Privacy Policy & Code of Ethics

Donor Privacy Policy

College Track is committed to protecting the privacy of its donors, volunteers, employees and other stakeholders.

We value the trust of those we deal with and of the public, and we recognize that maintaining this trust requires us to be transparent and accountable in maintaining the confidentiality of the personal information you choose to share with us.

This privacy policy statement outlines the principles that College Track applies in order to ensure the confidentiality and integrity of your personal information.


Personal information: Information that is recorded in any form, both fact and opinion, and that can be used to distinguish, identify, or contact a specific individual. It does not include business contact information and certain publicly available information, such as names, addresses, and telephone numbers as published in telephone directories.

Donor: Any individual or organization that contributes funds to College Track.

Employee: This policy’s definition of employee includes a volunteer. Hence, this pertains to both paid and volunteer workers for College Track.



We are responsible for the personal information under our control. While senior management is ultimately accountable for the protection of personal information, a designated Privacy Officer is responsible for monitoring practices and procedures to ensure compliance with the principles set out in this policy.

We are responsible for personal information in our possession or custody, including information that has been transferred to a third party for processing. We will use contractual or other means to provide a comparable level of protection when a third party is processing the information.


We collect, use, and disclose personal information concerning our donors for the following reasons:

  • to establish a relationship and to communicate with donors;
  • to understand who our donors are and how we may improve our services to meet their preferences and expectations;
  • to process a donation, for example, to process a credit card transaction;
  • to issue and deliver a donation tax receipt;
  • to distribute a designated donation to another registered charity;
  • to recognize contributions;
  • to respond to requests for information;
  • to meet requirements imposed by law.

If we plan to use personal information we have collected for a purpose not previously identified, we will identify and document this purpose before such use.

We will make a reasonable effort to specify the identified purposes, orally or in writing, to the individual from whom the personal information is collected either at the time of collection or after collection but before use. We will state the identified purposes so that an individual can reasonably understand how the information will be used or disclosed.

Limiting Collection

We will limit the amount and type of personal information collected to that which is necessary for our identified purposes and we will only collect personal information by fair and lawful means.

Limiting Use, Disclosure, and Retention

Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information will be retained only as long as necessary to fulfil the identified purposes.

Personal information which has been used to make a decision about an individual will be retained long enough to allow the individual access to the information after the decision has been made and, in the event of an access request or a challenge, long enough to exhaust any recourse an individual may have under the law. Where personal information is no longer required to fulfil the identified purposes, it will be destroyed, erased, or made anonymous.


We will use our best efforts to ensure that personal information, including information that is disclosed to third parties, is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Openness Concerning Policies and Practices

We will make readily available to donors and employees specific information about our policies and practices relating to the management of personal information.

The information we will make available will include: how to gain access to personal information; the type of personal information held by us, including a general account of its use; general information concerning our policies; what personal information is made available to other United Ways or a donor’s designated agencies; and how to contact our Privacy Officer.

Individual Access

Upon written request, we will inform an individual of the existence, use, and disclosure of his or her personal information and we will give the individual access to that personal information. An individual can challenge the accuracy and completeness of his or her personal information and have it amended as appropriate.

We will respond to an individual’s written request within a reasonable time (generally within 30 days). We will assist any individual who informs us that they need assistance in preparing a request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use, and disclosure of personal information.

While our response will typically be provided at no cost, depending on the nature of the request and the amount of information involved, we reserve the right to impose a cost. In these circumstances, we will inform the individual of the approximate cost to provide the response and request direction from the individual on whether or not to proceed with the request. Requested information will be provided or made available in a form that is generally understandable. Where possible, we will indicate the source of the information.

In providing an account of third parties to which we may have disclosed personal information about an individual, we will attempt to be as specific as possible.

If an individual successfully demonstrates the inaccuracy or incompleteness of personal information, we will amend the information as required. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.

In certain situations, we may refuse a request or not be able to provide access to all the personal information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request.


Any individual can address a challenge concerning our compliance with any of the Privacy Principles to our Privacy Officer.

We will investigate all written complaints. If we find a complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices.

Statement of Principles and Code of Ethics*

College Track conducts its mission within the highest standards of ethical behavior, exceeding the standards required by law. As a nonprofit public benefit corporation organized under the California Nonprofit Public Benefit Corporation Law for charitable purposes, College Track adheres to the principles stated below. All of these principles provide a foundation for the Code of Ethics that follows.

Our Nine Principles

College Track’s Code of Ethics integrates the following principles:

  1. Putting our student’s well-being and success first
  2. Commitment to excellence
  3. Commitment to maintaining ethical standards
  4. Respect for the worth and dignity of individuals
  5. Inclusiveness, pluralism, diversity, equality of opportunity, and social justice
  6. Transparency, integrity and honesty
  7. Responsible stewardship of resources
  8. Compassion
  9. Accountability to the public, donors, beneficiaries and all stakeholders

Our Code of Ethics

I. Personal and Professional Integrity

All stakeholders in College Track (students and families, staff, board members, volunteers, suppliers and others interacting with the organization) act with honesty, integrity and openness. College Track promotes a working environment that principles respect, fairness and integrity.

II. Mission

College Track has a clearly stated mission and purpose, approved by the board of directors, in pursuit of the public good as follows: Empower students from underserved communities to graduate from college.

All of its programs support that mission and all who work for or on behalf of the organization understand and prioritize that mission and purpose. The mission is responsive to the constituency and communities served by the organization and of value to society at large. The mission rests on a foundational goal of empowering others.

III. Governance

College Track’s Board of Directors sets the mission and strategic direction and hires, dismisses and regularly evaluates performance of the chief executive officer. The Board of Directors prudently oversees its finances, operations, executive compensation,and policies (including conflicts of interest or potential conflicts of interest). The Board of Directors also

  • Recruits members who have the requisite skills to carry out their governance responsibilities for the benefit of College Track
  • Engages the chief executive officer and staff to provide the Board of Directors with timely and comprehensive information to carry out its duties effectively
  • Implements practices to verify with senior management that College Track conducts all transactions and dealings with integrity and honesty and in accordance with this Code
  • Adopts policies (officially and in writing) and promotes a working environment requiring working relationships with board members, staff, volunteers, and program beneficiaries that are based on this Code

IV. Legal Compliance

College Track is knowledgeable of and complies with all applicable laws and regulations.

V. Fundraising and Responsible Stewardship

College Track thoughtfully stewards its donors, resources and other relationships. College Track expends funds responsibly and consistently with donor intent and respects the privacy and confidentiality of individual donors as appropriate. College Track also

  • Implements policies and practices requiring all relationships with individuals representing College Track to be professional in nature
  • Spends a reasonable percentage of its annual budget on: mission-related programs; administrative expenses to ensure effective financial oversight, competent staff, and professional advising; and reasonable and appropriate staff compensation
  • Regularly reviews all spending practices and policies (including those relating to fundraising) for fairness, reasonableness and appropriateness to fulfilling its mission.

VI. Openness and Disclosure

College Track strives to provide comprehensive and timely information that is accurate in all material respects to the public, donors and potential donors, the media, and all stakeholders. College Track strives to respond in a timely manner to reasonable requests for information.

VII. Inclusiveness and Diversity

College Track has a policy of promoting inclusiveness and diversity. College Track takes meaningful steps to promote inclusiveness and diversity in its hiring, retention, promotion, board recruitment and constituencies served.

VIII. Listening and Speaking Up

College Track prioritizes listening to others and promotes an environment conducive to free expression of diverse and dissenting points of view. Based in large part on the Independent Sector Model Statement of Values and Code of Ethics for Nonprofit and Philanthropic Organizations.

*Based in large part on the Independent Sector Model Statement of Values and Code of Ethics for Nonprofit and Philanthropic Organizations.