In connection with its issuance of charitable gift annuities and student loans, the Community Foundation of Western Massachusetts collects and retains non-public personal information concerning donors, beneficiaries, grant applicants, scholarship and loan applicants, and individuals associated or connected with them. This information may include birth dates, social security or taxpayer identification numbers and financial information.
Without the prior agreement of the disclosing party or except as required by law, we will not disclose such non-public personal information except to our employees and others working with us on the applicable matter who agree not to disclose such information.
We take the following steps to safeguard such non-public personal information:
• All staff are instructed at least annually in the implementation of this policy;
• We protect our information systems with physical, electronic and procedural safeguards, including the detection, prevention and response to attacks, intrusions or systems failures, that are appropriate for the risks we identify through regular monitoring of those systems;
• We take reasonable steps to insure that those to whom non-public personal information is disclosed are able to safeguard such information.
Bruce Hiltunen, our Vice President of Finance & Operations, coordinates our information security program.
This policy applies only to non-public personal information obtained in connection with the application for and issuance of charitable gift annuities and student loans.