that link to this Internet site to comply with the provisions of the State Web Site Link and Privacy Policy, especially regarding protection of the privacy rights of individuals, and to make reasonable efforts to provide accessible sites.

What Site Owners May Not Do in Linking to State Agency Websites
Site owners may not:

• Capture state agency pages within the site owner's frames. 
• Present state agency website content as that of the site owner. 
• Otherwise misrepresent the content of the state agency pages. 
• Misinform users about the origin or ownership of the content of the state agency website. 

Any link to a state agency site should be a full forward link that passes the client browser to the state agency site unencumbered. The BACK button should return the visitor to the site owner's site if the visitor wishes to back out. 

TVC is not responsible or liable for any content on private web sites that have linked to TVC’s web site.

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Fraud Detection Policy

BACKGROUND 
The Texas Veterans Commission (also called the Commission) fraud policy is established to facilitate the development of controls which will aid in the detection and prevention of fraud against the Texas Veterans Commission. It is the intent of the Texas Veterans Commission to promote consistent organizational behavior by providing guidelines and assigning responsibility for the development of controls and conduct of investigations. 

ELEMENTS OF THE FRAUD CONTROL POLICY
The basis of a strong antifraud program is an agency culture of honesty and ethics. The fundamentals of a culture of honesty and ethics include but are not limited to the following: 

• Management creating a workplace environment that promotes ethical behavior.
• A workplace that enhances employee morale and loyalty.
• Hiring and promoting employees who are qualified for their jobs by virtue of education, work experience, past accomplishments and evidence of integrity and ethical behavior.
• Training that includes Commission standards for conduct, “Actions Constituting Fraud” (as outlined in this policy), and procedures and responsibilities for reporting fraud.
• Employee commitment to a culture of honesty, integrity and ethics.
• A “Code of Conduct” statement read and signed by all Commission employees.

SCOPE OF POLICY 
This policy applies to any fraud, or suspected fraud, involving employees as well as clients, consultants, vendors, contractors, outside agencies doing business with employees of such agencies, and/or any other parties with a business relationship with the Texas Veterans Commission.

Required investigative activity will be conducted without regard to the suspected wrongdoer’s length of service, position/title, or relationship to the Commission.

POLICY 
Management is responsible for the detection and prevention of fraud, misappropriations, and other inappropriate conduct. Fraud is defined as the intentional, false representation or concealment of a material fact for the purpose of inducing another to act upon it to his or her injury. Each member of the management team will be familiar with the types of improprieties that might occur within his or her area of responsibility, and be alert for any indication of irregularity.

Any fraud that is detected or suspected must be reported immediately to the Director of Finance and Information Resources, who coordinates all investigations with the Attorney General and other affected areas, both internal and external.

ACTIONS CONSTITUTING FRAUD
The terms defalcation, misappropriation, and other fiscal wrongdoings refer to, but are not limited to: 

• Any dishonest or fraudulent act,
• Forgery or alteration of any document or account belonging to the Texas Veterans Commission,
• Forgery or alteration of a check, bank draft, or any other financial document,
• Misappropriation of funds, supplies, or other assets,
• Impropriety in the handling or reporting of money or financial transactions,
• Profiting as a result of insider knowledge of Commission or State activities,
• Disclosing confidential and proprietary information to outside parties,
• Disclosing to other persons activities engaged in or contemplated by the Commission,
• Accepting or seeking anything of material value from contractors, vendors or persons providing services/materials to the Commission, that are in violation of the guidelines set by the Texas Ethics Commission or State law, 
• Destruction, removal or inappropriate use of records, furniture, fixtures, and equipment; and/or
• Any similar or related inappropriate conduct.

OTHER INAPPROPRIATE CONDUCT
Suspected improprieties concerning an employee’s moral, ethical, or behavioral conduct, should be resolved by Regional Directors and/or the Director of Administration and Training rather than the Director of Finance and Information Resources.

If there is any question as to whether an action constitutes fraud, contact the Director of Finance and Information Resources for guidance.

INVESTIGATION RESPONSIBILITIES
The Director of Finance and Information Resources has the primary responsibility for the investigation of all suspected fraudulent acts as defined in the policy. If the investigation substantiates that fraudulent activities have occurred, the Director of Finance and Information Resources will issue a report to the Executive Director or the Chairman of the Commission as appropriate. 

Decisions to prosecute or refer the investigation results to the appropriate law enforcement agencies for independent investigation will be made in conjunction with legal counsel and the Chairman of the Texas Veterans Commission, as will final decisions on disposition of the case.

CONFIDENTIALITY 
The Director of Finance and Information Resources treats all information received confidentially. Any employee who suspects dishonest or fraudulent activity will notify the Director of Finance and Information Resources immediately, and should not attempt to personally conduct investigations or interviews/interrogations related to any suspected fraudulent act (see REPORTING PROCEDURES section below).

Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. This is important in order to avoid damaging the reputations of persons suspected but subsequently found innocent of wrongful conduct and to protect the Texas Veterans Commission from potential civil liability.

AUTHORIZATION FOR INVESTIGATING SUSPECTED FRAUD
Any personnel involved in an ethics or fraud investigation will have:

• Free and unrestricted access to all Commission records and premises (coordination will be made with the appropriate host agency for office space); and
• The authority to examine, copy, and/or remove all or any portion of the contents of files, desks, cabinets, and other storage facilities on the premises without prior knowledge or consent of any individual who may use or have custody of any such items or facilities when it is within the scope of their investigation.

REPORTING PROCEDURES 
Great care must be taken in the investigation of suspected improprieties or wrongdoings so as to avoid mistaken accusations or alerting suspected individuals that an investigation is under way.

An employee who discovers or suspects fraudulent activity will contact the Director of Finance and Information Resources. The employee or other complainant may remain anonymous. All inquiries concerning the activity under investigation from the suspected individual, his or her attorney or representative, or any other inquirer should be directed to the Director of Finance and Information Resources.

No information concerning the status of an investigation will be given out. The proper response to any inquiries is: “I am not at liberty to discuss this matter.” Under no circumstances should any reference be made to “the allegation,” “the crime,” “the fraud,” “the forgery,” “the misappropriation,” or any other specific reference.

The reporting individual should be informed of the following:

• Do not contact the suspected individual in an effort to determine facts or demand restitution.
• Do not discuss the case, facts, suspicions, or allegations with anyone unless specifically asked to do so by the appropriate investigating authority.

TERMINATION 
If an investigation results in a recommendation to terminate an individual, the recommendation will be reviewed for approval by the Director of Administration and Training, the Executive Director and the legal counsel provided to the Commission by the Attorney General’s office before any such action is taken. The parties investigating the fraud do not have the authority to terminate an employee.

The decision to terminate an employee is made by the employee's direct supervisor. Should the Regional Director or Executive Director believe the manager’s decision inappropriate for the facts presented, the facts will be presented to executive level management for a decision.

ADMINISTRATION
The Executive Director is responsible for the administration, revision, interpretation, and application of this policy. The policy will be reviewed every two years from the date of approval by the members of the Texas Veterans Commission and revised as needed.

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Social Media Policies

Terms of Service
Texas Veterans Commission social media sites are third party sites and have terms of service and policies that are not governed by Texas Veterans Commission. These third party sites are not official Texas Veterans Commission web sites and the third party’s website terms of service and policies apply. The terms of service for the social media sites used by Texas Veterans Commission can be found below:

• Twitter
• Facebook
• Flickr
• YouTube

Content of Social Media Posts
All published Texas Veterans Commission social media content is subject to monitoring. This content may take the form of digital text for Twitter and Facebook, photography images for Flickr, and videos for YouTube. User-generated posts will be rejected or removed if possible when the content of a post:

• is off-subject or out of context
• contains obscenity or material that appeals to the prurient interest
• contains personal identifying information or sensitive personal information, as defined in Tex. Code Bus & Com. Sec. 521.001 et. seq.
• contains offensive terms that target protected classes
• is threatening, harassing or discriminatory
• incites or promotes violence or illegal activities
• contains information that reasonably could compromise public safety
• advertises or promotes a commercial product or service, or any entity or individual
• promotes or endorses political campaigns or candidates

Twitter
Accessibility: To accommodate Texas Veterans Commission users with disabilities, www.accessibletwitter.com is the suggested alternative access to the Texas Veterans Commission Twitter profile.

Record Retention: Texas Veterans Commission Twitter content will be archived and retained for the required period of time in accordance with the DIR Records Retention Schedule.

Facebook
Accessibility: To accommodate Texas Veterans Commission users with disabilities, there are two suggested alternatives to access the Texas Veterans Commission Facebook Fan page:

1. The Facebook mobile site http://m.facebook.com is a suggested accessible alternative to the original Texas Veterans Commission Facebook page.
2. Texas Veterans Commission will post the same content to Twitter and Facebook. Therefore, http://www.accessibletwitter.com will serve as an accessible alternative.

Record Retention: Texas Veterans Commission Facebook updates will be archived and retained for the required period of time in accordance with the DIR Records Retention Schedule.

Flickr
Accessibility: To accommodate Texas Veterans Commission users with disabilities, the mobile version of Flickr http://m.flickr.com/ is the suggested alternative to access the Texas Veterans Commission Flickr pool.

Record Retention: The following Texas Veterans Commission Flickr photos will be archived and retained for the required period of time in accordance with the DIR Records Retention Schedule:

1. Photos posted to Flickr by Texas Veterans Commission
2. Photos not accepted by Texas Veterans Commission due to noncompliance with submission guidelines

Content: By submitting a photo to the Texas Veterans Commission Flickr pool, you are giving Texas Veterans Commission permission to use your photo on the Texas Veterans Commission website.

YouTube
Accessibility: Texas Veterans Commission will make an effort to link to and display videos on its YouTube channel that have closed captioning available for hearing impaired viewers. For more information about the closed captioning feature on YouTube, visit: http://www.youtube.com/t/captions_about

Record Retention: The Texas Veterans Commission YouTube photos will be archived and retained for the required period of time in accordance with the DIR Records Retention Schedule.

Content: Videos displayed on the Texas Veterans Commission YouTube site will be related to Texas veterans or veterans in general.

Moderating Comments
In some social media formats such as Facebook, Blogs, Twitter responses, etc., you may encounter comments which cause you concern as a moderator or responsible party. If user content is positive or negative and in context to the conversation, then the content should be allowed to remain, regardless of whether it is favorable or unfavorable to the State. If the content is ugly, offensive, denigrating and completely out of context, then the content should be rejected and removed.
 

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