Privacy

DONOR CONFIDENTIALITY POLICY

PURPOSE OF THE POLICY
The purpose of this policy of The Hudson Community Foundation (Foundation) is to guide the actions of the Board of Directors and Staff regarding the rights of donors and potential donors to confidentiality regarding their transactions with the Foundation.

The operation of the Foundation requires the maintenance and management of extensive donor and prospect records. Donor records often contain sensitive information that has been shared with or developed by the Foundation staff on a confidential basis. “Records” means all files, including electronic data, containing information on donors or prospective donors to the Foundation.

POLICIES:

Confidentiality of Records:
The President is responsible for maintaining the confidentiality of donor and prospect records and will ensure that all staff has clear direction regarding the confidentiality of records through HCF of appropriate operating procedures. The President may, at his discretion, make all or part of any record available to staff or Committee members or volunteers if essential to them in executing their responsibilities. Any such decision will honor the wishes of donors related to disclosure unless a larger legal issue is related.

To carry out its responsibilities, the Board may need to review donor/prospect records. The Board will respect the Foundation’s significant interest in protecting the sensitive nature of those records and will maintain these policies for donor confidentiality.

The Foundation’s professional service providers (e.g., financial institutions. financial advisors, accountants, auditors, attorneys, etc.) are authorized to review donor and prospect records as required for the purposes for which they are engaged.

Fund agreements are considered to be strictly confidential information and are not public documents. Particulars of a fund agreement will not be shared with the general public or with grant recipients unless the donor has granted permission to do this or unless these details are essential to be shared in order for the fund to be administered as desired by the donor.
Donor Advisors and Fund Representatives:

For Donor Advised Funds, the donor or donors who sign the fund agreements are the Donor Advisors. For other donor funds the donor is the Fund Representative. The CEO of a nonprofit agency that has an agency endowment is the Fund Representative for that fund. For memorial funds, the family will designate a Fund Representative. For unrestricted, field of interest, administrative endowment, operating or other funds created by the Board, it will be the Foundation’s discretion to designate others as Fund Representative.

A Donor Advisor or Fund Representative may petition the Foundation in writing to designate another Donor Advisor of Fund Representative. Successive generation Donor Advisors or Fund Representatives will succeed once they receive donor privilege upon the death of a donor.

Publication of Donor Names:
The names of all individual donors will be listed in the Foundation’s annual report and/or in similar public relations communications. Exceptions will be made for any donor who specifically requests anonymity.

The Foundation will not publish the specific amounts 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 who establish Donor Advised Funds will be made aware that the name of their fund may be published as part of the Foundation’s annual report and marketing publications.

Donors of substantial gifts will be informed that their information will be included in the Foundation’s annual IRS 990 statement as required by law and that this Form 990 is a public document. There is no linkage or connection between the name of the donor and their grantee organizations he or she supports on IRS Form 990

Honor/Memorial Gifts:
The names of donors of memorial or honor 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 Chairman or the President is authorized to accept anonymous gifts to the Foundation. The President may disclose to the Board the names of any anonymous donors unless the donor specifies otherwise.

Publication of Grant Information:
For grants made from unrestricted, field of interest, administrative endowment or other funds created by the Board, the recipient organization, amount and purpose of each grant may be made public. For grants made from all other funds, the Foundation will not disclose the name of recipient organizations or amounts of distributions made from any such fund unless specifically requested to do so by the appropriate Fund Representative.

As of 4-14-2011