Staff Policy D-510.00
Institutional Effectiveness Criterion: Operations

Use of Generative Artificial Intelligence Technologies

Purpose

Generative artificial intelligence (GenAI) tools have a wide and growing range of applications. Some of these uses may serve Northwestern Michigan College’s mission and values while others may conflict with them. As an educational institution dedicated to keeping learning at the center and preparing students for an ever-changing world, we must distinguish between these uses in a way that facilitates both creative innovation and critical literacy. Because the capabilities of GenAI tools can bring some of our institutional values into tension with one another, the purpose of this policy is to provide clear guidance for employees as they evaluate whether and how to use GenAI tools in the course of their work in both instructional and non-instructional contexts. The college recognizes that GenAI is an evolving technology and that this policy represents the current juncture in an ongoing dialogue among faculty, staff, and students about the potential uses and abuses of this technology in our institutional context. We will revisit this policy on a regular basis to make revisions as needed to reflect changes in GenAI and in our understanding of this technology.  

Scope

This policy governs any use of GenAI applications by employees, contractors, partners, and students within the scope of their work at NMC, including the use of GenAI tools on personal devices (see Staff Policy D-506.06 Computer and Network Acceptable Use).

Values-Driven Approach

Decisions about what constitutes appropriate use of GenAI tools at NMC must align with our shared institutional values: Learning, Integrity, Collaboration, Respect, Inclusion, Innovation, Stewardship and Excellence.

• Learning

Our GenAI use and experimentation will seek to support lifelong human learning and contribute to community thriving.

• Integrity

We will use GenAI in ways that are open, ethical, and fair. We take personal as well as collective responsibility for our GenAI use.

• Collaboration

We will use GenAI in ways that empower our work with each other and with our communities.

• Respect

We will use GenAI in ways that emphasize our mutual regard and appreciation for each other and for the contributions of each individual at NMC.

• Inclusion

We will use GenAI in ways that support our efforts to foster belonging and build organizational capacity that celebrates diversity and promotes equity.

• Innovation

We will use GenAI to support agile, imaginative, and ethical risk taking to meet our communities’ needs and challenges.

• Stewardship

Our use of GenAI will reflect our commitment to practice stewardship by investing responsibly in the human, physical, financial and environmental resources entrusted to our care.

• Excellence

Our use of GenAI will reflect our commitment to maintaining the highest standards of quality and service and that align with our academic integrity policies.

Data Privacy & Security

Many GenAI applications include terms of service that grant their owning corporations permission to collect and use the data users enter. This poses risks for data privacy and security, as well as implications for our institutional values of integrity, respect, and stewardship. For these reasons, NMC employees should not submit any material containing college data to GenAI applications, except for specifically approved purposes (see Purchasing and Licensing of GenAI Tools below). College data is defined as information protected by FERPA, HIPAA, personally identifiable information (PII), financial records, academic records, legal documents or contracts, personnel records, funding agreements, core business systems data, network configurations, software keys, or any proprietary information.

Purchasing and Licensing of GenAI Tools

The college may choose to license a GenAI application for a specific use case that involves uploading proprietary or sensitive data. In such a case, the application and purpose would first need to be vetted and approved per Staff Policy D-508.02 IT Asset Acquisition.

Intellectual Property

Although most works created by NMC employees within the scope of their employment are the college's intellectual property, employees retain important rights related to ‘Traditional Works of Scholarship’ and creative works (see Staff Policy D-506.02 Intellectual Property).

Additionally, students own the copyright to academic work they create except in cases where they grant this right through some other agreement (e.g., work for hire as part of student employment, an applied research project with a funding partner).

Because the terms of service of GenAI applications vary widely in their treatment of intellectual property which is uploaded on their platforms, submitting others’ work as an input to a GenAI application may violate colleagues’ or students’ intellectual property rights, as well as conflict with our institutional values of respect, collaboration, integrity, and stewardship.

As such, NMC employees, contractors and students should proceed with great caution when considering submitting others' writings, creative works, or work products into a GenAI application, seeking the creators' permission where appropriate.

User Responsibilities

Staff, faculty, and students using GenAI tools to work, communicate, or create at NMC have a responsibility to develop an understanding of how these tools function and to follow college, department, and course guidelines on allowed and disallowed uses of GenAI. Faculty have a further responsibility to become GenAI literate within their respective fields, to collaborate with their departments to develop specific GenAI guidance, and to communicate department and course policies about the uses of GenAI to their students.

Accuracy & Bias

GenAI applications rely on language models trained on large data sets containing works created by humans and have been demonstrated to reproduce biases present in that training data. Furthermore, GenAI applications have been demonstrated to generate factually inaccurate outputs, sometimes termed ‘hallucinations.’  These documented traits of language models require us to proceed accordingly, guided by our commitment to learning, respect, inclusion, integrity, and excellence. When an NMC employee uses a GenAI application (see Acceptable Uses below), it is that employee’s responsibility to verify the accuracy of the resulting work product, as well as to evaluate potential bias reflected in the application’s output.

Transparency & Disclosure 

NMC expects students to disclose the use of GenAI tools (see Staff Policy D-602.01 Student Rights and Responsibilities – Process) as a matter of both policy and academic integrity, ensuring that they do not misrepresent GenAI contributions as their own exclusive work. In keeping with our institutional values of integrity, respect, and collaboration, NMC faculty and staff should consider this standard of transparency and disclosure, noting where applicable the use of GenAI in the creation of work products.

Trust, Authenticity and Human Communication

Communication is a human activity. Because GenAI applications are incapable of intent, feeling, judgment or authentic human communication, overreliance on GenAI tools in the creation of communications can have serious consequences including losing audiences’ trust and attention. NMC employees’, contractors’, partners’, and students’ use of GenAI in communication should reflect a sensitivity to these dynamics of trust and human authenticity, informed by our institutional values of integrity and respect for one another. NMC employees and contractors should avoid using GenAI tools in lieu of human expertise and judgment in contexts where there is a reasonable assumption that human expertise and judgment would be exercised.

Northwestern Michigan College prohibits any malicious use of AI tools to create deepfakes or any other audio, visual, or textual content using the name, image, voice, likeness, or identity of an individual without their consent. 

All uses of Gen AI at NMC will also be subject to relevant college, program, and department procedures that are developed regarding this technology.

The VP for Student Services and Technologies, in conjunction with the appropriate faculty and staff, is responsible for the development and publication of any procedures or guidelines that may be necessary to administer this policy effectively.

 

If any provision(s) of this policy or set of bylaws conflicts with laws applicable to Northwestern Michigan College, including the Community College Act of 1966, the Freedom of Information Act, or the Open Meetings Act, as each may be amended from time to time, such laws shall control and supersede such provision(s).