The Christian Women’s Job Corps® (hereinafter CWJC®) has an ethical and legal obligation to respect the privacy of donors and program participants, and to protect and maintain the confidentiality of all information it acquires concerning these parties.
Confidentiality, for the purpose of this document, includes information that should be held in the strictest confidence and trust whether disclosed orally or in writing to employees, directors, board members, volunteers, donors, prospective donors, vendors, or others holding a business relationship with CWJC. With these principals in mind, CWJC has developed this “Confidentiality Policy” to more clearly define the scope and nature of confidential information.
I. General Statement
Information in the possession of CWJC and discussions of CWJC business should generally be presumed to be confidential. All CWJC personnel at every level are responsible for maintaining confidentiality.
II. Confidentiality of Donor Information
Except as required by law, CWJC will not disclose information about a donor or a donor’s gift. However, unless otherwise requested by the donor, CWJC may publish the names of individual donors in CWJC’s Circles Fundraiser Program and other appropriate listings. In the case of memorial gifts, CWJC will provide the names of donors to members of the immediate family unless the donor has requested anonymity. CWJC will not publish the amount of any gift without donor consent. Unless otherwise specified in the document, donors making gifts to CWJC by bequest or other testamentary device are deemed to have granted such permission. CWJC may accept anonymous gifts on a case-by-case basis.
III. Confidentiality of Program Participants
Except as required by law, the personal information of all applicants of the program and individuals who are accepted as participants (collectively referred to as “participants in this section) shall remain confidential except to those whom the participant has given written permission to disclose her/his personal information. Personal information for the purposes of this section shall include, but not be limited to, personal, academic, and financial information. Participant identity may be revealed to medical professionals or law enforcement in the case of an emergency. Unless otherwise requested in writing by a participant, the identity of participants will be shared with the public as part of CWJC marketing. CWJC will obtain signed photo/video releases from all participants. If a photo/video release is not signed, CWJC will not release that participant’s image on any public materials.
IV. Third Party Disclosures
CWJC shall not release to third parties or allow third parties to copy, inspect or otherwise use CWJC records or other information pertaining to a grant applicant or the identification of a donor or donor’s gifts. No disclosures to third parties of such information, including addresses and demographic information shall be made without the donor’s consent.
V. Confidentiality of Business
Discussions which take place in the context of CWJC’s operations require discretion, including discussions pertaining to grants or scholarships, personnel issues, development activities, operational fundraising, investment management, etc. The positions or statements of individual board members, directors, or employees, as well as all CWJC business, will not be shared or discussed with non-trustees outside of official CWJC meetings, sessions, or communications. The only persons who may speak for the Board outside of its official written resolutions and actions is the President/CEO. Likewise, the content of CWJC business, including documents or CWJC analysis of documents, should not be discussed, photocopied, transmitted electronically or shared after a meeting or session.
This policy does not apply to disclosures to attorneys, accountants, and other professionals providing assistance to CWJC. It also does not apply to disclosures to tax authorities, government agencies, courts, or as otherwise required by law.
The following are considered public documents and information contained in them is not subject to the confidentiality requirements of this policy:
- CWJC’s annual report or financial review once it has been accepted by the board.
- CWJC’s Form 990 as required to be publicly disclosed. This does not include the names and addresses of donors as that information is not required to be disclosed.
- CWJC’s investment and spending policies.
- CWJC’s investment performance.
VII. Protection of Confidential Information
CWJC personnel who have executed a copy of this policy may access confidential information necessary to the performance of their functions. CWJC personnel are expected to exercise sound judgment in securing information taken outside CWJC’s offices or copied from its network. Any information so removed should be returned as soon as possible and deleted from laptops or other personal devices.
VIII. Consequences of Policy Violation
Violations of the Confidentiality Policy are considered serious, and may result in disciplinary action, up to and including dismissal for employees, agents or contractors, or removal from the Board of Trustees or the separation of any volunteer from a committee or other representative role on behalf of CWJC. Violations of this policy are to be reported to the President/CEO or the Chairperson of the Board.