Privacy Policy

Article I. PURPOSE

The purpose of this policy is to ensure that FACCNE is aware and respectful of its commitment to privacy,

manages data in an efficient and effective manner, maintains historical records related to its financial and administrative operations, and purges documents as part of its normal management process.

By establishing a specific timeline for document purging, this policy is also designed to help ensure compliance with the Sarbanes-Oxley Act, which prohibits the alteration, falsification or destruction of documents that are part of certain official proceedings.

If anyone associated with FACCNE becomes aware of any investigation, they should notify FACCNE immediately so that FACCNE can take appropriate steps to cease purging, and to identify and protect relevant documents or communications.

Article II. DEFINITIONS

“Document” refers to any item listed in the table below, in either hard copy, or electronic form. Electronic files also include those in audio/visual or emailed forms.
“Administrative” refers to documents pertinent to the day-to-day operations of FACCNE.
“Historic” refers to documents that are valuable for maintaining knowledge of the history of FACCNE
“Legal” refers to any document that is a contract or agreement between parties, that contains financial

information relevant to IRS filings, or that must be maintained to comply with laws and regulations.
“Recycle/scrap paper” includes disposal by normal recycling methods or reuse as scrap paper for internal

printing or note taking.
“Shred” means using a shredder machine to properly shred and dispose of documents.
“Delete” means to delete an electronic file.

Article III. LABELING AND STORAGE

All files, both hard copy and electronic, should be labeled by topic and year (if applicable). Electronic copies

should be saved in appropriate folders on network drive. Hard copies should be stored in file cabinets, or archived in FACCNE’s offices or at a predefined alternate remote location.

Archived hard copy files should be stored in firm, water and animal proof containers, clearly labeled with “FACCNE,” topic, and year. If documents of similar type and with the same retention and destruction requirements are stored together, they should also be labeled with a “destroy after” date so that they do not have to be reviewed additional times.

Article IV. REVIEW AND PURGING

Review and purging of files may take place in an ongoing manner but should occur at least every other year in

even numbered years and should follow the minimum retention requirements stated below. Such review and purging should also occur prior to archival storage of any files.

Article V. DOCUMENT DRAFTS

Once the final copy of a document has been completed, the drafts may be recycled or deleted, unless they are

documents of legal value. For documents determined to be of legal value, drafts containing comments should be saved for a minimum of two years, and drafts without comment may be destroyed once the final version is complete.

Article VI. DOCUMENT TYPES AND RETENTION

The following tables provides the minimum retention requirement and expected destruction method by document type.

Section 6.1 Corporate Records

Document	Type	Minimum Retention Requirement	Destruction Method
Articles of incorporation	Corporate records	Permanent	Not applicable
Annual reports to the secretary of state or attorney general	Corporate records	Permanent	Not applicable
By-Laws and amendments (FACCNE and FACC)	Corporate records	Permanent	Not applicable
Board meeting and board committee minutes	Corporate records	Permanent	Not applicable
Board policies and resolutions	Corporate records	Permanent	Not applicable
Construction documents	Corporate records	Permanent	Not applicable
Fixed asset records	Corporate records	Permanent	Not applicable
IRS application for tax- exempt status (Form 1023)	Corporate records	Permanent	Not applicable
IRS determination letter	Corporate records	Permanent	Not applicable
State sales tax exemption letter	Corporate records	Permanent	Not applicable
Contracts	Corporate records	7 years after termination	Shred; delete
General correspondence	Corporate records	3 years	Recycle/scrap; delete

Section 6.2 Accounting and corporate tax records

Document	Type	Minimum Retention Requirement	Destruction Method
Annual audits and year-end financial statements	Accounting and corporate tax records	Permanent	Not applicable
Depreciation schedules	Accounting and corporate tax records	Permanent	Not applicable
IRS Form 990 tax returns	Accounting and corporate tax records	Permanent	Not applicable
General ledgers	Accounting and corporate tax records	7 years	Shred; delete
Business expense records	Accounting and corporate tax records	7 years	Shred; delete
IRS Form 1099	Accounting and corporate tax records	7 years	Shred; delete
Journal entries	Accounting and corporate tax records	7 years	Shred; delete
Invoices	Accounting and corporate tax records	7 years	Shred; delete
Sales records (books)	Accounting and corporate tax records	5 years	Shred; delete
Petty cash vouchers	Accounting and corporate tax records	3 years	Shred if contains personal / financial information, or recycle / scrap
Cash receipts	Accounting and corporate tax records	3 years	Shred if contains personal / financial information, or recycle / scrap
Credit card receipts	Accounting and corporate tax records	3 years	Shred; delete
Expense reports	Accounting and corporate tax records	3 years	Shred if contains personal / financial information, or recycle / scrap

Section 6.3 Bank records

Document	Type	Minimum Retention Requirement	Destruction Method
Check registers	Bank records	7 years	Shred; delete
Bank deposit slips	Bank records	7 years	Shred; delete
Bank statement and reconciliation	Bank records	7 years	Shred; delete
Electronic fund transfer documents	Bank records	7 years	Shred; delete

Section 6.4 Payroll and employment tax records

Document	Type	Minimum Retention Requirement	Destruction Method
State unemployment tax records	Payroll and employment tax records	Permanent	Not applicable
Payroll records	Payroll and employment tax records	Permanent	Not applicable
Garnishment records	Payroll and employment tax records	7 years	Shred; delete
Payroll tax returns	Payroll and employment tax records	7 years	Shred; delete
W-2 statements	Payroll and employment tax records	7 years	Shred; delete
Employment tax records	Payroll and employment tax records	At least 4 years after filing the year's 4th quarter taxes (or longer, if required by state law)	Shred; delete

Section 6.5 Human resource records

Document	Type	Minimum Retention Requirement	Destruction Method
Employment and termination agreements	Human resource records	Permanent	Not applicable
Retirement and pension plan documents	Human resource records	Permanent	Not applicable
Records relating to promotion, demotion or discharge	Human resource records	7 years after termination	Shred; delete
Accident reports and workers' compensation records	Human resource records	5 years	Shred; delete
Background checks, drug test results, driving records and employment verifications	Human resource records	5 years	Shred; delete
Resumes, employment applications and related materials (including interview notes) for employees	Human resource records	4 years after termination	Shred; delete
Resumes, employment applications and related materials (including interview notes) for applicants not hired	Human resource records	3 years	Shred; delete
Timesheets, compensation history and job history	Human resource records	4 years after termination	Shred; delete
Performance appraisal and disciplinary action records	Human resource records	4 years after termination	Shred; delete
I-9 forms	Human resource records	3 years after hire date or 1 year after employment ends (whichever is later)	Shred; delete
Volunteer records	Human resource records	3 years	Shred; delete

Section 6.6 Donor and grant records

Document	Type	Minimum Retention Requirement	Destruction Method
Donor records and acknowledgment letters	Donor and grant records	7 years	Shred financial and private information. Recycle / scrap publicly available materials. Delete electronic version
Grant applications and contracts	Donor and grant records	7 years after expiration	Shred; delete

Section 6.7 Legal, insurance and safety records

Document	Type	Minimum Retention Requirement	Destruction Method
Appraisals	Legal, insurance and safety records	Permanent	Not applicable
Copyright registrations	Legal, insurance and safety records	Permanent	Not applicable
Environmental studies	Legal, insurance and safety records	Permanent	Not applicable
Insurance policies	Legal, insurance and safety records	Permanent	Not applicable
Real estate documents	Legal, insurance and safety records	Permanent	Not applicable
Stock and bond records	Legal, insurance and safety records	Permanent	Not applicable
Trademark registrations	Legal, insurance and safety records	Permanent	Not applicable
Leases	Legal, insurance and safety records	7 years after expiration	Shred; delete
OSHA documents	Legal, insurance and safety records	5 years	Shred; delete
General contracts	Legal, insurance and safety records	3 years after expiration	Shred; delete

Article VII. PRIVACY NOTICE

The content of this part (Article VII Privacy Notice), or a subsequent revision thereof, should be posted as a Privacy Notice on FACCNE’s website with the date of revision, as applicable.

Section 7.1 Overall Privacy Approach

FACCNE is committed to respecting privacy. This privacy approach governs our collection and use of personal and business information collected from members and visitors to our website, through our email and regular mail correspondence, telephone calls, and faxes, and reflects our policies toward privacy in respect of all other means of gathering and disseminating data.

Our policy is to use any and all data collected by any means, whether through the internet, email, our online database and/or any interactive forms or surveys only for such uses that are important to our organization and our mission, in light of the professional standards required and expected from nonprofit organizations.

FACCNE reserves the right to change this policy whenever deemed necessary without prior notification. Should changes be made, they will be posted as a Privacy Notice on FACCNE’s website with the date of revision.

Information posted about our members on FACCNE’s website consists only of the organization’s name and city, in addition to key FACCNE contact information such as board members or industry forum members. We do, however, maintain internal lists of members and contacts. Because physical mail and e-mail addresses are confidential, we never share either type of list with outside parties unless you give us permission to do so, and only key FACCNE personnel, FACCNE volunteers and certain technical contractors are allowed access to the areas of the computer systems in which we store FACCNE lists. Lists are accessed only for the purpose of upgrading our computer systems or distributing FACCNE newsletters, publicity campaigns, alerts, correspondence, event notifications, or other professional communications that help us accomplish our mission as a nonprofit organization.

Section 7.2 Privacy Specifics

(a) FACCNE website

FACCNE’s website collects information about each visitor in a number of ways, including but not limited to:

Though IP addresses
Though cookies
Though online forms

Your IP address does not reveal any personal information about you or your activities. Our web server host logs all IP addresses of all visitors to automate information collection concerning web traffic, usage, length of time visitors stayed, new visitors, entry and exit points, and the like. It is also used as statistical information for reporting and to find ways to improve web usability.

Our website uses cookies to gather information about traffic and to enhance your visit to our site. Cookies are used to customize web pages to provide the user with preferences. They can be deactivated in your browser if you wish by configuring your browser's preferences not to accept them. No information gathered by any cookies we have on our site is used to disseminate information about your personal use of the Internet, nor is it ever used for any marketing or advertising purposes.

Online forms are generated by our database to gather information about you and your organization when you register or make postings. None of this information is shared with 3rd parties, other than directly for the provision of services for which the form is posted, except that which is intended to be shown on results pages as delineated on the form. If you post information that is available on the FACCNE website, and wish to have it removed or corrected, please contact us, and we will comply with your request as soon as possible.

(b) Correspondence

None of your contact information or any of your correspondence that you send via regular mail, online through forms, through email, or any other means is ever sold to third parties under any circumstances, and is used only to conduct our daily business in accomplishing our mission under our policies as a nonprofit entity.

None of the information we collect is shared with any 3rd-party except as aggregated statistics for organizational performance reporting purposes, capturing and defining web traffic patterns, and website improvement. Information of this kind is never used to track or monitor individual users. Our purpose is to provide communications and collaboration with and among organizations of the French American ecosystem, to improve the information flow to our communities, and to improve the content and usability of our website, programs, products, and services.

If you send us questions about our website content or any of our areas of operation, we may forward your request for information to parties who would be able to assist you, or we may respond to you with that information in kind. You may at any time request us not to do so, and we will comply with that request, except as we are required by legal regulations or a court order to do so. It is unlikely we will contact you for verification, but we reserve the right to do so, should it become necessary. If you contact us by email or phone, we may ask you to verify your personal information so that we may respond to your inquiry with an assurance of your identity.

Our online database is protected by security put in place to safeguard data integrity and to prevent unauthorized access and/or use of its systems. These security measures have been designed to provide the user with reasonable protection of private information entrusted to our possession.

(d) Opt In / Opt Out of FACCNE Communications

You can become part of FACCNE’s distribution lists by various means, including becoming a member, signing up for events or contacting us. Once you are part of our contact/distribution lists, you can opt out any time by contacting FACCNE by email or by selecting the ‘unsubscribe’ option at the bottom of our email communications.

(e) Links to Other Websites

FACCNE serves as an information clearinghouse for various organization as part of the French New England ecosystem, and our website links to many other websites at the global, national, regional, state, or local levels. Although we work hard to make sure we are linking to appropriate sites and are responsible for the content of our site and our own privacy policy, we are not responsible for the privacy practices or the content of sites to which we link.

(f) Online Surveys

Occasionally we may ask you to participate in online surveys in the interest of accomplishing our mission. Such surveys are always voluntary, and it is not necessary for you to complete any survey. Should you decide to respond to a survey, the types of information that are collected may include demographics such as zip codes, age group, services received or provided, etc. However, none of this information will be collected on any one individual or that can be used to identify any one individual. Survey information is used in the aggregate to improve our organizational and online services.

(g) Corrections to Personal Information

If your personal or your organization's information needs to be updated, please contact FACCNE by email (contact@faccne.org) or via our website (https://faccne.org/contact-us/).

(h) Online Purchases

FACCNE may provide you with links to affiliate sites to allow you to purchase items related to FACCNE concerns and activities. Any transaction conducted as a result of those links is not conducted on our site, but is conducted on the site of the seller or the company managing the transaction through their online ecommerce functions. Therefore, FACCNE does not either see or collect any personal information about you, your transaction, and/or your credit card. All transactions and transaction details are between the purchaser and the company, and FACCNE makes no guarantee about these transactions. Buyers are responsible to be fully informed about sellers' and/or companies managing online transactions policies, and will hold FACCNE harmless from any and all disputes between the buyer and the seller/transaction management company. Should FACCNE offer products and services for online purchase directly on FACCNE's website in the future, FACCNE will update this policy as necessary.

Section 7.3 Contacting FACCNE

If you believe that your personal and/or private information is being used for a purpose other than its intended purpose, or if you have any questions about our Privacy Policy or the practices of our site, please contact FACCNE by email (contact@faccne.org) or via our website (https://faccne.org/contact-us/).