Enable Madison County has an ethical and legal obligation to respect the privacy of donors, grantees, and applicants, and to protect and maintain the confidentiality of all information it acquires concerning these parties. Confidentiality includes information that should be held in the strictest confidence and trust whether disclosed orally or in writing, to directors, volunteers, staff, donors, prospective donors, vendors, or others holding a business relationship with Enable Madison County.

Confidentiality of Records
Enable Madison County has an obligation to protect the information about its sources of funding, donors, staff, volunteers, and clientele. The following is a list of information whose confidentiality must be respected unless specifically released by the appropriate individual (note: the list is a sample; it is not all-inclusive):

• Grants: source and amount
• Donors: names, addresses, amounts of donation
• Volunteers: names, addresses, interests, and areas of expertise
• Board of Directors: names, addresses, titles, functions
• Clientele: names, addresses, specific needs, previous support provided by Enable Madison County
• Employees: names, addresses, salary, job title
• Fund Raising: status of any fund drives, potential sources of funding
• Budget: status of Enable Madison County’s budget, both current, year-to-date, annual
• Board of Director meetings: minutes, positions of individual members on specific topics

Enable Madison County Directors, staff and volunteers shall be responsible for maintaining the confidentiality of donor and prospect records, fund information, and all Enable Madison County information and communication. There are possible exceptions to the principle of protecting confidential information. At the discretion of the Executive Director, staff may make all or part of any record available to Enable Madison County volunteers to assist them in executing their specific responsibilities. Enable Madison County’s auditors, legal counsel and other contractors are authorized to review donor/prospect and fund records as required specifically for the areas of their purview.

All persons accessing donor/prospect or fund records in the conduct of Enable Madison County business shall maintain the confidentiality of said records. This applies to donor gifts and the various types of fund agreements. Staff may share information with donors, fund beneficiaries, and grantees pertaining to their own gifts, funds, grants, etc. Except in those instances, any copies of confidential information held outside Enable Madison County office shall not be maintained other than for the specific period its information is needed and then returned to the Enable Madison County offices or destroyed. Directors, staff, and volunteers will consider all Enable Madison County information and communication confidential. They may not delegate their responsibility for maintaining confidentiality to anyone else including but not limited to subordinates, co-workers, or family members.

Staff, volunteers, and the Board of Directors will sign a Confidentiality Agreement when they first begin work with or for Enable Madison County, and annually thereafter.

Disposal of Records
Unless otherwise directed, all records will be disposed of in accordance with the schedule published in the Document Retention and Destruction policy.

Publication of Donor Names
Unless otherwise requested by the donor, the names of all individual donors may be printed in Enable Madison County’s annual report and in other appropriate listings or categories. Enable Madison County will not publish the amount of any donor’s gift without the permission of the donor. Unless otherwise specified in the document, donors making gifts to Enable Madison County by bequest or other testamentary device are deemed to have granted such permission.

Remembrance Gifts
The names of donors of memorial, honorarium, or tribute gifts to Enable Madison County 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
Donors may choose to remain anonymous by communicating their intent to Enable Madison County. The name of the donor and/or gift amount may be withheld from Enable Madison County publications, not-for-profit beneficiaries, and/or remembrance gift beneficiaries if so, requested by the donor. When such a request for anonymity is made, Enable Madison County will respect the request and refrain from publishing the name(s) or amount(s) of the gift(s).

Third-Party Disclosures
Enable Madison County shall not release to third parties or allow third parties to copy, inspect, or otherwise use organizational 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. If such information is shared, Enable Madison County will verify that the recipient has a legitimate need to know the information and will be fully briefed on protecting it from any further disclosure.

Confidentiality of Enable Madison County Business
Discussions that take place in the context of Enable Madison County’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 regarding all Enable Madison County businesses will not be shared or discussed with volunteers or employees other than the Executive Director. The only persons who may speak for the Board outside of its official written resolutions and actions shall be the President of the Board or their designated spokesperson.

Public Disclosure
Enable Madison County will comply with both the letter and spirit of all public disclosure requirements, including the open availability of its Form 990 tax returns and annual audit. This Confidentiality Policy shall not be construed in any manner to prevent Enable Madison County from disclosing information to taxing authorities or other governmental agencies or courts having regulatory control or jurisdiction over Enable Madison County. However, all board members, staff, volunteers, agents, and contractors must hold strictly confidential all information of a private nature, including, but not limited to, all items explicitly discussed in this policy.

Enable Madison County employees, volunteers, and board members must especially be cognizant of the pervasive nature of social media. Confidential information, as listed above, once exposed on social media is irretrievable. Therefore, it is incumbent upon all individuals supporting Enable Madison County that they refrain from using social media when conducting Enable Madison County business, particularly when it comes to interacting with sources of funding or clientele.

Consequences of Policy Violation
Violations of the Confidentiality Policy are considered serious. Such violations may result in:

• Disciplinary action, up to and including dismissal for employees, agents, or contractors; or
• Removal from the Board of Directors; or
• Separation of any volunteer from a committee or other representative role on behalf of Enable Madison County.

Violations of this policy are to be reported to the Executive Director or the President of the Board. If there is some question or ambiguity as to whether there was a violation or whether the violation was intentional, an internal investigation will be conducted by the Governance Committee of the Board of Directors. The results of the investigation and recommended follow­ up action(s) shall be reported to the Executive Director and to the Board of Directors for their approval or adjustment to the final recommended disposition.