Who is this for?
This content is designed for participants in Anti Entropy's SparkWell fiscal sponsorship program. While some context will be specific to SparkWell and may need more context, we've made these resources public because they may, nevertheless, be useful to others who may be founding or building an organization.
1. About this Policy
1.1. Protecting confidential information is essential to Anti Entropy's mission, reputation, and legal obligations.
1.2. As a nonprofit, we handle sensitive information about donors, staff, partners, and SparkWell Projects.
1.3. This policy applies to all employees, contractors, board members, and volunteers with access to Anti Entropy's confidential information.
1.4. This policy does not form part of any employment contract and may be amended at any time.
2. What Is Confidential Information?
2.1. Confidential information is any non-public information that could harm Anti Entropy, our stakeholders, or SparkWell Projects if disclosed without authorization, including:
2.1.1. Personnel: Personal information, compensation, health records, performance reviews
2.1.2. Financial: Bank accounts, budgets, grant details, SparkWell Project finances
2.1.3. Donors: Contact information, giving amounts, donor conversations and strategies
2.1.4. Organizational: Strategic plans, board materials, legal documents, internal communications
2.1.5. SparkWell Projects: Applications, finances, strategies, beneficiary information
2.1.6. Technology: Passwords, databases, systems, proprietary tools
2.2. What Is NOT Confidential
2.2.1. Information already public or on our website
2.2.2. Employee discussions about wages and working conditions (protected by NLRA)
2.2.3. Information disclosed under whistleblower protections (see Whistleblowing policy)
2.2.4. Reports to government agencies about suspected violations
2.2.5. When in doubt, ask the Board President before disclosing.
3. SparkWell Projects
3.1. Anti Entropy Will
3.1.1. Maintain Project information confidentially
3.1.2. Share only on need-to-know basis
3.1.3. Protect Project information as carefully as our own
3.2. Project Leads Must
3.2.1. Protect Anti Entropy's confidential information
3.2.2. Establish confidentiality practices for their teams
3.2.3. Report any breaches immediately
3.2.4. Get permission before discussing other Projects
4. Protecting Confidential Information
4.1. When You Can Share
4.1.1. Only share confidential information when:
- Required to perform your job
- Authorized by Board President
- Required by law or legal process
- Protected under whistleblower laws
4.2. When You Cannot Share
4.2.1. Never share confidential information:
- With family, friends, or on social media
- In public places where others can overhear
- With unauthorized third parties
- For personal gain
- After employment ends (obligations continue)
4.3. Practical Measures
4.3.1. Digital:
- Lock computers when away
- Use strong passwords; never share them
- Don't email confidential info to personal accounts
- Use secure connections for remote work
4.3.2. Physical:
- Don't leave confidential documents visible
- Shred before discarding
- Close doors for sensitive discussions
- Be aware who can overhear
4.3.3. Special considerations:
- Donors: Don't discuss giving amounts or donor info without permission
- Projects: Don't discuss Project finances or operations outside appropriate channels
- Board materials: Highly confidential; don't share externally
5. Consequences
5.1. Breaches result in disciplinary action per the Misconduct & Discipline policy:
5.1.1. Minor/accidental: Warning, training
5.1.2. Serious: Final warning, suspension, removal of access
5.1.3. Gross misconduct: Immediate termination, legal action, law enforcement referral
5.2. Breaches may also result in personal civil liability, regulatory penalties, criminal charges, and damage to professional reputation.
5.3. Unauthorized disclosure of highly sensitive information (bank accounts, donor financial details, health records) may result in immediate termination.
6. Whistleblower Protections
6.1. This policy does not prevent you from:
6.1.1. Reporting suspected illegal conduct to authorities
6.1.2. Filing complaints with regulatory agencies (EEOC, OSHA, IRS, etc.)
6.1.3. Participating in government investigations
6.1.4. Discussing wages and working conditions (NLRA-protected)
6.2. You do not need permission to exercise these legal rights. See Whistleblowing policy for details.
7. After You Leave
7.1. Confidentiality obligations continue indefinitely after employment ends.
7.2. You must:
7.2.1. Not disclose information learned during your time with Anti Entropy
7.2.2. Return all documents and equipment
7.2.3. Delete all organizational information from personal devices
7.2.4. Sign certification of compliance
8. Questions and Reporting
8.1. If unsure whether information is confidential: Ask Board President before disclosing.
8.2. If you witness a breach: Report immediately to Board President (or another board member if it involves the Board President).
8.3. If you accidentally breach confidentiality: Report immediately and honestly. Early reporting may reduce consequences; cover-ups will be treated more seriously.