Protection Of Confidential Personal Information Policy

Safeguarding Confidential Personal Information related to our employees, job applicants, volunteers, donors or potential donors, or any persons who provide us with that information in the course of their interaction with the Foundation is a fundamental responsibility of each employee, and of the Foundation’s Directors and volunteers. "Confidential Personal Information" includes, but is not limited to, social security numbers, drivers’ license numbers, account numbers, credit or debit card numbers, passport or alien registration numbers and health insurance identification numbers and any other information capable of being associated with a particular person through one or more personal identifiers.

It is the responsibility of all Foundation employees, directors and volunteers who collect, verify, review, or maintain files of such information, whether the information is in print or electronic form, to do so with strict attention to maintaining the confidentiality of that information. The Foundation strictly prohibits the disclosure of a person’s  Confidential Personal Information to a third party without the express written permission of the person, unless permitted or required by law, or unless the information has otherwise been made public, in accordance with applicable state and federal law. For employees, any disclosure of Confidential Personal Information in violation of this policy may result in management action, up to and including termination of employment, and depending on the circumstances, may subject the employee to additional penalties under state or federal law.

In addition, whenever Confidential Personal Information is provided to Foundation vendors or subcontractors, confidentiality agreements must be executed prior to the release of any such information.  A copy of the standard agreement is available from the Vice President for Finance and Administration.  Under appropriate circumstances, the Foundation may agree to use a vendor’s  standard confidentiality agreement as part of a universal contract, provided that the vendor’s contract provides comparable protection, with the express written approval of the Vice President, Finance and Administration. 

All employment and pre-employment personnel information is maintained in locked, segregated areas and is not viewed by anyone except authorized Human Resources and Administration staff with a legitimate business need. The Foundation complies with applicable state and federal law pertaining to the protection of personnel records.  Please refer to the Foundation policy regarding access to employee personnel files.

Confidential Personal Information maintained in electronic form or transmitted over the Foundation’s business system applications will be safeguarded under Foundation proprietary electronic transmission and intranet policies and security systems. Participants in the Foundation’s benefit plans should be aware that personal information will be shared from time to time with plan providers as required for their claims handling or record keeping needs, in accordance with applicable state and federal law.

The Foundation has implemented internal safeguards to protect any data, computer files, and documents containing Confidential Personal Information, and to destroy or make unreadable such information prior to disposal.  In certain instances, employees may be required to comply with safeguards specific to their job duties to ensure the protection or proper disposal of Confidential Personal Information.  Employees will be provided additional information regarding any safeguards applicable to them.  Any employee failing to comply with applicable safeguards may be subject to management action, up to and including termination of employment.



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