System and Member Library Relationship Policy

OWWL Library System’s Purpose

The OWWL Library System exists to expand and strengthen public library services across Ontario, Wayne, Wyoming, and Livingston Counties. The System provides consultation services, technology support, and guidance on library operations and governance. It also facilitates discussion, coordinates services, and manages the distribution of State and Federal aid to its member libraries.

System Relationships with Member Libraries

The System supports its 42 member libraries through continuing education, policy and governance consulting, administrative guidance, and technology services. All advice and recommendations from System staff are advisory in nature and should not substitute for legal counsel or certified professional consultation.

Each member library is independently governed by its own Board of Trustees. The System does not hold any administrative, managerial, or governance authority over member libraries, except where System policies apply to shared services, resources, or support infrastructure.

The System plays no role in the hiring, supervision, or employment of staff at member libraries. Each library employs its own director and staff and oversees its own organizational structure.

The System is not responsible for decisions made by member library boards or administrations, and it assumes no liability for local governance, management, or fiscal actions. The System has no financial obligations to member libraries except where outlined in approved contracts or in accordance with New York State Education Law regarding the disbursement of State Aid.

The OWWL Library System and its member libraries operate as separate entities. Member libraries and external organizations may not use OWWL Library System information for business purposes (e.g., vendor negotiations, pricing, contracts) without explicit written approval. Any unauthorized use of such information will be considered invalid and without legal effect.

The System offers training and continuing education for library staff and trustees; however, it is the responsibility of each individual or library to document participation in compliance with institutional or State requirements.

The System provides technology support to member libraries only as outlined in the Computer Support Policy. It holds no responsibility for library-owned technologies or software outside the scope of that policy.

The System supports public library services and does not advocate for any individual or group outside the context of serving its member libraries.

System Policies Impacting Member Libraries

The following policies directly impact the relationship between the System and its member libraries. Adherence to these policies is required for access to System support, services, programs, and membership:

• Acceptable Use and Internet Safety Policy – Sets Children’s Internet Protection Act (CIPA) requirements for E-Rate funding to subsidize member library Internet costs.
• Brand Usage Policy – Defines appropriate use of the “OWWL” name and logos.
• Code of Conduct Policy – Establishes expectations for interactions with System staff.
• Collection Management and Circulation Policy – Outlines procedures for System collections and interlibrary loan.
• Computer Support Policy – Details the scope and limits of System technology support.
• Confidentiality of Patron Records Policy – Complies with Civil Practice Law §4509 regarding the protection of patron information.
• Data Breach Policy – Defines roles and responsibilities related to data security incidents.
• Delivery Policy – Details guidelines for System delivery service to libraries.
• E-Rate Participation and Compliance Policy – Outlines shared responsibilities under the Federal E-Rate Program.
• Email Account and Use Policy – Establishes rules for creating and using System-managed email accounts.
• Mileage and Scholarship Reimbursement Policy – Specifies requirements for mileage and scholarship reimbursements.
• Minimum Standards Compliance Confirmation Policy – Requires member libraries to annually certify compliance with New York State’s Minimum Standards by board action and submit a signed confirmation form to support System reporting.
• New York State Aid for Library Construction Policy – Provides requirements and guidance for applying to the NYS Library Construction Aid program.
• Pest Management Policy – Details procedures for managing pest outbreaks in library facilities.
• Procurement Policy – Defines System procurement processes on behalf of member libraries; does not impact local purchasing decisions.
• Support for Trustee Education Requirements Policy – Outlines System support for libraries meeting the trustee education mandate.
• Systems Access and Confidentiality of Library Records Policy – Sets requirements for accessing Evergreen, email, and patron data.
• Wi-Fi Access Policy – Establishes rules for managing wireless access points at member libraries.

All policies are available at: https://owwl.org/system/policies/  

Consultations on Sensitive Information

Consultations involving sensitive topics (such as governance, personnel, funding, or administrative authority) are limited to the System Executive Director and member library administrators (Directors and/or Trustees).

These communications are considered confidential unless disclosure is necessary to prevent legal, financial, or reputational harm. System staff may share sensitive concerns with the Executive Director as appropriate.

Requesting Support

Member libraries are encouraged to contact the System for support on a wide range of topics, including governance, policy, finance, outreach, continuing education, and day-to-day library operations. The Executive Director and System staff are available to provide guidance, answer questions, and connect libraries with the appropriate resources or services.

For all technology-related issues (including Evergreen support, cataloging, hardware, and software) libraries must submit a support ticket through the System’s Help Desk. This ensures timely response, clear communication, and accurate tracking of ongoing or recurring issues. Additional details are provided in the Computer Support Policy.

Agreements between Member Libraries and the System

All agreements between the System and its member libraries are reviewed and/or renewed annually. These include, but are not limited to:

• System Plan of Service
• Free Direct Access Plan
• Evergreen Cost Shares
• OverDrive Funding Commitments

System-Wide Decision Making

When System-wide policies, activities, or agreements may affect member libraries, the System may present them to Directors for discussion and input. Final authority on all decisions rests with the OWWL Library System Board of Trustees. 

Enforcement of System and Member Library Policies

The OWWL Library System respects the independent governance of each member library and does not seek to manage, oversee, or interfere with local library operations. However, the System has a critical responsibility to protect the integrity, security, and lawful use of shared resources, sensitive patron data, and System-wide services.

Our strength as a System comes from the collective integrity, diligence, and dedication of each member library. The services we provide, the technology we share, and the trust our communities place in us depend on consistent adherence to the laws, regulations, and policies that guide our operations. Every library that meets or exceeds these standards makes the entire System more resilient, effective, and respected.

Policies and regulations for public libraries exist to ensure consistency, equity, and accountability across our shared system. Over time, adherence to some requirements can become uneven due to shifting priorities, staff turnover, or the complexity of multiple overlapping standards. The System’s enforcement approach is designed to restore consistency and provide clear expectations, supporting libraries in maintaining compliance through communication, guidance, and accountability.

Compliance with System policies that govern access, confidentiality, conduct, and shared infrastructure is therefore mandatory. Enforcement actions are intended to safeguard the entire System and its member libraries, not to assume a compliance or governance role over individual libraries.

Consequences of Non-Compliance

Compliance with System policies is required at all times. Libraries are expected to maintain ongoing adherence and promptly address any known gaps.

Because these requirements have been clearly communicated to libraries, the System will take immediate action when violations are confirmed. The level of response depends on the type and severity of the violation. Libraries that identify and report issues proactively, and present a plan to address them, will not face penalties (see Self-Reporting Exception below).

Standard Enforcement Process

1. Immediate Action (Critical Violations Only) – Confirmed violations that compromise System security, integrity, or compliance will trigger automatic loss of the Evergreen subsidy and any other necessary service suspensions. This applies to violations of the Systems Access and Confidentiality of Library Records Policy, Computer Support Policy, Wi-Fi Access Policy, E-Rate Participation and Compliance Policy, Acceptable Use and Internet Safety Policy, Data Breach Policy, Confidentiality of Patron Records Policy, or Minimum Standards Compliance Confirmation Policy.
2. Written Notice (All Violations) – The System will document all violations and communicate the findings, applied or potential consequences, and required corrective steps to the library director and board president.
3. Follow-Up Review (All Violations) – The System will confirm that corrective actions have been completed within the timeframe provided.
4. Escalation of Consequences (All Violations) – Continued, repeated, or willful non-compliance will result in additional actions, up to and including referral to the Commissioner of Education or the OWWL Library System Board of Trustees.

Potential Consequences

1. Loss of Evergreen Subsidy – Confirmed violations of critical policies, or repeated violations of non-critical policies, will result in revocation of the Evergreen subsidy for the fiscal year in which the violation is confirmed.
2. Suspension of System Services – Violations may result in the suspension of consultation, computer support, cataloging, or other staff assistance, with support limited to system-wide emergencies.
3. Restriction from Shared Programs – Violations may result in suspension from participation in delivery, OverDrive, or other System-supported initiatives.
4. Ineligibility for System-Sponsored Grant Programs – Violations may result in ineligibility to apply for or receive grants facilitated or administered by the System.
5. Withholding of Aid – Violations may result in the withholding of State or Federal aid administered through the System until compliance is demonstrated.
6. Ineligibility for Construction Aid – Violations may result in loss of eligibility for State aid under the library construction program.
7. E-Rate Filing Suspension – Violations may result in suspension of System filing of E-Rate applications on behalf of the library until compliance is restored.
8. Financial Liability for Legal or Corrective Costs – Violations may result in the library being held responsible for any legal counsel fees, financial damages, or other costs incurred by the System or by third parties as a direct result of the library’s non-compliance.
9. Referral to the Commissioner of Education – Serious or repeated violations may result in referral to the Commissioner of Education for review or further action.
10. Referral to the OWWL Library System Board of Trustees – Willful, repeated, or egregious violations may result in referral to the OWWL Library System Board of Trustees for consideration of additional sanctions, including suspension of membership benefits or termination of participation in the OWWL Library System, in accordance with New York State Education Law.

Discretion and Consistency

The System applies enforcement consistently across all member libraries. However, discretion may be exercised to address exceptional, time-sensitive, or high-risk circumstances that pose a direct threat to shared services or data security. Any such deviations will be documented and communicated in writing to the affected library.

Self-Reporting Exception

If a library identifies a compliance issue on its own and promptly reports it to the System, no penalties will be applied provided:

1. The library acknowledges the issue openly and directly with the System.
2. The library presents a plan for correcting the issue or requests assistance from the System to correct it.
3. Corrective actions are completed within a reasonable timeframe agreed upon with the System.

Auditing and Verification

The System may request documentation or conduct reviews to verify compliance with policies. Examples include:

• Signed staff acknowledgment forms for Evergreen and email access, cross-checked against active accounts.
• Verification of 24/7 Wi-Fi access.
• Annual confirmation of compliance with Minimum Standards, supported by board resolutions.
• Review of OWWL brand/logo use on websites and promotional materials.
• Monitoring of delivery compliance and cataloging procedures.
• Confirmation that all Trustees have completed their required two hours of continuing education according to State Education Law 260-d.

Audits may be scheduled or unannounced. Findings will be shared with the library director and board president.

Obligation to Comply

Even when consequences are applied, libraries remain responsible for correcting violations and maintaining compliance with System policies.

Last Updated by the OWWL Library System Board of Trustees on November 13, 2025