Propósito

El propósito de esta política es garantizar la seguridad y el bienestar de los niños y adultos vulnerables mientras se encuentren en la biblioteca. La biblioteca se esfuerza por ofrecer un entorno acogedor, seguro y de apoyo para todos los visitantes, y esta política establece las expectativas respecto a los niños y adultos vulnerables que no se encuentren acompañados.

Alcance

Esta política se aplica a todas las personas que visitan la biblioteca, incluidos los niños y adultos vulnerables, y establece instrucciones sobre el comportamiento, la supervisión y las responsabilidades tanto del personal de la biblioteca como de los cuidadores de dichos individuos.

Definiciones

• Niños: Personas menores de 18 años.
• Adultos vulnerables: Personas mayores de 18 años que pueden tener una discapacidad física, mental o emocional que afecte su capacidad para cuidarse a sí mismas o tomar decisiones.
• Cuidador: Adulto responsable que acompaña a un niño o adulto vulnerable a la biblioteca, asegurando su seguridad y comportamiento adecuado.
• No acompañado: Se considera que un niño o adulto vulnerable está “no acompañado” si se encuentra en la biblioteca sin la presencia de un adulto responsable o cuidador.

Niños No Acompañados

Responsabilidad: Los padres, tutores y cuidadores son responsables de la supervisión y el comportamiento de los niños mientras se encuentren en la biblioteca.

Comportamiento: Si un niño está causando disturbios, incomodando a otros usuarios o comportándose de manera insegura, el personal de la biblioteca intentará contactar al adulto responsable. Si no es posible localizar al adulto, se podrá pedir al niño que se retire o permanecer en un área designada hasta que llegue el adulto responsable.

Fuera del horario de atención: Los niños deben ser recogidos a la hora de cierre de la biblioteca. Si no hay un adulto responsable presente a dicha hora, la biblioteca contactará a las autoridades locales para garantizar la seguridad del menor.

Adultos Vulnerables No Acompañados

Responsabilidad: Los adultos vulnerables deben estar acompañados por un cuidador, familiar u otro adulto responsable mientras estén en la biblioteca, a menos que puedan demostrar que son capaces de cuidarse por sí mismos de manera independiente.

Comportamiento: Si un adulto vulnerable se comporta de forma insegura o disruptiva, el personal de la biblioteca intentará contactar al adulto responsable o cuidador. Si no se puede localizar a ningún cuidador, el personal podrá contactar a los servicios de emergencia para solicitar asistencia.

Apoyo: La biblioteca se compromete a proporcionar adaptaciones razonables para ayudar a los adultos vulnerables a acceder a los servicios bibliotecarios. Esto puede incluir apoyo adicional del personal, recursos accesibles o asistencia para garantizar su seguridad y comodidad.

Funciones y Responsabilidades del Personal de la Biblioteca

Supervisión de la seguridad: El personal de seguridad de la biblioteca supervisará los espacios para identificar la presencia de niños y adultos vulnerables no acompañados, y garantizar su seguridad. Intervendrán si es necesario para prevenir daños o resolver conductas disruptivas.

Comunicación con cuidadores: Si se encuentra a un niño o adulto vulnerable no acompañado, el personal de seguridad intentará contactar de inmediato al adulto responsable o cuidador. Si está disponible, se utilizará la información de contacto registrada.

Manejo de emergencias: En caso de emergencia, el personal de seguridad priorizará la seguridad y el bienestar de la persona afectada, y podrá contactar a los servicios de emergencia según se requiera.

Incumplimientos

Niños no acompañados: Si un niño se encuentra no acompañado y no hay un adulto responsable disponible, el personal intentará contactar a sus padres o cuidadores. Si no se logra establecer contacto, se podrá llamar a las autoridades para garantizar la seguridad del menor.

Adultos vulnerables no acompañados: Si un adulto vulnerable se encuentra sin cuidador y en situación de angustia, el personal de la biblioteca tomará las medidas apropiadas para brindar asistencia, incluyendo contactar a los servicios de emergencia o servicios sociales si fuera necesario.

Excepciones

Programas y eventos: En ciertos programas y eventos organizados por la biblioteca, los niños y adultos vulnerables pueden permanecer bajo el cuidado de personal capacitado o voluntarios de la biblioteca. Las instrucciones del programa comunicarán claramente estas excepciones.

Esta política se aplica en conjunto con la ordenanza de Reglas de Conducta y el Artículo V de la Declaración de Derechos de las Bibliotecas, Acceso Libre a las Bibliotecas para Menores.

Aprobado por la Junta Directiva el 14 de enero de 2025

Background

Indirect costs, also known as facilities and administrative costs (F&A costs), are the institutional or infrastructure costs of managing and running programs that cannot be directly attributed to a program or activity. These costs include items such as printing, equipment use, accounting, utilities, professional development, security, ITS, and administrative costs that are hard to calculate but are true costs for running programs.

This policy is designed to establish the internal processes necessary to ensure consistency and uniformity in cost allocation for both direct and indirect costs. This policy provides consistent principles and standards for determining costs of federal awards carried out through grants, cost reimbursement contracts, and other agreements with governmental units. This policy applies to all employees and officers of GBPLD.

Requirements

• All costs incurred are either direct costs or indirect costs depending on final cost objectives.
• Expenditures charged as direct costs will be consistently and economically identified to an item of work associated with a given project, task, or other cost objective.
• Expenditures not readily subject to treatment as direct costs because of their occurrence for common or joint objectives may be charged as indirect costs. These costs may be assigned to indirect overhead pools for collection and allocated to the project’s benefiting objectives.
• Routine administrative and overhead functions may be charged to appropriate (overhead) accounts and pools.

Responsibilities

• GBPLD will use the Negotiated Indirect Cost Rate Agreement (NICRA) rate when applicable.
• The CEO and Director of Grants are responsible for drafting and finalizing any future indirect cost rate agreements and extensions and ensuring there is consistency in:
  • Classification of costs incurred, and functions performed as direct or indirect costs or activities.
  • Establishment of indirect cost pools for indirect activities and support.
  • Assignment of indirect cost elements to overhead pools.
• GBPLD will use the 15% de minimis cost rate allowed under 2 CFR 200.414(f) and 45 CFR Part 75.414(f) for awards that allow indirect cost recovery and where a NICRA has not been established.
• The Director of Grants will ensure the appropriate documentation for all costs is retained for a minimum of three (3) years.

(8/2025)

This policy establishes Gail Borden Public Library District’s (GBPLD) internal controls to safeguard Personally Identifiable Information (PII) and other sensitive information. GBPLD complies with the provisions of the Identity Protection Act (5 ILCS 179/1 et seq.), the Library Records Confidentiality Act (75 ILCS 70/), as well as relevant federal regulations including 2 CFR 200.303(e). This policy applies to all employees, officers, and contractors doing business with GBPLD.

Definitions

• Personally Identifiable Information (PII): Information that can be used to distinguish or trace an individual's identity, either alone or when combined with other personal or identifying information that is linked or linkable to a specific individual.
• Protected Personally Identifiable Information (Protected PII): PII that is not required to be disclosed by law.
• Sensitive Information: Information that GBPLD has determined should be treated with a higher standard of care.

Identifying PII and Sensitive Information

PII is any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means. It requires a case-by-case assessment of the specific risk that an individual can be identified. Further, PII is defined as information:

• That directly identifies an individual (e.g., name, address, social security number or other identifying number or code, telephone number, email address, etc.) or
• By which specific individuals can be identified in conjunction with other data elements, i.e., indirect identification. (These data elements may include a combination of gender, race, birth date, geographic indicator, and other descriptors).

Additionally, information permitting the physical or online contacting of a specific individual is the same as PII. This information may be in the form of paper, electronic, or other media. Examples of PII include, but are not limited to: names, addresses, social security numbers, credit card numbers, bank numbers, biometrics, date and place of birth, mother's maiden name, criminal, medical, and financial records, and educational transcripts.

GBPLD may designate any information as sensitive or confidential even if it does not fall into the category of PII.

Requirements

GBPLD must take reasonable cybersecurity and other measures to safeguard information including protected PII. This also includes information a federal awarding agency or pass-through entity designates as sensitive or other information GBPLD considers sensitive and is consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.

GBPLD Safeguards PII and other sensitive information by:

• Educating Staff about Risks and Responsibilities: GBPLD personnel who have access to PII or sensitive information receive training about the risks of disclosure and their responsibilities for protection of this type information.
• Limiting Collection and Access: GPLD collects the minimum information that is necessary to fulfill its objectives and avoids collection of unnecessary PII. Only employees who are required to use or handle PII or sensitive information will have access to such information. GBPLD has established administrative, technical, and physical safeguards to protect PII commensurate with the risk and magnitude of the harm that would result from its unauthorized access, use, modification, loss, destruction, dissemination, or disclosure. Physical files with PII or sensitive information are secured in filing cabinets, locked offices, and secured buildings as appropriate. Sensitive electronic files are protected through security mechanisms including the use of multi-factor authentication and encryption as appropriate.
• Appropriately Maintaining Records: GBPLD follows all applicable records management laws, regulations, and policies. Records are not maintained longer than required. Records containing PII or other sensitive information are disposed of appropriately.
• Redacting Protected PII from Records Subject to Release: As a public organization and a recipient of federal funds, certain GBPLD records may be subject to release under the Freedom of Information Act (FOIA). Protected PII will be redacted from documents prior to release.

Incident Response

A data breach occurs when PII or other sensitive information is viewed, leaked, or accessed by anyone who is not the individual, or someone authorized to have access to this information as part of his/her official duties. Staff must promptly report all suspected compromises of PII or sensitive information to their immediate supervisor or Department Director. Violations of GBPLD’s information security policies will be referred to the Chief Executive Officer and personnel may be disciplined for security violations or irresponsible use.

Responsibilities

• Department Directors will ensure personnel receive appropriate training on the protection of PII and sensitive information related to their duties.
• The Chief Executive Officer will oversee the implementation and enforcement of this policy to ensure compliance.

Review of this Policy

The GBPLD Board of Trustees will review this policy annually to maintain best practices.

Related Policies

Identity Protection

Personnel Records and Confidentiality

(8/2025)

This policy is designed to establish techniques and procedures for the proper comparison of financial records, such as transactions, accounts, and statements, to ensure accuracy, consistency, and integrity in GBPLD’s financial data. This policy establishes internal controls to effectively and efficiently minimize the risks associated with financial reconciliation practices, reduce the risks of fraud and costly errors, and protect the assets of the GBPLD. This policy applies to all employees, officers, and contractors doing business with GBPLD.

Requirements

• GBPLD will perform financial reconciliation in accordance with generally accepted accounting principles (GAAP) to provide accuracy and consistency in financial accounts.
• GBPLD will ensure written procedures exist for all applicable financial reconciliation activities, including but not limited to bank reconciliation, account reconciliation, invoice reconciliation, and balance sheet reconciliation.
• GBPLD will ensure responsibilities for financial reconciliation are segregated from collections and general ledger posting.
• Reconciliations will be performed consistently, and documentation will be maintained for audit purposes.
• GBPLD will ensure accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329.
• To the extent possible, GBPLD will complete reconciliations prior to the certification of financial statements or financial reports. When it is not possible, reconciliations should be completed as soon as practicable after the issuance of statements or reports.

Responsibilities

• The Director of Finance will create written procedures for all forms of reconciliation that at a minimum address comparing internal records with various statements or reports, identifying and recording discrepancies, and resolving errors and balancing records.
• Written procedures will be reviewed and approved by the Director of Finance on an annual basis. They are also responsible for enforcing the segregation of duties and recommending improvements to the reconciliation process.
• The Director of Finance will complete reconciliations quarterly, monthly, or more frequently as needed, addressing specific aspects of GBPLD's financial activities. They are also responsible for maintaining appropriate documentation, escalating problems or variances with reconciliations, and providing justifications for material discrepancies.

(8/2025)

This policy is designed to establish the techniques and procedures to properly ensure adequate monitoring of program performance and the reporting of project activities sufficient to assure compliance with the program and fiscal requirements of the project and demonstrate project accomplishment. This policy applies to all employees, officers, and contractors doing business with GBPLD.

Requirements

Performance Monitoring

• GBPLD will ensure that all grant activities are conducted in a timely manner, and in accordance with the award agreement.
• GBPLD will assess internal continuing capacity to implement the approved project.
• GBPLD will identify potential problem areas to assist in complying with applicable laws and regulations.

Reporting

• GBPLD will prepare and submit all reports required by funding sources in a timely and accurate manner in accordance with the provided instructions.
• GBPLD will maintain legible copies of documentation that will set forth details sufficient for a proper pre-audit and post-audit review.
• GBPLD will submit written reports on progress and outcomes of the project as described in the approved project. Progress reports may include updates on
  • Tasks – Specific activities that are required to be performed to complete the Project Narrative/Scope of Work goals and objectives.
  • Deliverables - Products and/or services that directly relate to a task specified in the Scope of Work. Deliverables must be quantifiable, measurable, and verifiable.
  • Performance Metrics – Pre-established performance expectations for the delivery of services or production of resources.

Responsibilities

Performance Monitoring

• The Director of Finance and Director of Grants will oversee project activities to ensure total compliance with 2 CFR 200, Uniform Administrative Requirements, applicable Cost Principals and Audit Requirements for Federal Awards, applicable federal program statutes and regulations, and the terms and conditions of award agreements.
• The Director of Finance and Director of Grants will assist in resolving compliance problems through discussion, negotiation, and the provision of technical assistance and training.
• The Director of Finance and Director of Grants will provide adequate follow-up measures to ensure that performance and compliance deficiencies are corrected and not repeated.

Reporting

• The Director of Finance prepares and the Director of Grants reviews the SF-425 report to ensure it is completed on time and complies with the OMB Form Instructions, using cumulative financial data from the sponsor’s payment system and the GBPLD financial system to complete the report. The Chief Executive Officer will review and approve the SF-425.
• Research staff is responsible for ensuring all performance/programmatic reporting complies with established federal requirements as well as any additional requirements set forth by the Grant Award Notice or Special Conditions. The Director of Grants will review and approve programmatic reporting before submission to the sponsor.

Board Approved 5/14/2024

This policy is designed to establish the techniques and procedures to properly prepare, comply, and cooperate with any inspections, reviews, investigations, or audits deemed necessary. Grants awarded by the federal government are subject to on-site monitoring and/or audits. This policy applies to all employees, officers, and contractors doing business with the GBPLD.

Pre-Monitoring

In preparation for the reviews, the Director of Grants will perform the following pre-monitoring tasks:

• Become thoroughly familiar with the program;
• Develop a clear understanding of the governing statutes, regulations, and official guidance.
• Review and analyze reports, available data, and financial information, from previous monitoring reports and issues;
• Determine the programs/areas/functions to be reviewed;
• Determine the data or information to be submitted prior to monitoring (if any);
• Prepare the staff members who will need to be consulted during the monitoring; and
• Finalize the schedule for conducting the monitoring tasks and the anticipated time frames.

On-Site Monitoring

On-site reviews involve monitoring overall program administration and can include examining information and materials provided to the awarding agency by GBPLD to track performance and identify potential problem areas. The monitoring event is designed to assess and document compliance with the requirements based on:

• File reviews to determine the accuracy of the information, using both automated and manual data and reports submitted by GBPLD; and
• Interviews with staff to clarify and determine the accuracy of the information.

The documents reviewed include activity status reports, if applicable, monthly review of the project schedule, monthly project updates, and financial information to assess performance and look for indicators of performance or compliance problems. In addition, GBPLD may submit progress reports that include the activity showing the progress, accomplishments, barriers, and spending patterns against planned activities and accomplishments.

Post-Monitoring

At the end of the review, the monitoring agency will provide GBPLD with a formal written notification of the results of the monitoring review. The letter will outline any concerns, findings, recognize successes, and the deadline for a written response to correct actions. An important and fundamental principle of the monitoring process is the documentation of deficiencies when there is evidence that a statute, regulation, or requirement has been violated but it retains discretion in identifying appropriate corrective action(s) to resolve deficiencies. An equally fundamental principle is that GBPLD has a process to respond to and resolve deficiencies.

Identified monitoring deficiencies require corrective action. The corrective action responsibility rests both with the awarding agency and GBPLD. GBPLD has a responsibility to determine, or assist the awarding agency in determining, the reason a requirement was violated or provide evidence of compliance.

A key piece of effective monitoring is the ability to identify the root cause(s) of any identified deficiencies, or whether the problem is an isolated occurrence or systemic. Such knowledge leads to the development of optimal corrective actions. In some cases, GBPLD may need to determine appropriate action if compliance is not possible.

Board Approved 5/14/2024

This policy establishes the internal processes necessary to ensure consistency and uniformity in cost estimating and budget development. This policy applies to all employees, officers, and contractors doing business with GBPLD and to all sources and uses of funding received by GBPLD.

Requirements

• Budget development processes shall be properly documented, measured, and managed to ensure accuracy, financial transparency, strict compliance with generally accepted accounting principles (GAAP), reporting requirements, and continuous improvement.
• Budget development practices must comply with all applicable government laws and regulations.
• Estimating, budgeting, and accounting practices must be consistent with those practices used for accumulating and reporting costs.
• Estimating, budgeting, and accounting practices must comply with generally recognized and government approved cost principles and accounting standards (GAAP).
• Illinois Statutes are followed in determining timing and final dates of action.
  • The GBPLD Fiscal Year is July 1 through June 30.

Responsibilities

• GBPLD Managers will project departmental needs for the upcoming fiscal year and report to their Division Chiefs.
• Division Chiefs will consolidate their departments’ budget information and submit to the Director of Finance (DOF).
• The DOF will prepare the District budget for review by Cabinet.
• Cabinet will balance the proposed budget with anticipated tax revenues and make final decisions for line-item cuts.
  • Cabinet must include Division Chiefs, the Chief Executive Officer, and both Chief Operating Officers.
• Preliminary draft budget will be presented at the June Board of Trustees meeting and approved at the July Board meeting.
• Budget appropriation document will be approved in September of the same FY.

Board approved 5/14/2024

The GBPLD is committed to the highest possible standards of openness, transparency, and accountability in all its affairs. We wish to promote a culture of honesty and opposition to fraud in all its forms. The purpose of this policy is to provide:

• A clear definition of what we mean by “fraud”.
• A definitive statement to staff forbidding fraudulent activity in all its forms.
• A summary to staff of their responsibilities for identifying exposures to fraudulent activities and for establishing controls and procedures for preventing such fraudulent activity and/or detecting such fraudulent activity when it occurs.
• Guidance to employees as to action which should be taken where they suspect any fraudulent activity.
• Clear guidance as to responsibilities for conducting investigations into fraud related activities. Protection to employees in circumstances where they may be victimized as a consequence of reporting, or being a witness to, fraudulent activities.

Definition

GBPLD defines fraud as: "The theft or misuse of GBPLD funds or other resources by an employee, officer, vendor, contractor, or an independent third-party provider, which may or may not also involve misstatement of financial documents or records to conceal the theft or misuse.”

For example, fraud includes but is not limited to the following:

• Theft of funds or any other GBPLD property.
• Falsification of costs or expenses.
• Forgery or alteration of documents.
• Destruction or removal of records to conceal fraudulent behavior.
• Inappropriate personal use of GBPLD assets.
• Employees seeking or accepting cash, gifts, or other benefits from third parties in exchange for preferment of the third parties in their dealings with GBPLD.
• Blackmail or extortion.
• Paying excessive prices or fees to third parties with the aim of personal gain.

Responsibilities of Employees

Managers

It is the responsibility of managers to be familiar with the types of fraud that might occur in their area, be alert for any indication of fraud or improper activity, and maintain controls to avoid such occurrences. Managers are required to ensure that all staff under their control are given a copy of this policy in a language they can understand and acknowledge its receipt. Managers should also ensure that staff are encouraged to report suspected issues of fraud.

All Staff

It is the responsibility of all employees to carry out their work in such a way as to prevent fraud from occurring in the workplace. Employees must also be alert for occurrences of fraud, be aware that unusual transactions or behaviors could be indications of fraud, and report potential cases of fraud as outlined below.

Reporting Suspected Fraud

Employees are required to report issues of suspected fraud. Employees should report their suspicions as follows:

• To the Chief Executive Officer.
• To the President of the GBPLD Board of Trustees.

Employees who suspect fraud should not do any of the following:

• Contact the suspected individual(s) directly in an effort to determine facts, demand explanations, or restitution.
• Discuss the issue with anyone within GBPLD other than the people listed above.
• Discuss the issue with anyone outside of GBPLD, except as required by law.

Additional information can be found in the GBPLD Whistleblower Policy (2.45).

Dealing with Reports of Suspected Fraud

Any suspicions of fraud will be taken seriously by GBPLD. GBPLD expects its managers to deal firmly and quickly with any reports of suspected fraud. Managers receiving reports of suspected fraud must immediately identify the issue and propose actions to the President of the GBPLD Board of Trustees.

Investigation Guidelines

Arrangements must be made for a comprehensive investigation of the issue. The following are responsible for managing these investigations:

• President of the GBPLD Board of Trustees who will bring the issue to:
  • Compliance Officer and Secretary of the GBPLD Board of Trustees, or if either of these individuals is implicated to another member of the Executive Committee of the Board.
  • The employee’s immediate supervisor if the supervisor is not implicated.
  • The President of the GBPLD Board of Trustees will assign responsibility to the senior management team and/or other GBPLD Board members to investigate and report back.

All work of the investigation team should be documented, including transcripts of interviews conducted. The conclusion of all fraud investigations must be documented and reported to the GBPLD Board of Trustees. The person(s) who initially reported the suspicions should be informed of the outcome of the investigation, but this should be done only once the report and proposed course of action has been finalized.

Safeguards for Employees

Harassment or Victimization

GBPLD recognizes that the decision to report a suspicion can be a difficult one to make, not least because of the fear of reprisal from those responsible for the malpractice. GBPLD, in accordance with its Human Resource Policies, will not tolerate harassment or victimization and will take all practical steps to protect those who raise an issue in good faith. The Whistleblower Protection Act has been expanded to include grant recipients. Under Title 41, United States Code, Section 4712, it is illegal for an employee of a Federal contractor, subcontractor grantee, or subgrantee or personal services contractor to be discharged, demoted, or otherwise discriminated against for making a protected whistleblower disclosure. Also, under Presidential Policy Directive (PPD-19), an action affecting access to classified information cannot be taken in reprisal for protected whistleblowing.

Confidentiality

GBPLD will endeavor to protect an individual’s identity when he or she raises an issue and does not want their name to be disclosed. It should be understood, however, that an investigation of any malpractice may need to identify the source of the information and a statement by the individual may be required as part of the evidence.

Anonymous Allegations

GBPLD discourages anonymous allegations. Issues expressed anonymously will be considered at the discretion of the GBPLD Board Trustees. In exercising this discretion, the factors considered will include:

• The seriousness of the issues raised.
• The credibility of the allegations and the supporting facts.
• The likelihood of confirming the allegation from attributable sources.

Untrue Allegations

If an allegation is made in good faith, but it is not confirmed by an investigation, GBPLD guarantees that no action will be taken against the complainant. If, however, individuals make malicious or vexatious allegations, disciplinary action will be considered against the individual making the allegation.

Actions Arising from Fraud Investigations

Disciplinary Procedures

Persons judged guilty of fraud or who have committed gross misconduct may be dismissed. Where appropriate, GBPLD will refer significant fraud to the local law enforcement agencies to initiate criminal prosecution.

Recovery of losses

Where GBPLD has suffered loss, full restitution will be sought of any benefit or advantage obtained and the recovery of costs will be sought from the individual(s) or organizations responsible for the loss. If the individual or organization cannot or will not make good the loss, consideration will be given to taking civil legal action to recover losses. This is in addition to any criminal proceedings which may result.

Review of this Policy

The contents of this Anti-Fraud Policy will be reviewed by the GBPLD Board of Trustees on an annual basis.

References

Referenced GBPLD policies include:

• GBPLD Whistleblower Policy (2.45)

Approved by the Board 4/9/2024