Terms and Policies

The FBI Newark Citizens Academy Alumni Association (hereinafter the “Chapter”) is a non-profit organization separate and apart from the FBI. The purpose of the Chapter, acting in conjunction with and under the oversight of the FBI National Citizens Academy Alumni Association (the “FBINCAAA”), is to promote safer communities through community service projects and educating business, labor, media, medical, minority, religious, government, senior citizens, and other community leaders about law enforcement, with particular emphasis on the mission and resources of the FBI.

The Chapter has entered into a Memorandum of Agreement (“MOA”) with the FBI to create and administer a program ensuring that each local Citizens Academy Alumni Association (“CAAA”) board of directors receives training on best practices for the governance of non-profits, model documents, and other resources to assist in the development and administration of the local CAAA.

Additionally, the FBINCAAA is charged with providing oversight and accountability of all CAAAs to ensure that CAAA operations and activities do not conflict with the best interests of the FBI and are in good standing with local, state and federal corporate, charitable and tax laws. The policies set forth herein are intended to supplement, but not to supersede, any existing statements of policy now in existence or hereinafter adopted.

In light of the unique relationship between the Chapter, the FBINCAAA and the FBI, and to ensure compliance with state and federal laws, the Chapter’s Board of Directors (hereinafter the “Board”) has adopted this Code of Conduct and Ethics Policy (the “Code of Conduct and Ethics Policy”) for officers, directors and members of the Chapter (hereinafter collectively the “CAAA Members” and individuals a “CAAA Member”). CAAA Members must act in the best interests of the Chapter, the FBINCAAA and the FBI and must comply with both the letter and the spirit of this Code of Conduct and Ethics Policy.

No code or policy can anticipate every situation that may arise. Therefore, this policy is intended to serve as a guide and each CAAA Member is encouraged to contact the President of the Chapter with questions about specific circumstances that may implicate one or more of the provisions of this policy.

1. Use of the FBI Name, Initials and Seal. CAAA Members may not use any name that refers to the Federal Bureau of Investigation, or any name that includes “FBI” without the prior approval of the FBI. CAAA Members may not use the FBI’s official seal without the specific approval of the FBI’s Office of the General Counsel. CAAA Members may not use the FBI badge or other FBI insignia without the specific approval of the responsible FBI official. CAAA Members are prohibited from selling or otherwise distributing any of the FBI’s material from the Citizens Academy without the prior approval of the FBI.

2. Use of the Chapter Name and Logo. CAAA Members may use the Chapter name to indicate that they are a graduate of the Citizens Academy and a member of the Chapter. CAAA Members may not use the Chapter name or the Chapter logo to suggest that an event or activity is sponsored, endorsed or authorized by, or affiliated with the Chapter without prior approval of the Chapter. CAAA Members may not use the FBINCAAA name or the FBINCAAA without prior approval of the FBINCAAA.

3. Personal Advantage. CAAA Members are prohibited from using their position as a CAAA Member to procure personal advantages not available to the general public.

4. Citizens Academy Nominations and Fundraising. CAAA Members may not solicit any contribution in connection with any nomination or access to the FBI’s Citizens Academy (CA). Nominations shall be based solely on the needs and criteria established by the FBI. All fundraising literature must specifically state “Monetary contributions are not required to participate, or to be nominated for participation, in any FBI program or event.”

5. Media. CAAA Members may not speak or appear to speak on behalf of the FBI, nor represent that they are agents or employees of the FBI. CAAA Members may not speak on behalf of the Chapter without prior approval. All requests from the media regarding the FBI must be directed to the Community Outreach Specialist, designee of FBI HQ or such affected FBI division. All requests from the media regarding the Chapter must be directed to the President of the Chapter.

6. Violations and Sanctions. Violations of this Policy will be brought to the attention of the Board. The action taken by the Board will be commensurate with the seriousness of the violation and may result in disqualification from CAAA membership, and/or termination of service as an officer, director, or member of a committee.

Sexual Harassment Policy

The Chapter hereby adopts this Sexual Harassment Policy Statement (the “Harassment Policy”) which governs the behavior of each CAAA Member. The undersigned does hereby affirm the following:

1. Sexual Harassment is prohibited conduct. To that end, this policy prohibits all forms of harassment including inappropriate and unwelcomed physical touching, obscene gestures, threats, derogatory comments, jokes, teasing, sexually explicit language, sexual jokes, display of sexual materials, inappropriate comments based on sex or gender, sex or gender-related jokes, requests for dates or other expressions of attraction or sexual interest, and other similar conduct;

2. The Chapter will not tolerate harassment against any person based upon a protected status, including race, color, religion, gender, national origin, age, disability, marital status, sexual orientation, military or veteran status, or any other classification protected by state, federal or local laws and ordinances.

3. Individuals who feel they have been victims of any kind of harassment or believe they have witnessed harassment should report the incident immediately to an officer of the Chapter. All reports of harassment shall be investigated by the Chapter; and

4. Violations of this policy will not be tolerated and may result in disciplinary action, including disqualification from CAAA membership, and/or termination of service as an officer, director, or member of a committee.

Conflict of Interest Policy

The Chapter hereby adopts this Conflict of Interest Policy (the “Conflict of Interest Policy”). The undersigned does hereby affirm the following:

1. A “Conflict of Interest” transaction is any proposed or effected transaction, decision or vote involving the Chapter in which an officer, director, or member of a committee, or a person related to the officer, director, or member of a committee, (an “Interested Person”) has a beneficial interest or any other relationship or connection to the transaction, decision or vote that would reasonably be expected to bias or otherwise influence the Interested Person’s judgment; and

2. Interested persons must disclose Conflict of Interest transactions to the Board and cannot play any direct or indirect role in the deliberations or vote on the matter.

3. The Chapter shall annually survey its officers, directors, and committee members to provide for disclosure of situations potentially giving rise to Conflict of Interest situations involving the Chapter. Not less than annually, the Chapter shall review compliance with this reporting requirement and shall consider revisions or additions to the Chapter’s Conflict of Interest policy; and

4. The Chapter shall not lend money to, nor use its credit, to assist an officer, director, or member of a committee. Any person who assents to or participates in the making of any such loan or use of credit shall be liable to for the cost of such use of credit and for the amount of such loan until the repayment for such loan.

The Chapter hereby adopts this Document Retention Policy (the “Document Retention Policy”). The undersigned does hereby affirm the following:

1. This policy governs the retention and destruction of documents and other records, both in hard copy and electronic media (referred to as “documents” in this Policy).

2. Documents shall be maintained in either paper or electronic media with adequate provisions for backup and archival to reasonably assure the safe keeping of the documents. Usage of an internet based electronic document storage system approved by the FBINCAAA Board of Directors shall constitute prima facie evidence of compliance with requirements for secure storage.

3. No person shall knowingly destroy any document with an intent to obstruct or influence the investigation or proper administration of any matter within the jurisdiction of any government department or agency or in relation to or contemplation of any such matter or case.

4. The information listed in the retention schedule below is intended as a guideline for identification of categories of documents and the minimum length of storage required. Documents may be retained stored for periods of time longer than as provided. Questions regarding the retention of documents not listed below should be directed to the Chapter President.

5. Provided that at such time there is no known circumstance supporting a longer period of retention, after expiration of the applicable period, documents may be destroyed in accordance with this Policy by any means of high security and confidential disposal.

6. Document Retention Schedule:

Document Type – Retention Period

Annual Financial Statements – Permanent

Bank records, receipts, other financial records – 7 years

Compliance and Awards records – 7 years

Contracts and related correspondence and documents – 10 years

Contribution Records & Donation Receipt – Permanent

Corporate records, Articles, Bylaws, Agendas, Minutes & Resolutions –Permanent

Electronic Mail (E-mail) Correspondence and internal memoranda – 7 years

Insurance policies and claim records – Permanent

IRS Exemption records and Annual Tax Filings – Permanent

Membership Records – Permanent

Strategic Plans, Policies, Procedures & Affirmation Statements – 7 years

All documents not otherwise indicated – 7 years

The Chapter hereby adopts this Whistleblower Protection Policy (the “Whistleblower Policy”). The undersigned does hereby affirm the following:

1. CAAA Members must practice honesty and integrity in fulfilling responsibilities and must comply with all applicable laws and regulations.

2. The Chapter has an open-door policy and encourages CAAA Members to share their questions, concerns, suggestions or complaints.

3. If any person reasonably believes that a suspected violation of law or written policy exists, a written complaint may be filed by that person with any officer of the Chapter. Violations or suspected violations may be submitted on a confidential basis by the complainant.

4. All reports of unlawful activity shall be investigated and resolved by the Chapter. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

5. A complainant who in good faith follows this policy shall be protected from retaliation.

6. Any CAAA Member who retaliates against any person who has reported a violation in good faith is subject to discipline up to and including disqualification from CAAA membership, and/or termination of service as an officer, director, or member or a committee.

All CAAA members must at all times maintain compliance with all applicable FBI security requirements in the sole and absolute discretion of the FBI (the “FBI Requirements”). Failure to maintain such certification shall immediately disqualify an individual from CAAA membership, including all service as an officer, director or member of a committee. The undersigned hereby consents that the FBI may communicate the status of my compliance (or non-compliance) with the FBI Requirements to the CAAA and/or the FBINCAAA.

1. The Chapter may adopt expanded statements of policy which supplement or are in addition to the above policies.

2. Officers, directors and members of any committee shall agree in writing with the above and any other policies duly adopted upon election or appointment as such, and shall thereafter annually agree in writing with these policies.

3. The undersigned has read and hereby affirmatively agrees and subscribes to the policies contained herein.

4. The undersigned understands the Chapter is charitable tax-exempt organization and, to maintain its federal tax exemption, must engage exclusively in activities which accomplish one or more of its tax-exempt purposes.

5. This document may be executed in one or more counterparts, each of which shall be deemed to be an original, but all of which together shall
constitute one and the same instrument.

FBI Newark CAAA respects the privacy of every visitor to our website. Your privacy is paramount, and we go to great lengths to preserve it. This Privacy Policy describes how we collect and use information about our online visitors. We know you care about your information, and we want you fully informed of our practices.

This Policy may be changed or updated periodically. By visiting the FBI Newark CAAA website you accept the practices outlined in this Policy. 

The Data We Collect

Our website provide convenient ways for you to access our services and learn about important FBI Newark CAAA opportunities and events. We collect information about our online visitors both directly from our visitors and indirectly from other companies that provide data to us. We utilize this information to communicate with our supporters and clients and process their transactions. We do not sell it to other organizations. 

When you use our website to make a financial contribution, sign up to volunteer or register for an event, we may ask you for your name, address, phone number(s) and other information relevant to your transaction. We will ask for standard credit card information when you make a financial donation or pay membership fees. 

We also collect non-personal information about our online visitors using “cookies,” pixels, web beacons and other technologies that operate automatically when you visit our website. We use this information to give our website visitors a more personalized online experience and to help us make website improvements. The information helps us understand which parts of our website are the most popular, where our online visitors are going and how long they spend there. If you do not want us to collect information using cookies, you can disable this function in your browser. If you block cookies from us, we may not be able to customize your experience and our website may not function optimally. 

How We Secure Data

We use a variety of security measures to protect your data. We maintain physical, electronic and procedural safeguards to help prevent unauthorized access to and improper use of personally identifiable information. 

We protect the security of credit card transactions using a number of measures such as encryption, access controls, network firewalls and physical security. These measures make it extremely difficult for anyone to intercept the credit card information you send to us. When we work with other companies to process credit card transactions, those companies also use encryption and other appropriate security measures.

No website or electronic data can ever be completely secure, but we are always working to maintain up-to-date and appropriate security mechanisms.

How We Use Your Information

If you provide FBI Newark CAAA with personal information when you visit our website, we may utilize the information in our programs and activities. We may enter your information into one of our databases so we can contact you to obtain your input, provide information about our programs and events, request donations or provide a more personalized online experience.

FBI Newark CAAA does not sell, trade or share our members or donors’ personally identifiable information with any other entity, except as described below. We do not send mailings to our donors on behalf of other organizations unless the donor has given us specific permission to do so. 

On occasion, FBI Newark CAAA may share your information with our vendors and other partners that help us with our activities and programs. For example, we share information with vendors that help us fulfill orders, manage data and process donations and credit card payments. These vendors are bound by strict confidentiality rules and are permitted to use the information only to support FBI Newark CAAA operations. We also disclose information as required by law.  

Contact Us About Privacy

To let us know how you would like us to contact you, opt-out of receiving communications from FBI Newark CAAA or if you need to contact us to review your information or make corrections, please reach us by email to info@fbinewarkcaaa.org 

We Respect Your Privacy

FBI Newark CAAA is committed to respecting the privacy of its financial and in-kind donors, whether the donation is made online, by mail or any other method. When you make a financial or in-kind donation, you provide your name and contact information. Financial donors provide standard payment information including, in many circumstances, credit card data. We protect your information in a variety of ways, as outlined below.

We use industry standard safeguards to protect your information. Many donors use credit cards for donations. We protect the security of credit card transactions using a number of measures such as encryption, access controls, network firewalls and physical security. These measures make it extremely difficult for anyone to intercept the credit card information you send to us. When we work with other companies to process credit card transactions, those companies also use encryption and other appropriate security measures

We will not sell, share or trade our donors’ personally identifiable information with any other entity, except as described below. Additionally, we will not send mailings to our donors on behalf of other organizations, unless a donor has given us specific permission to do so. FBI Newark CAAA has vendors that assist with processing and managing donations and donor data. We give these vendors access to donor data. Our vendors are bound by strict confidentiality rules and are permitted to use donor data only to support FBI Newark CAAA operations.