Oneida Business Committee (2026)

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Oneida Nation

Oneida Business Committee

Legislative Operating Committee

PO Box 365 • Oneida, WI 54155-0365

Oneida-nsn.gov

ONEIDA

LEGISLATIVE OPERATING COMMITTEE MEETING AGENDA

Business Committee Conference Room - 2nd Floor Norbert Hill Center

August 19, 2026

9:00 a.m.

Call to Order and Approval of the Agenda

II.

Minutes to be Approved

1. August 5, 2026 LOC Meeting Minutes (pg. 2)

III.

Current Business

IV.

New Submissions

Additions

VI.

Administrative Updates

1. Certification of the Technology Resources Law Rules (pg. 4)

2. Certification of the Real Property Law Rule No. 3 – Easements Amendments (pg.63)

3. Legislative Operating Committee End of 2023-2026 Legislative Term Report (pg. 93)

VII.

Executive Session

VIII. Recess/Adjourn

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Oneida Nation

Oneida Business Committee

Legislative Operating Committee

PO Box 365 • Oneida, WI 54155-0365

Oneida-nsn.gov

ONEIDA

GOOODO

LEGISLATIVE OPERATING COMMITTEE MEETING MINUTES

Oneida Business Committee Conference Room-2nd Floor Norbert Hill Center

August 5, 2026

9:00 a.m.

Present: Jameson Wilson, Jonas Hill, Kirby Metoxen, Jennifer Webster

Others Present: Clorissa Leeman, Grace Elliott, Carolyn Salutz

Others Present on Microsoft Teams: Ashley Blaker, Rhiannon Metoxen, Fawn Cottrell, Melissa

Alvarado, Rae Skenandore, Kaylynn Biely, Kristal Hill, Fawn Billie, Thurston Denny, Lora

Danforth, Michelle Braaten, Jada Lassila, Peggy Helm-Quest, Derrick King, Isaiah Skenandore,

Kristin Jorgenson-Dann, Quailen Thao, Taryn Webster, Sidney White, Valerie Webster, Tina

Jorgenson, Lorna Skenandore, Michelle Tipple, Justin Nishimoto, David Jordan

Call to Order and Approval of the Agenda

Jameson Wilson called the August 5, 2026, Legislative Operating Committee meeting to

order at 9:00 a.m.

Motion by Jennifer Webster to adopt the agenda; seconded by Jonas Hill. Motion carried

unanimously.

II.

Minutes to be Approved

1. July 15, 2026 LOC Meeting Minutes.

Motion by Jennifer Webster to approve the July 15, 2026, LOC meeting minutes and forward to the Oneida Business Committee; seconded by Kirby Metoxen. Motion carried

unanimously.

III.

Current Business

1. Safe Neighborhoods Law.

Motion by Jennifer Webster to approve the public meeting packet for the proposed Safe

Neighborhoods law and forward the Safe Neighborhoods law to a public meeting to be

held on September 10, 2026; seconded by Kirby Metoxen. Motion carried unanimously.

Motion by Kirby Metoxen to approve the emergency adoption extension packet for the

Safe Neighborhoods law and forward to the Oneida Business Committee for consideration;

seconded by Jennifer Webster. Motion carried unanimously.

G00DOC)

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Legislative Operating Committee Meeting Minutes of August 5, 2026

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ONEIDA

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2. Petition: G. Powless-Buenrostro – Amend the Judiciary Law #2026-01.

Motion by Jennifer Websyer to approve the updated public comment review memorandum,

draft, and legislative analysis for the proposed amendments to the Boards, Committees,

and Commissions law; seconded by Jonas Hill. Kirby Metoxen opposed Motion carried.

3. Boards, Committees, and Commissions Law Amendments.

Motion by Jonas Hill to approve the adoption packet for the Boards, Committees, and

Commissions Law Amendments and forward to the Oneida Business Committee for consideration; seconded by Jennifer Webster. Motion carried unanimously.

4. Code of Ethics Amendments.

Motion by Jennifer Webster to approve the adoption packet for the proposed amendments

to the Code of Ethics and forward to the Oneida Business Committee for consideration;

seconded by Jonas Hill. Motion carried unanimously.

IV.

New Submissions

Additions

VI.

Administrative Updates

1. Legislative Operating Committee Fiscal Year 2026 Third Quarter Report.

Motion by Jennifer Webster to approve the LOC Fiscal Year 2026 Third Quarter Report

and forward to the Oneida Business Committee; seconded by Kirby Metoxen. Motion carried unanimously.

VII.

Executive Session

VIII. Adjourn

Motion by Jennifer Webster to adjourn at 9:41 a.m.; seconded by Kirby Metoxen. Motion

carried unanimously.

Legislative Operating Committee Meeting Minutes of August 5, 2026

Page 2 of 2

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Oneida Nation

Oneida Business Committee

Legislative Operating Committee

PO Box365 • Oneida, WI 54155-0365

Oneida-nsn.gov

000000

ONEIDA

AGENDA REQUEST FORM

8/10/2026

1) Request Date: _____________________________________________________

...t

Jesse

Kujawa

2) Contact Person(s): ______________________________________

Digital Technology Services

Dept:____________________________

920-429-3234

jkujawa@oneidanation.org

Phone Number:_________________________

Email: __________________________________

Technology Resource Law Rule Amendments

3) Agenda Title:___________________________________________________________________

4) Detailed description of the item and the reason/justification it is being brought before the LOC:

The Technology Resources Law is a framework for identifying rules and

_______________________________________________________________________________

expectations to safeguard Oneida information. Additional rules are

_______________________________________________________________________________

required to outline compliance in accordance to the law.

_______________________________________________________________________________

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

Rule Approval Memo with timeline

Public Meeting

1) ________________________________

3) ________________________________

Rule Packet

2) ________________________________

4) ________________________________

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

Technology Reousrce Law

_______________________________________________________________________________

6) Please list all other departments or person(s) you have brought your concern to:

Oneida CEO's CFO, CISO, CIO, and DTS Staff

______________________________________________________________________________

7) Do you consider this request urgent?

Iii Yes

□ No

If yes, please indicate why:

The technology resource law requires further clarity and context due to recent events and incidents

________________________________________________________________

I, the undersigned, have reviewed the attached materials, and understand that they are subject to action by

the Legislative Operating Committee.

Signature of Requester:

Digitally signed by Jesse Kujawa

Jesse Kujawa

Date: 2026.08.10 11 :30:14 -05'00'

__________________________________________________________________________

Please send this form and all supporting materials to:

LOC@oneidanation.org

Legislative Operating Committee (LOC)

P.O. Box 365

Oneida, WI 54155

Phone 920-869-4376

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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:

000000

ONEIDA

Legislative Operating Committee (LOC)

Clorissa N. Leeman, Legislative Reference Office, Senior Staff Attorney

August 19, 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. 215.1-2(b)].

Page 1 of 4

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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 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.

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 Yes

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

No change after

public meeting.

N/A

Yes

N/A

Yes

N/A

Compliance with Procedural Requirements

Based on the information provided for by DTS, the promulgation of the Rules did comply with the

procedural requirements contained in the Administrative Rulemaking law.

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.

GDODOO

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ONEIDA

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Conclusion

The Rules provided by DTS are eligible for certification by the Legislative Operating Committee

under section 106.7-2 of the Administrative Rulemaking law.

Requested Action

Certify the following Rules and forward to the Oneida Business Committee:

 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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ONEIDA

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Digital Technology Services (DTS) Department

909 Packerland Drive

Green Bay, WI 54313

Memorandum

To:

From:

Date:

Re:

GDDDDC)

ONEIDA

Oneida Nation Legislative Operating Committee (LOC)

Jason W. Doxtator, Chief Information Officer

07/27/2026

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

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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.

Rule Procedural Timeline:

• Statement of Effects Provided: March 3, 2026

• Public Meeting Notice Published in Kalihwisaks: July 2026 edition [Published on June 30, 2026]

• Public Meeting Held: July 23, 2026

• Public Comment Period Closure: August 4th, 2026

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ONEIDA

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ONEIDA-NSN.GOV

NOTICES

JULY 2026 I 25

PUBLIC MEETING NOTICE - 9am, Thurs., July 23, 2026

In accordance w ith the Administrative Rulemaking

Law, the Digital Technology Services Department

is h osting this Public Meeting to gather feedback

from the community regarding THE FOLLOWING

PROPOSED RULES to the Techno logy

Reso urces Law

• 001- Acceptable Use

• 002- Clear Desk

• 003-Asset Management

• 004-Security Awareness

• 008- Third Party Provider

• 009-Generative Al Usage

Who would be aected:

• Employees and Contractors,

• Vendors, and Third-Party

Providers

This is a proposal to adopt rules which would:

Establish clear standards for responsible and secure use of

digital technology.

Promote data protection and reduce the risk of unauthorized

access or data breaches.

Ensure proper tracking and disposal of IT assets.

Require ongoing security awareness training for employees.

Regulate secure access and evaluate risk for vendors

and third-party providers.

Govern the ethical and secure use of generative

Al technologies.

PUBLIC COMMENT PERIOD OPEN UNTIL

TUESDAY, AUGUST 4, 2026

DTS DIGITAL SECURITY

909 PACKERLAND DR. • GREEN BAY, WI 54303

lnfoSec@OneidaNation.org • 920.869.4357

During the public comment period, anyone may submit

written comments, questions. or input. Comments may be

submitted to the Oneida Nation DTS Office or the

Skenandoah Front Desk in person, by U.S. mall, interoffice

mail, or e-mail.

lndiViduals may attend the public meeting for the proposed amendments to the Technology Resources Law in person

at the Skenandoah Complex or virtually throug h Microsoft Teams (MT). If you wish to attend the public meeting through

MT, email infosec@oneidanation.org

For more in formation on the proposed Technology Resources Law amendments. please review the public meeting

packet at www.oneida-nsn.gov/Register/PublicMeet ings or email infosec@oneidanation.org for electronic copies.

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Digital Technology Services (DTS) Department

909 Packerland Drive

Green Bay, WI 54313

Memorandum

To:

From:

Date:

Re:

GDDDDC)

ONEIDA

Oneida Nation Legislative Operating Committee (LOC)

Jesse Kujawa, Digital Technology Services Security Analyst

08/10/2026

Public Comment Period for Amendments to the Technology Resources Law

This memorandum serves as documentation that the public comment period regarding the proposed

amendments to the Technology Resources Law was completed in accordance with applicable procedures and

timeframes.

Upon the close of the public comment period, no comments, concerns, recommendations, or objections were

received from members of the public, stakeholders, or other interested parties regarding the proposed

amendments.

As no public comments were submitted during the designated comment period, there are no comments

requiring review, response, or incorporation into the proposed amendments.

This memorandum is being provided for the official record and to document the completion of the public

comment process.

Oneida Digital Technology Services (DTS) Department

909 Packerland Drive - Green Bay, WI 54313

oneida-nsn.gov

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Title 2. Employment

Tut~e

1Emp~oyme111t –

= Chapter

Clhlapterr 215

2 TI 5

rTechnology

echno~ogy Resources

ResolUI rrces Law

lLalw

Rule

Acceptable Use

RIUl~e #001

#00 ~ –

= Accepttab~e

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.

Technology Resources Law Rule 001 –Acceptable Use

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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.

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.

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.

Technology Resources Law Rule 001 –Acceptable Use

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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.

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.

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.

Technology Resources Law Rule 001 –Acceptable Use

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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.

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.

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.

Technology Resources Law Rule 001 –Acceptable Use

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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)

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.

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.

Technology Resources Law Rule 001 –Acceptable Use

Page 5 of 6

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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

(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 )

Technology Resources Law Rule 001 –Acceptable Use

Page 6 of 6

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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.

20 of 141

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

21 of 141

Oneida Nation

Oneida Business Committee

Legislative Operating Committee

PO Box 365 • Oneida, WI 54155-0365

Oneida-nsn.gov

GODOOO

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)].

Page 1 of 2

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

22 of 141

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.

Page 2 of 2

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

ONEIDA

23 of 141

Title 2.

Tn1t~e

2. Employment

!Emp~oymen1t – Chapter

CChap1terr 215

2~5

TECHNOLOGY RESOURCES

T!ECCHNOlOGY

!R!E§OU!RCC!E§ LAW

Rule

!Ru~e #002 – Clear

CC~earr Desk/Screen

Deslkj§crreen

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.

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.

Technology Resources Law Rule 002 – Clear Desk/Screen

Page 1TI of 3

24 of 141

(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.

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 employee is not sure what information shall be secured or what lockable storage is

available.

(b) Their desk and work area is clear (clear desk) of papers and removable storage media

when leaving their work area unsecured. In addition, monitors shall be cleared (clear

screen) to protect against unauthorized access to information or Information Systems.

Screen savers shall be automatically activated after a period of inactivity. See the

Workstation Security policy for more information.

media, tablets, cellular phones) shall be secured when Staff leave their work area.

Storage areas containing Sensitive Information shall remain locked or digitally secured

when Staff are away from their work areas. Keys to secure storage areas shall not be

left in the lock or accessible by unauthorized personnel.

(d) Devices that transmit or print (e.g., Fax machines, printers) Sensitive Information shall

have the documents immediately removed from the device by authorized staff to

prevent unauthorized disclosure or access.

(e) Documents waiting to be shredded shall not be accessible by unauthorized staff.

(f) Violations to this rule may be subject to disciplinary action, up to and including

termination.

2.6. References

(a) 2.6.1. COBIT EDM03.07, APO07.05, APO12.02, APO12.07, APO14.02, DSS06.07

(b) 2.6.2. GDPR Article 25, 32

Technology Resources Law Rule 002 – Clear Desk/Screen

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25 of 141

(d) 2.6.4. ISO 27001 A.7.7

(e) 2.6.5.NIST SP 800-37 3.1, 3.3

(f) 2.6.6. NIST SP 800-53 AC-11, MP-2, MP-4

(g) 2,6.7. NIST Cybersecurity Framework ID.AM-6, ID.GV-4, ID.RA-3, PR.AC-2, PR.AT-1,

DE.DP-2

(h) 2.6.8. PCI 9.4.1, 12.1.1

End.

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

Technology Resources Law Rule 002 – Clear Desk/Screen

Page 3 of 3

26 of 141

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.

27 of 141

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

28 of 141

Oneida Nation

Oneida Business Committee

Legislative Operating Committee

PO Box 365 • Oneida, WI 54155-0365

Oneida-nsn.gov

GODOOO

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.