Policy: 4.5 Access Device and Key Control

Business and Operating Policies and Procedures

Adoption Date: July 30, 2025 Revised

The purpose of this policy is to establish clear procedures for the issuance, use, accountability, and security of access devices and keyrings at Howard College. This policy is intended to protect the integrity of the college’s physical infrastructure by limiting access to authorized individuals based on their official job responsibilities. It ensures compliance with applicable state directives, including Executive Order GA-48, and helps maintain a safe and secure environment for students, employees, and visitors.

Definitions

Access Devices: An Access Device is any physical or electronic item issued by Howard College that provides authorized entry to secured campus areas. This includes, but is not limited to, metal keys, electronic access devices (fobs, proximity cards, access badges, swipe cards), and other security credentials. All access devices will be issued by the Facilities Department and must be secured on a college-issued keyring and may not be altered or duplicated without authorization.
Electronic Access Devices (Fob): An Electronic Access Device, commonly referred to as a fob, is a type of access device that uses RFID or similar contactless technology to unlock electronic door hardware or access-controlled systems. Examples include key fobs, proximity cards, access badges, or other RFID-enabled tokens. These devices are programmable and may be customized based on a user’s role, assigned areas, and authorized timeframes.

Procurement of Electronic Access Devices: All electronic access devices-including but not limited to key fobs, proximity cards, access badges, or other contactless credentials-must be purchased by the respective Campus Security Department. Centralizing the procurement of these devices ensures secure activation, proper tracking, and compliance with the college’s access control protocols. No other department or individual is authorized to purchase, duplicate, or activate electronic access devices.

Request for Access Devices: Only an employee’s immediate supervisor is authorized to submit an Access Request Form through DocuSign on behalf of that employee. Once the request is approved through the proper channels and the keyring is issued, the employee must sign and date the form to acknowledge receipt of the keyring with attached access devices and to confirm that they will abide by all rules and regulations outlined on the Access Request Form. No access devices will be issued without a properly completed and signed Access Request Form.

Issuance of Electronic Access Devices: Electronic access devices will be issued only upon submission and approval of an Access Request Form, following the steps outlined in the Request for Access Devices section of this policy.

For the Big Spring, Lamesa, and SWCD campuses, only the Chief Operations and Safety Security Officer is authorized to issue electronic access devices.
For the San Angelo campus, electronic devices will be issued only by the San Angelo District Director of Administrative Services.

This centralized issuance process ensures consistency, accountability, and alignment with the college’s access control section.

Student Electronic Access Devices: Electronic access devices assigned to students will be issued and managed by Student Housing staff. These devices are intended for residence hall entry and, when applicable, may also be used by student-athletes requiring access to athletic fieldhouses. In such cases, the same device issued for residence hall entry will be programmed to include fieldhouse access—no additional device will be issued. These devices remain the property of Howard College and may be reused each school year. Student Housing is responsible for maintaining accurate records of issuance, return, programming, and reuse, and must ensure that all devices are deactivated and reprogrammed prior to reassignment. Student electronic access devices are to be used exclusively for these two purposes (residence halls and athletic fieldhouses). Any request for student access beyond these areas must receive prior approval from the Chief Operations and Safety Security Officer. All student electronic access devices must be supplied from inventory procured exclusively by the respective Campus Security Departments to ensure compatibility, security, and centralized control.

Childcare Facility Electronic Access Devices (Howard Cottage): Electronic access devices used for entry into Howard Cottage (the college’s child development center) will be programmed and managed solely by the Director of the Child Development Center. These devices will be issued only to parents or guardians who are actively paying for childcare services. The Director is responsible for maintaining accurate records of issuance, return, programming, and reuse, and must ensure that all devices are deactivated and reprogrammed prior to reassignment to maintain a secure environment for children and staff. All access devices for Howard Cottage must be supplied from inventory procured exclusively by the Big Spring Campus Security Department to ensure compatibility, security, and centralized access control.

Issuance of Access Devices: Keyrings with attached access devices will be issued by, and records kept by the Facilities Department for employees, contractors, and temporary access needs as applicable.

Reuse of Employee Access Devices and Keyrings: Electronic access devices and/or keyrings issued to employees shall not be reassigned to a different employee following resignation or termination. Upon separation from the college, all issued access devices must be returned to the Facilities Department, deactivated, and securely stored. This policy ensures that access is managed securely and remains aligned with individual job responsibilities and access permissions

Exterior Door Access Devices: Employees will only be issued fob access to exterior doors of the building in which their office is located and to the exterior doors of buildings that access is necessary to perform their job functions. There will be an effort to limit building and room access to maintain a more secure environment and reduce the risk of compromising campus safety. Contractors or individuals requiring temporary access will be issued a temporary access device for the specific time needed. These devices must be checked out from and returned to the Facilities Department.

Interior Door Access Devices: Access devices to interior doors will be issued to employees, contracted service providers, or individuals requiring temporary access, and only when the level of access requested is directly justified by the duties outlined in their job description or assigned responsibilities. Interior master or sub-master keys, due to their broad access capabilities, will be issued only to individuals who have supervisor responsibilities and are members of the President’s Council or in some cases program directors, and only when such access is essential to perform their job functions as defined in their official roles.

Exterior and Interior Grand Master Access: To maintain the security and integrity of Howard College’s infrastructure and to ensure compliance with Executive Order GA-48, access to grand master keys and exterior grand master fob access will be strictly limited to employees whose job descriptions explicitly state they have the ability to maintain the security or integrity of the college’s infrastructure. As outlined in the Executive Order, the ability to maintain the security or integrity of the infrastructure is a requirement to be hired for and to continue to be employed in these positions. Accordingly, only those individuals who meet this qualification will be considered eligible for grand master access. Additionally, employees issued this access must pass and maintain satisfactory compliance with all required reviews, including but not limited to criminal history checks and assessments for continuous connections to foreign governments or political entities, as mandated under state guidance. Grand master access will not be issued outside of these criteria. This policy applies to both Howard College personnel and contracted service providers.

Loaning of Access Devices: Access devices may not be loaned under any circumstances. Violation of this policy without justification may result in termination.

Duplication and Tampering: The duplication of any access devices, including keys or electronic access devices, is strictly prohibited. Tampering with keyrings or altering the assigned configuration of keys is also not allowed. Any violation of this policy may result in disciplinary action and revocation of access privileges.

Broken Access Devices: Broken access devices will be replaced at no cost when they are returned to the Facilities Department or site administrator as applicable.

Lost Access Devices: All lost or stolen access devices must be reported immediately to the Facilities Department upon discovery. Prompt reporting is critical to maintain campus security and prevent unauthorized access. If the loss or theft is discovered outside of regular college business hours, it must be reported immediately to Campus Security. Delays in reporting may result in disciplinary action and increased risk to the safety of college facilities. Lost access devices will be replaced and charged to the individual at a cost of $40 per issued access device.

Stolen Access Devices: Stolen access devices will be replaced at no cost if a copy of the police report accompanies the request.

Access Device Inventory: Access devices no longer needed should be returned to the Facilities Department immediately. Upon resignation or termination, it is the employee’s responsibility to return access devices to the Facilities Department or site administrator as applicable on or before the last day of work. Access devices not returned by an employee who resigns or is terminated will be charged to the employee’s final check at a cost of $40 per issued access device.