DONOR CONFIDENTIALITY POLICY
PURPOSE:
The Italo-Greek Orthodox Archdiocese of the Americas & Canada recognizes that the proper administration of the Archdiocese 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 Archdiocese staff on a confidential basis. “Records” means all files, including electronic data, containing information on donors or prospective donors to the Archdiocese and/or any of its parishes, missions, congregations, institutions o,r affiliated organizations.
Donors and prospective donors are frequently attracted to the Italo-Greek Orthodox Archdiocese on the basis of its ability to assure temporary or permanent anonymity. The purpose of this policy is to state the position of the Archdiocese on donor confidentiality and donor anonymity.
POLICIES:
Confidentiality of Records
The Metropolitan and Chief Operating Officer shall be responsible for maintaining the confidentiality of donor and prospect records and will ensure that all archdiocesan staff has clear direction regarding the confidentiality of records through the establishment of appropriate operating procedures. The Metropolitan, at his sole discretion, or the Chief Operating Officer, with the permission of the Metropolitan, may make all or part of any record available to archdiocesan staff members if essential to them in executing their responsibilities. Disclosure decisions will, at all times, honor the wishes of donors and benefactors related to donations made or contemplated to be made to the Archdiocese or any of its parishes, missions, monasteries, institutions, organizations, or programs. If a donor specially requests, as a condition for his/her donation or bequest, that his/her identity remains at all times confidential before, during, and after a donation and bequest has been, such request shall remain inviolate. The Metropolitan shall be bound and at all times shall ensure that the donor's/benefactor's request shall not be violated under any circumstances, even if threatened with a civil penalty or censure.
To carry out its responsibilities, the Metropolitan Council may need to review donor/prospect records. All Council members shall respect the Archdiocese’s significant interest in protecting the sensitive nature of those records and shall maintain these policies for donor confidentiality.
The Archdiocese’s auditors are authorized to review donor and prospect records as required for the purposes for which they are engaged but at no time may any personal information regarding the identity of donors and the nature of their donation or contemplated donation be taken out of the Chancery Office.
Bequests, Funds, and Endowment Agreements are considered “strictly confidential information” and are not public documents. Particulars of a bequest, fund, or endowment document will not be shared with the general public or with fund recipients unless the donor or benefactor 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 founding documents of memorial or honor gifts shall be the Fund Representatives. A donor may petition the Archdiocese, in writing, to designate another fund representative or representatives. Previously designated succsuccessive-generation or advisors will be fund representatives once they receive donor privilege upon the death of a donor. In addition to the donor, the diocesan bishop shall also be named as fund representative on all endowments and gifts in his capacity as Metropolitan and ruling Diocesan Ordinary
In the case of direct endowments which are unrestricted the diocesan bishop (the Metropolitan) shall be named the sole fund representative.
Only Fund Representatives are authorized to receive fund statements of information concerning the activities of the fund. Release of fund information to auditors will be done only upon written request of the Fund Representative. For memorial funds, the family will designate a Fund Representative.
For unrestricted donations, funds, administrative endowment, or other funds endowed by a given donor, the diocesan bishop (the Metropolitan) shall be named as the sole Fund Representative.
Publication of Donor Names
The names of all individual donors will be listed in the Archdiocese’s annual report and/or in similar public relations communications. Exceptions will be made for any donor who specifically requests anonymity.
The Archdiocese will not publish the specific amount of any donor’s gift without the express written permission of the donor. Donors making gifts to the Archdiocese by bequest or other testamentary device are deemed to have granted such permission.
Donors should be aware that it is the Archdiocese’s policy, from time to time, to publish the current market value of its funds from which a reader may be able to determine the approximate size of a donor’s gift.
Honor/Memorial Gifts
The names of donors of memorial or honor gifts may not 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 exprthe ess written consent of the donor.
Anonymous Gifts
The diocesan bishop (the Metropolitan) is authorized to accept anonymous gifts to the Archdiocese. In the event the Metropolitan is uncertain about the desirability of accepting an anonymous gift, he shall consult with the Metropolitan Council and the Archdiocesan General Counsel. If the anonymous gift is deemed to be questionable, it is to be immediately returned to the donor.
Disclosure of Pending Gifts
In the event that the diocesan bishop (the Metropolitan) concludes that the Archdiocese is likely to receive, in the immediate or near future (90 days or less), a gift equal to or greater than five percent of its then existing assets, the diocesan bishop (the Metropolitan) shall notify the Chief Operating Officer. The Metropolitan and the Chief Operating Officer shall apply all requirements of the gift acceptance policy and determine the appropriate course for notifying the Metropolitan Council and the Archdiocesan Finance Council, as well as the Archdiocesan General Council.
Amendment
This policy may be amended from time to time by the Metropolitan Council in consultation with the Archdiocesan Finance Counsel and the Archdiocesan General Council.
Adopted on March 11, 2017
Decreed, Published, and Enacted on March 12, 2017