Community Partners International (“CPI”, “we”, “us”, “our”) values your support and recognizes and respects the privacy of our donors.
In this Donor Privacy Policy we provide detailed information on when and why we collect your personal information, how we use it, how we keep it secure, and how you can update your contact preferences.
This Donor Privacy Policy applies to donors who make financial contributions via various means (e.g., online, via mail, EFC, through a donor-advised fund, over the phone, and so forth).
This document should be read together with CPI’s Privacy Policy.
Donor Data
If you choose to make a donation to CPI, you will be asked to submit financial and contact information to allow us to collect the donation, provide you with a receipt, and comply with legal and regulatory obligations. The information we may obtain in connection with your donation includes:
Concerning planned gifts, we also may collect information such as your Social Security number (where required by law) and estate documentation.
If you make a donation using a credit card by phone, by mail, or in person at an event, we will obtain your credit card information for the purposes of processing that transaction. We never store credit card or financial information, whether the gift is processed online, over the phone, or via mail.
How Donor Data Is Used
CPI uses your information to process your donation, issue a receipt, understand your needs, and provide you with better service. We use the comments you offer to provide you with information requested, and we take seriously each recommendation as to how we might improve communication. We also acknowledge and thank our donors in publications such as our Annual Report when donors have not opted to remain anonymous.
We offer our donors the option of donating anonymously, meaning we will not publicly recognize their gift in any way.
Your personal information will not be shared, leased, or sold to other organizations for fundraising purposes unless you have provided CPI with specific permission to do so or as otherwise disclosed in our Privacy Policy. CPI will not send donor mailings on behalf of other organizations. This commitment applies to information we receive from you both online and offline.
How Donor Data Is Secured
Donor contact information and gift history are maintained in our secure databases, to which access is strictly limited and password protected.
All online donation pages are protected by an SSL certificate. You’ll know this is enabled when you see a lock appear next to the URL. If you click on this lock icon, you can see CPI’s certificate.
When you donate to CPI online, your credit card information is secured by Fundraise Up’s secure payment processor. Fundraise Up’s integrated payment processing capabilities are powered by Stripe, which has the highest level of certification attainable in the payments industry: PCI Level 1. Fundraise Up uses 256-bit encryption and maintains SOC II, ISO 27001, and PCI DSS Level 1 security compliances. Your credit card number is used only for that particular transaction. Your card is never stored. For more information, please see Fundraise Up’s Privacy Policy.
Donations of cryptocurrency to CPI are processed through a secure third-party cryptocurrency donation processor, The Giving Block. For more information, please see The Giving Block’s Privacy Policy.
CPI partners with FreeWill to offer our donors free will, trust-making, and beneficiary designation tools. For more information, please see FreeWill’s Privacy Policy.
Contact Preferences
You may at any time request to be removed completely or partially from our emails, social media, and conventional mailings, and we comply immediately with requests we receive.
To update your contact preferences or opt out of any or all forms of communication, please email us at info@cpintl.org or write to us at Community Partners International, 580 California St Fl 16, Ste 1658, San Francisco, CA 94104-1068, USA.
Additional Information
For additional information about our practices for collecting, using, disclosing, and otherwise managing the information we collect from and about you, as well as the measures we take to protect personal information and the choices you can make about our use of the information, please email us at info@cpintl.org or write to us at Community Partners International, 580 California St Fl 16, Ste 1658, San Francisco, CA 94104-1068, USA.
Last Updated: September 17, 2024
The purpose of the following policy and procedures is to prevent the personal interest of board members from interfering with the performance of their duties to Community Partners International, or result in personal financial, professional, or political gain on the part of such persons at the expense of Community Partners International or its supporters, and other stakeholders.
Definitions: Conflict of Interest (also Conflict) means a conflict, or the appearance of a conflict, between the private interests and official responsibilities of a person in a position of trust. Persons in a position of trust include board members and officers. Board means the Board of Directors. Officer means an officer of the Board of Directors of Community Partners International.
Policy and practices
Full disclosure, by notice in writing, shall be made by the interested parties to the full Board of Directors in all conflicts of interest, including but not limited to the following:
Following full disclosure of a possible conflict of interest or any condition listed above, the Board of Directors shall determine whether a conflict of interest exists and, if so the Board shall vote to authorize or reject the transaction or take any other action deemed necessary to address the conflict and protect Community Partners International’s best interests. Both votes shall be by a majority vote without counting the vote of any interested director.
A Board member who is formally considering salaried employment with Community Partners International must take a temporary leave of absence until the position is filled. Such a leave will be taken within the Board member’s elected term which will not be extended because of the leave. A Board member who is formally considering employment with Community Partners International must submit a written request for a temporary leave of absence to the Secretary of the Community Partners International Board, c/o the Community Partners International’s office, indicating the time period of the leave. The Secretary of Community Partners International will inform the Chair of the Board of such a request. The Chair will bring the request to the Board for action. The request and any action taken shall be reflected in the official minutes of Community Partners International.
An interested Board member shall not participate in any discussion or debate of the Board of Directors, or of any committee or subcommittee thereof in which the subject of discussion is a contract, transaction, or situation in which there may be a perceived or actual conflict of interest. However, they may be present to provide clarifying information in such a discussion or debate unless objected to by any present board member.
Anyone in a position to make decisions about spending Community Partners International’s resources (i.e., transactions such as purchases, grants, contracts) – who also stands to benefit from that decision – has a duty to disclose that conflict as soon as it arises (or becomes apparent); s/he should not participate in any final decisions.
A copy of this policy shall be given to all Board members at the official adoption of stated policy. Each Board member shall sign and date the policy at the beginning of his/her term of service and each year thereafter. Failure to sign does not nullify the policy.
In accordance with the Sarbanes-Oxley Act, which makes it a crime to alter, cover up, falsify, or destroy any document with the intent of impeding or obstructing any official proceeding, this policy provides for the systematic review, retention, and destruction of documents received or created by Community Partners International (“CPI”) in connection with the transaction of organization business. This policy covers all records and documents, regardless of physical form, contains guidelines for how long certain documents should be kept, and how records should be destroyed (unless under a legal hold). The policy is designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records, and to facilitate CPI’s operations by promoting efficiency and freeing up valuable storage space.
Document Retention
CPI follows the document retention procedures outlined below. Documents that are not listed, but are substantially similar to those listed in the schedule, will be retained for the appropriate length of time.
Corporate Records
Bank Records
Payroll and Employment Tax Records
Employee Records
Donor and Grant Records
Legal, Insurance, and Safety Records
Electronic Documents and Records
Electronic documents will be retained as if they were paper documents. Therefore, any electronic files, including records of donations made online, that fall into one of the document types on the above schedule will be maintained for the appropriate amount of time. If a user has sufficient reason to keep an e-mail message, the message should be printed in hard copy and kept in the appropriate file or moved to an “archive” computer file folder. Backup and recovery methods will be tested on a regular basis.
Emergency Planning
CPI’s records will be stored in a safe, secure, and accessible manner. Documents and financial files that are essential to keeping CPI operating in an emergency will be duplicated or backed up at least every week and maintained off-site. Copies of all electronic files and folders are maintained using duplicate online back up systems.
Document Destruction
CPI’s operations manager is responsible for the ongoing process of identifying its records, which have met the required retention period, and overseeing their destruction. Destruction of financial and personnel-related documents will be accomplished by shredding. Document destruction will be suspended immediately, upon any indication of an official investigation or when a lawsuit is filed or appears imminent. Destruction will be reinstated upon conclusion of the investigation.
Compliance
Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against CPI and its employees and possible disciplinary action against responsible individuals. The manager of operations and finance committee chair will periodically review these procedures with legal counsel or the organization’s certified public accountant to ensure that they are in compliance with new or revised regulations.
A committee of the Community Partners International (CPI) Board of Directors reviews the compensation of all high-level personnel annually in accordance with Internal Revenue Service (IRS) rules and regulations. Efforts are made to secure compensation data from industry sources in order to determine competitiveness and appropriateness of salaries. CPI does not have any top management members with a salary in excess of $150,000. Every effort is made to ensure that the process is thorough and transparent in accordance with IRS guidelines and the organization’s policies and procedures.
I. Background
The United States Department of Health and Human Services has issued revised regulations pertaining to financial conflicts of interest. The regulations require that all individuals who participate in the design, conduct, or reporting of research funded by the Public Health Service complete training on financial conflicts and disclose personal financial interests that could give rise to an actual conflict of interest or the appearance of a conflict. A copy of the full text of the regulations and the final rule implementing the regulations published in the Federal Register can be accessed at https://www.gpo.gov/fdsys/pkg/FR-2011-08-25/pdf/2011-21633.pdf.
All Community Partners International (CPI) research professionals, including full-time, part-time, and adjunct staff, will be required to complete training provided by CPI, submit a financial conflict of interest screening form, and disclose relevant Financial Interests if they worked on a PHS-funded project in the preceding year, if they expect to work on a PHS-funded project in the upcoming year, or at any time they are named in a proposal for a PHS-funded project. Key members of management and certain administrative and support department staff also will be required to complete the training and the screening form and provide relevant disclosures.
The PHS financial conflict of interest disclosure requirement is entirely consistent with CPI’s corporate values and Institutional Principles, including objectivity in our work and our commitment to avoid actual or apparent conflicts of interest. The requirements of this Policy should be read in conjunction with CPI’s Conflict of Interest Policy, which provides general instruction on preventing, recognizing, and mitigating conflicts of interest.
II. Definitions
A. Disclosure means an Investigator’s disclosure of significant Financial Interests to CPI.
B. Financial Conflict of Interest (FCOI) means a significant financial interest that could directly and significantly affect the design, conduct, or reporting of PHS-funded research.
C. Financial Interest means anything of monetary value, whether or not the value is readily ascertainable.
D. Healthcare-Related Entities include any organization or entity (including both publicly traded and private companies) that provides healthcare-related products or services, including but not limited to:
E. Institutional Responsibilities means an Investigator’s professional responsibilities relating to seeking (by submission of proposals for the award of contracts or grants) or conducting PHS-funded Research, including but not limited to: research; peer review; editing, publication, and dissemination of research; and relevant work performed in administrative or support functions.
F. Investigator means the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants. For purposes of this policy, this includes the following at CPI:
G. Managing an FCOI means taking action to address an FCOI, which can include reducing or eliminating the FCOI to ensure, to the extent possible, that the design, conduct, and reporting of Research will be free from bias.
H. PHS means the Public Health Service of the United States Department of Health and Human Services, and any components of the PHS to which the authority involved may be delegated, including the National Institutes of Health. The PHS includes the agencies listed below:
I. Research means a systematic investigation, study, or experiment designed to develop or contribute to knowledge relating broadly to public health, including behavioral and social-sciences research. The term encompasses basic and applied research (e.g., a published article, book, or book chapter) and product development (e.g., a diagnostic test or drug). The term includes any such activity for which research funding is available from PHS.
J. Significant Financial Interest (SFI) means:
1. “Significant” means that the Financial Interest would have a material effect on the Research.
2. A Significant Financial Interest means a Financial Interest in any Healthcare-Related Entity consisting of one or more of the following interests of the Investigator, and of the Investigator’s spouse or domestic partner, dependent child, or other member of the Investigator’s household, if : (i) the financial interest reasonably appears to be related to the Investigator’s Institutional Responsibilities at CPI, and (ii) the aggregate value of all interests held in a particular Healthcare-Related Entity exceeds $5,000: a. Remuneration (including salary, wages, consulting fees, honoraria, and any other fee for services) b. Defined benefit pension payments or other post-employment payments c. Service in a management position such as a board member, director, officer, partner, or trustee of a Healthcare-Related Entity d. Ownership of an equity interest (including stock, stock options, bonds, or any other ownership interest) e. Holdings in a healthcare sector-oriented mutual fund f. Intellectual property rights (e.g., patents or copyrights) from which income is received g. Reimbursed or sponsored travel related to an Investigator’s Institutional Responsibilities i. Sponsored travel means travel expenses paid on behalf of an Investigator (or relevant family member) rather than paid by reimbursement ii. Travel reimbursed or sponsored by the following is excluded: federal, state, or local government agencies; institutions of higher education; academic teaching hospitals; medical centers; and research institutes affiliated with institutions of higher education. iii. Investigators will be required to provide the following information with respect to any reimbursed or sponsored travel: name of entity that sponsored or reimbursed any expenses associated with the trip; purpose of the trip; destination; date and duration of the trip; and amount of reimbursement received
3. SFIs do not include:
a. Salary, wages, and remuneration paid by CPI b. Travel expenses paid or reimbursed by CPI c. Income from mutual funds and retirement accounts (other than healthcare sector-oriented funds, see paragraph J.2.e, above), as long as the Investigator does not directly control the investment decisions made by the funds d. Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency; an institution of higher education; an academic teaching hospital; a medical center; or a research institute that is affiliated with an institution of higher education e. Service on advisory committees or review panels for a federal, state, or local government agency; an institution of higher education; an academic teaching hospital; a medical center; or a research institute that is affiliated with an institution of higher education
III. Financial Reporting Requirements
All full- and part-time CPI Investigators and all adjunct and affiliated adjunct staff must complete a screening form and disclose all Financial Interests relating to Research funded by PHS and complete the related training provided by a designated official(s) at CPI. All Investigators must fully and accurately complete the form within the time allotted depending on the circumstances giving rise to the need for disclosure. Failure to accurately and timely complete the training and the form and to provide updates as required by this policy could result in disciplinary action, up to and including termination.
Investigators named in a proposal for a PHS-funded project must complete the training and the screening and disclosure form before the proposal is submitted. Investigators who participate in the design, conduct, or reporting of PHS-funded work must also complete the training and the form before beginning any work on the project, whether or not they were named in the proposal.
All Investigators must update the disclosure form at least annually and within 30 days of receiving, acquiring, or discovering either a new Financial Interest or additional interests from an entity previously disclosed by the Investigator. All employees covered by the PHS regulations are expected to recognize their continuing obligation to timely disclose relevant Financial Interests to ensure CPI’s compliance with the reporting and certification requirements of the PHS regulations.
CPI is required to comply with different regulatory and contractual requirements relating to conflicts of interest that require different disclosure thresholds. Because of the variability among the regulatory schemes that apply to CPI, and because of the potential for enactment of changes in the disclosure thresholds, CPI has not set a minimum threshold for disclosure. This obviates the need for staff to resubmit disclosures if thresholds are changed and reduces the potential for confusion about the threshold that applies in a particular situation. Investigators therefore are required to disclose the Financial Interests listed in paragraph II.J.2.a — g, regardless of the value of such Financial Interests.
IV. Review and Evaluation of Financial Interests Disclosed by Investigators
A disclosure of a Financial Interest does not, by itself, create an impermissible conflict of interest. Each Financial Interest disclosure will be reviewed by CPI’s designated official(s). The designated official(s) is/are responsible for determining when an actual or potential conflict of interest exists in a given situation — that is, when a Significant Financial Interest could directly and significantly affect the design, conduct, or reporting of PHS-funded research — and for taking action as necessary to Manage such conflicts of interest, including development and implementation of a management plan. This responsibility will be exercised in cooperation with the relevant unit or corporate manager and with full participation by the employee. A variety of criteria may be considered in determining whether a particular Financial Interest creates a conflict of interest with respect to a particular PHS-funded project.
CPI will take appropriate steps to Manage FCOI to ensure that CPI’s research is free of bias or the appearance of bias. As described in the PHS regulations, some examples of how financial conflicts of interest may be addressed and managed include:
V. CPI’s Responsibilities
CPI will take reasonable steps to ensure that its subcontractors comply with the Department of Health and Human Services Financial Conflict of Interest regulations.
CPI will comply with regulatory requirements relating to our institutional responsibilities, including certification of compliance, maintenance of records, responses to requests for information, and reporting requirements.
Questions regarding this policy should be directed to info@cpintl.org.
It is the responsibility of all directors, officers and employees to comply with the Standards of Conduct and Business Ethics and to report violations or suspected violations in accordance with this Whistleblower Policy. No director, officer or employee who in good faith reports a violation of the Standards of Conduct or Business Ethics shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within CPI prior to seeking resolution outside CPI.
CPI will not retaliate against any employee for filing a complaint and will not knowingly permit retaliation by management, employees or coworkers. CPI is particularly interested in doing what it can to prevent and correct incidents of unlawful discrimination, workplace violence and harassment. Retaliation against anyone for reporting an actual or suspected violation of a policy in good faith will not be tolerated and will subject the individual engaging in the retaliation to discipline up to termination. Appropriate action will also be taken to deter any future retaliation. Applicable law also prohibits retaliation against any employee by another employee or by CPI for reporting, filing, testifying, assisting or participating in any manner in any investigation, proceeding or hearing conducted by CPI or a federal or state enforcement agency. Please report any complaints about retaliation in accordance with CPI’s Open-Door Reporting Policy.
Retaliation against any employee as a result of their bringing forward any questions, concerns or complaints about accounting or auditing matters, recording of information, record retention, or in any other manner concerning the honesty and integrity of CPI’s operation is also strictly prohibited. Please understand that by reporting these types of incidents to CPI, employees are assisting CPI to prevent and correct behavior that is inappropriate for the workplace.
Help people in need with a single gift.
Change lives every day with a recurring monthly gift.
Launch your legacy with our free will and trust-making tools.
Δ
Thank you for subscribing! We will update you on impacts and milestones as we empower vulnerable communities in Asia to meet their essential health, humanitarian, and sustainable development needs.
