Date: Tue, 19 Mar 2024 07:34:33 -0400 (EDT)
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ROWAN UNIVERSITY POLICY
This policy=
outlines a code of ethics and principles for the stewardship of the person=
al information of University constituents and provides a Donor's Bill of Ri=
ghts. It also includes an overview of donor anonymity levels, a privacy pol=
icy statement regarding use of the Millennium database, processes for the r=
equest of information from Millennium, best practices regarding safeguardin=
g alumni and donor privacy, and a statement of understanding for all campus=
Millennium users.
II. ACCOUNTABILITY
Under the d=
irection of the President, the Associate Vice President for University Adva=
ncement/Executive Director of the Rowan University Foundation shall ensure =
compliance and implementation of this policy.
III. APPLICABILITY
This policy=
is applicable to all members of the Division of University Advancement, al=
l campus users of Millennium, and all University offices, affiliated organi=
zations and alumni constituent groups that request information from the Mil=
lennium database.
IV. =
POLICY
A. Mission Statement:
- Rowan University Advancement employees a=
re ethically obligated to respect and safeguard the privacy rights and the =
confidential information obtained from Rowan University alumni, prospects a=
nd donors. It is important that Advancement employees act with integrity an=
d are honest in their dealings with the University and with those that they=
come in contact with. Advancement employees shall avoid conflicts of inter=
ests and may not accept favors or any other benefits for personal gain and =
shall follow the letter and spirit of the laws and regulations affecting ad=
vancement and observe these standards by also encouraging your colleagues t=
o do so as well.
- Staff Members of Rowan University's Divi=
sion of Advancement are entrusted with sensitive and personal information r=
egarding University alumni, prospects and donors. It is therefore incumbent=
upon each employee to protect the privacy rights of those who have dealing=
s with the University. An employee's stewardship of personal information ca=
n be guided by the following code of ethics and principles set forth below:=
-
-
- Privacy =E2=80=93 University Advancement should neither obtain=
nor retain nonessential and highly personal information about donors in th=
eir paper or electronic files. Also, care must be taken to ensure that Adva=
ncement staff members do not take information about donors with them when t=
hey change jobs. University Advancement employees need to be methodical ste=
wards of personal information in an era where privacy concerns rightly run =
rampant.
- Stewardship =E2=80=93 University Advancement must assure the d=
onor that the funds the University receives are indeed being used for the p=
urposes for which they were given. The University must honor the spirit as =
well as the letter of donor intentions.
Honesty and full disclosure =E2=80=93 University Advancement must give our=
alumni, prospects and donors enough information to make informed giving de=
cisions. Honesty with donors is the essential foundation of healthy benefac=
tor relations.
Conflicts of interest =E2=80=93 An employee of the Advancement Division mu=
st avoid engaging in any activity that would put the interests of the donor=
, the University, and the employee's personal interest at odds with one ano=
ther. All transactions should be completely transparent and devoid of confl=
icting interests.
- The appearance of impropriety =E2=80=93 There are many things =
that fundraisers can do that are legal, but are unethical, such as benefitt=
ing personally from a benefactor's estate gift, bequest or outright gift. O=
ur profession views such behavior negatively. University Advancement employ=
ees shall refrain from engaging in such activities.
B. Donor's Bill of Rights
Philanthropy is based on voluntary action=
for the common good. It is a tradition of giving and sharing that is prima=
ry to the quality of life. To ensure that philanthropy merits the respect a=
nd trust of the general public, and that donors and prospective donors can =
have full confidence in the nonprofit organizations and causes they are ask=
ed to support, we declare that all donors have these rights:
- To be informed of the organization's mis=
sion, of the way the organization intends to use donated resources, and of =
its capacity to use donations effectively for their intended purposes.
- To be informed of the identity of those =
serving on the organization's governing board, and to expect the board to e=
xercise prudent judgment in its stewardship responsibilities.
- To have access to the organization's mos=
t recent financial statements.
- To be assured their gifts will be used f=
or the purposes for which they were given.
- To receive appropriate acknowledgement a=
nd recognition.
- To be assured that information about the=
ir donation is handled with respect and with confidentiality to the extent =
provided by law.
- To expect that all relationships with in=
dividuals representing organizations of interest to the donor will be profe=
ssional in nature.
- To be informed whether those seeking don=
ations are volunteers, employees of the organization or hired solicitors.=
li>
- To have the opportunity for their names =
to be deleted from mailing lists that an organization may intend to share.<=
/li>
- To feel free to ask questions when makin=
g a donation and to receive prompt, truthful and forthright answers.
C. Privacy Policy
- Rowan University's Department of Advance=
ment Services (DAS) maintains a database (Millennium) of biographical and g=
ift/pledge information about University alumni and friends in accordance wi=
th the general needs and expectations of the University community. The info=
rmation contained in this database is intended exclusively for purposes rel=
ated to Rowan University's programs.
- Staff members of University Advancement =
will have access to Millennium [alumni and/or development information as we=
ll as data analysis] from their workstations. Each employee user should dil=
igently deal with sensitive information regarding alumni, prospects and don=
ors in the areas of data retrieval, retention, dissemination and disposal. =
This policy document is designed to protect the privacy of Rowan University=
alumni and other constituents and to maintain standards of confidentiality=
associated with electronic records in Millennium. Exceptions to this polic=
y can only be made by the Vice President of University Advancement or his/h=
er designee.
- An employee's need to access Millennium =
does not equate to casual viewing. It is the employee's obligation, and his=
/her supervisor's responsibility, to ensure that access to Millennium is on=
ly to complete assigned functions.
- The Director of Advancement Services in =
recognition of the right to privacy of donors to Rowan University, ethical =
considerations, and the need for good donor relations has categorized Mille=
nnium data as restricted. Data and information available i=
n Millennium and in related reports and files is the property of Rowan Univ=
ersity and its use is governed be federal, state and local law, as well as =
University regulations. It may only be used to support University-sponsored=
or University-approved development or alumni relations functions.
- The Department of Advancement Services e=
xpects that individuals with access to Millennium data understand their res=
ponsibilities with respect to use, interpretation and distribution of that =
data and the consequences for misuse of data. The ability to access and pro=
duce reports and mailings does not constitute automatic authority to do so.=
Unauthorized release or use of Millennium information for any purpose is s=
trictly prohibited and may result in suspension, and/or termination of empl=
oyment for the employees involved. Additional legal action may be taken, wh=
en warranted.
- It is the desire of the Department of Ad=
vancement Services to support the ongoing activities of Rowan University by=
providing assistance for programs, communications, and events, which bring=
together alumni, donors, and friends of the University. In order to provid=
e the best possible service to those with legitimate needs for such informa=
tion, and at the same time maintain the confidentiality of the information =
entrusted to us by our alumni, the following policies have been developed.<=
/li>
D. Responsibilities
- Exc=
eptions to this policy can only be made by the Associate Vice President of =
University Advancement or his/her designee.
- In =
cases of dispute about whether an organization has a legitimate affiliation=
with the University, the final decision will rest with the Associate Vice =
President of University Advancement or his/her designee.
- In =
cases of dispute about what constitutes an approved activity, the final dec=
ision will rest with the Associate Vice President of University Advancement=
or his/her designee.
E. Compliance with the above policy. =
;
Failure to abide by any of the policies s=
tated within this document may result in denial of access to information co=
ntained in the Millennium database. Request for re-instatement of access to=
this information must be approved by the Director of Advancement Services =
and must include written assurance of future compliance with these policies=
.
VI. ATTACHMENTS
A. Attachment 1, Department Procedures
B. Attachment 2, Donor Anonymity
C. Attachment 3, Millennium Database Info=
rmation
D. Attachment 4, Protecting and Preservin=
g Rowan Alumni and Donor Privacy
E. Attachment 5, Internal Uses of Informa=
tion
F. Attachment 6, Distribution of Informat=
ion
ATTACHMENT 1
DEPARTMENT PROCEDURES
- All University Advancement employees and campus users of Millennium wil=
l know and abide by the code of ethics and principles regarding personal in=
formation of alumni, prospects and donors as set forth.
- All University Advancement employees will know and abide by the Donor's=
Bill of Rights and donor anonymity levels as set forth.
- All campus Millennium users will understand their responsibilities with=
respect to use, interpretation and distribution of the system's data and t=
he consequences for its misuse.
- All University offices, affiliated organizations and alumni constituent=
groups requesting information from the Millennium database will adhere to =
restrictions regarding "public information" and its proper distribution.
- All individuals with access to Rowan University alumni and donor inform=
ation will adhere to guidelines regarding the successful protection and pre=
servation of the data.
- All Millennium users are required to sign a Statement of Understanding.=
STATEMENT OF UNDERSTAN=
DING FOR MILLENNIUM USERS
I, the undersigned, have read and understa=
nd the policies for access to and privacy of Rowan University Alumni and Do=
nor records. I agree to use the information provided only for the approved =
University program(s). Furthermore, I understand that the use of the inform=
ation for political or commercial purposes is strictly prohibited.=
p>
___________________________________=
_______ ___________________=
_______________________
Name (print or type) &nb=
sp; =
&nb=
sp; =
&nb=
sp; =
Department
_________________________________________=
_ ___________________=
_______________________
Signature &n=
bsp;  =
; &n=
bsp;  =
; &n=
bsp;  =
; &n=
bsp; Date
_________________________________________=
_ ___________________=
_______________________
Supervisor Signature &nb=
sp; =
&nb=
sp; =
&nb=
sp; =
Supervisor Approval Date
Complete in duplicate:
Copy (1) Millennium User=
Copy (2) Office of Advancement Services=
p>
ATTACHMENT 2
DONOR ANONYMITY
The University Advancement office recognized three levels of donor anony=
mity. It is important that we honor the spirit as well as the intent of a d=
onor. Occasionally, a University Advancement Employee will encounter a dono=
r, individual, or an organization that desires to remain anonymous. When a =
request to remain anonymous has been made, the Employee should take steps t=
o identify the appropriate level of Donor Anonymity to assign to that donor=
. Below are the three levels of Donor Anonymity. Use them as a guide when d=
etermining which level of Donor Anonymity should attach to the donor.
Level I
The Donor provides his or her name, address, and/or other biographical i=
nformation and communicates that he/she wishes to remain anonymous regardin=
g and in reference to this specific one-time gift. The gift/pledge transact=
ion shall be tagged as "Anonymous." The Division of University Advancement =
retains the donor's biographical information for internal uses only.
Level II
The Donor provides his or her name, address, and/or other biographical i=
nformation and communicates that he/she wishes to remain anonymous regardin=
g this gift as well as all future gifts made by this particular donor. An A=
lert shall be created in the Millennium database, which shall attach to thi=
s particular donor and shall signal the donor's request to remain anonymous=
each time the donor's profile is accessed. The Division of University Adva=
ncement retains the donor's biographical information for internal uses only=
.
Level III
The Donor at this level is truly anonymous. The Donor refuses to provide=
the Advancement Employee with his or her name, address, or any other biogr=
aphical information and communicates his/her desire to make a gift on the c=
ondition of complete anonymity. The Advancement Employee shall assign the d=
onor a generic identification title and number (i.e. Anonymous Donor 2011 #=
1234). The Advancement Employee shall then forward all information pertaini=
ng to the Level III donor to the Vice President's Office where upon receipt=
shall document and maintain a file of such Level III donors.
ATTACHMENT 3
MILLENNIUM DATABASE <=
/strong>INFORMATION
The Following May Request Information from the Millennium Database:=
u>
- University-affiliated organizations and alumni constituent groups, in s=
upport of approved activities include, but are not limited to the organizat=
ions listed below. In cases of dispute about whether an organization has a =
legitimate affiliation with the University, the final decision will rest wi=
th the Vice President of University Advancement or his/her designee.
- Rowan University Alumni Engagement
- Alumni constituent groups chartered under the Rowan University Alumni A=
ssociation
- Rowan University Development
- Administrative units of Rowan University
- Academic units of Rowan University
- Athletic units of Rowan University
- Central Administration
- Career Development Center(s)
- Law enforcement agencies and student loan agencies.
- Agencies that assist the Department of Advancement Services in locating=
Rowan University's lost alumni, e.g. AlumniFinder, AlumniSync, HEPData, et=
c.
- All requests from anyone seeking information on another person =
will be forwarded to that person so that he/she can decide whether or not t=
o contact the requestor. No information will=
be released for those records coded "Do Not Release" indicating the alumnu=
s or alumna has requested no University contact.
- All requests for information from members of the media must be referred=
to the Division of University Relations.
Information That May be Released from the Millennium Database: <=
/u>
- Information available for release is confined to "public information" <=
sup>i<=
/sup> which is limited to:
- Full name
- Address and telephone number
- Degree(s) and date of degree(s) awarded by Rowan University
- School(s) from which degree(s) was/were granted with major field of stu=
dy
- Employer address and telephone number
- E-mail address
- Fax number(s)
- Federal law severely restricts the amount of information that may be re=
leased on current students ii . No information on students will,=
therefore, be released based on data maintained by Millennium. All request=
s for information on current students should be forwarded to the appropriat=
e Registrar's office.
- Information provided to volunteer alumni constituent groups will be lim=
ited to those alumni who are affiliated with the requesting group.
- In addition to "public information," requests from the Rowan University=
Alumni Association; Development; administrative, academic, or athletic uni=
ts of Rowan University; and Central Administration will be provided the fol=
lowing information:
- Employment History
- Student activities
- Alumni activities
- Family members
- Degrees obtained from other Schools
- Miscellaneous comments, awards, text, etc.
- Gift/Pledge data
ATTACHMENT 4
PROTECTIN=
G AND PRESERVING ROWAN ALUMNI AND DONOR PRIVACY
- Securing Paper Records
- Store paper records in a room, cabinet, or other container that is lock=
ed when unattended
- Ensure that storage areas are protected against destruction or potentia=
l damage from physical hazards, like fire or floods, by keeping doors close=
d and items off the floor
- Promptly shred and dispose of outdated constituent information recorded=
on paper
- Securing Computers and Electronic =
Records
- Shut down applications if you leave for lunch or any extended period of=
time
- Use password-activated screensavers
- If you use a computer other than the one you have been assigned, leave =
a note to notify the assigned user that includes the date and your name as =
an authorized employee of the College
- Use strong passwords (at least eight characters long) including numbers=
and letters and non-numeric characters
- Change passwords every ninety days
- Do not post passwords near your computer (for example: passwords writte=
n on post-it notes)
- Do not download unauthorized files
- Check with software vendors regularly to obtain and install patches tha=
t resolve software vulnerabilities (for example: Microsoft updates, interne=
t explorer upgrades, etc.)
- Use anti-virus software that updates automatically
- Store electronic customer information on a secure server that is access=
ible only with a password - or has other security protections (for example:=
in Banner or on network drives, which are backed up by I.T. nightly)
- Maintain secure backup media and keep archived data secure, for example=
, by storing off-line or in a physically-secure area
- If you transmit sensitive data by electronic mail:
- DO NOT include the constituent's social security number or credit card =
information
- But DO include a confidentiality notice:
"This communication, in=
cluding any attachment(s), contains information that may be confidential or=
privileged, and is intended solely for the individual(s) to whom it is add=
ressed. If you are not the intended recipient, please notify the sender at =
once and then delete this message. You are hereby notified that any disclos=
ure, copying, or distribution of this message is strictly prohibited."=
- Secure laptops to avoid theft and possible access to constituent data w=
hen traveling and in the office =E2=80=93 lock doors when leaving for the d=
ay
- Do not save constituent data on your home computer
- Backup your hard drive on a regular basis
ATTACHMENT 5
INTERNAL USES OF INFORMATION =
Acceptable Internal Uses of Information from the Millennium Database<=
/u>
- Rowan University's Department of Advancement Services will make availab=
le information from Millennium for the support of approved, University-rela=
ted activities. Approved activities include the following:
- Alumni engagement
- Development
- Public relations
- Government relations
- School/department communications to alumni/constituents
- University-sanctioned research
- Continuing education programs
- Student recruitment
- In cases of dispute about what con=
stitutes an approved activity, the final decision will rest with the Vice P=
resident of University Advancement.
- Information maintained by Millennium is not available for release for n=
on-related commercial or political purposes.
- If the information provided will result in the preparation of lists or =
directories that are to be published in book, magazine, newsletter or other=
forms for general distribution among alumni groups, prior to publication e=
ach individual who might be included must be provided the opportunity to in=
dicate in writing whether he/she wishes to be excluded.
ATTACHMENT 6
DISTRIBUTION OF INFORMATION
Formats Available for Distribution of Information
Information may be obtained in the form of lists, labels, electronic fil=
es and downloads by authorized university representatives in support of app=
roved activities as noted in Section III.A of this document. It is the resp=
onsibility of the unit requesting information to maintain the absolute conf=
identiality of that information as specified in this policy statement.
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