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12 WWW.UNWLA.ORG “НАШЕ ЖИТТЯ”, ГРУДЕНЬ 2017 SHARING EMAIL LISTS Part V of presentation compiled by the UNWLA Parliamen- tarian, retired U.S. Administrative Law Judge Oksana Xenos, which was delivered on May 28, 2017, by Vera An- drushkiw (President of Detroit Regional Council) at the UN- WLA XXXI Convention at Tampa, Florida. The opinions ex- pressed in this article are the author’s own and do not reflect the views of the Internal Revenue Service, the Social Secu- rity Administration, or the United States government. Can we share lists of our donors’ names and email addresses with other nonprofit or- ganizations? Donor names and addresses (email or physical) should never be shared with other organizations. Our first and foremost responsibility is to see to it that our own organization does its best to r aise as much money as it needs to serve those counting on us for our programs and services. Donors want to know where their money is going and how it will be used. It’s their charitable choice. However, they lose that choice when their good names are indis- criminately shared with other charities they do not know or would not be likely to support. Sharing email lists with other organizations is a bad prac- tice. What if another organization gives us a list of their donors and email addresses. Can we email these donors? The CAN - SPAM Act of 2003 allows emails to be sent to recipients with whom the emailing organi- zation has a transactional relationship. This means that a charity can communicate freely with its do- nors by email and otherwise. If someone makes a dona tion and gives us his email address, we are free to email him, even without expressly stating that we will email him. Such a donor has effectively opted - in to receive our com munications. 1 How- ever, donors to other organizations have not opted - in to receive our emails. Because no opt - in occurred, the CAN - SPAM Act prohibits adding these email addresses to our bulk list. Therefore, we should not email the donors of these other or- ganizations. What is the best policy for emailing donors and prospective donors? We should have a written donor email privacy pol- icy published on our website, which states unam- biguously that (1) we will not share a donor’s per- sonal information with anyone else, nor send do- nor mailings on behalf of other organizations, or (2) we will only share personal information once the donor has given us specific permission to do so. 2 Notes 1. Nonetheless, we must make sure that the recipient does not become fatigued or irritated by our emails, which could lead to such negative consequences as unsubscribing, filing a spam report, and, of course, refraining from any future donations. 2. Sample email privacy policy: “Your privacy is extremely important to us, and we will do everything we can to protect it. To that end, our organization maintains a n opt - in policy for its email communications. That means we want to send emails only to individuals who have requested that these mailings be sent to them or to people with whom we have an ongoing individual or transactional relationship. Your right to con trol what emails, if any, you receive from us is important to us. Although we may include announcements from partner organizations or other third parties in some emails, these messages will come directly from us, and we will not share your email address wi th anyone, nor will we sell it or rent it. The right to be let alone — the most comprehensive of rights and the most valued by civilized men. — Judge Louis D. Brandeis (1928)
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