Handbook of Operating Procedures 4-1020

Key Control and Accountability

Effective March 09, 2020
Executive Sponsor: Senior Vice President and Chief
Policy Owner: Facilities Services Director Financial Officer

 

1. Policy Statement

In order to promote a safe and secure campus environment, The University of Texas at Austin (University) limits and controls keys to University facilities and spaces. It is the policy of the University to ensure that keys to University facilities and spaces are issued only to authorized individuals who have a legitimate need for access, and that keys are properly returned when the individual is no longer authorized to possess them or the need for access is no longer warranted.
 

2. Reason for Policy

The purpose of this policy is to:

• provide increased security and protection for University personnel, property and equipment;
• establish and maintain proper control and accountability of University keys;
• establish the authority under which University keys will be manufactured and issued; and
• define the responsibilities of individual key holders, key issuing authorities and the Key Control Advisory Group.

3. Scope & Audience

This policy applies to all mechanical locks controlled by the University, except as noted below, as well as to all faculty, staff, students and contractors who authorize or possess keys to these locks.

This policy does not apply to electronic access control systems (i.e., locks that are controlled electronically via an ID card, fob, PIN code or other electronic means), which are governed under a separate policy.

This policy also does not apply to the facilities and spaces identified below, which are governed by their respective property managers and/or real estate lease agreements:
 

• UT Austin Admissions Centers in Dallas, El Paso, Harlingen, Houston, Longview, Lubbock and San Antonio.
• Buildings/properties located in Bonham, Corpus Christi, Dallas, Devine, Floresville, Fort Worth, Houston, Inez, Midland, Odessa, San Angelo, San Antonio, Uvalde, and Victoria, TX, as well as Burbank, CA, Los Angeles, CA and Washington, DC.

4. Definitions (specific to this policy)

Key Control Advisory Group:

Committee consisting of the associate vice president for Campus Safety (or delegate), the senior vice provost for Resource Management (or delegate), the UTPD chief of police, the director of Facilities Services, the lock & key services supervisor, an at-large academic unit representative from the Campus Safety and Security Committee and any other person(s) designated in writing by the senior vice president and chief financial officer (CFO).

Key Holder:

Person to whom a University key has been issued, either on a temporary or non-temporary basis.

Key Issuing Authority:

A department or unit authorized by this policy, or by letter signed by the SVP/CFO, to manufacture and issue University keys to individual key holders for certain, specified areas of the University (i.e., certain sites, buildings, facilities, structures, spaces, or land areas). Key issuing authorities are responsible for developing written procedures to ensure proper control and accountability of the University keys issued under their authority.

University Key:

Mechanical key that operates a University lock.

University Lock:

Mechanical lock and related hardware that restricts access to University-controlled buildings, facilities, structures, spaces and land areas, including padlocks used for this purpose. Normally excludes locks to lockers, desks, systems furniture, vehicles, equipment, cabinets, etc.
 

5. Website (for policy)

https://secure2.compliancebridge.com/utexas/public/getdoc.php?file=4-1020
 

6. Contacts

7. Responsibilities & Procedures
   1. General

1. Authorized individuals who require routine access to locked University facilities or spaces in order to perform their assigned duties will be provided access through the issuance of an appropriate University key.

2. University keys, which are considered State property, are issued to individual key holders, who become accountable for properly controlling and safeguarding assigned keys. The University prohibits defacing, marking, altering, copying and/or sharing of any University key, and may take administrative disciplinary action against a person who violates this prohibition.

3. Any person who knowingly makes, duplicates, or possesses a University key in violation of this policy or associated procedures, or uses a University key to gain access to University premises without the appropriate authorization, will be subject to administrative disciplinary action by the University and may also be subject to civil and/or criminal penalties under the laws of the State of Texas.

4. Any key holder who knowingly fails to return a University key as outlined in this policy and associated procedures will be subject to administrative disciplinary action by the University and may also be subject to civil and/or criminal penalties under the laws of the State of Texas. Key holders may contact their designated key issuing authority at any time to obtain a list of University keys currently assigned to them.

5. In the event a University key is lost or stolen, the key holder shall report the loss to their designated key issuing authority and UTPD as soon as possible, but no later than 24 hours after the loss was known. Within 24 hours, a written report must be submitted by the key holder documenting the circumstances of the loss.

1. This report will be evaluated by the Key Control Advisory Group, in consultation with the affected department(s) and key issuing authority, to determine the potential impact to building security.

2. The result of this evaluation may require that all, some, or none of the affected locks be re- keyed. This determination will be made on a case-by-case basis, with building security being the primary consideration. The number and type of keys lost, as well as the circumstances involved, will factor into the determination.

6. Failure to comply with this policy (and/or the associated procedures established by each respective key issuing authority) may result in the revocation of University keys, revocation of authority (e.g., authority to approve key requests), or other appropriate action as determined by the Key Control Advisory Group, in addition to administrative disciplinary action that may be taken by the University.

2. Key Issuing Authority

1. The following departments/units are hereby designated as key issuing authorities for the campus areas indicated:

1. 4500-000 - Facilities Services/Lock and Key Services: All University controlled buildings, facilities, structures, spaces and land areas except as specified below.

2. 4575-000 - University Housing and Dining (UHD): All buildings, facilities, structures and spaces under the exclusive jurisdiction and control of UHD.

3. 3100-000 - Applied Research Laboratory (ARL): All buildings, facilities, structures and spaces under the exclusive jurisdiction and control of ARL at the J.J. Pickle Research Campus.

4. 0050-000 - Lady Bird Johnson Wildflower Center (JWC): All buildings, facilities, structures, spaces and land areas under the exclusive jurisdiction and control of JWC.

5. 5005-000 - Texas Exes: The Etter-Harbin Alumni Center (UTX).

6. University of Texas Golf Club (UT Golf Club): All buildings, facilities, structures, spaces and land areas under the exclusive jurisdiction and control of the UT Golf Club.

7. 2660-000 - Marine Science Institute (MSI): All buildings, facilities, structures, spaces and land areas under the exclusive jurisdiction and control of MSI.

8. 0140-000 - McDonald Observatory: All buildings, facilities, structures, spaces and land areas under the exclusive jurisdiction and control of the McDonald Observatory.

2. Key issuing authorities shall develop and implement written procedures that ensure appropriate control and accountability of University keys issued under their authority. These procedures shall be approved by the Key Control Advisory Group to ensure compliance with this policy and relevant best practices. At a minimum, these procedures shall:

1. define the authority and conditions under which University keys will be issued;

2. define the responsibilities of University key holders and requesting departments;

3. establish protocols and responsibilities for lost/stolen/missing keys; and

4. establish protocols and responsibilities for auditing and reporting.

3. Key issuing authorities shall consult with the Key Control Advisory Group and obtain concurrence before approving any exception or deviation request to their written procedures.

4. Requests to designate other departments/units as key issuing authorities will be evaluated by the Key Control Advisory Group on the basis of need, practicality and risk. Following this evaluation, the Key Control Advisory Group will forward a recommendation for approval/disapproval to the CFO.

3. Key Control Advisory Group

1. The Key Control Advisory Group shall have authority to perform the following tasks and responsibilities:

1. Advise the CFO and recommend approval/disapproval of requests to designate additional departments/units as key issuing authorities.

2. Review and approve/disapprove the written procedures established by key issuing authorities, and concur with or disapprove requests for exceptions/deviations to those written procedures.

3. Review and approve/disapprove requests for exceptions/deviations to this policy.

4. Review violations of this policy (or associated procedures) and make determinations regarding appropriate action, including, but not limited to, revocation of University keys or referral for disciplinary action.

5. Review circumstances concerning lost/stolen/missing keys and make determinations regarding the need for re-keying.

6. Other appropriate tasks as documented by key issuing authorities in their written procedures, such as approval/disapproval of certain key or keying requests, etc.

2. Decisions of the Key Control Advisory Group may be appealed to the executive vice president and provost (provost) and CFO, who will jointly review the relevant facts and circumstances and make a final decision. In the event the provost and CFO cannot reach an agreement, the issue will be decided by the president.

8. Forms & Tools

Lock and Key Services Procedures Manual
 

9. Frequently Asked Questions

None
 

10. Related Information

HOP 8-1080 Building and Facility Access - Lock and Key Services Procedures Manual
 

11. History

Original Issue Date: March 9, 2020

Next scheduled review date: March 2022

Supersedes HOP 4-1020-PM "Keys to University Facilities" (dated July 20, 1976)
Previously PM 6.201