Conflict of Interest Policy
Purpose
The purpose of this Conflict of Interest Policy is to protect the interests of The IDDeal Foundation (“the Foundation”) when it is considering a transaction, arrangement, or relationship that may benefit the private interest of a board member, officer, employee, volunteer, or other affiliated person. This policy is intended to help ensure that decisions are made in the best interest of the Foundation and in compliance with applicable federal and state laws governing nonprofit organizations.
This policy is intended to supplement, but not replace, any applicable state and federal laws governing conflicts of interest applicable to nonprofit and charitable organizations.
Persons Covered by This Policy
This policy applies to all:
• Members of the Board of Directors
• Officers
• Employees
• Volunteers with decision-making authority
• Committee members with board-delegated powers
Each covered person has a duty to act in the best interests of the Foundation.
Definition of Conflict of Interest
A conflict of interest may exist when a person’s personal, financial, professional, or family interests could interfere with their ability to act in the best interest of the Foundation.
A conflict of interest may include, but is not limited to:
• Financial interest in a company doing business with the Foundation
• Ownership or investment interest in a vendor, contractor, or partner organization
• Compensation arrangements with outside entities connected to Foundation activities
• Family or close personal relationships that could influence decision-making
• Receipt of gifts, favors, or special consideration from individuals or entities seeking to do business with the Foundation
For purposes of this policy, “family member” includes spouse, domestic partner, parents, siblings, children, grandchildren, in-laws, and any household member.
Duty to Disclose
Any individual covered by this policy must disclose any actual, potential, or perceived conflict of interest to the Board of Directors or appropriate committee promptly upon becoming aware of the conflict.
Disclosures should include:
• The nature of the conflict
• Relevant financial or personal interests
• Any material facts necessary for informed decision-making
Procedures for Addressing Conflicts
Determining Whether a Conflict Exists:
After disclosure of the potential conflict and any discussion with the interested person, the interested person shall leave the meeting while the remaining board members or committee members discuss and determine whether a conflict of interest exists.
Addressing the Conflict:
If a conflict is determined to exist:
• The interested person may provide factual information or answer questions at the request of the Board or committee.
• The interested person shall not participate in deliberations or vote on the matter.
• The Board or committee shall determine whether the proposed transaction or arrangement is fair, reasonable, and in the best interests of the Foundation.
Whenever possible, the Foundation should seek competitive bids or alternative arrangements to ensure fairness and transparency.
Violations of the Policy
If the Board or committee has reasonable cause to believe an individual failed to disclose an actual or potential conflict of interest, it shall inform the individual of the basis for such belief and provide an opportunity for explanation.
If, after investigation, it is determined that an individual failed to disclose a conflict of interest, appropriate disciplinary or corrective action may be taken.
Compensation
A voting member of the Board of Directors who receives compensation, directly or indirectly, from the Foundation for services rendered is prohibited from voting on matters pertaining to that member’s compensation.
No compensated board member may participate in discussions or votes regarding compensation matters affecting themselves.
Annual Disclosure Statements
Each board member, officer, and key employee shall annually sign a statement affirming that they:
1. Have received a copy of the Conflict of Interest Policy;
2. Have read and understand the policy;
3. Agree to comply with the policy; and
4. Understand the Foundation is a charitable organization and must engage primarily in activities that accomplish its tax-exempt purposes.
Records of Proceedings
The minutes of meetings involving conflict of interest discussions shall include:
• The name of the interested person
• The nature of the conflict
• The determination as to whether a conflict existed
• Any alternatives considered
• The final decision and vote taken
Periodic Reviews
To ensure the Foundation operates in a manner consistent with its charitable mission and does not engage in activities that could jeopardize its tax-exempt status, periodic reviews may include:
• Compensation arrangements and benefits
• Partnerships and vendor relationships
• Compliance with governance policies and legal requirements
Distribution of Policy
A copy of this policy shall be provided to all board members, officers, employees, and relevant volunteers upon onboarding and annually thereafter.
Non-Discrimination Policy
The IDDeal Foundation is committed to fostering an inclusive, welcoming, and respectful environment for all individuals. The Foundation does not discriminate, and shall not discriminate, in its programs, services, employment practices, volunteer opportunities, board recruitment, vendor relationships, or any other organizational activities on the basis of race, color, religion, creed, sex, gender, gender identity or expression, sexual orientation, national origin, ancestry, age, disability, marital status, military or veteran status, genetic information, or any other characteristic protected by applicable federal, state, or local law.
The IDDeal Foundation is dedicated to providing equal opportunity and fair treatment to all individuals. We believe that welcoming and respecting individuals from diverse backgrounds strengthens our organization and enhances our ability to fulfill our mission of empowering individuals with intellectual and developmental disabilities to live, work, and thrive in their communities.
This policy applies to all employees, volunteers, board members, program participants, applicants, contractors, vendors, donors, and community partners. The Foundation will make reasonable accommodations for qualified individuals with disabilities and for sincerely held religious beliefs as required by law.
Any individual who believes they have experienced discrimination in connection with the Foundation’s activities is encouraged to report the matter to a member of organizational leadership, such as The Executive Director of The Board of Directors Chair. Reports will be reviewed promptly and addressed appropriately in accordance with applicable laws and organizational policies.
Record Retention Policy
Purpose
The purpose of this Records Retention and Destruction Policy (“Policy”) is to establish guidelines for the management, retention, storage, and destruction of records created or received by The IDDeal Foundation in connection with its operations, legal obligations, financial activities, and programs.
This Policy is intended to:
• Ensure compliance with federal and state laws and regulations;
• Promote efficient organization and retrieval of records;
• Safeguard confidential and sensitive information;
• Support operational continuity and transparency; and
• Provide standards for the secure destruction of records that are no longer required.
Policy Statement
The IDDeal Foundation shall maintain complete, accurate, and secure records for the periods required by law, operational necessity, and best practices for nonprofit governance.
Records may exist in physical or electronic form and shall be stored in a manner that protects confidentiality, accessibility, and integrity.
No records shall be destroyed if they are relevant to any pending or anticipated litigation, audit, investigation, or government inquiry.
Responsibility
The Executive Director and/or designated staff member shall oversee compliance with this Policy. Department managers are responsible for ensuring records within their area are maintained appropriately.
The Board of Directors shall review this Policy periodically.
Electronic Records
Electronic records, including email communications, cloud-based documents, donor databases, and accounting systems, shall be backed up regularly and protected with appropriate security measures.
Confidential information shall only be accessible to authorized personnel.
Destruction of Records
At the conclusion of the applicable retention period, records may be destroyed in a secure manner, including:
• Shredding physical documents;
• Permanently deleting electronic files; and
• Ensuring destruction methods protect confidential information.
Destruction shall be suspended immediately upon notice of pending litigation, audit, or investigation.
Document Preservation in Case of Investigation or Litigation
If The IDDeal Foundation becomes aware of an actual or potential legal action, audit, subpoena, or investigation, all relevant records must be preserved until the matter is resolved.
Staff and board members shall be notified if a “litigation hold” is required.
Policy Review
This Policy shall be reviewed periodically by the Board of Directors and updated as necessary to reflect operational or legal changes.
Record Retention Schedule
| Record Type | Retention Period |
| Articles of Incorporation | Permanent |
| Bylaws and Board Policies | Permanent |
| IRS Determination Letter | Permanent |
| Board Minutes and Meeting Materials | Permanent |
| Annual Reports | Permanent |
| Financial Statements & Audits | Permanent |
| General Ledgers | 7 Years |
| Bank Statements & Reconciliations | 7 Years |
| Accounts Payable/Receivable Records | 7 Years |
| Payroll Records | 7 Years |
| Employment Tax Records | 7 Years |
| Grant Agreements and Reports | 7 Years after close |
| Donor Records and Gift Documentation | 7 Years |
| Contracts and Leases | 7 Years after expiration |
| Insurance Policies | Permanent |
| Personnel Files (former employees) | 7 Years after separation |
| Volunteer Records | 3 Years |
| Program Records and Statistics | 7 Years |
| Marketing and Communications Materials | 3 Years |
| Email Correspondence (routine) | 3 Years |
| Form 990 Filings | Permanent |
| Legal and Litigation Files | Permanent |
| Property Records and Deeds | Permanent |
Whistleblower Protection Policy
Purpose
The IDDeal Foundation (“the Foundation”) is committed to conducting its activities with honesty, integrity, transparency, and accountability. This Whistleblower Protection Policy is intended to encourage employees, volunteers, board members, contractors, and other representatives of the Foundation to report in good faith any concerns regarding suspected unethical, illegal, fraudulent, or improper conduct without fear of retaliation.
This policy is designed to comply with nonprofit governance best practices and support transparency and accountability within the organization.
Policy Statement
No employee, volunteer, board member, or other individual affiliated with the Foundation who in good faith reports a concern shall suffer harassment, retaliation, discrimination, adverse employment consequences, or any other form of reprisal as a result of making such a report.
Any person who retaliates against an individual who has reported a concern in good faith will be subject to disciplinary action, up to and including termination of employment or removal from volunteer or board service.
Reportable Concerns
This policy applies to concerns related to, but not limited to:
• Fraud or financial misconduct
• Theft, embezzlement, or misuse of Foundation assets
• Violations of federal, state, or local laws or regulations
• Conflicts of interest
• Accounting or auditing irregularities
• Falsification of records or reports
• Unsafe or unethical practices
• Abuse, neglect, or misconduct involving program participants
• Discrimination, harassment, or retaliation
• Violations of Foundation policies or ethical standards
Reporting Procedures
Individuals are encouraged to report concerns promptly. Reports may be made verbally or in writing to any of the following:
• Executive Director
• President of the Board of Directors
• Chair of the Finance or Audit Committee (if applicable)
If the concern involves the Executive Director, the report should be made directly to the Board President or another designated board officer.
Reports should include as much detail as possible, including:
• Description of the alleged misconduct
• Dates and locations
• Names of individuals involved
• Supporting documentation or evidence, if available
Anonymous reports may be submitted; however, sufficient information should be provided to allow for an adequate investigation.
Investigation of Reports
All reports will be taken seriously and reviewed promptly and confidentially to the extent possible. The Foundation will conduct a fair and impartial investigation and take appropriate corrective action when warranted.
The Foundation may designate internal leadership, legal counsel, or an independent third party to investigate reported concerns.
Confidentiality
Reports of suspected misconduct will be kept confidential to the extent reasonably possible, consistent with the need to conduct a thorough investigation and comply with legal obligations.
Protection Against Retaliation
The Foundation strictly prohibits retaliation against any individual who:
• Reports a concern in good faith
• Participates in an investigation
• Refuses to participate in unlawful or unethical conduct
Retaliation itself constitutes a serious violation of this policy and may result in disciplinary action.
Individuals who knowingly make false allegations or provide intentionally misleading information may be subject to disciplinary action.
Document Retention
All reports and investigation records related to whistleblower complaints shall be maintained in accordance with the Foundation’s Document Retention and Destruction Policy.
Distribution of Policy
A copy of this policy shall be distributed to all board members, employees, and volunteers and shall be included in appropriate onboarding and governance materials.
Privacy Policy
The IDDeal Foundation found at https://theiddealfoundation.org (“Website”) is governed by the following privacy policy (“Privacy Policy”).
We respect your privacy and are committed to protecting it. The purpose of this Privacy Policy is to inform you what personally identifiable information we may collect and how it may be used. This statement only applies to this Website.
WHAT INFORMATION DO WE COLLECT AND HOW IS IT USED?
Information You Voluntarily Submit to the Website: We may collect personal information from you such as your name or email address. For example, you may voluntarily submit information to the Website by leaving a comment, subscribing to a newsletter, or submitting a contact form. In addition, you are able to create a user profile, which allows you to create a username and password. We will store the username, but your password will not be visible in our records.
Information We Collect from Others: We may receive information about you from other sources. You may link your Facebook, Instagram, and/or Google accounts to your user profile. If you choose to link your Facebook, Instagram, and/or Google accounts to your user profile, we will receive your name, email address and profile picture associated with that account. The Website utilizes the Facebook commenting system, so if you choose to comment on a Website post, your profile picture will appear.
Automatically-Collected Information: We automatically collect certain information about you and the device with which you access the Website. For example, when you use the Website, we will log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the Website. We may also collect information about actions you take when using the Website, such as links clicked.
Cookies: We may log information using cookies, which are small data files stored on your browser by the Website. We may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your browser until deleted, to provide you with a more personalized experience on the Website.
HOW YOUR INFORMATION MAY BE USED
We may use the information collected in the following ways:
- To operate and maintain the Website;
- To create your account, identify you as a user of the Website, and customize the Website for your account;
- To send you promotional information, such as newsletters. Each email promotion will provide information on how to opt-out of future mailings;
- To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;
- To respond to your comments or inquiries;
- To provide you with user support;
- To track and measure advertising on the Website;
- To protect, investigate, and deter against unauthorized or illegal activity.
THIRD-PARTY USE OF PERSONAL INFORMATION
We may share your information with third parties when you explicitly authorize us to share your information.
Additionally, the Website may use third-party service providers to service various aspects of the Website. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies.
The Website currently uses the following third-party service providers:
Flodesk – this service is used for delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications. Please refer to Flodesk’s privacy policy for further information.
DonorSnap – this service is used for processing online donations and managing our supporter database. We store your contact details and transaction history for purposes of issuing tax receipts and maintaining donor records. Please refer to DonorSnap’s privacy policy for further information.
At this time, your personal information is not shared with any other third-party applications. This list may be amended from time to time in the Website’s sole discretion.
Except when required by law, we will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, we may disclose or transfer personal information collected through the Website to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.
ANONYMOUS DATA
From time to time, we may use anonymous data, which does not identify you alone, or when combined with data from other parties. This type of anonymous data may be provided to other parties for marketing, advertising, or other uses. Examples of this anonymous data may include analytics or information collected from cookies.
PUBLICLY VISIBLE INFORMATION
If you create a user profile on the Website or leave a comment, certain information may be publicly visible. To create a user profile, you must choose a username and password and input your email address for profile confirmation. Your email address will never be available publicly. At your option, you may also add an avatar, a profile description, and a link to your website.
You may also choose to link your Facebook, Instagram, and Google Account.
Users may see your username, avatar, profile description and website information.
COOKIES
The Website uses cookies to store visitors’ preferences, record user-specific information on what pages users access or visit, ensure that visitors are not repeatedly sent the same banner ads, customize Website content based on visitors’ browser type or other information that the visitor sends. Cookies may also be used by third-party services, such as Google Analytics, as described herein.
Users may, at any time, prevent the setting of cookies, by the Website, by using a corresponding setting of your internet browser and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. However, if users deactivate the setting of cookies in your Internet browser, not all functions of our Website may be entirely usable.
ADVERTISING
Retargeting Ads
From time to time, the Website may engage in remarketing efforts with third-party companies, such as Google, Facebook, or Instagram, Pinterest in order to market the Website. These companies use cookies to serve ads based on someone’s past visits to the Website.
Newsletters
On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, we may see if and when you open an email and which links within the email you click. Also, this allows the Website to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties.
RIGHTS RELATED TO YOUR PERSONAL INFORMATION
Opt-out – You may opt-out of future email communications by following the unsubscribe links in our emails. You may also notify us at bonnie@theiddealfoundation.org to be removed from our mailing list.
Access – You may access the personal information we have about you by submitting a request to bonnie@theiddealfoundation.org.
Amend – You may contact us at bonnie@theiddealfoundation.org to amend or update your personal information.
Forget – In certain situations, you may request that we erase or forget your personal data. To do so, please submit a request to bonnie@theiddealfoundation.org.
Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions, or when required by law.
SENSITIVE PERSONAL INFORMATION
At no time should you submit sensitive personal information to the Website. This includes your social security number, information regarding race or ethnic origin, political opinions, religious beliefs, health information, criminal background, or trade union memberships. If you elect to submit such information to us, it will be subject to this Privacy Policy.
CHILDREN’S INFORMATION
The Website does not knowingly collect any personally identifiable information from children under the age of 16. If a parent or guardian believes that the Website has personally identifiable information of a child under the age of 16 in its database, please contact us immediately at ibonnie@theiddealfoundation.org and we will use our best efforts to promptly remove such information from our records.
CONTACT INFORMATION
At any time, please contact us at bonnie@theiddealfoundation.org for questions related to this Privacy Policy.