Policies

COMMUNITY FOUNDATION OF NORTHERN ILLINOIS
PRIVACY POLICY AND WEBSITE TERMS OF USE

The Community Foundation of Northern Illinois (“Foundation”) has created this privacy statement in order to demonstrate its firm commitment to the privacy of Foundation donors and website users. The following paragraphs describe the Foundation’s information gathering and dissemination practices. The privacy statement may change at any time; any changes will be posted on this page.

The following topics describe how the Foundation uses information voluntarily submitted by its donors and other visitors to this site, www.cfnil.org.

E-MAIL PRIVACY
The Foundation does not sell, rent, or lease e-mail addresses to anyone outside the organization. The Foundation may share data with trusted partners to help perform statistical analysis, send you e-mail or postal mail, or provide support. All such third parties are prohibited from using your personal information except to provide these services to the Foundation, and they are required to maintain the confidentiality of your information. If you do not wish to receive e-mail correspondence, you may opt out by clicking the unsubscribe button. If you have trouble doing so, please contact the Foundation.

USE OF IP ADDRESSES AND COOKIES
A unique number called an IP address identifies every computer on the Internet. Each time you connect to the Internet your machine is assigned an IP address. An IP address is a number that identifies each sender or receiver of information that is sent in packets across the Internet. The Foundation uses your IP address to help diagnose problems with our server, and to administer the Foundation’s website.

"Cookies" are small pieces of information that are stored by your browser on your computer's hard drive that help your computer talk to our computer. Most Web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Foundation uses cookies to maintain user session identity, store your username and password locally for ease of access, and personalize your website experience.

The Foundation may also collect certain demographic information about visitors to www.cfnil.org through the use of cookies. The Foundation only uses this data to improve the website and for internal business purposes.

SITE REGISTRATION AND CONTACT FORMS
The Foundation’s website registration and contact forms require users to provide contact information, including but not limited to name, e-mail address, and demographic information. The Foundation may use contact information from these forms to send the user information about the Foundation. The customer's contact information is also used to contact the visitor when necessary. We do not collect any personal information about you unless you voluntarily provide it to us.

EXTERNAL LINKS
The Foundation’s site contains links to external websites. The Foundation’s website is not responsible for the privacy practices or the content of such external websites. If you choose to follow such links to external websites, you do so at your own risk.

E-COMMERCE FOR DONATIONS
The Foundation’s website may use an order form for customers to make donations or purchase other products and services. Order forms may collect contact information (such as e-mail address) and method of payment. Contact information from an order form may be used to process orders and to send information about the Foundation. User payment information that is collected is used to check the users' qualifications and bill the user for donations, products, and services. This information is transmitted via a secure e-mail. 

SURVEYS
The Foundation may host online surveys that ask for contact information (such as e-mail address) and demographic information (such as zip code and age). The Foundation also may use contact data from its surveys to send information about the Foundation.

SECURITY
This site has security measures in place to protect the loss, misuse, and alteration of the information under the Foundation’s control. The Foundation uses the following methods for this purpose:

 -        SSL Protocol  

When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.

CHILDREN UNDER THIRTEEN 
The Foundation does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.

EXTERNAL DATA STORAGE SITES
We may store your data on servers provided by third party hosting vendors with whom we have contracted.

CONTACT INFORMATION
The Foundation welcomes your questions or comments regarding this Privacy Policy. You may contact the Foundation at:

Community Foundation of Northern Illinois
946 North Second Street
Rockford, IL 61107
(815) 962-2110
info@cfnil.org

Adopted by the CFNIL Board of Trustees February 21, 2024

Reviewed by Board Secretary: James Patterson, CFNIL President.

ARTICLE X

CONFLICT OF INTEREST

 

10.1

RECUSAL FOR ANY CONFLICT OF INTEREST.  

A Conflicted Person must declare a Conflict of Interest and recuse themselves from any Transaction related to the Conflict of Interest. To avoid any doubt:

1. A Conflicted Person shall not, directly nor indirectly, participate in deliberations or voting on a Transaction in which such person has a Conflict of Interest.

2. A Conflicted Person shall not attempt to influence the deliberations of the staff, committee, or Board pertaining to a Transaction in which such person has a Conflict of Interest.

3. A Conflicted Person shall not promote or lobby for an interest pertaining to a Transaction in which such person has a Conflict of Interest.

4. A Conflicted Person shall not attend that portion of meetings pertaining to a Transaction in which such person has a Conflict of Interest.

5. A Conflicted Person shall not disclose any Confidential Information regarding the Foundation’s deliberations pertaining to a Transaction in which such person has a Conflict of Interest.

6. A Conflicted Person shall not act to subvert or undermine any aspect of such Transaction in which such person has a Conflict of Interest.

 

10.2

PURPOSE.

The purpose of this Article is to protect the interest of the Foundation and its tax-exempt status when it is contemplating entering into a Transaction that might benefit — directly or indirectly — the private interest of an officer, Board Member, committee member, or employee.  This policy is intended to supplement but not replace any applicable state or federal laws or regulations governing conflicts of interest applicable to not-for-profit and charitable corporations.

 

10.3 

DEFINITIONS.

1. “Compensation.” Compensation includes direct and indirect remuneration or benefits as well as gifts or favors that are substantial in nature, including payment for service as a Board Member or staff.

2. "Conflict of Interest.”  A Conflict of Interest exists when an Interested Person, either directly or indirectly through a Related Person, has an Financial Interest in the outcome of a Transaction such that an ordinarily prudent person would reasonably expect that such Financial Interest would exert an influence on the Interested Person’s judgment if the Interested Person were called on to vote on the Transaction, except, however, it shall not be a Conflict of Interest for a Conflicted Person to vote upon budget allocations, committee action approvals, or similar proposals where the Conflict of Interest has been previously disclosed by the Conflicted Person, the Transaction with the Conflict of Interest was previously approved by the Board or a committee aware of the Conflict of Interest, the Transaction with the Conflict of Interest is an embedded portion of a larger proposal, and there is no discussion of the Transaction causing the Conflicted Person’s Conflict of Interest.
3. “Conflicted Person.”  An Interested Person becomes a Conflicted Person in relation to a Transaction when an Interested Person declares, or the appropriate Board or committee determines, that the Interested Person has a Conflict of Interest with the Transaction.
4. “Financial Interest.”  A person has a Financial Interest if the person has, directly or indirectly, through business, investment or a Related Person:
   
   
   1. An ownership, partnership, or investment interest in any entity with which the Foundation is considering a Transaction,
   2. A Compensation arrangement with the Foundation or with any entity or individual with which the Foundation is considering a Transaction, or
   3. A potential ownership, partnership, or investment interest in, or compensation arrangement with, any entity or individual with which the Foundation is considering a Transaction, or
   4. Any other professional or business or fiduciary or financial relationship with any entity or individual with which the Foundation is considering a Transaction.
      
      
5. “Interested Person.”  An Interested Person is any Board Member, officer, member of a committee with Board delegated powers, or staff member of the Foundation who is participating in the consideration of a Transaction.
6. “Related Person.”  A person is a Related Person if a family, business, or personal relationship with the Interested Person exists such that an ordinarily prudent person would reasonably expect the Related Person to be able to exert an influence on the Interested Person’s judgment regarding the interests of the Foundation. Related persons include, but are not limited to:
   
   
   1. Family - An Interested Person's spouse, domestic partner, parent, parent of a spouse or domestic partner, sibling, sibling of a spouse or domestic partner, child or grandchild, child or grandchild of a spouse or domestic partner, or spouse or domestic partner of a child or grandchild.
   2. Roommates - An Interested Person's friends and associates residing in the Interested Person's residence.
   3. Friendships and Associations - Mere friendships and associations between an Interested Person and persons who have a Financial Interest do not necessarily establish a Related Person, but friends and associates with whom the full disclosure of the relationship are such that an ordinarily prudent person would reasonably expect the friend or associate to be able to exert an influence on the Interested Person’s judgment regarding the interests of the Foundation do establish a Related Person. 
      
      
7. “Qualified Person.”  A Qualified Person means any Board Member, officer, member of a committee with Board delegated powers, or staff member of the Foundation who is not a Conflicted Person with respect to a Transaction.
8. “Transaction.” Any proposed action or arrangement of the Foundation under consideration, including any action on behalf of the Foundation by the Board, a committee, an employee, or an advisor.

 

10.4

PROCEDURES

1. Annual Disclosure.  To assist with the identification of any actual or possible conflicts of interest, each Board Member, member of a committee, and Foundation employee must annually:
   
   

   1. Disclose to the Secretary of the Foundation the existence and nature of such personal financial, fiduciary, or other interests that reasonably might create a Conflict of Interest; and
   2. Sign a statement affirming that such person has received a copy of this conflict-of-interest policy, has read and understands the policy, has agreed to comply with the policy, and understands that the Foundation is a charitable organization and that in order to maintain its federal tax exemption, it must engage primarily in activities that accomplish one or more of its tax-exempt purposes and must establish and comply with this Bylaw.
      
      
2. Transactional Disclosures.  When a Transaction is presented for consideration each Interested Person shall act as follows:
   
   
   1. Participate.  Interested Persons who believe in good faith they have no Conflict of Interest may participate in the consideration of the Transaction.
   2. Voluntary Recusal.  Any Interested Persons who acknowledges a personal Conflict of Interest shall declare the Conflict of Interest in committee or with the President, the Chairperson of the Board, or the Chairperson of the committee prior to discussion and voting on the Transaction. iii. iv. c.
   3. Voluntary Inquiry Concerning Personal Recusal.  An Interested Person concerned about a possible personal Conflict of Interest with a Transaction should raise the concern of whether or not a Conflict of Interest exists either in committee or with the President, the Chairperson of the Board, or the Chairperson of the committee prior to discussion and voting on the Transaction.
   4. Duty to Inquire Concerning Potential Conflict of Interest.  Any person concerned that a potential Conflict of Interest has not been disclosed or might not be disclosed in a timely fashion by an Interested Person with a potential Conflict of Interest must raise the question of whether or not a Conflict of Interest exists either in committee, or with the President, the Chairperson of the Board, or the Chairperson of the committee, prior to discussion and voting on the Transaction 
      
      
3. Determining Whether a Conflict of Interest Exists.   Unless the Interested Person acknowledges the existence of a Conflict of Interest and voluntarily recuses, the Interested Person whose potential Conflict of Interest is under review shall disclose all facts known to the Interested Person respecting the potential Conflict of Interest that an ordinarily prudent person would reasonably believe to be material to a judgment about whether or not a Conflict of Interest exists.  The Chairperson may gather for consideration such additional information or documents respecting the potential Conflict of Interest that an ordinarily prudent person would reasonably believe to be material to a judgment about whether or not a Conflict of Interest exists.  After disclosure of all material facts related to the Conflict of Interest and after discussion with the Interested Person that the Chairperson determines is required for adequate disclosure, the Interested Person with the potential Conflict of Interest shall leave the meeting while the determination of the existence of a Conflict of Interest is discussed and voted upon.  A majority of the Qualified Persons present shall decide if a Conflict of Interest exists.  If it is determined that a Conflict of Interest exists, the Conflicted Person is recused and additional actions shall be taken as provided for herein. 
   
   
4. Additional Procedures for Addressing a Conflict of Interest. 
   
   
   1. The Chairperson of the Board or committee shall, if appropriate, appoint a Qualified Person or committee to investigate alternatives to the proposed Transaction or arrangement.  
   2. If the Chairperson of the Board is a Conflicted Person, then the next available officer (in the order that they are listed in the Bylaws) who is a voting member of the Board and who is a Qualified Person shall become acting Chairperson for all deliberations and voting pertaining to the conflicted matter.  
   3. If the Chairperson of a committee is a Conflicted Person then another Trustee who is also a member of that committee (in the order of Trustee seniority) and who is a Qualified Person shall become acting Chairperson for all deliberations and voting pertaining to the conflicted matter.
   4. If an employee of the Foundation is a Conflicted Person, all employees of the Foundation subordinate to the Conflicted Person are also considered to be Conflicted Persons and the Conflicted Person employee and their subordinate employees shall recuse themselves consistent with this policy.   
      
      
5. Procedures for a Transaction Between the Foundation and a Conflicted Person. 
   
   
   1. Under appropriate circumstances, the Foundation may enter into a Transaction with a Conflicted Person, but due care must be taken to avoid an excess benefit Transaction. An excess benefit Transaction is a Transaction in which an economic benefit (such as compensation, payment for goods or services, the use of Foundation assets, etc.) is provided by the Foundation, directly or indirectly, to or for the use of any individual, and the value of the economic benefit provided by the Foundation exceeds the economic benefit of goods or services received by the Foundation in exchange.
   2. In regard to a Transaction between the Foundation and a Conflicted Person, after exercising due diligence, the Board or committee shall determine whether the Foundation can obtain a more advantageous Transaction with reasonable efforts from a person or entity that would not give rise to a Conflict of Interest.
   3. In regard to Transactions between the Foundation and a Conflicted Person, if a more advantageous Transaction is not reasonably attainable under circumstances that would not give rise to a Conflict of Interest, the Board or committee shall determine by a majority vote, of at least two Qualified Persons whether the Transaction is in the Foundation's best interest and for its own benefit and whether the Transaction is fair and reasonable to the Foundation and shall make its decision as to whether to enter into the Transaction or arrangement in conformity with such determination.
   4. A voting member of the Board of Trustees who receives compensation, directly or indirectly, from the Foundation for services is precluded from voting on all matters pertaining to that member’s compensation or benefits, or participating in the consideration thereof.  
   5. A voting member of any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from the Foundation for services is precluded from voting on matters pertaining to that member’s compensation or benefits, or participating in the consideration thereof. 
      
      
6. Violations of the Conflict of Interest Policy.  Any time after a decision on a Transaction, if any person has reasonable cause to believe that an Interested Person failed to comply with the Conflict of Interest policy, the person should advise the President or the Chairperson of the Board.  If the President or the Chairperson of the Board is concerned there may be a violation of the Conflict of Interest policy, the Chairperson of the Board shall investigate upon the terms the Chairperson of the Board determines to be appropriate.  The investigation shall inform the Board and the potentially Conflicted Person of the basis for such belief.  The Chairperson of the Board shall provide the potentially Conflicted Person an opportunity to explain the alleged failure to disclose or comply.  If, after considering any written or oral response of the potentially Conflicted Person and making such further investigation as may be warranted in the circumstances, the Board determines that the Interested Person materially failed to comply with the Conflict of Interest Article, it shall refer the matter to the Executive Committee of the Board for appropriate corrective action. 
   
   
   1. Except for making a one-time response to any such allegation, the potentially Conflicted Person shall not attend or participate in any meeting in which any such allegation is considered.
   2. Corrective action may include removal from the Board or committee or termination of employment.  
   3. The Board may also, to the extent legally possible, seek to invalidate a Transaction and seek reimbursement from a Conflicted Person if the Conflicted Person’s failure to comply with this policy resulted in damage to the Foundation.  
   
   Reviewed by Board Secretary: James Patterson, CFNIL President.

PURPOSE

The Community Foundation of Northern Illinois (Foundation) respects the privacy of its Corresponding Parties. Foundation Personnel may be exposed to or have access to the personal, financial, business, and deliberative information of the Foundation and Corresponding Parties. This information is confidential. It may not be disclosed or discussed with anyone for any purpose other than that required and allowed by the Foundation.  

 

This policy governs all types of confidential and privileged information. The specific examples below are not comprehensive. All questions pertaining to the confidentiality and handling of privileged information should be directed to the President of the Foundation.

 

DEFINITIONS

CORRESPONDING PARTIES are any persons or entities that have disclosed confidential or privileged information to the Foundation, including but not limited to donors, grant and scholarship seekers and awardees, volunteers, the Board of Trustees, suppliers, and employees.

 

FOUNDATION PERSONNEL includes the Foundation’s Board of Trustees, officers, employees, community advisors and other volunteers, agents, fiduciaries, consultants and contractors.  

 

Disclosure of confidential information may be required by statute or regulation or in the course of prudent stewardship and administration, for example, in the course of seeking legal or financial audit opinions. Disclosure may also be allowed by Corresponding Parties.  

 

In cases where privileged information is disclosed, the Foundation will exercise due care that information is disclosed only to the intended recipients.

 

Generally, Foundation Personnel will not disclose or discuss confidential information:

 

• about donors, prospective donors, individual funds, or specific gifts;

• from professional advisors about donors or prospective donors;  

• about grant and scholarship seekers or awardees;

• with beneficiaries;  

• about committee deliberations; or  

• that is intellectual property or business information of the Foundation. 

 

CONFIDENTIALITY OF DONOR INFORMATION

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

 

CONFIDENTIALITY OF GRANT APPLICANT AND GRANTEE INFORMATION OF ORGANIZATIONS

The Foundation will not disclose the identity of grant applicants except as necessary to process the application.  The Foundation will not publicly disclose or discuss confidential information provided by grant applicants. The Foundation will not disclose confidential information about individuals who are beneficiaries of charitable activities funded by Foundation without those individuals’ consent. The Foundation routinely reports information about grantees, including the organization’s name and the grant’s purpose, amount, and results.  

 

CONFIDENTIALITY OF GRANT APPLICANT AND GRANTEE INFORMATION OF INDIVIDUALS

The Foundation will not disclose the identity of grant applicants except as necessary to process the application.  The Foundation will not disclose or discuss confidential information provided by applicants for grants.  Generally, the Foundation will disclose the identity of grantees and scholarship awardees, the amount awarded, biographical information provided in the application, and/or affiliation with education institutions, except in the case of hardship assistance grants to individuals. Applicants must consent to this disclosure as a condition of applying for grants and scholarships.  Generally, the Foundation will not disclose contact information of its grantees and scholarship awardees without prior consent from awardees.  

 

CONFIDENTIALITY OF FOUNDATION BUSINESS

Except as authorized by the Foundation’s Board of Trustees, discussions and records of the Foundation’s operations may not be disclosed. This includes information about the Foundation’s financial operations, fundraising, investments, personnel, grant making, and contractual relationships or information considered to be intellectual property by the Foundation. 

 

EXCEPTIONS  

This policy does not apply to disclosures to attorneys, accountants, and other professionals providing assistance to the foundation. However, such professionals are prohibited by the Foundation and their own professional standards from disclosing confidential information. The policy 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: 

• The Foundation’s annual report or financial review once it has been accepted by the Board of Trustees.  

• The Foundation’s Form 990. The Foundation is required to publicly disclose this document. The 990 does not disclose identifying or confidential information about the Foundation’s donors.  

 

PROTECTION OF CONFIDENTIAL INFORMATION

Foundation personnel who have acknowledged receipt and understanding of this policy may access confidential information necessary to perform their functions. Foundation personnel are expected to exercise sound judgment in securing the confidential information of the Foundation in accordance with this policy.

 

Reviewed by Board Secretary: James Patterson, CFNIL President.