Fort Freedom Inc. Donor Privacy Policy
Commitment to Privacy
Fort Freedom is deeply committed to protecting the privacy of our donors and safeguarding all personal information.
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Personal Information
Personal information refers to any information that identifies you personally, such as first and last names, home addresses, e-mail addresses, phone numbers, payment information such as bank account and credit card numbers.
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Safeguards & Use of Personal Information
Every precaution shall be taken to protect and preserve the confidentiality of our donors’ personal information. All employees, agents, and authorized service providers of Fort Freedom are required to keep all information secure.
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Fort Freedom ensures that all personal information is properly collected, used only for the purposes for which it is collected, and is disposed of in a secure and timely manner when it is no longer needed.
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Any information supplied by donors to Fort Freedom will be used solely to fulfill their donation and purpose identified by donors. All requests to remain anonymous will be honored.
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Sharing or Selling of Personal Information
Fort Freedom will not ever share, sell, trade or rent a donor’s personal information to others. This applies to all donor information, whether collected offline or online, and pertains to all contents of donor files.
Fort Freedom will not send you donor mailings on behalf of other organizations.
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Online Collection of Information
Fort Freedom has procedures in place to safeguard and secure the information collected online. We do not collect personal information of those who visit our website except basic information from Veterans who opt to be contacted by our team.
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There are numerous safeguards in place to protect the security of credit card transactions. Technologies and processes such as encryption, access controls, network firewalls, and physical security are in place. Our Secure Sockets Layer (SSL) software is the industry standard and among the best software available today for secure commerce transactions. It encrypts all of your personal information so that it cannot be read over the internet.
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Communications Directly from Fort Freedom
From time to time, Fort Freedom will send announcements, invitations and foundation/program updates via email and/or regular mail.
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Supporters may choose to opt out at any time, which will cease all communications from us. You may unsubscribe from our e-mail list by using the unsubscribe link at the bottom of our newsletter emails or contact us through our postal address listed on our website. You may also unsubscribe from regular mailings using such postal address.
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External Links
At times, there may be links to other sites or servers that are not operated by Fort Freedom. These are links that do not fall under our domain. Fort Freedom takes no responsibility for, and exercises no control over, the organizations, views, or accuracy of the information contained on outside servers. If you visit one of these linked sites, you should review their privacy policy as we are not responsible for practices of other companies.
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Changes to our Privacy Policy
It may be necessary for Fort Freedom to change this Privacy Policy from time to time. When we do, we will note the last update at the bottom of this document. Any changes will not be retroactively applied and will not alter how we handle previously collected information.
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For changes on this policy that may be materially less restrictive on use or disclosure of personally identifiable information, Fort Freedom will obtain your consent before implementing the change by sending a notice to your primary email address and home address specified in our records and by placing a prominent notice on our website.
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Fort Freedom Inc. Donor Privacy Policy
Reviewed: November 2023
Document Retention and Destruction Policy
I. Purpose
Fort Freedom Inc. acknowledges its responsibility to (a) retain records and (b) preserve information relating to litigation, audits and investigations to remain in compliance with all federal and state laws and regulations. This Policy shall apply to all records regardless of whether the records are stored on paper or on computer hard drives, external hard drives or other electronic media.
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The purpose of this Document Retention and Destruction Policy (the “Policy”) is to:
a. ensure that all critical corporate records, are retained either permanently or for the required period (see Schedule A, Records Retention Schedule); and
b. ensure that records are destroyed pursuant to a standard policy that has been developed for business reasons.
II. Corporate Records
The corporate records of Fort Freedom include all records produced by directors, officers, members or employees, whether in paper or electronic form. The corporate records include memoranda, e-mail, contracts, minutes, voicemail, reports, receipts and revenue filings regardless of where the document is stored, including network servers, desktop or laptop computers and handheld computers and other wireless devices with text messaging capabilities.
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III. Retention of Records
The corporate records should be retained for the relevant period set forth below in Appendix A. The categories listed under Appendix A are intended to be general and should be interpreted as including all types of records relating to that category, including correspondence, notes, and reports. Documents sent to storage should be identified by category and should specify a scheduled destruction date in accordance with Appendix A.
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IV. Destruction of Records
1. The Chief Financial Officer (the “CFO”) and/or Secretary (the “Secretary”) of the Executive Board of Directors (the “Executive Board”; the “Board”) shall be responsible for ensuring that any scheduled destruction of the corporate records is carried out in accordance with Appendix A and this Policy.
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2. Prior to destruction of records, the permission of the CFO is required to ensure that there is no reason that an exception should be made to this policy. All discarded documents are to be shredded or sent to a recycling company, with which Fort Freedom has a confidentiality agreement.
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3. Destruction of records relating to litigation or governmental investigations may constitute a criminal offense. The CFO and/or Secretary shall be responsible for suspending destruction of any Corporate Records as soon as any litigation, governmental investigation or audit, civil action or enforcement proceeding is suspected, reasonably anticipated or commenced against the Corporation, its officers, directors, members or employees.
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4. A director, officer, member, or employee with knowledge of potential or actual litigation, an external audit, investigation or similar proceeding involving the Corporation, must report this information to the Board of Directors as soon as possible.
V. Administration and Oversight
1. From time to time, Fort Freedom may establish additional retention or destruction policies or schedules. Notwithstanding the foregoing, if any director or employee believes or is informed by the organization that certain records are relevant to litigation or potential litigation, then those records must be preserved until the board of directors determines the records are no longer needed.
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2. The CFO and/or Secretary is responsible for the administration and enforcement of this Policy. Either the CFO or Secretary must monitor compliance with the retention periods. That person is specifically charged with overseeing periodic reviews of records in accordance with the Policy. ​
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Appendix A
Corporate Records
Articles of Incorporation & By-laws
Board meeting agendas & materials
Board and Committee meeting minutes
Certificate of Incorporation & related legal documents
Conflict of Interest disclosure forms
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Correspondence, Finance, and Administration
Accounts payable ledgers and schedules
Accounts receivable ledgers and schedules
Auditor management letters, audit reports
Bank deposits & statements
Bank reconciliations
Budgets & Projections
Cash receipts and disbursements
Charitable organization registration statements
Charts of accounts
Checks (for important payments and purchases)
Checks (general)
Contracts, notes & agreements
Correspondence – general (including e-mail)
Correspondence – legal and important matters
Depreciation Schedules
Employee Payroll & timecards
Expense analyses/expense distribution schedules
Financial statements (audited)
Fixed asset records & appraisals
IRS Form I-9 (store separate from personnel file)
General Ledgers
Program & Trust Agreements
Promissory Notes
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Insurance
Policies – occurrence type and claims-made types
Accident reports, Claims (after settlement), Fire inspection reports
Disability, unemployment claims
Group disability records
Safety (OSHA) reports
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Real Estate
Deeds, Mortgages, and Bills of Sale
Leases (expired)
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Tax
Correspondence with legal counsel or accountants
IRS exemption determination & related correspondence
Tax audit closing letters and Tax returns
Withholding tax statements
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Development
Fund agreements (signed) and correspondence
Gift acknowledgments
Community Philanthropy
Approved grant applications, acknowledgement letters
Declined/withdrawn grant applications
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Human Resources
Consultant contracts/files
Employment Applications and Resumes (non-employed)
Employee handbook, orientation and training materials
Employee personnel files and records
Employee retirement and pension records
Employee timesheets
Payroll records and reports
Workers Compensation claims
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Technology
Software licenses & support agreements
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Permanent
7 Years
Permanent
Permanent
7 years
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7 Years
7 Years
Permanent
4 Years
4 Years
2 Years
Permanent
7 Years
Permanent
Permanent
4 Years
7 Years
1 Year
Permanent
Permanent
7 Years
7 Years
Permanent
Permanent
3 Years
Permanent
Permanent
Permanent
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Permanent
Permanent
7 Years
7 Years up ending
Permanent
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Permanent
7 Years
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7 Years
Permanent
Permanent
7 Years
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Permanent
Permanent
Community Philanthropy
7 Years
7 Years
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7 Years
1 Year
Permanent
7 years from term.
Permanent
7 Years
7 Years
11 Years from DOI
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7 Years
Conflict of Interest Policy
I. Purpose
The purpose of this Conflict of Interest Policy (the “Policy”) is to protect the interests of Fort Freedom Inc. when we are contemplating a transaction or arrangement that might benefit the private interests of an officer, director or key employee of the organization, and ensure that all officers, directors and key employees act in the organization’s best interests. This Policy is intended to supplement but not replace any applicable laws governing conflicts of interest for nonprofit and charitable corporations.
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II. Definitions
1. Interested Person
Any director, officer, or key employee of Fort Freedom that has a direct or indirect financial interest as defined below.
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2. Related Party
a. Any director, officer or key employee of Fort Freedom or any affiliate of the organization, or
b. any relative of any director, officer or key employee of Fort Freedom or any affiliate of the organization, or
c. any entity in which any individual described in clause (a) and (b) of this subparagraph has a thirty-five percent (35%) or greater ownership or beneficial interest or, in the case of a partnership or professional corporation, a direct or indirect ownership interest in excess of five percent (5%).
3. Related Party Transaction
Any transaction, agreement or any other arrangement in which a related party has a financial interest and in which the organization or any affiliate of the organization is a participant.
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4. Key Employee
Any person who is in a position to exercise substantial influence over the affairs of the corporation as referenced in 26 U.S.C. 4958(f)(1)(A) and further specified in 26 CFR 53.4958-3(c), (d) and (e) or succeeding provisions.
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​5. Affiliate
Any entity controlled by, in control of, or under common control with Fort Freedom.
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6. Conflict of Interest
a. A conflict of interest arises:
i. when an interested person has personal interests or concerns that conflict with the interests or concerns of Fort Freedom, or
ii. when there is bias or the appearance of bias in a decision-making process that would reflect a dual role played by an interested person of the organization, or
iii. when a related party transaction is being considered.
7. Financial Interest
a. A person has a financial interest if the person has directly or indirectly, through business, investment or family:
i. an ownership or investment interest in any entity with which the organization has a transaction or arrangement, or
ii. a compensation arrangement with the organization or with any entity or individual with which the organization has a transaction or arrangement, or
iii. a potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which the organization is negotiating a transaction or arrangement.
b. Compensation includes direct and indirect remuneration as well as gifts or favors that are not insubstantial.
c. A person who has a financial or other interest may have a conflict of interest only if the Executive Board of Directors (the “Executive Board”; the “Board”) decides that a conflict of interest exists.
III. Duty to Disclose
1. In connection with any actual or possible conflict of interest, an interested person must disclose the existence of such interest to the Executive Board.
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2. An interested person is under a continuing obligation to disclose any potential conflict of interest as soon as a potential conflict of interest is known or reasonably should be known.
IV. Determining and Addressing the Conflict of Interest
1. After disclosure of the conflict of interest, an interested person shall have the opportunity to present all material facts about the possible conflict or transaction to the Executive Board. The Board also may request the interested person or persons be available for questions prior to deliberations.
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2. Once an interested person makes a presentation to the Board, he/she must leave the meeting during the discussion of, and the vote on, the transaction or arrangement involving the possible conflict of interest. The remaining Board members shall decide if a conflict of interest exists.
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3. A person who has a conflict of interest with respect to a contract or transaction that will be voted on at a meeting will not be counted in determining the presence of a quorum for purposes of the vote.
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4. An interested person is prohibited from improperly influencing the deliberation or voting on the matter giving rise to such conflict of interest.
V. Related Party Transactions
1. Fort Freedom shall not enter into any related party transaction unless the transaction is determined by the Executive Board to be fair, reasonable and in the organization’s best interest at the time of such determination. Any director, officer or key employee who has an interest in a related party transaction shall disclose in good faith to the Board the material facts concerning such interest.
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2. Any related party transaction involving the organization and in which a related party has a substantial financial interest, the Executive Board shall:
a. Prior to entering into the transaction, consider alternative transactions to the extent possible.
b. Approve the transaction by not less than a majority vote of the directors present at the meeting;
c. Document in writing the basis for the Board’s approval, including its consideration of any alternative transactions.
3. No related party may participate in deliberations or voting involving such related party transaction except to present information concerning the related party transaction at a Board meeting prior to the deliberations or voting hereto.
VI. Violations of the Conflict of Interest Policy
1. If the Board has reasonable cause to believe an interested person has failed to disclose actual or possible conflicts of interest, it shall inform such person of the basis for such belief and afford he/she an opportunity to explain the alleged failure to disclose.
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2. If, after hearing the member's response and after making further investigation as warranted by the circumstances, the Board determines an interested person has failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary and corrective action.
VII. Records of Proceedings
1. The minutes of the Board and meeting at which an actual or possible conflict of interest is discussed or voted upon shall contain:
a. The names of the persons who disclosed or otherwise were found to have a financial interest in connection with an actual or possible conflict of interest, the nature of the financial interest, any action taken to determine whether a conflict of interest was present, and the Board’s decision as to whether a conflict of interest in fact existed.
b. The names of the persons who were present for discussions and votes relating to the transaction or arrangement, the content of the discussion, including any alternatives to the proposed transaction or arrangement, and a record of any notes taken in connection therewith.
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2. The minutes of the Board and meeting at which a Related Party Transaction is discussed or voted upon shall contain:
a. The names of the persons who disclosed a Related Party Transaction, the Related Parties with respect to such Related Party Transaction, a description of the Related Party Transaction, the content of the discussion, and the basis for the Board’s approval of the Related Party Transaction, including consideration of any alternative transactions.
b. The names of the persons who were present for discussions and votes relating to the Related Party Transaction and a record of any notes taken in connection therewith.
VIII. Compensation
1. A voting member of the Board who receives compensation, directly or indirectly from the organization for services is precluded from voting on matters pertaining to that member’s compensation.
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2. A voting member of any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from the organization for services is precluded from voting on matters pertaining to that member’s compensation.
IX. Annual Statements
1. Each director shall annually review this Policy.
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2. Prior to the initial election of any director and annually thereafter, such director shall sign a Disclosure and Affirmation of Compliance Statement which affirms that such person:
a. has received a copy of the Conflict of Interest Policy,
b. has read and understands this Policy,
c. has agreed to comply with such Policy,
d. will disclose potential conflicts of interest by identifying any relationships, positions or circumstances in which he or she is involved that he or she believe could contribute to a conflict of interest, and
e. has agreed to file a supplemental Disclosure whenever a potential conflict arises.
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3. All Disclosure and Affirmation of Compliance Statements shall be submitted to the Secretary of the Board. The Secretary shall provide a copy of all completed statements to the Chairman of the Board.
X. Periodic Reviews
1. To ensure that the organization operates in a manner consistent with its charitable purposes and that it does not engage in activities that could jeopardize its status as an organization exempt from the federal income tax, periodic reviews shall be conducted. The periodic reviews shall, at a minimum, include the following subjects:
a. whether compensation arrangements and benefits are reasonable and are the result of arm length’s bargaining.
b. whether acquisitions of assets or property from any officer or director result in inurement or impermissible private benefit.
XI. Use of Outside Experts
1. In conducting the periodic reviews provided for in Article VII, the organization may, but need not, use outside advisors. If outside experts are used, their use shall not relieve the Board of its responsibility for ensuring that periodic reviews are conducted.
Fort Freedom Inc.
Conflict of Interest Policy
Reviewed: November 2023
Whistle-blower Policy and Procedures
Fort Freedom requires directors, officers, employees, service providers, and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of Fort Freedom, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
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I. Reporting Responsibility
This Whistle-blower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that Fort Freedom can address and correct inappropriate conduct or actions. It is the responsibility of all board members, any Veteran in our care, officers, employees, service providers, and volunteers to report concerns or violations of Fort Freedom's Code of Ethics or suspected violations of law or regulations that govern our operations.
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II. No Retaliation
It is contrary to the values of Fort Freedom for anyone to retaliate against any Veteran in our care, board member, officer, employee, service provider, or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operation of Fort Freedom. A board member or employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of relationship or employment with Fort Freedom.
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III. Reporting Procedure
Fort Freedom has an open-door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If an employee is not comfortable speaking with their supervisor or he/she is not satisfied with your supervisor’s response, the employee is encouraged to speak with the Chief Executive Officer (the “CEO”) or the Chief Operations Officer (the "COO"). All of Fort Freedom staff and service providers are required to report complaints or concerns about suspected ethical and legal violations in writing to the CEO or COO, who has the responsibility to investigate all reported complaints. Veterans in our care with concerns or complaints may also submit their concerns in writing directly to the COO or CEO. Board members, volunteers and any others with concerns or complaints should speak with or submit in writing to the COO or CEO. Reports may be made direct and named or anonymously.
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IV. Compliance
The CEO is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The CEO will advise the Executive Board of Directors of all complaints and his/her resolution and will report at least annually to the Audit Committee on compliance activity relating to accounting or alleged financial improprieties.
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V. Accounting and Auditing Matters
Fort Freedom's CEO shall immediately notify the Audit Committee of any concerns or complaints regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved.
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VI. Acting in Good Faith
Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense. This disciplinary action may include termination of the board or employee relationship, or other legal means to protect the reputation of the Foundation and members of its Board and staff.
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VII. Confidentiality
Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
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VIII. Reported Violations and Investigation
The CEO will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be investigated with due care and in a timely manner. If warranted by the investigation, appropriate corrective action will be taken up to and including expulsion, termination of employment or termination of relationship. If needed, legal counsel, accountants or other resources will be obtained to conduct a full and complete investigation.
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Fort Freedom Inc.
Whistle-blower Policy
Reviewed: November 2023
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