BVM Personal Information and Privacy Policy
Policy Summary
Black Voter Matter Fund Enterprises which include BVM Capacity Building Institute and Black Voters Matter fund (collectively referred to as BVM) is committed to maintaining the privacy of personal information. Throughout the performance of BVM operations, the BVM will safeguard the generation, collection, use, storage, disposal, and disclosure of personal information in accordance with best practices and as required by applicable laws and regulations. The responsibility for the protection of personal information is shared by all individuals who process such information on behalf of the BVM.
SMS Text Opt-Out:
If a person receives text messages from BVM and wishes to stop receiving them, simply respond with either “STOP” or “UNSUBSCRIBE” to the number from which the message was received. Once we receive BVM receives the message, BVM will no longer send further text messages to the number.
Related Regulations
This policy helps promote compliance with the requirements of privacy laws and regulations, including but not limited to the General Data Protection Regulation (GDPR).
Who is Governed by this Policy
- Staff
- Contractors
- Any persons or entities who generate, collect, use, store, or process personal information on behalf of the BVM.
Policy
Information plays a critical role in BVM’s educational, research, administrative, and public service field activities. BVM recognizes the importance of safeguarding personal information, in all formats, that is processed or shared within the BVM and with third parties on its behalf.
This policy provides guidance to BVM staff, contractors and any person responsible for the collection and gathering of data on the organization’s responsibilities with respect to privacy and protection of personal information.
Collection of Personal Information
All BVM offices, contractors, and others that collect personal information on behalf of the BVM (each a “data collector”) are responsible for collecting only the minimum amount of such information necessary. Collecting no more information than is necessary minimizes the information that the BVM must secure and hold private. When collecting personal information from individuals, the following is required:
a. Transparency: BVM must inform the individual what information is being collected (both actively and passively).
- Lawful Basis: BVM must establish a lawful basis for the collection of personal information. This may include obtaining consent, collection of information necessary to perform under a contract, a legal obligation, vital interest, public task, or a legitimate interest.
- Adherence with privacy notice: any information that is collected through a BVM webpage regardless of where it is hosted, must adhere to the organization’s privacy notice. This also applies to contracted third parties that host marketing web pages on behalf of BVM programs.
Use of Personal Information
Any BVM officer, staff, contractor engaged to act on the behalf of the BVM, or other BVM-authorized persons or entities using or processing personal information on behalf of the BVM collectively referred to as BVM, is required to do the following:
a. Notice: BVM must make available a privacy notice detailing how personal information will be used and who to contact with any questions or concerns.
b. Non-Public Information: The above cited persons at BVM using information collected on behalf of the BVM is prohibited from selling, sharing, or publicizing personal information. Personal information is to remain private and is considered “Non-Public Information,”. BVM Operations Department is responsible for reviewing and determining the types of Non-Public Information in their custody, by classifying it in accordance with the data classification principles. BVM Operations Department is also responsible for implementing appropriate managerial, operational, physical, and role-based control.
c. Disposal: BVM staff will securely depose of all personal information, in any form, or, for third party data processors acting on behalf of the BVM, as otherwise may be mandated by the terms of the contract to ensure the information is not made public.
In addition to the requirements set forth herein, third party data collectors and data processors that provide services on behalf of the BVM are also subject to the terms and conditions included in their respective service agreements.
All members of the BVM staff with access to BVM systems and information are responsible for reporting any suspected or actual unauthorized disclosures of personal information by reporting to BVM’s General Counsel.
If necessary, incident response procedures will be initiated which may ultimately include notifying appropriate parties.
Definitions
Personal Information: is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, can also constitute personal information.
Regulated Information: is information protected by local, national, or international statute or regulation mandating certain restrictions. If disclosed, altered or destroyed, regulated information could cause a significant adverse effect to the BVM, its affiliates, or an individual.
Non-Public Information: is information that is classified as Regulated or Restricted.