Far West Helping Foundation Corp

Privacy and Data Protection Policy

FY 2025 Edition
EIN: 22-3939782 | DUNS: 965047306 | UEI: HLJXD7LKUHM6
P.O. Box 695085, Miami, FL 33269-2085
info@fwhfc.org | fwhfcadmin@fwhfc.org
www.fwhfc.org
Service Areas: Lee • Miami-Dade • Broward • Brevard • Palm Beach

Privacy Protection

We protect personal, client, donor, volunteer, employee, and partner information.

Secure Data

We use administrative, technical, and physical safeguards to protect information.

No Data Selling

FWHFC does not sell, rent, exchange, or misuse donor, client, or personal information.

Government Ready

This policy supports transparency, accountability, grant compliance, and public trust.

1. Purpose and Commitment

Far West Helping Foundation Corp (FWHFC) values and protects the privacy of clients, donors, employees, volunteers, applicants, vendors, and community partners.

FWHFC collects and maintains personal information only when necessary to provide services, process donations, support programs, meet legal obligations, and strengthen underserved communities across Florida.

FWHFC is committed to confidentiality, integrity, data security, transparency, accountability, and responsible information management.

2. Scope of Policy

This policy applies to all FWHFC programs, departments, staff, board members, volunteers, contractors, consultants, vendors, partner agencies, and systems that collect, store, access, or process personal or confidential information.

  • Housing, food, disaster recovery, victim assistance, youth, education, transportation, and community support programs
  • Client applications, intake forms, case files, donation records, employee files, volunteer records, and program documents
  • Electronic systems, cloud services, databases, email, websites, and physical files

3. Information We Collect

FWHFC may collect information necessary for service delivery, eligibility review, compliance, reporting, donor relations, employment, volunteer coordination, and organizational operations.

  • Names, addresses, phone numbers, emails, dates of birth, and emergency contacts
  • Program applications, eligibility documents, intake forms, case notes, and consent forms
  • Donation records, giving history, receipts, and payment processing information
  • Employee, contractor, and volunteer applications, training records, payroll, and HR records
  • Limited website data such as page visits, form submissions, browser type, and security logs

4. How We Use Information

FWHFC uses information only for lawful, mission-driven, and compliant purposes.

  • To determine eligibility and provide housing, food, disaster relief, victim support, transportation, and community services
  • To process donations, send receipts, maintain donor records, and provide updates when permitted
  • To manage volunteers, employees, contractors, payroll, training, and compliance records
  • To prepare required reports for federal, state, local, and grant-funded programs
  • To respond to inquiries, improve services, prevent fraud, and protect safety

5. How We Protect Information

FWHFC uses reasonable safeguards to protect personal, financial, program, and organizational information from unauthorized access, loss, misuse, alteration, or disclosure.

  • Restricted access for authorized staff only
  • Password protection and multi-factor authentication where available
  • Secure cloud storage, encrypted systems, backups, and access controls
  • Locked file cabinets and restricted physical storage areas
  • Confidentiality agreements and annual privacy/data protection training
  • Secure shredding or certified digital deletion when records are no longer required

6. Data Sharing and Disclosure

FWHFC does not sell, rent, trade, or exchange personal information. Information is shared only when authorized, legally required, or necessary to provide services or meet compliance obligations.

  • With authorized FWHFC staff who have a legitimate need to access the information
  • With approved service partners, funders, auditors, or agencies when required for programs or grants
  • When required by law, subpoena, audit, investigation, or safety concern
  • In aggregate or de-identified reports that do not identify individuals

7. Donor and Client Confidentiality

FWHFC treats donor and client information as confidential and protects it with high ethical and professional standards.

  • Donor names, giving history, and contact information are not released without permission unless required by law.
  • Clients’ applications, case files, assistance records, and personal information are protected and accessed only by authorized personnel.
  • Photos, videos, testimonials, or success stories are used only with written consent.
  • Anonymous donor requests are honored whenever possible.

8. Volunteer and Employee Records

FWHFC maintains employee, contractor, and volunteer records for employment, service, compliance, safety, payroll, training, and operational purposes.

  • Personnel and volunteer files are confidential.
  • Access is limited to authorized HR, executive, finance, or supervisory personnel.
  • Records are stored securely and retained according to legal, audit, and grant requirements.
  • Individuals may request correction of inaccurate or outdated information.

9. Rights of Individuals

FWHFC respects the right of individuals to understand and control how their personal information is collected, used, corrected, and protected.

  • Right to request access to personal records maintained by FWHFC
  • Right to request correction of inaccurate or outdated information
  • Right to withdraw consent where permitted by law and program rules
  • Right to opt out of non-essential communications
  • Right to file a privacy complaint without retaliation

10. Data Retention and Disposal

FWHFC retains records only as long as necessary for operational, legal, audit, grant, and compliance purposes.

  • Most administrative, personnel, donor, financial, and program records are retained for a minimum of seven years unless a longer period is required.
  • Board governance documents may be retained permanently.
  • Records involved in audits, investigations, or litigation holds will not be destroyed until cleared.
  • Expired records are destroyed securely through shredding, certified disposal, or secure digital deletion.

11. Policy Enforcement

All FWHFC representatives are expected to follow this policy. Violations may result in corrective action, loss of system access, suspension, termination, contract cancellation, or legal referral when required.

  • Privacy incidents must be reported immediately to leadership.
  • Reports will be reviewed promptly and confidentially.
  • Retaliation against anyone reporting privacy concerns in good faith is prohibited.

12. Policy Review and Updates

This policy will be reviewed annually or whenever legal, regulatory, grant, cybersecurity, or operational requirements change.

  • Updates may be recommended by the Executive Director, Data Protection/Compliance Officer, or Board of Directors.
  • Substantive updates should be approved by the Board of Directors.
  • Updated versions may be distributed to staff, volunteers, contractors, partners, and the public.

13. Adoption and Approval

This Privacy and Data Protection Policy affirms FWHFC’s commitment to privacy, responsible data management, legal compliance, ethical conduct, and public trust.

Approved By: Clebert Merat, Executive Director

Board Chairperson: ___________________________

Board Approval Date: ___________________________

Effective Date: ___________________________

Review Cycle: Annual, or as required by law, regulation, grant, or organizational need.

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