Donor Confidentiality & Privacy Policy and Procedures

Connecticut News Project, Inc. d/b/a CT Mirror (“CNP”) adopts the following Confidentiality & Privacy Policy and Procedures to formally document its policies for ensuring the privacy and confidentiality of information it receives regarding individual donors and that it uses to carry out its development activities. The policy and procedures set forth below applies to all Directors, Officers, employees and volunteers of CNP (collectively “Personnel”).

Donor Privacy Statement

CNP respects the privacy of our donors. We protect personal information. We do not rent or sell our mailing or e-mail lists of donors. Name, address and other contact information will be used to provide donors with information regarding CNP activities, special events, fundraising needs, and to acknowledge donations. From time-to-time, CNP may exchange donor information with like-minded nonprofit organizations to effect fundraising synergies or administrative economies pursuant to partnership agreements or other cooperative arrangements. If at any time a donor wishes to not be acknowledged, to receive less mail, or to stop receiving our communications he or she may do so by contacting CNP by phone at 860-218-6380 or via e-mail at: borzechowski@ctmirror.org and we will gladly accommodate the request.

Confidentiality Statement

CNP strongly believes in protecting the privacy of our donors and prospective donors and the confidentiality of information concerning them. Donor records and other donor information are highly confidential and protected by this policy. The use of such information for personal, political or commercial purposes, except as specifically permitted under this policy, is strictly prohibited. Appropriate action, including but not limited to possible termination of employment, will be taken against persons or entities that violate this policy. Any individual, institution, or agency deemed to have violated this policy, or deemed to have jeopardized the confidentiality or privacy of any individual or organization affiliated with CNP by the inappropriate use of information covered under this policy will have access to such information discontinued.

Professional Standards and Privacy Practices

All Personnel of CNP are required to read and abide by this Confidentiality & Privacy Policy and Procedures, as well as the Association of Professional Researchers for Advancement’s ethics guidelines (incorporated herein by reference). These documents will be provided to all Personnel and may also be obtained from the CEO of CNP (the “CEO”).

All Personnel who have access to Restricted Information will be required to sign a Confidentiality Agreement. “Restricted Information” shall be defined to include donor giving histories as well as personal and financial information collected during the prospect research process or that is provided by the donor or prospect himself/herself, whether or not such information is publicly available. Safeguards shall be maintained to ensure that Restricted Information is not disclosed or shared more widely than is necessary to achieve the purposes for which it was gathered. CNP also takes such measures as are necessary and reasonable to ensure the accuracy of this information.

Donor gifts may be publicly acknowledged; however, all donors shall be provided with an opportunity to be anonymous and to request that his or her name and/or the amount of the gift not be publicly released. Donors who request anonymity, either for themselves or for gift amount, will be publicly acknowledged as “anonymous” or with their name only, respectively. Information on anonymous donors will be flagged prominently as “anonymous” in all paper files and computer records. Note, while donor information must be included on Schedule B of IRS Form 990, CNP is not required to share this data other than with the IRS.

Individual Donor Records

Individual donor records, whether in hard copy or electronic form, are the property of CNP. These records contain Restricted Information, and other information pertaining to those individuals important to the development efforts of CNP. Individual donor records are kept in the office of the CEO in a secure desk or file drawer that will be locked outside of normal work hours.

Restricted Information kept in donor records must be relevant to the goals of CNP. It is the responsibility of each Director, staff member, senior managers, and volunteers working in development to submit only appropriate and relevant information for inclusion in these files. Credit card numbers will be blocked out when they are no longer necessary. If any credit card numbers are found on former correspondence in a file, they should be blocked out immediately.

Access to the donor database is maintained and authorized by the CEO. Security procedures shall be maintained to ensure that different users have access to only those screens that are necessary to carry out their work at CNP.

In general, Restricted Information will not be provided via email. However, in those cases in which e-mail transmission may be necessary (for instance, due to time constraints), CNP staff will label the e-mail “confidential” in a prominent manner, password protect the file and instruct the recipient(s) not to share the Restricted Information in the e-mail, forward it, or otherwise compromise the privacy of its contents.

These policies and procedures acknowledge that the Board of Directors, as well as external auditors, regulatory agency personnel and persons operating pursuant to legal process who may be conducting audits, reviews, or other investigations, may require access to all hard copy and electronic files in the development records in order to conduct their work. Access shall be granted for these limited purposes, subject to confidentiality agreements, to the extent possible, and with no permission allowed for further disclosure of these confidential records.

Information Requests from External (Non-CNP) Parties

External parties (such as the media) requesting information about donors may be given access to public or published information that is not Restricted Information at the discretion of the CEO. Information may only be released if it is public and is not coded “anonymous” “no contact” or “unlisted.” Restricted Information such as research profiles, action reports, financial records and giving histories will not be released under any circumstances unless consent is provided by the donor. All media requests related to donors shall be forwarded to the CEO.

Outside consultants and vendors such as direct mail firms, mailing houses, publication publishers, and database screening firms, will be bound by this confidentiality policy. Appropriate confidentiality provisions shall be included in all contracts with such entities.