A web compliance officer is designated by the leadership in each of Penn's schools, centers, and administrative centers. Web compliance officers serve a variety of purposes to lead the web compliance efforts in their spheres of influence.

As a web compliance officer, your role is connective. You're the point of contact for your unit with ISC. You are not necessarily the person who implements the technical changes, but the person who knows what needs to happen and makes sure the right people are in the loop.

In practice, that means:

• Knowing your web properties. ISC will provide you with a site inventory generated from Little Forest as part of your onboarding. Review it for completeness: you may have properties that aren't in the initial scan, and you may have legacy sites that are no longer actively maintained. Both matter.
• Knowing who implements. When a site needs a technical change (adding the OneTrust script, for example) that work falls to whoever manages the site in your unit. You don't need to do it yourself; you need to know who does and be able to connect them with ISC's guidance.
• Reviewing scan results. Little Forest will flag tracking technologies running on your sites. Your job is to review those results, understand what's there, and flag anything that looks unexpected or unfamiliar. ISC is here to help interpret findings; you don't need to come in with all the answers.
• Being the escalation path for your unit. Questions from your unit about consent, tracking, or compliance come to you first. You'll have what you need to answer most of them. When you don't, ISC is the next stop.

ISC manages and operates the program infrastructure. That includes:

• OneTrust, the consent management platform deployed across Penn's web properties. ISC configures the consent banner, manages global settings, and maintains the platform. Individual units do not modify banner behavior or global policy.
• Little Forest, the automated scanning tool that identifies tracking technologies running on Penn websites. ISC manages the platform license and runs scans across the Penn web ecosystem. When you're onboarded as a web compliance officer, you'll receive access to your unit's scan results through Little Forest directly.
• Policy guidance and framework. ISC maintains the compliance framework (what requires consent, what doesn't, and how edge cases are handled) and updates it as the legal landscape evolves.
• Training and support. ISC runs onboarding sessions, maintains this documentation, and is the escalation point when something falls outside what a web compliance officer can resolve independently.
• Provisioning. ISC sets up your accounts in both OneTrust and Little Forest during onboarding. You don't need to request access separately.
   

Web compliance officers in schools and centers and ISC are collaborating to implement and maintain the program.

• ISC handles anything that affects the platform or policy implementation. 
• Web compliance officers manage their websites, handle anything that requires knowledge of their web presence, people, or vendors.
• When something is in a gray area or requires escalation or consultation, please contact ISC.