The nature of the Community Foundation of North Florida (CFNF) is the role as a funder, leader, convener, and decision-maker in the community, results in the acquisition of sensitive information that is considered confidential and/or privileged. Much information is shared with CFNF because of its reputation for trust in its ability to make fair decisions. To safeguard CFNF integrity as a responsible decision-maker and to protect its capacity to gather data necessary to make those decisions, CFNF subscribes to specific policies on confidentiality. As noted above, this policy applies to CFNF employees and volunteer leaders.

CFNF maintains and manages much information that must be kept confidential. This includes, but is not limited to, information about donors, prospective donors, grantees, prospective grantees, and wealth advisors and their firms. The effective functioning of CFNF also requires respecting the confidentiality of discussions that take place and information that is shared in the course of conducting CFNF business. The CFNF Board has adopted this Confidentiality Policy to assist the CFNF directors, officers, employees, committee members, agents, fiduciaries, and volunteers in fulfilling their confidentiality obligations and commitments. While the policy addresses some common confidentiality concerns, it is not an exhaustive list of all situations where a confidentiality obligation may arise. Questions about whether information is confidential or about situations in which confidential information may be released or discussed should be directed to the CFNF President & CEO or Board Chair. As used in this Policy, the term “CFNF personnel” includes the CFNF directors and officers, employees, agents, fiduciaries, consultants, and volunteers.

Information in the possession of CFNF and discussions of CFNF business should generally be presumed to be confidential. All CFNF personnel at every level are responsible for maintaining confidentiality and taking steps to ensure such information is safe, secure and remains confidential.

Except as required by law, CFNF will not disclose information about a donor or a donor’s gift. However, unless otherwise requested by the donor, CFNF may publish the names of individual donors in the CFNF Annual Report and other reported listings. In the case of memorial gifts, CFNF will provide the names of donors to members of the immediate family unless the donor has requested anonymity. CFNF will not disclose the amount of any gift without the donor’s consent. CFNF may accept anonymous gifts to it on a case-by-case basis.

CFNF will not disclose the identity of grant applicants except as necessary to process the application and will protect financial and personal information that applicants submit to it. This includes information provided by applicants for grants to individuals such as scholarships and hardship assistance. Except in the case of hardship assistance grants to individuals, CFNF will generally disclose the identity of grantees and the amount awarded.

Except as authorized by the CFNF Board, or by an appropriate board committee, discussions, and records of CFNF operations are generally not to be disclosed. This includes, but is not limited to, information about CFNF financial operations, fundraising, investments, personnel, grantmaking, and contractual relationships. The positions of individual directors, officers, employees, agents, fiduciaries, and volunteers should not be discussed, even within CFNF, except in the course of official CFNF meetings and processes where those subjects are discussed.

This policy does not apply to disclosures to attorneys, accountants and other professionals providing assistance to CFNF. It also does not apply to disclosures to tax authorities, government agencies, courts, or as otherwise required by law. The following are considered public documents and information contained in them is not subject to the confidentiality requirements of this policy; provided, however, the underlying information in these documents may, in fact, be confidential and must remain confidential: CFNF annual report or financial review once it has been accepted by the board. CFNF Form 990 as required to be publicly disclosed. This does not include the names and addresses of donors as that information is not required to be disclosed. CFNF investment and spending policies

CFNF personnel who have executed a copy of this policy may access confidential information necessary to the performance of their functions. CFNF personnel are expected to exercise sound judgment in securing information taken outside of the CFNF office or copied from its network. Any information so removed should be returned as soon as possible and deleted from laptops or other personal devices.

Penalties for violating this policy can include sanction or termination of employees and removal of board or committee members.

The Community Foundation of North Florida (CFNF) is a publicly supported charitable Foundation serving the communities of North Florida and is dedicated to its mission of expanding private philanthropy in those communities. CFNF operates within the public trust and strives to maintain the highest code of conduct in all of its operations. The Foundation recognizes that it can best accomplish its mission when the Board of Directors, volunteer committee members, staff and other groups associated with CFNF represent the diverse interests, cultures, occupations and expertise of the community. Thus, CFNF recognizes that members of the Board of Directors and others representing or affiliated with CFNF will from time-to-time face possible conflicts of interest or situations in which the appearance of conflict of interest could be detrimental to the Foundation and the communities it serves. CFNF adopts this policy in recognition of its responsibility to the public trust, in recognition of the importance of fairness and objectivity in its conduct of business, as a means of assuring that every decision of CFNF is made in the interest of CFNF and the communities it serves and as a means of publicly codifying its expectations of board, staff and volunteers, and others serving CFNF. This Conflict of Interest Policy applies to all persons holding positions of responsibility and trust on behalf of the Foundation, including but not limited to members of the Board of Directors, members of board committees who are not members of the Board of Directors, volunteer committee members, members of the boards of supporting organizations to CFNF, and members of the Foundation staff (hereinafter "members"). This Policy shall be provided to each member at the time that he or she is asked to serve CFNF and annually shall be reviewed and updated by all members.

In conducting the affairs of CFNF, duality or conflict of interest shall be presumed when a person to whom this policy applies or a member of his/her immediate family serves as a trustee, officer, staff member or holder of more than 10% of corporate stock of an affected organization or firm; has a formal affiliation or interest in an affected organization or firm; or could expect financial gain or loss from a particular decision. Each year staff, board and volunteer committee members serving with CFNF, shall file with the President & CEO of CFNF a list of his or her principal business activities, as well as involvement with other charitable and business organizations, vendors, or business interests, or with any other associations that might produce a conflict of interest. In addition to the disclosure required by the previous paragraph, each member is under an obligation to CFNF, to his or her fellow staff or volunteers, and to the community served by CFNF to inform CFNF of any position he or she holds or of any business or a vocational activity that may result in a possible conflict of interest or bias for or against a particular grantee, action or policy, at the time such grant, action or policy is under consideration by the board or any volunteer committee of CFNF. Any duality or possible conflict of interest on the part of any member shall be disclosed to the chair of the board (in the case of volunteers) or the President & CEO (in the case of staff members) and made a matter of record as soon as the issue in question is raised and a possible conflict is known. When the board, committee or staff is to decide upon an issue about which a member has an unavoidable conflict of interest, that member shall physically absent herself or himself without comment from not only the vote, but also from the deliberation, unless directly requested by the chair of the board or relevant committee to provide factual information or answer factual questions that may assist the board or committee in making a wise decision. In no case shall that member vote on such matter or attempt to exert personal influence in connection therewith. Disclosure and abstention shall be recorded in the minutes of the meeting(s) at which the issue is discussed and decided. In any situation not specifically covered by the previous sections of this policy, members shall carefully consider any potential conflict of their personal interests with the interests of CFNF and refrain from any action that might be perceived as an actual or apparent conflict of interest.