Policy Statement
Respecting the privacy of the individuals and families we serve, as well as all Cody
Dieruf Benefit Foundation (CDBF) donors, Board Members, employees, volunteers, and
the CDBF itself, is a basic value of the CDBF. It is the policy of the CDBF that its Board
Members, employees, and volunteers will not disclose confidential information belonging
to the CDBF, or obtained through their affiliation with the CDBF, to any person,
including their relatives, friends, and business and professional associates, unless the
CDBF has authorized such disclosure.

Confidential Information
“Confidential personal information” includes, but is not limited to, medical information,
telephone numbers and addresses, financial information, donation and assistance amounts
from and to specific individuals, etcetera. Additionally, as set forth below, there are
some instances that a person’s identity may be considered confidential personal
information.
“Confidential business and financial information” includes, but is not limited to,
employee performance evaluations, personnel dilemmas, business negotiations,
communication with the CDBF’s legal counsel, or any other sensitive matter that needs to
remain within the walls of the boardroom or in the files of the organization. Any
legitimate organizational activity that has not been made public should be treated as
confidential or should be communicated only by the CDBF’s chosen spokesperson.
The following information shall be treated as confidential pursuant to this policy:

• Confidential personal information regarding the individuals and families we serve
  (including their identities) should not be disclosed or discussed with anyone
  outside of the CDBF without written authorization from the individual about
  whom such information regards (or their legal guardian in the case of a minor).
• Confidential personal information regarding CDBF donors, including their
  identities if anonymity is requested, should not be disclosed or discussed with
  anyone outside of the CDBF without the permission of the person or entity about
  whom such information regards.
• Confidential personal information regarding CDBF employees, volunteers, and
  Board Members should not be disclosed or discussed with anyone outside of the
  CDBF without the permission of the person or entity about whom such
  information regards, except that the identifies of such persons shall not be
  considered confidential.
• Except in furtherance of official CDBF business, confidential business and
  financial information should not be disclosed or discussed with anyone outside of
  the CDBF without the permission the Executive Director, the President of the
  Board, or other person(s) authorized by the Board to disclose such information.

Information Not Considered Confidential
You are free to talk about the CDBF, its mission, values and programs, and your position
with the CDBF, as such information shall not considered confidential.
Additionally, “confidential information” shall not include information that is:

• Been previously made public;
• Is readily available to the public in the same or an equally usable form as that
  maintained by the CDBF;
• Has been lawfully received from an independent third party without any
  restriction and without any obligation of confidentiality; or
• Has been independently developed without access to, knowledge of, or use of the
  CDBF’s confidential information.

Protect Against Inadvertent Disclosure
Board Members, volunteers, and employees are cautioned to demonstrate
professionalism, good judgment, and care to avoid unauthorized or inadvertent
disclosures of confidential information and should, for example, refrain from leaving
confidential information contained in documents or on computer screens in plain view.
Care shall also be taken to ensure that unauthorized individuals do not overhear any
discussion of confidential information.

Post-Employment and Post-Service Obligations
Over the course of their involvement with the CDBF, its employees, volunteers, and
Board Members may be exposed to information which is confidential and/or privileged
and proprietary in nature, including personal and medical information regarding
individuals we serve and personal information about donors, employees, and volunteers.
It is the policy of the CDBF that such information be kept confidential both during and
after employment or volunteer service. Further, employees and volunteers, including
Board Members, are expected to return written materials containing privileged or
confidential information at the time of separation from employment or expiration of
service.

Penalty for Unauthorized Disclosure
Unauthorized disclosure of confidential or privileged information is a serious violation of
this policy and will subject the person(s) who made the unauthorized disclosure to
appropriate discipline, including removal and/or dismissal.

Disclosure Required By Law
Nothing in this policy is intended to prevent disclosure of information where disclosure is
required by law and/or by a valid Court Order.

In compliance with the Federal Trade Commission’s (FTC) Health Breach Notification Rule, the Cody Dieruf Foundation has outlined the ways in which we keep your digital health information safe and secure.

It should be noted that the Cody Dieruf Foundation does not produce, develop, or play a role in the development of software.

Health data is stored, managed, and secured within Google, Microsoft, and JotForm products. Each of these companies were chosen for their high level of professionalism and commitment to user security.

Should any of these companies experience a security breach, we will contact the affected parties immediately upon our discovery.

The use of digital products by staff, board members, and volunteers are subject to our Confidentiality Policy.