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Confidentiality Policy
Donor Confidentiality Policy
DONOR CONFIDENTIALITY POLICY
Donor Confidentiality PolicyDonor Confidentiality Policy


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PURPOSE OF THE POLICY

The purpose of this policy of The Morton Community Foundation (referred to as the "Foundation" in the following sections of this policy) is to guide the actions of the Board of Trustees, the Executive Director and such Committee members and staff who may serve the Foundation 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 Executive Director is responsible for maintaining the confidentiality of donor and prospect records and will ensure that all staff have clear direction regarding the confidentiality of records through the establishment of appropriate operating procedures. The Executive Director 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 of Trustees may need to review donor/prospect records. All Trustees 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., 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.

Fund Representatives:
The donor or donors who sign the fund agreements are the Fund Representatives. 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 of Trustees, it will be the Foundation?s discretion to designate others as Fund Representative.

A donor or Fund Representative may petition the Foundation in writing to designate another Fund Representative or Representatives. Previously designated successive generation donor advisors will become Fund Representatives once they receive donor privilege upon the death of a donor.

Only Fund Representatives are authorized to receive fund statements of information concerning activities of the fund. The Foundation will provide the CFO of a nonprofit agency information about their named endowment. Release of fund information to auditors or others acting as agents of the donor will be done only upon written request of the Fund Representative.

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.

Donor names may be grouped according to giving level (e.g., $5,000 - $9,999). 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 and the fund?s balance will be published as part of the Foundation?s annual report and marketing publications. From this information a reader may be able to deduce the approximate size of a donor?s gift.

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.

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 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 will consult with the Board of Trustees before doing so.

The Executive Director will disclose to the Board of Trustees the names of any anonymous donors.

Disclosure of Pending Gifts:
In the event 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 President of the Board of Trustees. The President and the Executive Director will apply all requirements of the Gift Acceptance policy and determine the appropriate course for notifying the Board of Trustees.

Publication of Grant Information:
For grants made from unrestricted, field of interest, administrative endowment or other funds created by the Board of Trustees, the recipient organization, amount and purpose of each grant will 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.

Adoption:
This policy has been adopted by the Morton Community Foundation Board of Trustees at its meeting on February 8, 2008.

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