Confidentiality Policy
The Christian Job Corps® (hereinafter CJC®) 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 CJC. With these principals in mind, CJC has developed this Confidentiality Policy to more clearly define the scope and nature of confidential information.
I. General Statement
Information in the possession of CJC and discussions of CJC business should generally be presumed to be confidential. All CJC personnel at every level are responsible for maintaining confidentiality.
II. Confidentiality of Donor Information
Except as required by law, CJC will not disclose information about a donor or a donor’s gift. However, unless otherwise requested by the donor, CJC may publish the names of individual donors in CJC’s Circles Fundraiser Program and other appropriate listings. In the case of memorial gifts, CJC will provide the names of donors to members of the immediate family unless the donor has requested anonymity. CJC will not publish the amount of any gift without donor consent. Unless otherwise specified in the document, donors making gifts to CJC by bequest or other testamentary device are deemed to have granted such permission. CJC 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 CJC marketing. CJC will obtain signed photo/video releases from all participants. If a photo/video release is not signed, CJC will not release that participant’s image on any public materials.
IV. Third Party Disclosures
CJC shall not release to third parties or allow third parties to copy, inspect or otherwise use CJC 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 CJC’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 CJC business, will not be shared or discussed with non-trustees outside of official CJC 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 CJC business, including documents or CJC analysis of documents, should not be discussed, photocopied, transmitted electronically or shared after a meeting or session.
VI. Exceptions
This policy does not apply to disclosures to attorneys, accountants, and other professionals providing assistance to CJC. 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:
- CJC’s annual report or financial review once it has been accepted by the board.
- CJC’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.
- CJC’s investment and spending policies.
- CJC’s investment performance.
VII. Protection of Confidential Information
CJC personnel who have executed a copy of this policy may access confidential information necessary to the performance of their functions. CJC personnel are expected to exercise sound judgment in securing information taken outside CJC’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 CJC. Violations of this policy are to be reported to the President/CEO or the Chairperson of the Board.
Donor Confidentiality Policy
Here at Christian Job Corps® of Madison County, AL Inc. (CJC®), we strive to follow the Standards for Charity Accountability as posted by the Better Business Bureau.
As the donor, it is your business to know what information we collect and how we use it. Here is our Donor Confidentiality Policy:
What information do we collect and how do we use that information?
We collect donors’ names and contact information on the pledge forms. The information could then be used for the following: a thank you letter, possibly a tax letter, solicitation during the next campaign, notification of upcoming events, as well as additional touches throughout the year and notification to other agencies if the donor asked their gift to be designated and did not request to remain anonymous.
How can donors contact us to review their personal information and request corrections?
If you have questions concerning your personal information, please contact Christian Job Corps of Madison County at our main number (256-428-9435).
How can a donor inform us that they do not want their information shared outside of CJC?
We do not share our donor information outside of CJC, aside from the annual Circles Luncheon Fundraiser program, in which we thank our donors and list their names. For those that do not wish to be listed in the program, they can contact Amy Harbarger at 256-428-9404 or aharbarger@cwjc.net to indicate that they would like to remain anonymous.
What security measures do we have in place to protect donor information?
All donor information is maintained in house (including credit card information) in a lockable file with limited access for 5 years. Donor information is only used for tracking donor pledges and payments. No specific donor information is shared outside of CJC. Information is shredded on site after 5 years.
If you are interested in reviewing our full Confidentiality Policy, Form 990, Annual Report, etc., please visit this link https://cwjc.net/about/ or look us up on Guidestar.org.