# Oneida Business Committee (2026)

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/tribal%3Aoneida_nation%3A24c9b2a02a96ebcd

## Record

- **Collection:** Tribal code
- **Document type:** Tribal code

## Text

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Oneida Nation

Oneida Business Committee
Legislative Operating Committee
PO Box 365 • Oneida, WI 54155-0365

Oneida-nsn.gov

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ONEIDA

LEGISLATIVE OPERATING COMMITTEE MEETING AGENDA
Business Committee Conference Room - 2nd Floor Norbert Hill Center
June 3, 2026
9:00 a.m.

I.

Call to Order and Approval of the Agenda

II.

Minutes to be Approved
1. May 20, 2026 LOC Meeting Minutes (pg. 2)

III.

Current Business
1. Pardon and Forgiveness Law Amendments (pg. 4)

IV.

New Submissions
1. Petition: G. Powless-Buenrostro – Amend the Judiciary Law #2026-01 (pg.
38)

V.

Additions

VI.

Administrative Updates
1. Certification of the Technology Resources Law Rules (pg. 39)

VII.

Executive Session

VIII. Recess/Adjourn

A good mind. A good heart. A strong fire.

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Oneida Nation

Oneida Business Committee
Legislative Operating Committee
PO Box 365 • Oneida, WI 54155-0365
Oneida-nsn.gov

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ONEIDA

LEGISLATIVE OPERATING COMMITTEE MEETING MINUTES
Oneida Business Committee Conference Room-2nd Floor Norbert Hill Center
May 20, 2026
9:00 a.m.
Present: Jameson Wilson, Jennifer Webster, Jonas Hill, Kirby Metoxen
Unexcused: Marlon Skenandore
Others Present: Grace Elliott, Carolyn Salutz
Others Present on Microsoft Teams: Clorissa Leeman, Ashley Blaker, Chad Fuss, Fawn Cottrell,
Jessalyn Havarth, Kaylynn Biely, Melissa Alvarado, Rae Skenandore, Shannon Stone, David Jordan, Tavia James-Charles, Fawn Billie, Kristal Hill, Sarah White, Ralinda Ninham-Lamberies, Eric
Boulanger, Jason Martinez, Katsitsiyo Danforth
I.

Call to Order and Approval of the Agenda
Jameson Wilson called the May 20, 2026, Legislative Operating Committee meeting to
order at 9:00 a.m.
Motion by Jonas Hill to adopt the agenda; seconded by Jennifer Webster. Motion carried
unanimously.

II.

Minutes to be Approved
1. May 6, 2026 LOC Meeting Minutes
Motion by Kirby Metoxen to approve the May 6, 2026, LOC meeting minutes and forward
to the Oneida Business Committee; seconded by Jonas Hill. Motion carried unanimously.

III.

Current Business
1. Elder Protection Law
Motion by Jennifer Webster to approve the public comment review memorandum with
LOC consideration, the updated legislative analysis, and final draft of the Elder Protection
law; seconded by Jonas Hill. Motion carried unanimously.
Motion by Jennifer Webster to approve the fiscal impact statement request memorandum
and direct the Finance Department to provide the LOC with a fiscal impact statement of
the proposed Elder Protection law by June 5, 2026; seconded by Jonas Hill. Motion carried
unanimously.
2. Uniform Commercial Code
Motion by Jennifer Webster to approve the public comment review memorandum, updated
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Legislative Operating Committee Meeting Minutes of May 20, 2026
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legislative analysis, and final draft of the Uniform Commercial Code.; seconded by Jonas
Hill. Motion carried unanimously.
Motion by Jennifer Webster to approve the fiscal impact statement request memorandum
and direct the Finance Department to provide the LOC with a fiscal impact statement of
the proposed Uniform Commercial Code by June 19, 2026.; seconded by Jonas Hill. Motion carried unanimously.
3. Eviction and Termination Law Amendments
Motion by Jennifer Webster to approve the updated public comment review memorandum,
draft, and legislative analysis; seconded by Kirby Metoxen. Motion carried unanimously.
Motion by Jennifer Webster to approve the fiscal impact statement request memorandum
with revision to the due date and direct that the Finance Administration provide the LOC a
fiscal impact statement for the proposed Eviction and Termination law amendments by
June 19, 2026; seconded by Jonas Hill. Motion carried unanimously.
IV.

New Submissions

V.

Additions

VI.

Administrative Updates

VII.

Executive Session

VIII. Adjourn
Motion by Jennifer Webster to adjourn at 9:19 a.m.; seconded by Jonas Hill. Motion carried
unanimously.

Legislative Operating Committee Meeting Minutes of May 20, 2026
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Oneida Nation
Oneida Business Committee
Legislative Operating Committee
PO Box 365 • Oneida, WI 54155-0365
Oneida-nsn.gov

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ONEIDA

Legislative Operating Committee
June 03, 2026

Pardon and Forgiveness Law
Amendments
Submission Date: 2/5/26
LOC Sponsor: Jonas Hill

Public Meeting: N/A
Emergency Enacted: N/A

Summary: This item was added to the Active Files List on February 18, 2026 at the request
of the Oneida Business Committee to allow flexibility in pardon eligibility when fines prevent
payment.
2/18/26 LOC: Motion by Jennifer Webster to add the Pardon and Forgiveness Law Amendments to
the Active Files List with Jonas Hill as the sponsor; seconded by Kirby Metoxen.
Motion carried unanimously.
2/25/26:

Work Meeting. Present: Kelly McAndrews, Grace Elliott. The purpose of this meeting
was to review attorney McAndrew’s comments on the proposed amendments to the
Pardon and Forgiveness law.

2/27/26:

Work Meeting. Present: Grace Elliott, Peggy VanGheem. The purpose this meeting
was to review attorney VanGheem’s comments on the proposed amendments to the
Pardon and Forgiveness law.

3/4/26:

Work Meeting. Present: Jameson Wilson, Jennifer Webster, Jonas Hill, Kirby
Metoxen, Carolyn Salutz, Kristal Hill, Fawn Billie, Clorissa Leeman, Grace Elliott.
The purpose of this meeting was to provide an update and complete a read through of
the amendments for LOC review and initial approval to move forward through the
legislative process.

5/14/26:

Public Meeting Held. No individuals provided comment during the public
comment meeting.

5/21/26:

Public Comment Closed. No individuals provided written comments.

Next Steps:
▪ Approve the public comment review memorandum, updated legislative analysis, and final
draft of the proposed Pardon and Forgiveness law amendments.
▪ Approve the Fiscal Impact Statement Request memorandum and direct that the Finance
Department provide the LOC a Fiscal Impact Statement for the proposed Pardon and
Forgiveness law amendments by June 25, 2026.
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Oneida Nation
Legislative Operating Committee
Legislative Reference Office
PO Box 365 • Oneida, WI 54155-0365
Oneida-nsn.gov

TO:
FROM:
DATE:
RE:

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ONEIDA

Legislative Operating Committee (LOC)
Grace Elliott, Legislative Reference Office, Staff Attorney
June 3, 2026
Pardon and Forgiveness: Public Comment Review

On May 14, 2026, a public meeting was held regarding amendments to the Pardon and Forgiveness
Law. No individuals provided comments during the public meeting. The public comment period
was then held open until May 21, 2026. No individuals submitted comments during the comment
period. This memorandum is submitted as a review of the comments received during the public
comment period. The public meeting draft and public meeting transcript are attached to this
memorandum for review.

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Oneida Nation
Oneida Business Committee
Legislative Operating Committee
PO Box 365 • Oneida, WI 54155-0365

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ONEIDA

Oneida-nsn.gov

LEGISLATIVE OPERATING COMMITTEE
PUBLIC MEETING
Code of Ethics Law Amendments
Pardon and Forgiveness Law Amendments
Norbert Hill Center Business Committee Conference Room and Microsoft Teams
May 14, 2026
12:15 p.m.
Present: Jonas Hill, Grace Elliott, Carolyn Salutz,
Present on Microsoft Teams: Joel Maxam, Terri Schiltz, Ashley Blaker, Jodi Tess, Peggy HelmQuest, Melissa Alverado, Shannon Stone
Jonas Hill: Good afternoon, the time is 12:15 p.m. and today’s date is Thursday, May 14, 2026. I
will now call to order the public meeting for the following two pieces of proposed legislation:
Code of Ethics law amendments, and Pardon and Forgiveness law amendments.
The Legislative Operating Committee is hosting this public meeting to gather feedback from the
community regarding these legislative proposals. The public meeting is not a question and answer
period. The LOC will review and consider all comments received during the public comment
period. The LOC will respond to all comments received in a memorandum, which will be
submitted in the meeting materials of a future LOC meeting.
All persons who wish to present oral testimony in person need to register on the sign in sheet.
Individuals who wish to present oral testimony on Microsoft Teams, please raise your hand and
you will be called on. If you leave an email address on the sign in sheet we can ensure you receive
a copy of the public comment review memorandum.
Additionally, written comments may be submitted to the Nation’s Secretary’s Office or to the
Legislative Reference Office in person, by U.S. mail, interoffice mail, e-mail or fax as provided
on the public meeting notice. These comments must be received by close of business on Thursday,
May 21, 2026.
In attendance from the LOC is myself, Jonas Hill.
The LOC may impose a time limit for all speakers pursuant to section 109.8-3(c) of the Legislative
Procedures Act. As the presiding LOC member, I am imposing a time limit of five minutes per
person. This time limit shall be applied equally to all persons.
We will now begin today’s public meeting for the two proposed legislative items.
We will be accepting comments on the Code of Ethics law amendments. The purpose of the Code
of Ethics law is to establish clear standards of conduct rooted in the values of the Oneida people,
A good mind. A good heart. A strong fire.

LOC Public Meeting Transcript of April 16, 2026
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to guide those entrusted with authority in serving the Nation with honor and responsibility. These
standards reflect the sacred trust between the government and the people, and are intended to
promote integrity, uphold the will of the Nation, and preserve the confidence of the Oneida people.
In a government founded upon the consent of the people, it is the right of the Oneida to expect
loyalty, honesty, and accountability from those who serve. The Code of Ethics law amendments
will:
▪ Update the Code of Ethics to focus exclusively on the Oneida Business Committee, bringing
all expectations for how leaders should conduct themselves into one easy-to-understand law.
▪ Integrate the Great Law of Peace into the ethical foundation, affirming decision-making
grounded in peace, unity, and thoughtful deliberation as cultural mandates for governance.
▪ Ground the ethical framework in the Good Mind teachings, infusing leadership obligations
with humility, compassion, clarity, and community-centered thinking.
▪ Articulate the concept of Sacred Trust, emphasizing leadership as a duty held on behalf of past,
present, and future generations rather than an individual entitlement.
▪ Clarify the definition of “Conflict of Interest” to encompass financial, personal, and political
interests affecting leaders and their immediate families, reinforcing impartial stewardship.
▪ Mandate transparent disclosure of conflicts, ensuring ethical clarity consistent with the Good
Mind’s call for honesty and openness in governance.
▪ Require OBC members to recuse themselves from matters in which conflicts exist, upholding
the Great Law of Peace’s expectation that leaders avoid self-interest.
▪ Implement structured annual and as-needed conflict-of-interest filings, create accountability
mechanisms that reinforce responsible leadership.
▪ Modernize gift and honoraria reporting by increasing financial thresholds and updating
reporting processes to better reflect contemporary governance realities including public
disclosure.
▪ Prohibit acceptance of gifts tied to influence or business advantage, protecting the Nation’s
decision-making from external pressure and maintaining community trust.
▪ Regulate OBC members’ applications for positions that report directly to the Committee,
preventing conflicts before they arise and strengthening procedural fairness.
▪ Safeguard confidential information by restricting its use for personal, financial, or political
benefit, aligning with the Haudenosaunee value of responsible and respectful speech.
▪ Reinforce accountability and transparency as essential qualities of public office, affirming that
OBC authority flows from the people and must remain answerable to them.
▪ Strengthen expectations for meeting attendance, preparation, and professional engagement,
acknowledging that presence and participation are integral to carrying the Sacred Trust.
▪ Codify a comprehensive list of prohibited behaviors including retaliation, discrimination,
misuse of office, and corruption to uphold dignity and protect community confidence in
leadership.
We will also be accepting comments on the Pardon and Forgiveness law amendments. The
purpose of the Pardon and Forgiveness law is to establish a fair, efficient, and formal process
through which individuals may seek relief from certain barriers created by past actions.
Specifically, the Law provides a process for: Tribal members to receive pardons for criminal
convictions or forgiveness for acts that make them ineligible for Tribal housing or Tribal
benefits; and Tribal and non-Tribal individuals to receive forgiveness for acts that make them

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LOC Public Meeting Transcript of May14, 2026
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ineligible for Tribal employment, occupational licenses, certifications, permits, housing, or other
Tribal benefits. The Pardon and Forgiveness law amendments will:
▪
▪

▪
▪
▪
▪

Create an exception allowing applicants with outstanding penalties/fines to proceed- only if
the application is for employment purposes and the applicant meets the requirements for a
conditional waiver.
Establish the full conditional waiver framework, including:
▪ waiver applies only to employment eligibility;
▪ outstanding penalties/fines remain fully enforceable;
▪ mandatory payment agreement (18 months or extended to 3 years if greater than
$5,000);
▪ requirements for Pardon and Forgiveness Committee recommendation;
▪ good-cause exception for missed payments;
▪ grounds for rescission for non-payment.
Allow an applicant proceeding under the conditional waiver (employment-only) to submit
proof of a Pardon and Forgiveness Committee-approved payment agreement instead of proof
of full payment.
Clarify that a pardon or forgiveness does not affect restrictions imposed under the Nation’s
Safe Neighborhoods law, in addition to existing sex-offender requirements.
Require the Oneida Secretary’s Office to monitor payment-related conditions and provide
quarterly reports to the Pardon and Forgiveness Committee; and clarify that monitoring is
solely for eligibility enforcement, not decision-making.
Authorize the OBC to rescind a pardon/forgiveness when a person fails to meet a payment
condition under 126.6-3, with notice and a 30-day cure period; reinstates all prior
ineligibilities.

Those who wish to speak please raise your hand. Please state your name when making a comment,
and which law you are commenting on. First up to speak is…we have nobody in person so if there
is anybody on Teams who would like to speak you can raise your hand…
With there being no more speakers, the public meeting for the Code of Ethics law amendments
and Pardon and Forgiveness law amendments is now closed at 12:26 p.m.
Written comments may be submitted until close of business on Thursday, May 21, 2026.

-End of Meeting-

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A good mind. A good heart. A strong fire.

LOC Public Meeting Transcript of May14, 2026
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ONEIDA

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Analysis to Draft 1
2026 06 03

PARDON AND FORGIVENESS
LAW AMENDMENTS
LEGISLATIVE ANALYSIS
SECTION 1. EXECUTIVE SUMMARY

Intent of the
Legislation or
Amendments

Purpose

Analysis by the Legislative Reference Office
▪ Create an exception allowing applicants with outstanding penalties/fines to
proceed only if the application is for employment purposes and the applicant
meets the requirements for a conditional waiver under 126.6-3. [1 O.C.
126.6-2(d)].
▪ Establish the full conditional waiver framework, including:
▪ waiver applies only to employment eligibility;
▪ outstanding penalties/fines remain fully enforceable;
▪ mandatory payment agreement (18 months or extended to 3 years if
>$5,000);
▪ requirements for Pardon and Forgiveness Committee
recommendation;
▪ good-cause exception for missed payments;
▪ grounds for rescission for non-payment. [1 O.C. 126.6-3].
▪ Allow an applicant proceeding under the conditional waiver
(employment-only) to submit proof of a Pardon and Forgiveness
Committee-approved payment agreement instead of proof of full payment. [1
O.C. 126.6-4(a)(12; 126.6-4(b)(11)].
▪ Clarify that a pardon or forgiveness does not affect restrictions imposed under
the Nation’s Safe Neighborhoods law, in addition to existing sex-offender
requirements. [1 O.C. 126.9-1(c)].
▪ Require the Oneida Secretary’s Office to monitor payment-related conditions
and provide quarterly reports to the Pardon and Forgiveness Committee; and
clarify that monitoring is solely for eligibility enforcement, not decisionmaking. [1 O.C. 126.9-4].
▪ Authorize the OBC to rescind a pardon/forgiveness when a person fails to
meet a payment condition under 126.6-3, with notice and a 30-day cure
period; reinstates all prior ineligibilities. Includes subsections specifying:
▪ rescission is an eligibility action, not an employment action;
▪ notice must be issued per 126.10-4. [1 O.C. 126.10-7].
The purpose of this law is to establish a fair, efficient, and formal process through
which individuals may seek relief from certain barriers created by past actions.
Specifically, the Law provides a process for:
▪ Tribal members to receive pardons for criminal convictions;
▪ Tribal members to receive forgiveness for acts that make them ineligible for
Tribal housing or other Tribal benefits; and
▪ Tribal and non-Tribal individuals to receive forgiveness for acts that make them
ineligible for Tribal employment, occupational licenses, certifications, permits,
housing, or other Tribal benefits [1 O.C. 126.1-1(a)].

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Analysis to Draft 1
2026 06 03

Affected Entities
Related Legislation
Enforcement

Due Process

The Law further aims to ensure that decisions on pardons and forgiveness are made
based on demonstrated rehabilitation, trustworthiness, and commitment to lawful
behavior. It clarifies that a pardon or forgiveness does not override obligations
imposed by other jurisdictions and does not permit employment in occupations
where individuals are legally disqualified [1 O.C. 126.1-2].
Oneida Business Committee; Office of the Oneida Secretary (records); Pardon and
Forgiveness Committee, Oneida community members.
Personnel, Policies, and Procedures; Safe Neighborhoods.
▪ Individuals may be automatically ineligible if they are under investigation,
appealing a termination, incarcerated, or have outstanding penalties/fines,
unless they qualify for the employment-only conditional waiver under 126.6-3
[1 O.C. 126.6-2].
▪ Applications may be denied, returned, or removed if incomplete, and
misrepresentation can result in denial or later rescission of a granted pardon or
forgiveness [1 O.C. 126.6-5–6].
▪ Failure to appear at a hearing allows the Committee to postpone action or
recommend denial if documentation is not provided within ten (10) days [1
O.C. 126.8-3].
▪ After relief is granted, the OBC or Committee may impose conditions (e.g.,
restitution, community service) and restrictions on employment or other
benefits, and applicants must comply to retain restored eligibilities [1 O.C.
126.9-2–3].
▪ The Secretary’s Office must monitor compliance with payment conditions and
submit quarterly reports under the new monitoring requirement [1 O.C.
126.9-4].
▪ The OBC may rescind a pardon, forgiveness, or conditional waiver for failure
to meet payment obligations, reinstating all prior ineligibilities after notice and
a 30-day cure period [1 O.C. 126.10-7].
The Pardon and Forgiveness Law provides several due process protections to ensure
that applicants receive fair treatment throughout the pardon or forgiveness process.
Applicants have the right to a public hearing with at least thirty (30) days’ notice
sent by certified mail and posted in prominent locations, giving them adequate time
to prepare [1 O.C. 126.8-1]. They also have the ability to request alternate
arrangements, such as appearing by video conference, when residing outside
Wisconsin or when attendance is otherwise impractical—thus ensuring access to
participation even when physical presence is difficult [1 O.C. 126.8-2]. During the
hearing, applicants may provide oral testimony, submit documents, and respond to
questions; victims and witnesses may also participate directly or through notarized
statements, supporting transparency and full consideration of relevant information
[1 O.C. 126.8-4]. Due process is also reinforced by allowing applicants ten (10)
days to provide documentation if they miss a hearing for legitimate reasons,
preventing automatic denial without an opportunity to be heard [1 O.C. 126.8-3].
After the hearing, due process continues through structured, accountable
decision-making requirements. The Committee must deliberate in executive session
and issue a formal written recommendation explaining the reasons for approval or
denial, which is forwarded to the Oneida Business Committee (OBC) with all
supporting materials [1 O.C. 126.8-5]. The OBC must then make the final decision
by resolution in open session, including the reasons for the decision and a listing of
the specific crimes pardoned or acts forgiven, ensuring a clear and reviewable
record [1 O.C. 126.10-3]. Applicants must receive written notice of the final

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Analysis to Draft 1
2026 06 03

Public Meeting
Fiscal Impact

decision within ten (10) business days [1 O.C. 126.10-4]. Even in rescission
proceedings—added through these proposed amendments—individuals are entitled
to notice and thirty (30) days to provide proof of compliance before the OBC may
revoke a pardon, forgiveness, or conditional waiver, preserving fundamental
fairness before any loss of eligibility occurs [1 O.C. 126.10-7]. Collectively, these
provisions embed procedural fairness at each stage and ensure that decisions
affecting rights and opportunities are made transparently, with meaningful
opportunities for participation.
A public meeting was held on May 14, 2026. No individuals provided comments
during the meeting. The public comment period closed on May 21, 2026 and no
individuals submitted written comments.
A fiscal impact statement prepared in accordance with the Legislative Procedures
Act has not yet been requested.

SECTION 2. LEGISLATIVE DEVELOPMENT
A. Background. The Pardon and Forgiveness law was previously adopted and amended as follows:
Resolution BC-05-25-11- A and amended by Resolution BC-01-22-14-B.
B. Request for Amendments. The Pardon and Forgiveness law was added to the Active Files List on
February 18, 2026 at the request of the Oneida Business Committee.

SECTION 3. CONSULTATION AND OUTREACH
▪

•

Representatives from the following departments or entities participated in the development of the
amendments to this Law and legislative analysis:
▪ Pardon and Forgiveness Committee and
▪ Oneida Law Office;
The following laws of the Nation were reviewed in the drafting of this analysis:
▪ Personnel, Policies, and Procedures, and
▪ Safe Neighborhoods.

SECTION 4. PROCESS
A. The amendments to this Law comply with the process set forth in the Legislative Procedures Act.
▪ On February 18, 2026, the Legislative Operating Committee added this Law to its Active Files
List for amendments.
B. At the time this legislative analysis was developed the following work meetings had been held
regarding the development of the amendments to this law:
▪ February 25, 2026: LRO work session with Oneida Law Office.
▪ February 27, 2026: LRO work session with Oneida Law Office.
▪ March 4, 2026: LOC work session.
▪ Additionally, several email communications with the Pardon and Forgiveness Committee
occurred between February 23, 2026 and February 26, 2026.
▪ May14, 2026: Public comment meeting held. No individuals provided comments.
▪ May21, 2026: Public comment period closed with no individuals providing written comments.

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Analysis to Draft 1
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SECTION 5. CONTENTS OF THE LEGISLATION
▪

▪

▪

▪

Definitions. The proposed amendments add and expand several definitions to support the new
conditional-waiver and rescission procedures. Definitions are added or amended for the following
terms: Conditional Waiver [1 O.C. 126.3-1(d)], Employment Purposes [1 O.C. 126.3-1(j)],
Outstanding Penalties, Fines, or Other Debts (expanded) [1 O.C. 126.3-1(o)] and Rescind [1 O.C.
126.3-1(r)].
▪ Effect. Updating and expanding these definitions clarifies key concepts governing eligibility,
outstanding debts, employment-only applications, and rescission. These changes enhance
clarity in the Law, reduce ambiguity, and ensure consistent interpretation. They also support
the new conditional-waiver process by clearly defining the terms used to determine when an
applicant may be considered despite outstanding financial obligations. Definitions strengthen
procedural transparency and ensure parties understand the meaning and implications of new
mechanisms introduced in later sections.
Good mind and Sacred Trust Framework. The proposed amendments incorporate the Good Mind
teachings directly into the ethical foundation of the law. These teachings — including Kahletsyaḻlésla
(encouraging the best in each other), Kanolukhwát^sla (compassion and identity), Kaʔnikuhli.yo̱
(openness of spirit), Kaʔtshatst^sla (strength of vision), Kalihwi.yo̱ (good words), Twahwahtsilay̱ʌ́ (we
are all family), and Yukwatsistay̱ʌ́ (the fire within) — are identified as core expectations for OBC
members. [1 O.C. 126.1-2].
▪ Effect. This change re-roots the Code in Oneida cultural teachings, reinforcing that ethical
leadership is not merely procedural but spiritual, relational, and reflective of ancestral values.
It supports community understanding that leaders are called to uphold balance, compassion,
truth, and unity when carrying out their responsibilities.
Eligibility Exception for Employment-Only Applications. The proposed amendments create a narrow
eligibility exception allowing applicants with outstanding penalties or fines to proceed when the
application is made solely for employment purposes and the individual qualifies for a conditional
waiver. [1 O.C. 126.6-2(d)].
▪ Effect. This amendment allows individuals whose only barrier to employment eligibility is
unpaid financial obligations to have their applications considered, provided they enter an
approved payment plan under Section 126.6-3. This improves fairness by recognizing that
individuals may be employable even if they have outstanding debts, while still requiring
accountability for repayment. The effect is not to forgive any fines but to allow the employment
review to proceed under structured conditions.
Creation of Conditional Waiver Framework. The proposed amendments to the Law create A new
section—Conditional Waiver—is created to establish detailed requirements for when the Committee
may recommend an exception to ineligibility. This section includes: criteria for eligibility; required
written payment agreements; standard and extended repayment timelines; mandatory conditions
under Section 126.9-3; a good-cause exception for missed payments; and provisions linking
non-payment to rescission under Section 126.10-7.[1 O.C. 126.6-3].
▪ Effect. The new Conditional Waiver provides an avenue for employment eligibility without
altering or forgiving unpaid penalties or fines. It creates a structured, accountability-focused
mechanism to allow hiring while requiring applicants to demonstrate good-faith repayment
efforts. The framework strengthens the Law by promoting economic stability and

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Analysis to Draft 1
2026 06 03

▪

rehabilitation, while maintaining the integrity of outstanding obligations. The effect is to
balance individual opportunity with responsibility through a regulated and enforceable process.
Application Documentation Modified. The proposed amendments to the Law allow applicants
proceeding under the Conditional Waiver to submit proof of a Committee-approved payment agreement
in place of proof of full payment of penalties or fines. [1 O.C. 126.6-4(a)(12)], [1 O.C. 126.6-4(b)(11)].
▪ Effect. These amendments align application requirements with the new Conditional

I

Waiver process, ensuring applicants are not excluded solely because they have not yet
completed repayment. This supports accessibility and ensures consistency in how
employment-only applications are processed under the amended eligibility structure.
▪

▪

▪

Sex-Offender Restrictions Clarified. The proposed amendments to the Law specify that a Tribal pardon
does not affect registration, tracking, or other restrictions, including those imposed under the Nation’s
Safe Neighborhoods law. [1 O.C. 126.9-1(c)].
▪ Effect. This change reinforces public-safety protections by ensuring that pardons do not
override legal obligations associated with sex-offender status. It clarifies the continuing
applicability of safety-related restrictions and prevents misinterpretation regarding the impact
of a Tribal pardon.
Monitoring Requirements Added. The proposed amendments to the Law require the Tribal Secretary’s
Office to monitor compliance with payment-related conditions and provide quarterly reports to the
Committee. [1 O.C. 126.9-4].
▪ Effect. This amendment institutionalizes oversight of repayment obligations associated with
conditional waivers. By assigning an office to track compliance, the Law ensures consistent
enforcement, enhances accountability, and supports the OBC’s ability to determine when
rescission is warranted.
Rescission for Non-Payment Codified. The proposed amendments to the Law authorizes the OBC to
rescind a pardon or forgiveness when an individual fails to meet payment conditions imposed under
126.6-3, after notice and a 30-day opportunity to cure. [1 O.C. 126.10-7].
▪ Effect. This amendment establishes a clear legal mechanism for restoring prior ineligibilities
when an individual does not comply with repayment requirements. It ensures the Conditional
Waiver system is enforceable, protects the integrity of eligibility standards, and prevents
misuse of the waiver process. It also clarifies that rescission is an eligibility action, not an
employment disciplinary action.

SECTION 6. EXISTING LEGISLATION
A. Related legislation. The following laws of the Nation are related to the proposed amendments to this
Law:
▪ Personnel, Policies and Procedures. The purpose of the Personnel, Policies and Procedures
law is to provide employees with a ready source of information about employee related Oneida
Nation policies and procedures. The law addresses recruiting, selection policy, compensation and
benefits, employee relations, safety and health, program/enterprise rules and regulations,
recordkeeping, and privacy and confidentiality of employee records.
▪

The proposed amendments to the Pardon and Forgiveness law establish a narrow
eligibility exception for applications made solely for employment purposes, allowing
individuals with outstanding fines or penalties to proceed if they qualify for a conditional

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Analysis to Draft 1
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▪

waiver under [1 O.C. 126.6(2)(d)]. This change applies only where unpaid financial
obligations are the individual’s sole barrier to employment and requires participation in
an approved payment plan pursuant to [1 O.C. 126.6(3)]. The amendments do not forgive
or eliminate any fines or penalties; rather, they allow employment-related applications to
move forward under structured conditions that maintain accountability while preventing
financial barriers from permanently excluding otherwise qualified individuals from
employment.
Safe Neighborhoods law. The purpose of the Safe Neighborhoods law is not to impose a criminal
penalty but rather to serve the Nation’s compelling interest to promote, protect, and improve the health, safety,
and welfare of the reservation population by prohibiting sex offenders from loitering or residing in specified
areas around locations where vulnerable populations, including children, regularly congregate. This law
recognizes the right of sex offenders to reenter the community. Therefore, through this law the Nation balances
its responsibility to sex offenders with its responsibility to protect the surrounding community by promoting
regulatory measures which provide protections for the community that do not wholly prohibit sex offenders
from being part of this community. [3 O.C. 310.1-1]. It is the underlying policy of the law that due to the high
rate of recidivism for sex offenders, the Nation declares that sex offenders are a serious threat to the public
safety of vulnerable populations, including children, if regulatory measures are not in place that protect the
community by reducing opportunity and temptation by prohibiting sex offenders from being present on or
residing in specified areas designated as places where vulnerable populations commonly congregate. [3 O.C.
310.1-2].
▪ The proposed amendments to the Pardon and Forgiveness law are narrowly tailored and
apply solely to employment-related purposes. These amendments do not alter, limit, or
affect the Safe Neighborhoods law in any way. All protections and provisions of the Safe
Neighborhoods law remain fully in effect.

SECTION 7. ENFORCEMENT AND ACCOUNTABILITY
▪

▪

The Pardon and Forgiveness Law enforces compliance through a combination of
eligibility controls, application requirements, hearing enforcement, and post-relief
oversight. Individuals may be deemed automatically ineligible if they are under
investigation, appealing a termination, incarcerated, or have outstanding penalties or
fines, unless they qualify for the employment-only conditional waiver under 126.6-3 [1
O.C. 126.6-2]. Applicants who fail to provide complete information or who misrepresent
facts may have their applications denied, returned, or removed from consideration, and
misrepresentation discovered after a pardon is granted may result in rescission [1 O.C.
126.6-5–6]. Hearing attendance is enforced by authorizing the Committee to postpone a
determination or recommend denial if the applicant does not appear and does not provide
valid documentation within ten days [1 O.C. 126.8-3].
Once a pardon, forgiveness, or conditional waiver is granted, the Law enforces continued
compliance through conditions, restrictions, monitoring, and rescission. The Oneida
Business Committee or the Screening Committee may impose restrictions on
employment or other Tribal benefits, or conditions such as restitution or community
service, and applicants must comply with these terms to retain their restored eligibilities
[1 O.C. 126.9-2–3]. Under the newly added monitoring requirement, the Tribal
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Secretary’s Office must track compliance with payment-related conditions and provide
quarterly reports to the Committee [1 O.C. 126.9-4]. The Law’s strongest enforcement
tool is the rescission authority, which allows the OBC to revoke a conditional waiver,
pardon, or forgiveness if an individual fails to meet payment conditions, reinstating all
prior ineligibilities after proper notice and opportunity to cure [1 O.C. 126.10-7].

SECTION 8. OTHER CONSIDERATIONS
Fiscal Impact. Under the Legislative Procedures Act, a fiscal impact statement is required for all
legislation except emergency legislation [1 O.C. 109.6-1]. Oneida Business Committee resolution BC-1028-20-A titled, “Further Interpretation of ‘Fiscal Impact Statement’ in the Legislative Procedures Act,”
provides further clarification on who the Legislative Operating Committee may direct complete a fiscal
impact statement at various stages of the legislative process, as well as timeframes for completing the
fiscal impact statement.
▪ Conclusion. The Legislative Operating Committee has not yet directed that a fiscal impact be
completed.

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Draft 1 (Redline)
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Title 1. Government and Finances - Chapter 126
PARDON AND FORGIVENESS
Tsi>n@hte a=ka, which includes:
(a) Kahletsyal&sla. The heartfelt encouragement of the best in each of us.
(b) Kanolukhw@sla. Compassion, caring, identity, and joy of being.
(c) Ka>nikuhli=y%. The openness of the good spirit and mind.
(d) Ka>tshatst^sla. The strength of belief and vision as a People.
(e) Kalihwi=y%. The use of the good words about ourselves, our Nation, and our future.
(f) Twahwahts$layn@hte a=ka, which includes:
(a) Kahletsyal&sla. The heartfelt encouragement of the best in each of us.
(b) Kanolukhw@sla. Compassion, caring, identity, and joy of being.
(c) Ka>nikuhli=y%. The openness of the good spirit and mind.
(d) Ka>tshatst^sla. The strength of belief and vision as a People.
(e) Kalihwi=y%. The use of the good words about ourselves, our Nation, and our future.
(f) Twahwahts$lay<. All of us are family.
(g) Yukwats$stay<. Our fire, our spirit within each one of us.
126.2. Adoption, Amendment, Conflicts
126.2-1. This Law was adopted by the Oneida Business Committee by Resolution BC-05-25-11A and amended by Resolutions BC-01-22-14-B, and BC-XX-XX-XX-X.
126.2-2. This Law may be amended pursuant to the procedures set out in Tribal law by the Oneida
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Business Committee or the Oneida General Tribal Council.
126.2-3. Should a provision of this Law or the application thereof to any person or circumstances
be held as invalid, such invalidity shall not affect other provisions of this Law which are considered
to have legal force without the invalid portions.
126.2-4. In the event of a conflict between a provision of this Law and a provision of another law,
ordinance, policy, regulation, rule, resolution, or motion, the provisions of this Law shall control.
Provided that, this Law repeals Resolution BC-7-31-02-A: Resolution Adopting a New Oneida
Pardon Ordinance.
126.2-5. This Law is adopted under authority of the Constitution of the Oneida Tribe of Indians
of Wisconsin.
126.3. Definitions
126.3-1. This section shall govern the definitions of words and phrases used within this Law. All
words not defined herein shall be used in their ordinary and everyday sense.
(a) “Applicant” means an individual who is applying for a pardon or forgiveness from the
Tribe.
(b) “Certified mail” means mail sent through either the United States Postal Service or the
Tribal Inter-Office Certified system that provides proof of delivery and receipt.
(c) “Committee” means the Pardon and Forgiveness Screening Committee.
(d) “Conditional Waiver” means a temporary exception to the ineligibility criteria under
section 126.6-2(d) for employment-related application; it does not constitute a pardon or
forgiveness and does not alter, waive, or satisfy any outstanding monetary obligation.
(e) “Conditions” means a requirement or prerequisite event or activity.
(f) “Conflict of interest” means a conflict between the private interests and the official
responsibilities of the committee member.
(g) “Conviction” means an individual was either found guilty or entered a plea of guilty
or no contest to charges of a crime in any court of competent jurisdiction.
(h) “Court of competent jurisdiction” means any court or forum that has the power and
authority to properly exercise jurisdiction over a dispute or interpret and/or enforce laws.
(i) “Crime” means any act, default, or conduct punishable as a felony or a misdemeanor.
(j) “Employment purposes” means seeking eligibility for employment with the Nation or
to remove a bar to continued employment with the Nation, including positions subject to
background eligibility determinations.
(k) “Forgiveness” means the formal and public act of acknowledging or excusing an
individual’s actions or behavior that makes him or her ineligible for Tribal employment,
an occupational license, certification or permit issued by the Tribe, housing through the
Tribe or other Tribal benefit
(l) “Hearing” means a public hearing, a noticed public forum in which an applicant has an
opportunity to present a case for obtaining a pardon or forgiveness from the Tribe.
(m) “Individual” means a Tribal member seeking a pardon for a conviction of a crime, a
Tribal member seeking forgiveness for an act(s) that makes him or her ineligible for
housing with the Tribe or other Tribal benefit(s) or anyone seeking forgiveness for an act(s)
that renders him or her ineligible for employment, an occupational license, certification or
permit issued by the Tribe.
(n) “Family member” means a spouse, child sibling, parent, grandparent, grandchild, stepparent, step-child, in-law or legal guardian.
(o) “Outstanding penalties, fines, or other debts” means any unpaid monetary obligations
owed to the Nation or arising from any Tribal, State, Federal, or Municipal court order,
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judgement, stipulation, or payment requirement, including but not limited to penalties,
fines, fees, repayment obligations, or court-ordered financial conditions that are due and
payable.
(p) “Pardon” means the formal and public act of acknowledging or excusing a Tribal
member’s criminal conviction that makes him or her ineligible for Tribal employment, an
occupational license, a certification or permit issued by the Tribe, housing through the
Tribe, or other Tribal benefit.
(q) “Prominent locations” shall include, but not be limited to, the following: the Tribal
newspaper; at least one (1) local newspaper with regular distribution within the Reservation
boundaries; one (1) regional Indian newspaper; and the Tribe’s official website.
(r) “Rescind” means to formally revoke, cancel, or withdraw a previously granted pardon
or forgiveness through Oneida Business Committee resolution, thereby restoring all prior
ineligibilities and returning the applicant to the status that existed before the pardon or
forgiveness was granted.
(s) “Restriction” means a limitation or constraint imposed.
(t) “Tribal” or “Tribe” means the Oneida Tribe of Indians of Wisconsin.
(u) “Victim” means a person or entity against whom an offense, either civil or criminal,
has been committed.
126.4. Pardon and Forgiveness Screening Committee Responsibilities
126.4-1. A Committee is hereby created for the purpose of carrying out the provisions of this Law.
126.4-2. Authority. The Committee shall:
(a) promulgate internal standard operating procedures necessary to govern its proceedings;
(b) review and process applications for a pardon or forgiveness in an orderly and
expeditious manner;
(c) review an applicant’s background investigation report received from the Oneida
Human Resources Department;
(d) conduct and preside over hearings;
(e) provide formal, written recommendations to the Oneida Business Committee to
approve or deny a pardon or forgiveness application; and
(f) take other actions reasonably related to the purpose of the Committee.
126.5. Tribal Secretary’s Office Responsibilities
126.5-1. The Tribal Secretary’s Office shall assist the Committee with carrying out the provisions
of this Law and assist individuals in applying for a pardon or forgiveness. The Tribal Secretary’s
Office shall:
(a) create and implement procedures necessary to process pardon and forgiveness
applications.
(b) accept pardon and forgiveness applications.
(c) submit and track requests for a background investigation.
(d) forward pardon and forgiveness applications to the Committee when the background
investigations are complete.
(e) maintain a record of all pardon and forgiveness applications filed, every pardon and
forgiveness request granted or denied, and the reasons for each action.
(f) maintain a complete and accurate record of all proceedings, including all
correspondence, transcripts, documents, evidence, and appearances made in connection
with the applications.
(g) perform other duties in connection with matters under this Law as may be requested
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by the Committee.
126.6. Pardon and Forgiveness Eligibility and Application
126.6-1. Eligibility. A Tribal member may receive a pardon for any criminal conviction(s), or a
forgiveness for an act(s) that renders the Tribal member ineligible for housing with the Tribe or
other Tribal benefit(s); and any individual may receive forgiveness for an act(s) that renders the
individual ineligible for Tribal employment, an occupational license, certification or permit issued
by the Tribe.
(a) Upon completion of incarceration, parole, probation and/or deferred prosecution,
Tribal members shall be eligible to apply for a pardon.
(b) One (1) year after an act is committed, or affirmed through the conclusion of any appeal
process, an individual shall be eligible to apply for pardon or forgiveness.
126.6-2. Ineligibility. An individual is ineligible for a pardon or forgiveness if he or she is:
(a) being investigated for an act and if found to have committed such act, would be
ineligible for the benefit he or she is seeking; or
(b) appealing a termination and the termination makes him or her ineligible for the benefit
he or she is seeking; or
(c) currently incarcerated, on parole, probation, and/or under a deferred prosecution
agreement; or
(d) has any outstanding penalties or fines; however, this paragraph does not apply to
an application made solely for employment purposes under Section 126.1-1(a)(3) when
outstanding penalties or fines are the only unmet eligibility requirement and the applicant
qualifies for a conditional waiver under Section 126.6-3.
126.6-3. Conditional Waiver. A conditional waiver is not a pardon or forgiveness and does not
waive or reduce any penalties, fines, or debts owed to the Nation or any other government. It
temporarily lifts the employment-related ineligibility under Section 126.6-2(d) solely for the
purpose of allowing an applicant to be considered for employment with the Nation. The conditional
waiver exists only within the Committee’s authority to recommend an exception to eligibility
requirements; it does not authorize the Nation to negotiate, modify, or forgive financial obligations
imposed by any court or governmental body.
(a) The Committee may recommend approval despite Section 126.6-2(d) only when:
(i) the application is solely for employment purposes as defined in Section 126.31(j);
(ii) outstanding penalties or fines are the sole basis for ineligibility; and
(iii) the applicant enters a written payment agreement with the Pardon and
Forgiveness Committee requiring full payment within eighteen (18) months from
the OBC resolution date. A payment agreement under this section may consist of
any documentation demonstrating how the applicant will satisfy the outstanding
obligation and does not require negotiation, approval, or participation from any
Tribal, State, Federal, or Municipal government. The payment agreement functions
solely as evidence that the applicant is actively addressing the eligibility condition
and is not an agreement between the Nation and any outside jurisdiction.
(b) Any recommendation under this section shall include a mandatory condition under
Section 126.9-3(a) requiring full payment within eighteen (18) months and compliance
with an approved installment plan.
(c) Failure to comply with the payment agreement constitutes grounds for recission under
Section 126.10-7 and immediate reinstatement of prior ineligibility.
(d) Nothing in this section authorizes the Committee to forgive, modify, reduce, or
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negotiate penalties or fines imposed by any government; the waiver pertains only to
employment eligibility with the Nation.
(e) Exception for Larger Outstanding Obligations. Notwithstanding Section 126.6-3(a)(iii)
and 126.6-3(b), the Committee may recommend a conditional waiver under the following
extended timeframes, based on the total amount of outstanding penalties or fines:
i. Obligations of five thousand dollars ($5,000) or less. The applicant may be
granted up to eighteen (18) months from the OBC resolution date to satisfy the
outstanding obligation, provided all other requirements of this section are met.
ii. Obligations greater than five thousand dollars ($5,000). The applicant may be
granted up to three (3) years from the OBC resolution date to satisfy the
outstanding obligation provided:
(A) the applicant submits a written payment plan demonstrating the ability
to complete payment within the extended period;
(B) the Committee determines that the extended timeframe is necessary to
prevent unreasonable hardship; and
(C) the applicant remains in full compliance with the approved installment
plan.
(f) Good-Cause Exception for Missed Payment. A missed payment under an approved
repayment plan may be excused upon a finding of good cause, provided that:
i. The applicant submits a written explanation within thirty (30) days of the missed
payment;
ii. The Committee determines that the missed payment resulted from good cause,
which may include but is not limited to unforeseen medical emergencies, loss of
income, or other significant and verifiable circumstances; and
iii. The applicant resumes payment under a revised schedule approved by the
Committee within thirty (30) days of the good-cause determination.
126.6-3. Initiating an Application. Applications for a pardon or forgiveness may be obtained from
the Tribal Secretary’s Office or on the Tribal website. Completed applications shall be filed with
the Tribal Secretary’s Office in person, during normal Tribal business hours, or sent by certified
mail to the Tribal Secretary at P.O. Box 365, Oneida, WI 54155.
126.6-4. Required Application Information. Each applicant is responsible for submitting all
required materials and authorizations.
(a) A completed pardon application shall include the following:
(1) a copy of the applicant’s Tribal enrollment card.
(2) a copy or copies of any discharge papers from incarceration or jail.
(3) official verification of any successful completion date of the probation, parole
or deferred prosecution.
(4) any necessary releases for investigations and/or background checks.
(5) any authorizations from a probation officer to release information.
(6) the required non-refundable fee as specified under 126.6.
(7) a personal written statement, including the reason(s) for requesting a pardon
and a description and documentation of the applicant’s efforts towards selfimprovement.
(8) information regarding the conviction(s) for which the applicant is seeking a
pardon, including:
(A) date(s) upon which the crime(s) occurred;
(B) location(s) where the crime(s) occurred;
(C) date(s) of conviction(s); and
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(D) jurisdiction(s) which imposed the sentence(s).
(9) verification of attendance or successful completion of any counseling, therapy,
or rehabilitative programs such as anger management or coping skills classes.
(10) letters of reference or support from people well-regarded in the community.
Such letters shall detail the applicant’s accomplishments or contributions to the
community or attest to the applicant’s rehabilitation and trustworthiness. These
may include, but are not limited to:
(A) clergy or other spiritual leaders.
(B) employers and/or community members.
(C) teachers.
(D) organizers of support groups the applicant attends or has attended.
(11) any other information relevant to the applicant’s conviction(s) or rehabilitation
efforts.
(12) proof of payment of all penalties and fines. For application proceeding under
Section 126.6-3, proof of a Committee-approved payment agreement satisfies the
requirement to document outstanding penalties or fines.
(b) A completed forgiveness application shall include the following:
(1) a copy of the applicant’s Tribal enrollment card, if applicable.
(2) the applicant’s employment record prior to the act, if applicable.
(3) the applicant’s background records.
(4) the act that triggered the applicant’s ineligibility.
(5) the impact of the act on the Tribe.
(6) the length of time since the act.
(7) a written statement from the applicant demonstrating remorse for the violation.
(8) two (2) letters of recommendation, with no more than one (1) recommendation
coming from a person who is a family member of the applicant.
(9) the required non-refundable fee as specified under 126.6.
(10) any additional credible and relevant information.
(11) proof of payment of all penalties and fines. For application proceeding under
Section 126.6-3, proof of a Committee-approved payment agreement satisfies the
requirement to document outstanding penalties or fines.
126.6-5. Failure of the applicant to provide a complete application, or any of the required
information and/or materials may result in:
(a) the application being returned with a request for more information; or
(b) the application being removed from consideration; or
(c) denial of a pardon or forgiveness.
126.6-6. Applicant Misrepresentations. Any applicant who misrepresents, omits, or falsifies any
information on the application or during the pardon process shall be denied a pardon. If a pardon
is granted and it is later determined that there is misrepresented or false information, or pertinent
information was purposefully omitted, the Oneida Business Committee shall have the right to
rescind the pardon.
126.7. Fees
126.7-1. Each application shall be accompanied by a non-refundable fee as set by the Oneida
Business Committee in a resolution. Said payment shall be made payable to the Oneida Tribe in
the form of a:
(a) money order; or
(b) cashier’s check; or
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(c) intra-tribal purchase document, if a Tribal department or program, such as Social
Services, will be providing the funds for the application fee.
126.8. Hearings
126.8-1. Notice of the Hearing. The Committee shall conduct quarterly hearings and provide
official notice to the applicant by certified mail, including the date, time and location of the
hearing, at least thirty (30) calendar days prior to the hearing. Notice shall also be posted in
prominent locations at least thirty (30) calendar days prior to the hearing. If alternate arrangements
have been made under 126.8-2, notice shall be posted in prominent locations with as much advance
notice as possible and as time permits.
(a) Notice of the hearings scheduled for the year shall be posted on the Tribal website and
periodically in the Tribal newspaper.
(b) Hearings shall take place at a regularly scheduled time and location to be determined
by the Committee and shall be open to the public.
126.8-2. Alternate Hearing Arrangements. Applicants who reside out of the State of Wisconsin
who are unable to attend a hearing may submit a written request by certified mail to the Tribal
Secretary’s Office for alternate arrangements to appear by video conference and/or to reschedule
the hearing date. If alternate arrangements are unavailable, the applicant may withdraw the
application up to three (3) business days prior to the hearing without penalty, and may re-apply for
a pardon at any time.
126.8-3. Failure of Applicant to Attend Hearing. Failure of the applicant to appear at the hearing
may result in the Committee postponing making a determination on the application or
recommending the Oneida Business Committee deny the application.
(a) Applicants with a legitimate reason for failing to appear for a hearing shall have ten
(10) calendar days from the date of the missed hearing to provide documentation to the
Committee. Such documentation may include, but is not limited to; a Doctor’s excuse,
accident/police report, or funeral notice.
126.8-4. Testimony and Notarized Statements. The Committee shall obtain oral testimony at the
hearing from the applicant, and any victims, witnesses or other persons supporting or opposing the
pardon or forgiveness.
(a) Victims, witnesses, and other persons unavailable for a scheduled hearing may submit
a notarized statement for consideration.
(b) The Committee may institute recesses and postponements as they see fit.
(c) The Committee may ask questions at any time during the hearing.
(d) The Committee may require the applicant to provide further documentation.
(1) Within five (5) business days of the hearing, the Committee shall send a written
request by certified mail to the applicant for the additional documentation.
(2) The applicant shall submit the documentation to the Tribal Secretary’s Office
within thirty (30) calendar days after receiving the request for the documentation.
Failure of the applicant to provide any of the required documentation may result in:
(A) the application being removed from consideration; or
(B) denial of the application.
126.8-5. Deliberations and Recommendation. After the hearing, the Committee shall go into
executive session for deliberations.
(a) The Committee shall consider all information gathered from the hearing, the
application, the background investigation, and any testimony or notarized statements when
determining whether to recommend that the application be approved or denied.
(1) The Committee shall be responsible for weighing the appropriateness of
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granting a pardon or forgiveness.
(b) Recommendation. After considering the factors provided, the Committee shall make
a decision and compose a formal, written recommendation for each application, including
reasons to approve or deny the application within sixty (60) days after the pardon or
forgiveness hearing. The recommendation, including any dissenting opinions issued by
the Committee shall be forwarded to the Oneida Business Committee within thirty (30)
calendar days after making a decision, along with the following materials for review:
(1) All information from the application and the background investigation;
(2) Any notarized statements submitted;
(3) A proposed draft resolution; and
(4) An audio recording of the hearing, upon request by an Oneida Business
Committee member.
126.9. Conditions and Restrictions
126.9-1. Pardons. Certain convictions may affect a Tribal member’s rights under state or federal
law, or result in restrictions being placed on a Tribal member, regardless of whether a Tribal pardon
has been granted.
(a) Civil Rights. A pardon by the Tribe does not guarantee the restoration of all civil rights,
and each recipient of a Tribal pardon is responsible for determining whether the pardon
affects any non-Tribal restrictions or limitations that may be applicable pursuant to the
conviction.
(b) Employment. Individuals convicted of a crime that is “substantially related” to the care
of another person or animal may be subject to extended or permanent restrictions on
licensing or professional credentials in fields relating to such caretaking. A Tribal pardon
shall not affect these restrictions.
(c) Sex Offender Registry. Receipt of a Tribal pardon shall in no way affect registration,
tracking or other restrictions or obligations imposed upon sex offenders, including any
restrictions imposed through the Nation’s Safe Neighborhoods law.
(d) Voting Rights. Each state, and the federal government are empowered to determine
whether felons may vote in elections, caucuses, referendums or any other venue dependent
on the votes of citizenry. The granting of a Tribal pardon shall not supersede the rights of
these jurisdictions to determine the eligibility of voters.
126.9-2. Other Restrictions. The Committee’s written recommendation to the Oneida Business
Committee to approve an applicant’s request for a pardon or forgiveness may also recommend the
Oneida Business Committee impose restrictions on the applicant. If the Committee does not
recommend a restriction, the Oneida Business Committee shall have the authority to place
restrictions on the applicant before approving the pardon or forgiveness request. Restrictions shall
specify the time lines attached to them, which may expand over a period of months, years, or
indefinitely.
(a) Restrictions shall be clearly defined and may include the following:
(1) The applicant is ineligible for a transfer, promotion or job reassignment.
(2) The applicant may be prohibited from:
(A) Handling cash and/or merchandise.
(B) Having Tribal property sign-off authority.
(C) Supervising staff.
(D) Supervising or caring for children or the elderly.
(E) Any other restrictions the Oneida Business Committee determines as
appropriate.
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(b) When restrictions are imposed for a period of greater than five (5) years, the applicant
may, after five (5) years, apply to have the restrictions modified or lifted. The request to
modify or lift restrictions will follow the same process required to request a pardon.
(c) The applicant shall sign a written statement describing each restriction, and time period
of such restriction prior to becoming employed by the Tribe.
126.9-3. Conditions. The Committee may also recommend that an applicant requesting a pardon
or forgiveness be required to complete conditions before the applicant is granted the pardon or
forgiveness. If the Committee does not recommend a condition, the Oneida Business Committee
shall have the authority to place conditions on the applicant before approving the pardon or
forgiveness request.
(a) Conditions shall be clearly defined and may include the following:
(1) perform community service hours within a Tribal Department.
(2) payment of restitution to the Tribe.
(3) any other conditions the Oneida Business Committee determines as
appropriate.
126.9-4. Monitoring. The Tribal Secretary’s Office shall monitor compliance with all
payment-related conditions and provide quarterly status reports to the Committee until those
conditions have been fully satisfied. Monitoring payment conditions is an integral component of
enforcing eligibility requirements and does not constitute a ministerial or administrative processing
function of the Secretary’s Office. The Secretary’s Office conducts this monitoring solely to
determine whether the required eligibility conditions have been met and does not exercise
decision-making authority regarding eligibility determinations or the continuation of any
conditional waiver.
126.10. Oneida Business Committee
126.10-1. The Oneida Business Committee shall consider all of the information received by the
Committee prior to making a determination on whether to issue or deny a pardon or forgiveness
application. The Oneida Business Committee may accept, reject or modify the Committee’s
recommendation.
126.10-2. Deliberations. Deliberations by the Oneida Business Committee shall take place in
executive session. The Oneida Business Committee may request, by written notice, that the
applicant be present during the deliberations to provide oral testimony or to answer questions. The
notice shall be provided to the applicant thirty (30) days prior to the deliberations and shall contain
the time, place and date of the deliberations.
126.10-3. Final Decision. The Oneida Business Committee shall issue or deny the pardon or
forgiveness in open session, by resolution, including the reasons therefor and shall include for the
record a clear indication of any decision and shall list the specific crimes to be pardoned or acts to
be forgiven. This decision is final and cannot be appealed. Applicants may be eligible to re-apply
for a pardon or forgiveness one (1) year from the date of the most recent denial of a pardon or
forgiveness.
126.10-4. Notification. Notification of the final decision shall be sent to the applicant from the
Tribal Secretary’s office by certified mail or personally served within ten (10) business days
following the decision. Applicants have a right to documentation of the final decision along with
the resolution, and the reason(s) for the final decision.
126.10-5. Resolution. To grant or deny a pardon or forgiveness, a majority vote of the Oneida
Business Committee is required.
126.10-6. Eligibilities. Unless otherwise directed by the Oneida Business Committee, a pardon
or forgiveness may fully or partially restore some Tribal eligibilities lost as a result of a conviction
1 O.C. 126 – Page 9

35 of 98

419
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or act including:
(a) employment; and/or
(b) an occupational license, certificate or permit; and/or
(c) housing; and/or
(d) other Tribal benefit.
126.10-7. Recission for non-payment. If an individual does not satisfy a payment condition
imposed under Section 126.6-3, the OBC may rescind the pardon or forgiveness by resolution.
Before rescission occurs, the individual shall receive notice and be given thirty (30) days from the
date of that notice to provide proof of payment or otherwise demonstrate compliance. If the
individual does not provide such proof within the thirty-day period, the OBC may proceed with
rescission. Upon rescission, all prior ineligibilities are reinstated.
(a) For the purposes of this section, “individual” means a person who has been granted a
conditional waiver under Section 126.6-3.
(b) Rescission is a determination of eligibility status under this Law and is not an
employment action. Any employment related consequences are processed separately under
applicable personnel policies.
(c) Notification of rescission shall be issued to the individual by the Secretary’s Office in
accordance with Section 126.10-4.

End.
Adopted – BC-2-19-93-I
Adopted – BC-11-13-93-B (Oneida Pardon Procedures Policy)
Adopted – BC-11-24-93-B (Temporary Pardons)
Adopted – BC-7-31-02-A
Adopted – BC-05-25-11-A
Adopted – BC-01-22-14-B
Emergency Adoption – BC-04-28-21-A
Emergency Extended – BC-10-27-21-A (Emergency Expired)
Amended – BC-XX-XX-XX-X

1 O.C. 126 – Page 10

36 of 98

Oneida Nation

Oneida Business Committee
Legislative Operating Committee
PO Box 365 • Oneida, WI 54155-0365

Oneida-nsn.gov

TO:
FROM:
DATE:
RE:

"'

=DDDDOO

ONEIDA

Ralinda Ninham-Lamberies, Chief Financial Officer
Jameson Wilson, Legislative Operating Committee Chairman
June 3, 2026
Pardon and Forgiveness Law Fiscal Impact Statement

The Legislative Operating Committee (LOC) is currently developing amendments to the Pardon
and Forgiveness Law. The Legislative Procedures Act requires that a fiscal impact statement be
provided for all proposed legislation of the Nation. [1 O.C. 109.6-1]. The fiscal impact statement
is an estimate of the total fiscal year financial effects associated with the proposed legislation, and
should include:
 startup costs;
 personnel;
 office costs;
 documentation costs; and
 an estimate of the amount of time necessary for an individual or agency to comply with the
law after implementation. [1 O.C. 109.3-1(c)].
The fiscal impact statement must be completed and submitted to the LOC prior to the proposed
legislation being forwarded to the Oneida Business Committee for consideration. [1 O.C. 109.62]. The fiscal impact statement provides the Oneida Business Committee information on what the
potential adoption of the proposed legislation will cost the Nation, so that the Oneida Business
Committee can determine if adoption of the proposed legislation is in the best interest of the Nation.
The Legislative Procedures Act grants the LOC the authority to direct the Finance Department or
any agency who may administer a program if the legislation is enacted or may have financial
information concerning the subject matter of the legislation to submit a fiscal impact statement. [1
O.C. 109.6-1].
Oneida Business Committee resolution BC-10-28-20-A titled, “Further Interpretation of ‘Fiscal
Impact Statement’ in the Legislative Procedures Act” provides further clarification on the process
for directing a fiscal impact statement be completed. This resolution provides that upon final
approval of draft legislation by the LOC, the LOC may direct the Finance Department to provide
a neutral and unbiased fiscal impact statement to the LOC within ten (10) business days for
inclusion in adoption materials.
On June 3, 2026, the Legislative Operating Committee approved the final draft of the Pardon and
Forgiveness Law. Therefore, the LOC is directing the Finance Department to provide a fiscal
impact statement on the Pardon and Forgiveness Law by June 25, 2026.

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A copy of the Pardon and Forgiveness Law, as well as the legislative analysis, have been attached to
this memorandum for your convenience.
Requested Action
Provide the LOC a fiscal impact statement of the Pardon and Forgiveness Law by June 25, 2026.

~

fflJDOOO
A good mind. A good heart. A strong fire.

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ONEIDA

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Oneida Nation

Oneida Business Committee
Legislative Operating Committee
PO Box 365 • Oneida, WI 54155-0365
Oneida-nsn.gov

r'\

=DODDOO

ONEIDA

AGENDA REQUEST FORM
May , 2026
1) Request Date: _____________________________________________________
Clorissa N. Leeman
2) Contact Person(s): ______________________________________
Legislative Reference Office
Dept:____________________________

(920) 869-4417
cleeman@oneidanation.org
Phone Number:_________________________
Email: __________________________________
Petition: G. Powless-Buenrostro - Amend Judiciary Law
3) Agenda Title:___________________________________________________________________
4) Detailed description of the item and the reason/justification it is being brought before the LOC:
_______________________________________________________________________________
On 5/27/26 the OBC acknowledged the receipt of this Petition and

directed the LRO to develop a SOE or status update by 7/8/26.
_______________________________________________________________________________
_______________________________________________________________________________
_______________________________________________________________________________

List any supporting materials included and submitted with the Agenda Request Form
1) ________________________________

3) ________________________________

2) ________________________________

4) ________________________________

5) Please list any laws, policies or resolutions that might be affected:

Judiciary law
_______________________________________________________________________________
6) Please list all other departments or person(s) you have brought your concern to:
______________________________________________________________________________
7) Do you consider this request urgent?

□ Yes

□ No

If yes, please indicate why:

LRO directed to provide SOE or status update by 7/8/26
________________________________________________________________
I, the undersigned, have reviewed the attached materials, and understand that they are subject to action by
the Legislative Operating Committee.
Signature of Requester:
__________________________________________________________________________

Please send this form and all supporting materials to:
LOC@oneidanation.org
or
Legislative Operating Committee (LOC)
P.O. Box 365
Oneida, WI 54155
Phone 920-869-4376

A good mind. A good heart. A strong fire.

39 of 98

Oneida Nation

Oneida Business Committee
Legislative Operating Committee
PO Box 365 • Oneida, WI 54155-0365
Oneida-nsn.gov

r'\

=DODDOO

ONEIDA

AGENDA REQUEST FORM
May , 2026
1) Request Date: _____________________________________________________
Clorissa N. Leeman
2) Contact Person(s): ______________________________________
Legislative Reference Office
Dept:____________________________

(920) 869-4417
cleeman@oneidanation.org
Phone Number:_________________________
Email: __________________________________
Petition: G. Powless-Buenrostro - Amend Judiciary Law
3) Agenda Title:___________________________________________________________________
4) Detailed description of the item and the reason/justification it is being brought before the LOC:
_______________________________________________________________________________
On 5/27/26 the OBC acknowledged the receipt of this Petition and

directed the LRO to develop a SOE or status update by 7/8/26.
_______________________________________________________________________________
_______________________________________________________________________________
_______________________________________________________________________________

List any supporting materials included and submitted with the Agenda Request Form
1) ________________________________

3) ________________________________

2) ________________________________

4) ________________________________

5) Please list any laws, policies or resolutions that might be affected:

Judiciary law
_______________________________________________________________________________
6) Please list all other departments or person(s) you have brought your concern to:
______________________________________________________________________________
7) Do you consider this request urgent?

□ Yes

□ No

If yes, please indicate why:

LRO directed to provide SOE or status update by 7/8/26
________________________________________________________________
I, the undersigned, have reviewed the attached materials, and understand that they are subject to action by
the Legislative Operating Committee.
Signature of Requester:
__________________________________________________________________________

Please send this form and all supporting materials to:
LOC@oneidanation.org
or
Legislative Operating Committee (LOC)
P.O. Box 365
Oneida, WI 54155
Phone 920-869-4376

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40 of 98

Oneida Nation

Legislative Operating Committee
Legislative Reference Office
PO Box 365 • Oneida, WI 54155-0365

Oneida-nsn.gov

TO:
FROM:
DATE:
RE:

"'

000000

ONEIDA

Legislative Operating Committee (LOC)
Clorissa N. Leeman, Legislative Reference Office, Senior Staff Attorney
June 3, 2026
Certification of Technology Resources Law Rules

Background
The Legislative Operating Committee received the certification packet provided for the following
rules [“the Rules”] from the Digital Technology Services Department (DTS):
 Technology Resources Law Rule No. 1 – Acceptable Use;
 Technology Resources Law Rule No. 2 – Clear Desk/Screen;
 Technology Resources Law Rule No. 3 – Asset Management;
 Technology Resources Law Rule No. 4 – Security Awareness Training;
 Technology Resources Law Rule No. 8 – Third Party Providers; and
 Technology Resources Law Rule No. 9 – Generative AI Usage.
The Legislative Operating Committee is responsible for certifying a proposed rule after
determining the authorized agency has complied with the requirements for certification stated in
section 106.7-2 of the Administrative Rulemaking law, and forwarding the rule to the Oneida
Business Committee for consideration of adoption. [1 O.C. 106.7-3].
Certification by the Legislative Operating Committee means:
 The certification packets provided by DTS for the Rules contained all documentation
required by the Administrative Rulemaking law for a complete administrative record;
 The promulgation of the Rules complied with the procedural requirements contained in
the Administrative Rulemaking law; and
 The Rule did not exceed the rulemaking authority granted under the law for which the
Rule is being promulgated. [1 O.C. 106.7-2].
The Legislative Operating Committee is now being asked to consider the certification of the Rules.
Administrative Rulemaking Authority
The Technology Resources law regulates the usage of technology resources and processed data
owned and operated by the Nation. [2 O.C. 215.1-1]. It is the policy of the Nation to provide its
community and employees access to the tools necessary to participate in a technological society.
[2 O.C. 215.1-2]. The Technology Resources law provides that the Digital Technology Services
(“DTS”) is delegated administrative rulemaking authority in accordance with the Administrative
Rulemaking law to promulgate rules to govern technology resources of the Nation. [2 O.C. 215.12(b)].

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Summary of Technology Resources Law Rules
DTS has brought forward six (6) Technology Resources law rules for certification and adoption.
Below please find a summary of the purpose of each Rule.
The purpose of the Technology Resources Law Rule No. 1 – Acceptable Use (Rule No. 1) is to
provide guidelines and techniques to promote effective use of Nation’s Digital Technology
Systems. [Rule 1.1-1]. It applies to all Nation systems located on, or accessed from, Nation
properties and systems provided by the Nation for use in the Nation’s business. Id. It is the policy
of the Nation to provide sophisticated computer and communications systems to support official
business activities, enabling effective and timely communication among staff, customers, partners,
and vendors. [Rule 1.1-2]. This rule establishes expectations for all staff regarding the access, use,
and disclosure of information via the Nation’s Information Systems, which are to be used solely
for official business purposes in accordance with these guidelines and other relevant policies. Id..
The purpose of the Technology Resources Law Rule No. 2 – Clear Desk/Screen (Rule No. 2) is to
improve security and confidentiality, whenever possible for papers, digital storage devices, and
screens which contain sensitive or confidential information. [Rule 2.1-1].
The purpose of the Technology Resources Law Rule No. 3 – Asset Management (Rule No. 3) is
to establish a comprehensive framework for the effective management, tracking, and security of
Information Technology assets within the organization. [Rule 3.1-1].
The purpose of the Technology Resources Law Rule No. 4 – Security Awareness Training (Rule
No. 4) is to ensure that security awareness and training measures safeguard Information Resources,
maintaining their availability, confidentiality, and integrity. [Rule 4.1-1].
The purpose of the Technology Resources Law Rule No. 8 – Third Party Providers (Rule No. 8)
is to establish guidelines to limit and control third party service providers to minimize risks such
as revenue loss, liability, loss of trust, and embarrassment to Oneida Nation, while ensuring the
responsible use of company information and resources. [Rule 8.1-1].
The purpose of the Technology Resources Law Rule No. 9 – Generative AI Usage (Rule No. 9) is
to establish proper use of Artificial Intelligence (AI) technologies while working for the Nation.
[Rule 9.1-1]. This Rule sets out to protect employees, clients, suppliers, customers, and the Nation
from harm, while leveraging AI to enhance efficiency, innovation, and competitive advantage. Id.
Eligibility for Certification by the Legislative Operating Committee
The materials submitted by DTS for the certification of the Rules have been reviewed, and this
section of the memorandum provides conclusions regarding the eligibility of the Rules for
certification by the Legislative Operating Committee.

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Complete Administrative Record
The certification packet provided by DTS for the Rules did not contain all documentation required
by the Administrative Rulemaking law for a complete administrative record. Below, please find a
chart of the required documentation for the administrative record and whether or not the
documentation was submitted:
Administrative Record Documents
Submitted
Memo from the authorized agency’s highest level of management Yes
approving the proposed rule
and/or
Minutes from the authorized agency’s meeting during which the
proposed rule was an agenda item.
Memo provided by the authorized agency containing the rule’s No procedural timeline including the dates the requirements of this law were
fulfilled.
Summary Report:
 Document containing summary information;
 Statement of Effect from Legislative Reference Office; and
 Fiscal Impact Statement.
Draft of proposed Rule
Draft of proposed rule that went to public meeting if the rule changed
after the public meeting.
If the rule is being amended, redline drafts from the currently effective
rule illustrating the proposed amendments.
Public Meeting Notice
Public Meeting Sign in sheet
A memorandum provided by the authorized agency containing the
public comments that were received, both orally and written, and the
authorized agency’s response to each comment
The effective dates of the original rule and any rule amendments
subsequently made as established by the authorized agency.

Yes

Yes
No change after
public meeting.
N/A
Yes
Yes
Yes

N/A

The administrative record was missing a memorandum or information provided by the authorized
agency containing the rule’s procedural timeline including the dates the requirements of this law
were fulfilled.
Although this information is not provided as set forth in section 106.11-1(a) of the Administrative
Rulemaking law, review of the materials that were submitted provided the following:
 Statements of Effects Provided: March 5, 2026
 Public Meeting Notice Published in the Kalihwisaks: April 2026 Edition [Published on
March 31, 2026]
 Public Meeting Held: April 6, 2026
 Public Comment Period Closure Date: April 14, 2026
 Approval Memorandum from Jason Doxtator, Chief Information Officer: April 27, 2026
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Compliance with Procedural Requirements
Based on the information provided for by DTS, the promulgation of the Rules did not comply with
the procedural requirements contained in the Administrative Rulemaking law.
Section 106.6-2(a) of the Administrative Rulemaking law requires that the public meeting notice
be published in the Kalihwisaks and on the Oneida Register not less than ten (10) business days
prior to the meeting. The public meeting notice for the Rules was published in the April 2026
Edition of the Kalihwisaks, which was published on March 31, 2026. The public meeting for the
Rules was then held on April 6, 2026. Ten (10) business days before April 6, 2026, would have
been March 20, 2026. Therefore, the public meeting was held less than ten (10) business days in
violation of section 106.6-2(a) of the Administrative Rulemaking law.
Additionally, the public meeting notice did not contain a statement of “information for
electronically accessing the proposed rule and summary report and a statement that hard copies of
the materials will be available with the authorized agency” as required by section 106.6-2(b)(2) of
the Administrative Rulemaking law. The public meeting materials were provided to the Legislative
Reference Office on March 25, 2026, and then ultimately placed on the Public Meeting page of
the Oneida Register.
Compliance with Rulemaking Authority
Based upon a review of the Rules, the Rules did not exceed the rulemaking authority granted under
the Technology Resources law.
Conclusion
The Rules provided by DTS would not be eligible for certification due to the fact that the
certification packets provided by DTS for the Rules did not contain all documentation required by
the Administrative Rulemaking law for a complete administrative record, and the promulgation of
the Rules did not comply with all procedural requirements contained in the Administrative
Rulemaking law.
Section 106.7-3 of the Administrative Rulemaking law provides that if the Legislative Operating
Committee determines that the authorized agency has not complied with the certification
requirements stated in section 106.7-2 of the Administrative Rulemaking law, the Legislative
Operating Committee shall not certify the proposed rule.
The Administrative Rulemaking law goes on to provide that upon the denial of certification of the
rule the Legislative Operating Committee shall return the proposed rule to the authorized agency
with specific feedback as to which requirements were not fulfilled. The authorized agency may
resubmit the proposed rule for certification by the Legislative Operating Committee once all
requirements for certification have been met.
Requested Action
Deny the certification of the following Rules and forward this memorandum to the Digital
Technology Services Department:
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






Technology Resources Law Rule No. 1 – Acceptable Use;
Technology Resources Law Rule No. 2 – Clear Desk/Screen;
Technology Resources Law Rule No. 3 – Asset Management;
Technology Resources Law Rule No. 4 – Security Awareness Training;
Technology Resources Law Rule No. 8 – Third Party Providers; and
Technology Resources Law Rule No. 9 – Generative AI Usage.

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Digital Technology Services (DTS) Department
909 Packerland Drive
Green Bay, WI 54313

Memorandum
To:
From:
Date:
Re:

"'

(XJOOOC)

ONEIDA

Oneida Nation Legislative Operating Committee (LOC)
Jason W. Doxtator, Chief Information Officer
04/27/2026
Approval of Proposed Technology Resources Law - Security Rules

CC: Mark Powless, CEO Nation Services; Ralinda Ninham-Lamberies, CFO; James Petitjean, CEO Retail;
Taryn Webster, CEO Oneida Casino Hotel; Laura Laitinen-Warren, CEO Human Resources
Purpose:
Following a comprehensive review of the proposed security rules governing technology resources, I am formally
approving the framework as outlined. This decision is based on alignment with current Oneida Nation
cybersecurity directives, regulatory standards, and best practices in digital security governance.
Summary of Approval:
The proposed rules incorporate a robust structure of governance that is essential for maintaining the integrity,
confidentiality, and availability of our digital assets. These components are consistent with Oneida Nation’s
cybersecurity initiatives and legal mandates.
Key Elements of the Approved Rules:
1. Acceptable Use
a. Provides guidelines and techniques to promote effective use of Nation’s Technology Systems
2. Clear Desk
a. To improve security and confidentiality, whenever possible for papers, digital storage devices,
and screens which contain sensitive or confidential information.
3. Asset Management
a. Establishes a comprehensive framework for the effective management, tracking, and security
of Information Technology assets within the organization.
b. Ensures the protection of sensitive data, compliance with applicable laws and regulations, and
the efficient use of technology resources to support the mission and operations of the Nation.
4. Security Awareness
a. A robust security program necessitates that staff are trained in security policies, procedures, and
technical controls.
5. Password Management
a. Passwords play a crucial role in digital security, protecting user accounts and Oneida Nation’s
digital assets.
6. Generative AI Usage
a. Outlines the proper use of AI technologies while working at Oneida Nation the goal is to protect
employees, clients, suppliers, customers, and the Nation from harm, while leveraging AI to
enhance efficiency, innovation, and competitive advantage.
Oneida Digital Technology Services (DTS) Department
909 Packerland Drive - Green Bay, WI 54313
oneida-nsn.gov

46 of 98

Implementation and Oversight:
The Digital Security Office will oversee the implementation of these rules, upon the Oneida Nations LOC
acceptance and adoption.
Please consider this memo as formal approval to proceed with the implementation of the proposed security
rules. I appreciate the committee’s diligence in crafting a framework that strengthens our digital resilience while
upholding legal and ethical standards.

A good mind. A good heart. A strong fire.

~
ONEIDA

47 of 98

Oneida Nation

Oneida Business Committee
Legislative Operating Committee
PO Box 365 • Oneida, WI 54155-0365
Oneida-nsn.gov

~
ONEIDA

Statement of Effect
Technology Resources Law Rule No. 1 – Acceptable Use
Summary
The Technology Resources Law Rule No. 1 – Acceptable Use provides guidelines and techniques
to promote effective use of Nation’s Digital Technology Systems. [Rule 1.1-1].
Submitted by: Clorissa N. Leeman, Senior Staff Attorney, Legislative Reference Office
Date: March 5, 2026
Analysis by the Legislative Reference Office
The Administrative Rulemaking law provides authorized agencies the opportunity to promulgate
rules interpreting the provisions of any law enforced or administered by it; provided that, a rule
may not exceed the rulemaking authority granted under the law for which the rule is being
promulgated. [1 O.C. 106.4-1]. Rulemaking authority is defined as the delegation of authority to
authorized agencies found in the Nation’s laws, other than the Administrative Rulemaking law,
which allows authorized agencies to implement, interpret and/or enforce a law of the Nation. [1
O.C. 106.3-1(i)]. An authorized agency is defined as any board, committee, commission,
department, program or officer of the Nation that has been granted rulemaking authority.[1 O.C.
106.3-1(a)].
The Technology Resources law regulates the usage of technology resources and processed data
owned and operated by the Nation. [2 O.C. 215.1-1]. It is the policy of the Nation to provide its
community and employees access to the tools necessary to participate in a technological society.
[2 O.C. 215.1-2]. Allowing limited personal use of these tools helps enhance the quality of the
workplace and helps the Nation to retain highly qualified and skilled workers and officials, as well
as to develop the technological skills of the community. Id. Pursuant to this law, users are
permitted limited use of technology resources of the Nation for personal needs if the use does not
interfere with the authorized duties of the user or official business of the Nation. Id. The
Technology Resources law does not create a right to use technology resources of the Nation for
personal use. [2 O.C. 215.1-2(a)]. The Technology Resources law in no way limits use of
technology resources to fulfill authorized duties. [2 O.C. 215.9-1].
The Technology Resources law provides that the Digital Technology Services (“DTS”) is
delegated administrative rulemaking authority in accordance with the Administrative Rulemaking
law to promulgate rules to govern technology resources of the Nation. [2 O.C. 215.1-2(b)].
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The Technology Resources law addresses acceptable use. The Technology Resources law provides
that users may utilize technology resources for authorized activities. [2 O.C. 215-4-1]. Users may
engage in personal use of technology resources when such use does not interfere with the mission
or operations of the entity in control of the resources and does not violate applicable laws, rules,
or standard operating procedures of the Nation. [2 O.C. 215-4-2]. Employees may engage in
limited personal use of technology resources if the usage does not violate section 215.5-1 of the
law regarding inappropriate personal use or standards enacted pursuant to section 215.7-1 of the
regarding limitations on use. [2 O.C. 215-4-3].
The purpose of the Technology Resources Law Rule No. 1 – Acceptable Use (“the Rule”) is to
provide guidelines and techniques to promote effective use of Nation’s Digital Technology
Systems. [Rule 1.1-1]. It applies to all Nation systems located on, or accessed from, Nation
properties and systems provided by the Nation for use in the Nation’s business. Id. It is the policy
of the Nation to provide sophisticated computer and communications systems to support official
business activities, enabling effective and timely communication among staff, customers, partners,
and vendors. [Rule 1.1-2]. This rule establishes expectations for all staff regarding the access, use,
and disclosure of information via the Nation’s Information Systems, which are to be used solely
for official business purposes in accordance with these guidelines and other relevant policies. Id.
The Rule addresses:











Facilities and Equipment [Rule 1.4];
Information Access, Content, and Use [Rule 1.5];
Protecting Confidential Information [Rule 1.6];
Copyrighted Information [Rule 1.7];
Privacy and Monitoring [Rule 1.8];
Storing and Archiving Information [Rule 1.9];
Employee Usage [Rule 1.10];
Email Etiquette [Rule 1.11];
Enforcement [Rule 1.12]; and
References [Rule 1.13].

Conclusion
There are no legal bars to adopting the Technology Resources Law Rule No. 1 – Acceptable Use.

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Financial Analysis for Acceptable Use Rule

Start Up Costs

Type of Cost

N/A

Description/Comment

Dollar Amount
$0.00

Personnel

N/A

$0.00

Office

N/A

$0.00

Documentation Costs

N/A

$0.00

Estimate of time necessary for an individual
or agency to comply with the rule after
implementation

Estimated 3 months to 9 months

Other, please explain
Total Annual Net Revenue

$0.00

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Summary Report for Acceptable Use Rule
Original effective date: Ten days after rule adoption.
Amendment effective date:

Name of Rule: Acceptable Use
Name of law being interpreted: Technology Resources Law
Rule Number: 1
Other Laws or Rules that may be affected: Proposed Data Classification Rule, proposed Data Retention
Rule, proposed Password Standard, & proposed BYOD Rule.
Brief Summary of the proposed rule: Provides guidelines and techniques for acceptable and effective
use of Oneida Nation’s Digital Technology Systems.
Statement of Effect: Obtained after requesting from the Legislative Reference Office.
Financial Analysis: See Attached.

Note: In addition- the agency must send a written request to each entity which may be affected by the
rule- asking that they provide information about how the rule would financially affect them.
The agency must include each entity’s response in the financial analysis. If the agency does not receive a
response within 10 business days after the request is made, the financial analysis can note which entities
did not provide a response.

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Title 2. Employment – Chapter 215

Technology Resources Law
Rule #001 – Acceptable Use
1.1 Purpose and Authority
1.2 Adoption, Amendment and Repeal
1.3 Definitions
1.4 Purpose and Scope
1.5 Facilities and Equipment
1.6 Information Access, Content, and Use
1.7 Protecting Confidential Information
1.8 Copyrighted Information
1.9 Privacy and Monitoring
1.10 Storing and Archiving Information
1.11 Employee Usage
1.12 Email Etiquette
1.13 Enforcement
1.14 References

1.1 Purpose and Authority
1.1-1. Purpose. The purpose of this rule is to provide guidelines and techniques to promote
effective use of the Nation’s Digital Technology Systems. It applies to all of the Nation’s systems
located on, or accessed from, Nation properties and systems provided by the Nation for use in the
Nation’s business.
1.1-2. Policy. It is the policy of the Nation to provide sophisticated computer and communications
systems to support official business activities, enabling effective and timely communication
among staff, customers, partners, and vendors. This rule establishes expectations for all staff
regarding the access, use, and disclosure of information via the Nation’s Information Systems,
which are to be used solely for official business purposes in accordance with these guidelines and
other relevant policies.
1.1-3. Authority. The Technology Resources Law delegates rulemaking authority to the Digital
Technology Services Department pursuant to the Administrative Rulemaking law.
1.2. Adoption, Amendment and Repeal
1.2-1. This rule was adopted by the Oneida Business Committee in accordance with the procedures
of the Administrative Rulemaking law.
1.2-2. This rule may be amended or repealed by the Digital Technology Services Department
and/or the Oneida Business Committee pursuant to the procedures set out in the Administrative
Rulemaking law.
1.2-3. Should a provision of this rule or the application thereof to any person or circumstances be
held as invalid, such invalidity shall not affect other provisions of this rule which are considered
to have legal force without the invalid portions.
1.2-4. In the event of a conflict between a provision of this rule and a provision of another rule,
internal policy, procedure, or other regulation; the provisions of this rule shall control.
1.2-5. This rule supersedes all internal department rules, regulations, policies, or other
requirements relating to acceptable use as referenced in the Technology Resources Law.

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1.3. Definitions
1.3-1. This section shall govern the definitions of words and phrases used within this rule. All
words not defined herein shall be used in their ordinary and everyday sense.
(a) “Nation” means the Oneida Nation.
(b) “Confidential data” means any information that the Nation is obligated by law, policy,
or regulation to protect from unauthorized access, use, disclosure, modification, or
destruction.
(c) “Personal use” means any technology resource use that is conducted for purposes other
than accomplishing an authorized activity or official business of the Nation.
(d) “Technology resources” means any tools, systems, and applications that use technology
to fulfill their purposes. Technology resources may include, but are not limited to,
computers, tablets, telephones, facsimile machines, photocopiers, networks, virtual
applications, and software, such as internet connectivity and access to internet
services and electronic mail.
(e) “Staff” means any individual who uses the technology resources of the Nation,
including but not limited to employees, independent contractor personnel, interns,
members of boards, committees or commissions, volunteers, guests, and visitors.
1.4. Facilities and Equipment
1.4-1. The Nation maintains facilities, equipment, and communication systems (e.g., telephones,
email, computers, fax machines) to enhance operational efficiency. These systems, provided at
the Nation’s expense, are for official business only. Access is granted based on job
responsibilities, and use is subject to this rule.
1.4-2. Staff shall not remove equipment or software from the Nation’s premises or use personal
equipment for official business without prior express consent from the employee’s senior level
manager or director.
1.4-3. Alternate internet service provider connections to the Nation’s network are prohibited
unless approved by management and secured by appropriate security devices.
1.5 Information Access, Content, and Use
1.5-1. Technology and Resources. The Nation invests in advanced technology to support official
business. All staff with access to technology resources shall read, understand, and comply with
this rule.
15-2. Business Use.
(a) Information Systems are owned by the Nation and shall be used exclusively for
business purposes, serving customer interests, and supporting normal operations.
(b) Staff decisions to use these systems should be based on sound business practices,
reducing costs, or improving services measurably, while maintaining a professional image.
(c) Staff using the Nation’s accounts act as representatives of the Nation and shall avoid
damaging the organization’s reputation.
1.5-3. Acceptable Use. Use of the Nation’s facilities, equipment, or systems is limited to
acceptable use as defined in this rule. Incidental personal use is permitted if it is not excessive,
does not interfere with job performance, consume significant resources, or disrupt other staff
activities, as determined by the Nation.

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1.5-4. Professional Conduct. Staff shall conduct official business consistent with the Nation’s
mission and comply with tribal, state, and federal laws, maintaining standards of integrity,
accountability, and legal sufficiency.
1.5-5. Information Accuracy.
(a) Staff shall disseminate current, accurate, complete, and compliant information.
(b) Information shared through technology resources shall be handled with the same level
of care as other forms of communication. Users should ensure that content respects
intellectual property rights, including copyrights, trademarks, and trade secrets.
(c) Staff using Internet information for strategic business decisions shall verify its
integrity, ensuring the source is regularly updated and valid.
1.5-6. Confidential and Proprietary Information.
(a) Staff shall protect confidential and proprietary information.
(b) Questions regarding the appropriate use of technology resources or handling of
information, staff should consult their area manager or director for guidance.
(c) Staff shall not discuss the Nation’s business prospects, financial condition, or future
products with third parties unless publicly disclosed by the Nation.
(d) Unauthorized disclosure of confidential or proprietary information may result in legal
action.
1.5-7. Public Accessibility.
(a) Designated staff may make information publicly accessible after management review
to verify accuracy and appropriateness.
(b) Publicly accessible information shall be periodically reviewed to remove inaccurate,
inappropriate, or nonpublic content.
1.6. Protecting Confidential Information
1.6-1. Importance and Procedures. Maintaining confidentiality is critical to the Nation’s success.
Staff shall follow appropriate procedures to protect confidential information, exercising caution
when communicating externally, as electronic communications are not fully secure.
1.6-2. Data Classification. Confidential data shall be marked with designations such as
“Confidential,” “Do not reproduce,” or “Do not forward.” Emails containing confidential
information shall include “Confidential” in the subject line.
1.6-3. Access Restrictions.
(a) Access to directories containing sensitive or confidential data is restricted.
(b) Unauthorized attempts to bypass restrictions, including hacking, violate this rule and
may lead to disciplinary action, including termination or legal action. Hacking may
also violate the Federal Electronic Communications Privacy Act (18 U.S.C. 2510).
1.6-4. Privacy of Communications. Staff shall respect the privacy of messages received, securing
voicemail and email accounts with proper password protection, closing messages after reading,
and deleting unnecessary messages.
1.6-5. Internet Privacy.
(a) The internet does not guarantee privacy. Staff shall exercise caution when transferring
sensitive material online by using secure methods (e.g., encrypted channels, approved
platforms) and avoiding public or unsecured networks. This helps prevent unauthorized
access or third-party interception.

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(b) Staff shall not place the Nation’s materials—such as copyrighted software, internal
correspondence, or other proprietary content—on publicly accessible internet-connected
devices or platforms without prior approval from their area manager or director.
1.7. Copyrighted Information
1.7.1. Intellectual Property Rights.
(a) The Nation respects intellectual property rights. Staff shall comply with license terms
for copyrighted material (e.g., literature, software, graphics) and not assume
availability on electronic systems permits downloading or dissemination.
(b) Unauthorized or illegal use of third-party intellectual property, including downloading
copyrighted software, video, or audio clips, is prohibited.
(c) Employees/users shall consult with management if unsure about use of third=party
intellectual property.
1.7-2. Trademark and Copyright Notices.
(a) The Nation’s trademarked or copyrighted material shall be properly marked.
(b) Staff shall not remove third-party trademark or copyright notices.
1.7-3. Software Use.
(a) Software use shall comply with the Nation’s licensing agreements.
(b) Copying software, loading personal software, or downloading Internet software
without permission is prohibited.
(c) Software and firmware shall be digitally signed using a recognized, approved
certificate.
(d) All Nation-owned software remains with Nation upon staff departure.
1.8. Privacy and Monitoring
1.8-1. Expectation of Privacy. Staff have no reasonable expectation of personal privacy regarding
data, communications, or activities on the Nation systems, which may be monitored, accessed, or
reviewed by authorized personnel without notice to ensure compliance with policies, legal
requirements, and security protocols.
1.8-2. Monitoring and Inspection.
(a) The Nation reserves the right to access, inspect, or search all Information Systems,
including directories, files, emails, and communication systems, without prior notice.
Monitoring may occur to:
(1) Prevent transmission of discriminatory, harassing, or offensive messages.
(2) Detect illegal material or unlicensed software.
(3) Ensure communication tools are not used for unauthorized or disruptive
purposes.
(4) Investigate allegations of impropriety.
(5) Access information in staff absence.
(6) Respond to legal proceedings or court orders. Staff refusing to cooperate with
legitimate inspections or provide passwords may face disciplinary action,
including termination. The Nation may restrict or cancel staff access to systems
at any time.
1.8-3. System Ownership.
(a) All messages, data, and applications on Information Systems are Oneida Nation
property, subject to third-party intellectual property rights.

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(b) The Nation may access, review, copy, delete, or disclose data for legitimate business
purposes.
1.9. Storing and Archiving Information
1.9-1. Electronic data is subject to routine backups and archival procedures, retaining copies for
extended periods. Deleting data does not ensure privacy, as archives remain property of the Nation
and may be used for business purposes.
1.9-2. Staff may need to preserve data for litigation or investigations per the Data Retention Rule.
Staff shall regularly delete or archive files to manage disk space, avoiding large file transfers
during prime hours to minimize network impact.
1.10. Employee Usage
1.10-1. Compliance. Staff shall comply with this rule. Violations of this rule may result in
disciplinary action, including termination or legal action.
1.10-2. Prohibited Activities.
(a) Personal use of technology resources for financial gain or soliciting for non-business
purposes (e.g., political, religious causes) is prohibited.
(b) Inappropriate use of technology resources includes accessing, storing, or transmitting
sexually explicit, illegal, or disruptive materials (e.g., defamatory, obscene, or
harassing content)
(c) Sending threatening, slanderous, or anonymous messages, or misrepresenting identity,
is prohibited.
(d) Staff shall not copy or transfer files without permission, disable virus protection,
circumvent security mechanisms, or share confidential information externally.
(e) Staff shall cooperate with authorized investigations.
(f) If offensive material is accessed, staff shall disengage immediately.
(g) The Nation is not responsible for offensive content on external servers.
1.10-3. System Awareness. Staff shall:
(a) Protect equipment from food and/or drink and know fire suppression equipment
locations.
(b) Keep unauthorized people away from equipment and data. Question strangers in areas.
(c) Report security violations, including unauthorized data changes or loss, to
management immediately.
1.11. Email Etiquette
(a) Email is for official business. Use of the Nation’s accounts for personal email use
should be limited to occasional use.
(b) Staff shall:
(1) Use descriptive subject lines and include contact information in signatures.
(2) Acknowledge receipt of important emails, even if unable to respond
immediately.
(3) Delete read or sent emails to conserve storage.
(4) Avoid sending unnecessary or large emails to preserve network resources.
(5) Refrain from harassing, offensive, anonymous, or all-caps messages, avoiding
terse or rude tones.

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(6) Proofread messages, prioritize appropriately, and send to relevant recipients
only.
(7) Exercise caution with unencrypted emails and attachments, as email is
generally not secure.
(8) Reply carefully, avoiding unintended “Reply all,” and consider sender’s
intentions before forwarding.
1-12. Enforcement
1.12-1. Violations of this rule may result in disciplinary action, up to and including termination,
and potential legal action.
1.13. References
1.13-1. References include:
(a) COBIT APO01.02, APO01.11, APO07.03, APO07.05, APO13.01, APO13.02,
DSS04.05
(b) GDPR Article 32
(c) HIPAA 164.308(a)(1)(ii)(B), 164.312(a)(2)(iv)
(d) ISO 27001 7.3, A.5.4, A.5.10, A.5.12-13, A.6.3-4, A.8.16
(e) NIST SP 800-37 3.3
(f) NIST SP 800-53 AT-3.2, CA-3.4, PS-3.16
(g) NIST Cybersecurity Framework ID.AM-6, ID.GV-2, DE.DP-2
(h) PCI 12.1.1
End.

Original effective date: [add effective date established by authorized entity] (Certified by LOC on )

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Oneida Nation

Oneida Business Committee
Legislative Operating Committee
PO Box 365 • Oneida, WI 54155-0365
Oneida-nsn.gov

~
ONEIDA

Statement of Effect
Technology Resources Law Rule No. 2 – Clear Desk/Screen
Summary
The Technology Resources Law Rule No. 2 – Clear Desk/Screen sets out to improve security and
confidentiality, whenever possible for papers, digital storage devices, and screens which contain
sensitive or confidential information.
Submitted by: Clorissa N. Leeman, Senior Staff Attorney, Legislative Reference Office
Date: March 5, 2026
Analysis by the Legislative Reference Office
The Administrative Rulemaking law provides authorized agencies the opportunity to promulgate
rules interpreting the provisions of any law enforced or administered by it; provided that, a rule
may not exceed the rulemaking authority granted under the law for which the rule is being
promulgated. [1 O.C. 106.4-1]. Rulemaking authority is defined as the delegation of authority to
authorized agencies found in the Nation’s laws, other than the Administrative Rulemaking law,
which allows authorized agencies to implement, interpret and/or enforce a law of the Nation. [1
O.C. 106.3-1(i)]. An authorized agency is defined as any board, committee, commission,
department, program or officer of the Nation that has been granted rulemaking authority.[1 O.C.
106.3-1(a)].
The Technology Resources law regulates the usage of technology resources and processed data
owned and operated by the Nation. [2 O.C. 215.1-1]. It is the policy of the Nation to provide its
community and employees access to the tools necessary to participate in a technological society.
[2 O.C. 215.1-2]. Allowing limited personal use of these tools helps enhance the quality of the
workplace and helps the Nation to retain highly qualified and skilled workers and officials, as well
as to develop the technological skills of the community. Id. Pursuant to this law, users are
permitted limited use of technology resources of the Nation for personal needs if the use does not
interfere with the authorized duties of the user or official business of the Nation. Id. The
Technology Resources law does not create a right to use technology resources of the Nation for
personal use. [2 O.C. 215.1-2(a)]. The Technology Resources law in no way limits use of
technology resources to fulfill authorized duties. [2 O.C. 215.9-1].

Page 1 of 2
A good mind. A good heart. A strong fire.

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The Technology Resources law provides that the Digital Technology Services (“DTS”) is
delegated administrative rulemaking authority in accordance with the Administrative Rulemaking
law to promulgate rules to govern technology resources of the Nation. [2 O.C. 215.1-2(b)].
The purpose of the Technology Resources Law Rule No. 2 – Clear Desk/Screen (“the Rule”) is to
improve security and confidentiality, whenever possible for papers, digital storage devices, and
screens which contain sensitive or confidential information. [Rule 2.1-1]. The Rule addresses:




Digital Security Office Responsibilities [Rule 2.5];
Staff Responsibilities [Rule 2.6]; and
References [Rule 2.7].

Conclusion
There are no legal bars to adopting the Technology Resources Law Rule No. 2 – Clear
Desk/Screen.

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A good mind. A good heart. A strong fire.

~
ONEIDA

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Financial Analysis for Clear Desk Rule

Start Up

Type of Cost

N/A

Description/Comment

Dollar Amount
$0.00

Personnel

N/A

$0.00

Office

N/A

$0.00

Documentation

N/A

$0.00

Estimate of time necessary for an individual
or agency to comply with the rule after
implementation

Estimated 3 months to 9 months

Other, please explain
Total Annual Net Revenue

$0.00

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Summary Report for Clear Desk Rule
Original effective date: Ten days after rule adoption.
Amendment effective date:

Name of Rule: Clear Desk
Name of law being interpreted: Technology Resources Law
Rule Number: 2
Other Laws or Rules that may be affected: Proposed Mobile device rule and proposed Workstation
security rule.
Brief Summary of the proposed rule: The Clear Desk Rule aims to enhance security and confidentiality
by ensuring that papers, digital storage devices, and screens containing sensitive or confidential
information are secured when not in use. This rule mandates that workspaces be kept clear of such
materials to prevent unauthorized access or disclosure.
Statement of Effect: Obtained after requesting from the Legislative Reference Office.
Financial Analysis: See Attached.

Note: In addition- the agency must send a written request to each entity which may be affected by the
rule- asking that they provide information about how the rule would financially affect them.
The agency must include each entity’s response in the financial analysis. If the agency does not receive a
response within 10 business days after the request is made, the financial analysis can note which entities
did not provide a response.

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Title 2. Employment – Chapter 215
TECHNOLOGY RESOURCES LAW
Rule #002 – Clear Desk/Screen
2.1 Purpose and Authority
2.2 Adoption, Amendment and Repeal
2.3 Definitions
2.4 Digital Security Office Responsibilities
2.5 Staff Responsibilities
2.6 References

2.1 Purpose and Authority
2.1-1. Purpose. To improve security and confidentiality, whenever possible for papers, digital
storage devices, and screens which contain sensitive or confidential information.
2.1-2. Authority. The Technology Resources Law delegates rulemaking authority to the Digital
Technology Services Department pursuant to the Administrative Rulemaking law.
2.2. Adoption, Amendment and Repeal
2.2-1. This rule was adopted by the Oneida Business Committee in accordance with the procedures
of the Administrative Rulemaking law.
2.2-2. This rule may be amended or repealed by the Digital Technology Services Department
and/or the Oneida Business Committee pursuant to the procedures set out in the Administrative
Rulemaking law.
2.2.3. Shall a provision of this rule or the application thereof to any person or circumstances be
held as invalid, such invalidity shall not affect other provisions of this rule which are considered
to have legal force without the invalid portions.
2.2-4. In the event of a conflict between a provision of this rule and a provision of another rule,
internal policy, procedure, or other regulation; the provisions of this rule shall control.
2.2-5. This rule supersedes all prior rules, regulations, internal policies or other requirements
relating to clear desk/screens.
2.3. Definitions
2.3-1. This section shall govern the definitions of words and phrases used within this rule. All
words not defined herein shall be used in their ordinary and everyday sense.
(a) “Authorized Individual” means a person who has the proper authorization to access,
handle, or remove Sensitive Information from devices that transmit or print such
information.
(b) “Information Systems” means systems used to store, process, and manage information,
including computers, networks, and databases.
(c) “Removable Storage Media” means devices such as flash drives, removable media,
tablets, and cellular phones that can store electronic data and be physically removed
from a workstation.
(d) “Secure Storage Areas” means areas where sensitive information is stored that shall
remain locked or digitally secured when staff are away from their work areas.

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(e) “Sensitive Information” means information (both hardcopy and electronic) that shall

be protected from unauthorized access or disclosure. This includes private, non-public,
or confidential data.
(f) “Staff” means any individual who uses the technology resources of the Nation,
including but not limited to employees, independent contractor personnel, interns,
members of boards, committees or commissions, volunteers, guests, and visitors.
(g) “Unauthorized Access” means access to Sensitive Information by individuals who do
not have the proper authorization or clearance.
(h) “Unauthorized Disclosure” means the release or sharing of Sensitive Information to
individuals who are not authorized to receive it.
2.4. Digital Security Office Responsibilities
2.4-1. The Digital Security Office shall ensure processes are in place to:
(a) Identify Sensitive Information (hardcopy and electronic) that shall be protected from
unauthorized access or disclosure.
(b) Identify workstations that shall be shut down at the end of the workday and those to
remain powered on at night to receive security updates.
(c) Laptops/tablets/cellular phones containing Sensitive Information shall be secured per
the Mobile Device policy.
2.5. Staff Responsibilities
2.5-1. Oneida Staff shall ensure that:
(a) Sensitive or private/non-public electronic information is secured and/or removed from
unauthorized disclosure or access when they leave their work areas. Staff who work
with Sensitive Information shall have means to store information in a secure area when
not in use. Staff shall check with their immediate supervisor or Oneida management if
an emp

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/tribal%3Aoneida_nation%3A24c9b2a02a96ebcd. Public record. Not legal advice.
