General: The Community Foundation of Chippewa County (the Foundation) recognizes that the efficient operation of the Foundation requires the maintenance and management of extensive donor and prospective donor records. These records often contain sensitive information that has been shared with or developed by the Foundation staff on a confidential basis.
Additionally, donors and prospective donors are frequently attracted to the Foundation on the basis of its ability to ensure temporary or permanent anonymity. The purpose of this policy is to codify the position of the Foundation on anonymity and donor/prospective donor records. “Records” is construed to mean all files, including electronic data, containing information on donors or prospective donors to the Foundation.
Further, care must be taken to preserve confidentiality of discussions that take place and information that is shared in the course of conducting Foundation business.
Confidentiality of Records: The Executive Director shall be responsible for maintaining the confidentiality of donor and prospective donor records. He/she may, in his/her discretion, make all or part of any record available to staff members or Foundation volunteers to assist them in executing their responsibilities.
The Foundation’s auditors are authorized to review donor and prospect records as required for the purposes for which they are engaged.
The Board of Directors and/or the Development Committee, may from time to time, review donor/prospective donor lists for the purpose of endowed, planned giving, or annual giving activities. Any such review activity shall respect the Foundation’s significant interest in protecting the sensitive nature of donor names and information.
Publication of Donor Names: Unless otherwise requested by the donor, the names of all individual donors will be listed in the Foundation’s annual report and/or in other appropriate publications. The Foundation will not publish the amount of any donor’s gift without the permission of the donor. Donors making gifts to the Foundation by bequest or other testamentary device are deemed to have granted such permission.
Donors should be aware that it is the Foundation’s policy to, from time to time, publish the current market value of its funds, from which a reader may be able to determine the approximate size of a donor’s gift.
Memorial / Honor Gifts: The names of donors who have made “in memory of” or “in honor of” gifts may be released to the honoree, next of kin, or appropriate member of the immediate family, unless otherwise specified by the donor. Gift amounts are not to be released without the express consent of the donor.
Anonymous Gifts: The Executive Director is authorized to accept anonymous gifts to the Foundation. In the event the Executive Director is uncertain about the desirability of accepting an anonymous gift, he/she shall consult with the Executive Committee.
The Executive Director shall disclose to the Executive Committee, upon a request by a majority of the Executive Committee, the names of any anonymous donors.
Disclosure of Pending Gifts: In the event that the Executive Director concludes that the Foundation is likely to receive, in the immediate future, a gift equal to or greater than five percent of its then existing assets, the Executive Director shall notify the Board Chair. The Board Chair and the Executive Director shall determine the appropriate course for notifying the Board of Directors.
Disclosures to Third Parties: The Foundation shall not release to third parties or allow third parties to copy, inspect or otherwise use Foundation records or other information pertaining to the identification of a donor or a donor’s gifts. No disclosures to third parties of such information, including addresses and demographic information, shall be made without the donor’s consent. Exceptions would include Foundation records which are deemed necessary to conduct the business affairs of the Foundation by a third party entity which has an authorized contractual arrangement with the Foundation and has signed this confidentiality policy.
Confidentiality of Foundation Business: Discussions that take place in the context of the Foundation’s operations require discretion, including discussions pertaining to grant making, personnel issues, development activities, operational fundraising, investment management, etc. The positions or statements of individual board members, advisors, or staff should not be discussed outside of official Foundation meetings and processes. Likewise, the content of Foundation business, including documents or Foundation analysis or documents, should not be discussed or shared outside official meetings and processes.
Public Disclosure: The Foundation will comply with both the letter and spirit of all public disclosure requirements, including the open availability of its Form 990 tax returns. This Confidentiality Policy shall not be construed in any manner to prevent the Foundation from disclosing information to taxing authorities or other governmental agencies or courts having regulatory control or jurisdiction over the Foundation. However, all Board members, committee members, staff, volunteers, and contractors must hold strictly confidential all information of a private nature, including, but not limited to, all items explicitly discussed in this policy.