INFORMATION ABOUT FINANCIAL ACCOUNTABILITY
FINANCIAL ACCOUNTABILITY OVERVIEW
All God’s Children International is an orphan care ministry answering God’s call to provide the love and hope that every child deserves.
We believe every gift, regardless of the size or type of contribution, must be stewarded in a manner that is consistent with our stated mission to fulfill God’s command to look after orphans.
All God’s Children International is accredited by the Evangelical Council for Financial Accountability (ECFA). We are committed to the utmost standards of stewardship, financial responsibility, and accounting practices. An independent public accounting firm audits our financial statements annually. Our current financial statement is available upon request.
Under state and federal laws, our Board of Directors must have official control of the organization’s funds and the freedom to allocate these funds in a manner which will carry out the expressed mission of AGCI. We will exert every effort to honor any stated donation designation or preference. In certain circumstances, where the project or need is overfunded or cannot be carried out in accordance with the donor’s preference, the funds will be used for similar projects or needs approved by our Board of Directors.
Contributions to AGCI may be tax deductible. Please contact your tax accountant or visit irs.gov (Publication 526) for further information.
IRS FORM 990
Last Updated: March 31, 2019
Welcome to All God’s Children International, (“AGCI”) and its website, provided and maintained by All God’s Children International, Inc., ( “AGCI”, or “Organization,” or “We,” or “Us,” or “Our”), a not-for-profit international orphan care ministry, family preservation, adoption program and child sponsorship program, that helps orphans transition to family, independence, break the cycle of poverty and create successful futures (“Services”). Our Services are offered through Our Website located at https://allgodschildren.org (“Website” or “Site”). Our Services work together to create lasting change for the 8 million orphans living in institutions, and to open up more paths to family and independence.
In the event You choose not to agree and accept the current Policy, or any new, modified or amended terms to this Policy, You shall immediately cease use of any of the AGCI Services. Nothing in this Policy shall be deemed to confer any third-party rights or benefits. Additional terms may apply to certain Services and/or products, and those additional terms shall become part of Your agreement with Us if You use those Services and/or Products.
1. AGCI Services and Information Use
a. Use by AGCI
b. Use by Our Users
AGCI acknowledges that You have the right to access Your Personal Information upon Your written request. Our Users control and are responsible for correcting, deleting or keeping their information up-to-date and accurate. If You request to remove data, User Information and/or Personal Information, We will respond within a reasonable timeframe. You may do so by contacting Us at firstname.lastname@example.org
AGCI collects information under the direction of its Users, and has no direct relationship with the individuals whose Personal Information it processes. We may transfer User Information and Personal Information to companies, third party affiliates, agencies, partners, and/or vendors that help Us provide, analyze and improve AGCI Services and Our business. We will only provide information necessary to improve and operate Our business.
This refers to full name, address, email address, telephone numbers, date of birth, state of residence, years married (if applicable), number of children, ages of children, health or mental health history, arrest and/or criminal history, credit or debit card numbers, driver’s license numbers or similar personal identifiers, passport numbers, education, religion, racial or ethnic origin, marital status, disability information, or other employment, financial or health information.
Personal Information also includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual. Navigational Information refers to information about Your computer and Your visits to this website such as Your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the “Navigation Information” section below. We may collect and process payment information, including credit cards numbers and billing information (“Payment Information”), from You when You pay for training or courses on Our Site and additional services, using a secured third party payment gateway, such as Stripe.
User information includes, but is not limited to, email, address, password, phone number, location, number of users accessing AGCI Services, gender, ethnicity, race, and names of users associated with Your account, and content, text, course answers, information and media uploaded to Your Account through the use of AGCI Services. User Information can also include information about any transactions, both free and paid, that You enter into on the Websites, and information about You that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that We acquire from service providers.
2. Information We Collect
a. When You Visit AGCI Site
We may use analytics software to allow Us to better understand the functionality of AGCI Services on Your devices. These analytics tools may record information such as how often You use the Site, the events that occur within the Services, aggregated usage, performance data, and where the Services were accessed from. In addition to information We collect on Our Sites, We may also collect Your city location, device model and version, device identifier (or “UDID”), OS version, and Your AGCI Service credentials.
We may send emails, text notifications, chat and/or postal mailings from time to time in order to update You about events, promotions, offers, changes to Your account, changes to Our Terms of Service and this Policy. If You no longer wish to receive such communications, You may opt-out or unsubscribe to all marketing and email campaigns. However, You cannot unsubscribe from emails regarding Your Account, unless You delete Your Account with AGCI.
We may send You an email on behalf of a User who has invited You to register for AGCI Services (“Invitation Email”). You may opt out of any Invitation Email at any time by clicking on the “unsubscribe” button located at the bottom of the Invitation Email.
We may link information We store within the analytics software to Personal Information you submit within the Services. We do this solely to improve the AGCI Services We offer You, and to improve Our marketing, content, analytics and Site functionality.
b. When You Register for AGCI Services
c. When You Use AGCI Services
If You choose to use AGCI Services after registering on Our Site, You will be required to provide User Information and Personal Information. You may also be required to pay for educational and Training Fees and other costs, where We will ask for and collect Payment Information. We will ask for and collect the same information as outlined in Section 2(b) above. The User Information and Personal Information provided for the AGCI Services is stored and managed on servers and third party hosting services such as SAM, InReach Solutions.
d. When You Use Non-AGCI Services Provided on the Site
If You choose to use Non-AGCI Services through Our Site, You will be required to provide the same User Information and Personal Information and additional information outlined in Section 2(b) above. The User Information and Personal Information provided for the Non-AGCI Services is stored and managed on SAM, InReach Solutions.
e. Log Files
When You use AGCI Services We automatically collect information about Your computer hardware and software. This information can include Your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses (“Log Files”). This information is used by Us for the operation of AGCI Services, to maintain quality of AGCI Services, and to provide general statistics regarding use of AGCI Services. For these purposes, We do link this automatically-collected data to Personal Information such as name, email address, address, and phone number.
f. Information Received From Third Parties
From time to time, We may receive User Information and/or Personal Information about You from third party sources including partners, affiliates, and agencies, (“Third Parties”) with which We may offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites. We will only use the User Information and/or Personal Information received from Third Parties for business purposes and to enhance the AGCI Services.
g. Information About Children
AGCI Services are not intended for or targeted at children under the age of eighteen (18) (“Minor”), and We do not knowingly or intentionally collect information about Minors, unless information about a Minor is provided by You in order for Us to assess adoption eligibility. In order to properly assess a prospective adoptive parent’s adoption eligibility, We may require You to provide information about Your current Minor children. Information includes, without limitation, Your Minor child’s legal name, gender, date of birth, and age (“Minor Information”). We do not use Minor Information collected for any purpose other than assessing a prospective adoptive parent’s adoption eligibility. If You believe that We have wrongfully collected information about a Minor, please contact Us at email@example.com so that We may delete the information.
3. Information We Collect Online and Offline
a. Online Data Collection Methods
Training Course Information
Current Family Information
Information Received from Responses Provided to AGCI
Adoption Program Applications
b. Offline Data Collection Method
Other Adoption Agencies
4. How We Use the Information We Collect
b. Use of Your Information
We use the information We collect in a variety of ways, including using the information to customize features and training that appear on the Site. We also may provide Your User Information and/or Personal Information to third parties, such as service providers, and contractors, in order to operate and manage the AGCI Services. The User Information and/or Personal Information We gather and collect enables Us to provide the Site and AGCI Services to help You make full use of AGCI Services. You hereby agree that We may use Your User Information and/or Personal Information that We collect to:
i. Provide AGCI Services;
ii. Contact You for customer service and/or training purposes;
iii. Contact You to inform You of important changes or additions to Our Site or AGCI Services offered;
iv. Send You material by trusted third parties, including but not limited to Families Are Forever;
v. Send You administrative notices, offers and any other communications that We believe may be of interest to You;
vi. Any company that acquires ownership or control of AGCI or that may purchase some or all of AGCI’s assets;
vii. Analyze the use, design, functionality and user feedback of the Site and AGCI Services;
viii. Amalgamate data and information for analysis and publication;
ix. Collect and segment data to optimize and improve AGCI Services;
x. Operate, improve and maintain Our Products and AGCI Services, including analyzing user behavior;
xi. Process payments and refunds;
xii. Administer promotions, offers, new feature notifications, and to provide features and display relevant content to You;
xiv. Provide other companies with statistical information about Our users — but this information will not be used to identify any individual user;
You hereby agree to be contacted by Us by email, office phone, mobile phone, text, chat boxes and features, social media, postal mail, chat and any future communication methods that You provide to Us through the use of AGCI Services. You may, at any time and for any reason, withdraw Your consent to Our use of Your User Information and/or Personal Information by contacting Us using the contact information below.
c. Use of Navigational Information
We use Navigational Information to operate and improve AGCI Services. We may also use Navigational Information alone or in combination with Personal Information to provide You with personalized information about AGCI and its partners, affiliates and third parties, to which You may unsubscribe from.
d. Use of Credit Card Information
If You give Us credit card information, We use it solely to collect payment from You as necessary to complete certain Services and/or trainings. We use third-party service providers to manage credit card processing. These third party service providers are not permitted to store, retain, and/or use the financial, banking and/or credit card information that You provide them, except for the sole purpose of credit card processing on Our behalf.
e. Customer Testimonials and Comments
We may post user testimonials and comments on Our Sites upon written notice to You, which may contain Personal Information. You have the right to request removal of such testimonial and/or comment(s) upon receiving Our written notice.
5. Information We Share
a. Service Providers and Contractors
b. By Law or to Protect Rights
We may disclose part or all User Information and/or Personal Information collected through AGCI Services, if (1) required by law; (2) if We believe that disclosure is necessary to comply with the law; (3) to enforce Our intellectual property rights; (4) to protect the rights, property or safety of Us and Our employees or agents; and (5) if necessary to defend against third-party claims. We may also disclose User Information and/or Personal Information collected on the Site when requested to comply with a court order, investigation, subpoena or governmental request. We will notify You of such use, either by a notification on the Site or by email to Our Users.
c. Business Transfers
d. With Your Consent
We may share User Information and/or Personal Information when You provide Us with Your consent to do so. This may occur when You consent affirmatively or it may occur through Your use of AGCI Services as provided in this Policy. For instance, when You request information or services from Our affiliates, partners, service providers, or other third parties through Us, or when You post information to Our Site, You provide Your consent for Us to share that information with others in the regular course of business.
e. We Never Sell Personal Information
Please bear in mind that whenever You voluntarily make Your User Information and/or Personal Information available for viewing by third parties online – for example through email or registering on a website- that information can be seen, collected and used by others besides Us. We are not responsible for any unauthorized third-party use of such User Information and/or Personal Information.
We may, from time to time, contact You on behalf of external business partners, such as Families Are Forever, about a particular offering that may be of interest to You. In those cases, We do not transfer Your User Information and/or Personal Information to the third party unless You provide Us written approval.
6. Global Digital Privacy Regulations (GDPR) Compliance
Our legal basis for collecting and using the Personal Information described above will depend on the User Information and/or Personal Information concerned and the specific context in which We collect it. However, We will normally collect User Information and/or Personal Information from You only where We have Your consent to do so, where We need the User Information and/or Personal Information to perform a contract with You, or where the processing is in Our legitimate interests is not outweighed by Your data protection interests or fundamental rights and freedoms. In some cases, We may also have a legal obligation to collect and maintain User Information and/or Personal Information from You.
You may opt-out of promotional and marketing e-mails by using the “Unsubscribe” link in Our e-mails and notifications. Under rare circumstances We may need to contact some or all Users to make an important announcement about the Site and/or AGCI Services, its use, privacy or service changes. You may not unsubscribe or “opt-in/opt-out” of these announcements because they may contain very important information regarding Your legal rights, User rights, privacy concerns and/or account information. You may unsubscribe from all emails by deleting Your Account.
If We ask You to provide Personal Information to comply with a legal requirement or to perform a contract with You, We will make this clear at the relevant time and advise You whether the provision of Your Personal Information is mandatory or not (as well as of the possible consequences if You do not provide Your Personal Information). Similarly, if We collect and use Your User Information and/or Personal Information in reliance on Our legitimate interests (or those of any third party), We will make clear to You at the relevant time what those legitimate interests are.
a. Processing shall be lawful only if and to the extent that at least one of the following applies:
a. the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
b. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
c. processing is necessary for compliance with a legal obligation to which the controller is subject;
d. processing is necessary in order to protect the vital interests of the data subject or of another natural person;
e. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
f. processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
7. Security of Your User Information and/or Personal Information
AGCI works to protect Your User Information and/or Personal Information by using reasonable and appropriate technical, administrative and physical procedures to protect User Information and/or Personal Information from loss, misuse, unauthorized access, disclosure, destruction or alteration. We also take precautions to protect Users’ User Information and/or Personal Information off-line, and We follow generally accepted industry standards to protect the information submitted to Us, both during transmission and once We receive it. However, We cannot fully ensure or guarantee the security of any information You send to Us, and You do so at Your own risk.
All of Our Users’ User Information and/or Personal Information is restricted in Our office(s) and only employees, AGCI affiliated service providers, engineers, developers and/or independent contractors who need the information to perform a specific job, are granted access to Your User Information and/or Personal Information. Employees and independent contractors who violate AGCI’s customer privacy safeguards are subject to disciplinary action, including termination. We use industry standard measures, including encryption where appropriate. We cannot and do not guarantee that information supplied to Us will not be intercepted while being transmitted over the Internet. Our servers are based in the United States, so Your User Information and/or Personal Information and other data will be hosted and processed by Us.
If, and when, a User accesses secured areas of Our Sites, Secure Sockets Layer (SSL) technology protects user information using both server authentication and data encryption, ensuring that user data is safe, secure, and available only to authorized persons.
Our computer systems are hosted in a secure data center environment that uses a firewall, intrusion detection systems, and other advanced technology to prevent interference or access from outside intruders. The data center is a highly protected environment with several levels of physical access security and twenty-four (24) hour surveillance.
8. Social Media Features
9. External Websites
10. Public Forums
We may offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if You directly disclose any information through Our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information You have posted on the Sites if You so request, as described in “Opting Out and Unsubscribing” below.
11. To Unsubscribe From Our Communications
You may unsubscribe from Our marketing, sales, and promotional communications by clicking on the “unsubscribe” link located on the bottom of Our e-mails, updating Your communication preferences, or by sending Us an email at firstname.lastname@example.org or postal mail 1400 NE 136th Ave., Suite 201, Vancouver, WA 98684, Attention: Privacy Update and Request. However, Users cannot opt out of receiving transactional emails related to their account with Us or AGCI Services, unless they delete their Account.
12. To Unsubscribe from Our Partners’ Communications
Our partners are solely responsible for their own marketing emails and other communications directed to You. We cannot unsubscribe You from Our partners’ communications. You may, however, unsubscribe from Our communications regarding Our partners’ by clicking on the “unsubscribe” link located on the bottom of their emails, or by contacting them directly.
13. Retention of Personal Information
When We have no ongoing legitimate business need to process Your Personal information, Navigation Information, and/or User Information, We securely delete the information or anonymize it or, if this is not possible, then We will securely store/archive Your User Information and/or Personal Information and isolate it from any further processing until deletion is possible. If practical, We will delete this information from the servers at an earlier date if You so request, as described above.
If You provide any information to Our partners as part of their use of AGCI Services, Our partners decide how long to retain the Personal Information, Navigation Information, and User Information they collect from You. After termination, We may, unless legally prohibited, delete all Personal information, Navigation Information, and User Information.
If You have elected to receive marketing communications from Us, We retain information about Your marketing preferences for a reasonable period of time from the date You last expressed interest in Our content, Products, or Services, such as when You last opened an email from Us or ceased using Your AGCI Account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
14. Cookies and Similar Technologies
15. How to Access & Control Your Personal and User Information
Reviewing, Correcting and Removing Your Personal Information
If You share User Information and/or Personal Information with Us, You will have the opportunity and right to review, update, change or delete the User Information and/or Personal Information You have provided to Us (and that We continue to store) at any time. If and when You ask Us to delete or modify Your User Information and/or Personal Information, We reserve the right to retain a record of certain User Information and/or Personal Information, and to record changes in order to comply with applicable federal, state or local law(s). If You remove User Information and/or Personal Information that You have made public on the Sites, copies may remain viewable in cached and archived pages of the Sites.
You have the following data protection rights:
i. You can request access, correction, updates or deletion of Your Personal Information and User Information;
ii. You can object to processing of Your User Information and/or Personal Information, ask Us to restrict processing of Your User Information and/or Personal Information or request portability of Your User Information and/or Personal Information;
iii. If We have collected and processed Your User Information and/or Personal Information with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We conducted prior to Your withdrawal, nor will it affect processing of Your User Information and/or Personal Information conducted in reliance on lawful processing grounds other than consent; and
iv. You have the right to complain to a data protection authority about Our collection and use of Your User Information and/or Personal Information.
To exercise any of these rights, You may contact us at email@example.com. We will respond to Your request to change, correct, or delete Your User Information and/or Personal Information within a reasonable timeframe and notify You of the action We have taken, if any.
16. Your Responsibilities and Consent
By using any of AGCI Services, You expressly consent to the following:
ii. Our servers are based in the United States, so Your User Information and/or Personal Information will be primarily processed by Us in the United States. You consent to the transfer and processing of Your User Information and/or Personal Information in the United States by Us and by Our partners and affiliates;
iii. You consent and agree that We may transfer Your User Information and/or Personal Information to data processors located in countries, including the United States, which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area. Your consent is voluntary, and You may revoke Your consent by opting out at any time, as described above. Please note that if You opt-out, We may no longer be able to provide You with Our Service;
iv. You consent to Us sharing Your User Information and/or Personal Information with relevant persons working for service providers who assist Us to provide Our Service; and
1400 NE 136th Ave., Suite 200, Vancouver, WA 98684
As a nonprofit, tax-exempt entity, ALL GOD’S CHILDREN INTERNATIONAL (AGCI) accepts charitable gifts and donations from persons who wish to support AGCI’s mission and programs. Charitable gifts and donations may be outright or deferred, and may be directed toward different AGCI programs. Regardless of the nature, form and amount of any such donation, AGCI recognizes a fiduciary responsibility to donors, clients and children served, and wishes to avoid any appearance of conflict of interest or preferential treatment to donors. The following procedures are intended to achieve those objectives.
WHO IS RESPONSIBLE
All policies and guidelines for charitable gifts and donations must be established or approved by the AGCI Board of Directors. The AGCI President, in coordination with the Vice President of Administrative Services, is responsible for managing all donor solicitation programs and activities.
COMMUNICATIONS WITH DONORS
AGCI may inform, guide or assist donors or potential donors who wish to support AGCI’s mission and programs. Under no circumstances may AGCI pressure or unduly persuade any person or entity to make a charitable gift or donation to AGCI. Employees or representatives of AGCI who communicate with donors or potential donors should in all cases encourage such donors to consult with independent legal and/or tax advisers prior to making any gift, to ensure that the donor obtains full and accurate information regarding all aspects of the proposed gift. Under no circumstances should any agent or employee of AGCI provide tax or legal advice to a donor or potential donor.
HUMANITARIAN CONTRIBUTIONS AS A COMPONENT OF REQUIRED FEES
Notwithstanding any other provision of this procedure, AGCI may set adoption fees that require, as a component of such fees, a fixed contribution toward the child welfare services or child protection programs of AGCI or of another agency or entity in the U.S. or in the child’s country of origin. However, any such required contribution must be clearly designated and explained to clients who are required to pay such fees, in accordance with Standard 96.40.
DECLINED AND PROHIBITED DONATIONS
AGCI reserves the right to refuse acceptance of any gift or donation and to consult with counsel regarding the suitability of any gift. No gift would be accepted that would:
- Result in AGCI violating its bylaws.
- Result in losing its status as an IRS 501c3 not-for-profit organization.
- Be too difficult or too expensive to administer in relation to the value.
- Be for purposes outside AGCI’s mission.
No donation will be accepted that is earmarked for or otherwise intended to benefit, or is restricted to any particular person, client or prospective adoptive parent.
AGCI will not solicit donations of cash, securities, annuities or specific property from an adopting parent working with AGCI from:1. The time a contract is received until six months after an adoption is finalized.
- The time a contract is received until six months after an adoption is finalized.
- The time AGCI’s services to the adopting parent have terminated.
ADOPTING PARENT ADVOCACY RULES
Adopting parents may be informed of and choose to participate in advocacy activities that support AGCI, including:
- Contributing in-kind goods and services for AGCI’s homes and partners while traveling to their child’s country of origin as a requirement of the adoption process.
- Grassroots awareness and fundraising activities including house parties, runs, walks, auctions, dinners, web-campaigns, etc., as volunteers and/or contributors.
- AGCI short-term mission trips, including paying fees that support trip-related orphan care projects.
- Fulfill an outstanding pledge, including sponsorship, made prior to the time a contract is received. An adopting parent may fulfill the pledge term and renew the pledge at the same level under the conditions outlined in sections 6 and 7 of this procedure.
UNSOLICITED DONATIONS FROM AN ADOPTING PARENT
In the event an unsolicited donation is received from an adopting parent after an adoption is contracted, AGCI may accept the gift under the following conditions:
- Any offer of a donation will be referred to a member of the development staff for follow-up with the adopting parent.
- The donation will be made through AGCI’s standard development process and coordinated by a member of the development staff.
- Donation information will be held confidential by the development staff, senior management and Board of Directors. Information will not be shared with adoption, inquiry and social services staff. Documentation of gifts will be kept confidential and separate from AGCI’s adoption database and files.
- The adopting parent will sign a document stating that the donation was not solicited and that they have not benefited from and do not expect to benefit as a result of making the gift.
- Contributions made in conflict with these terms will be declined.
PLEDGES AND SPONSORSHIPS
AGCI may accept pledges, which are commitments to give a specific dollar amount according to a fixed time schedule, including sponsorship pledges.
- Sponsorship pledges are usually for amounts of $1,200 or less and for a period of one year. Sponsorship pledges may be paid monthly, quarterly, or annually. Sponsorship pledges may renew from year to year.
- All other pledges must have written documentation that contains the amount of the pledge clearly specified and a clearly defined payment schedule. Before a pledge is accepted, the donor must be considered to be financially capable of making the gift.
- Acknowledgements and any naming opportunity associated with a pledge or sponsorship shall be removed if for any reason the pledge is not completed within the agreed upon payment schedule.
- In the event of death, pledge balances will be written off when AGCI is notified, unless there are provisions in the donor’s estate plans or the donor’s family indicates intent to complete the pledge.
- All requests to deactivate a pledge must be presented to and approved by AGCI.
GIFTS OF SECURITIES, ANNUITIES OR SPECIFIC PROPERTY
AGCI may accept gifts of securities, charitable gift annuities (immediate or deferred), real estate or tangible personal property only upon the prior review and approval by the AGCI President.
AGCI may establish an endowment fund to benefit the general purposes of the agency. The Board of Directors will determine what percentage of the income from the endowment fund may be used for current AGCI program activities.
All God’s Children International does not sell, trade or share a donor’s personal information outside the organization. When AGCI partners with other organizations (public, private, non-profit or government) to fulfill its ministry of serving orphans around the world, donor information remains confidential and is not disclosed to partner entities unless the donor gives specific permission to do so.
STORAGE AND ACCESS TO RECORDS
ALL GOD’S CHILDREN INTERNATIONAL (“AGCI”) adoption files will be maintained in a manner best designed to ensure their confidentiality and to protect the records from loss, damage, or destruction. When not in use, case files, medical records, and adoption registry records will be kept in locked filing cabinets, or secured file storage facility called Iron Mountain.
Only authorized personnel will have access to files. No adoption records will remain out and/or accessible and available for general viewing, whether on desktops or elsewhere. Files are stored in two rooms, the active filing room (families currently in the adoption process) and the post filing room (families in the process of completing post-adoption reports).
All files are color coded by country, with the following colors representing the respective countries:
• Blue – Bulgaria
• Red – China
• Yellow – Ethiopia
• Black – Guatemala
• Green – India
• Brown – Kazakhstan
• Light Blue – African American Infant Program (currently) and Nepal (formerly)
• Light Green – Oregon Foster Care Adoptions
• Orange – Vietnam
When a family completes their adoption, their program director takes their file from the active room, reviews the file to make sure it is complete, and files the file in the post room. The family’s file remains in the post room for approximately one year, until all of their social worker written reports are complete. At this point the file is sent to the secure offsite file location. When a family’s self-written post adoption reports arrive in the office, they are compiled by program for the year and then filed all at once with Iron Mountain. Off-site filing codes are kept for both the actual file and for the location of each self-report. Once all post-adoption reports are complete, including self-written family assessments, the family is sent a closing letter.
Computer backups of all electronic case files, medical records and adoption registry records, as of 1997, are backed up monthly and stored offsite. A paper copy of all case files, medical records, and adoption registry records will be maintained off premises by AGCI once the client file closes. All records subject to this procedure will be stored in a manner that allows for the records to be located and retrieved, using an index system.
When a client file closes in one of our satellite offices and becomes in-active or the social worker completes all post-adoption requirements, the entire client file, including electronic copies of documents, must be sent to AGCI’s main office in Vancouver by a traceable carrier with a signature requirement upon delivery. All packages must be insured at a value of $250.00. Once the package is received in the Vancouver office it will be signed for and archived in the client files.
RETENTION OF RECORDS
AGCI files regarding child placement, disruption, and child and birth parent information–including all adoption case files, adoption-related medical records, and adoption registry records–will be retained permanently by AGCI. Applicant files that have not resulted in an adoptive placement will be retained for three years. General correspondence will be retained for three years. All employment and contractor files will be permanently retained. Publicity, newsletters, information appearing on websites, grant requests will be retained permanently. Articles of incorporation, bylaws, annual reports, and corporate minutes will be permanently retained. Contracts, leases, and agreements with non-clients will be retained for ten years after full performance. Accounting ledgers and journals, audit reports, balance sheets, profit and loss reports, tax and nonprofit filings, payroll records, insurance policies will be retained permanently. All other financial and business records will be retained for ten years.
TRANSFER OF RECORDS
In the event that AGCI ceases to provide adoption services, all retained adoption-related records will be transferred to a licensed adoption agency in the state where AGCI’s retained adoption records are permanently stored. If an agency qualified and willing to accept AGCI’s adoption records cannot be found, the records will be transferred to the Oregon Department of Human Services or the appropriate state agency in the state where AGCI is licensed. AGCI will notify the appropriate state agency, the accrediting entity, and the U.S. Secretary of State of any transfer of adoption records. The notice must be given within 30 days of when AGCI ceases to provide adoption services, and must specify to whom records will be transferred.
A whistleblower as defined by this policy is an employee of AGCI who reports an activity that he/she considers to be illegal or dishonest to one or more of the parties specified in this policy. The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities.
Examples of illegal or dishonest activities are violations of federal, state or local laws; billing for services not performed or for goods not delivered; and other fraudulent financial reporting.
If an employee has knowledge of or a concern of illegal or dishonest fraudulent activity, the employee is to contact his/her immediate supervisor, the AGCI President or Human Resources. The employee must exercise sound judgment to avoid baseless allegations. An employee who intentionally files a false report of wrongdoing will be subject to discipline up to and including termination.
Whistleblower protections are provided in two important areas–confidentiality and against retaliation. Insofar as possible, the confidentiality of the whistleblower will be maintained. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defense.
AGCI will not retaliate against a whistleblower. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, or poor work assignments and threats of physical harm. Any whistleblower who believes he/she is being retaliated against must contact the AGCI President or Human Resources immediately. The right of a whistleblower for protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.
All reports of illegal and dishonest activities will be promptly submitted to the AGCI President or Human Resources who is responsible for investigating and coordinating corrective action.
Employees with any questions regarding this policy should contact the AGCI President.
CONFLICT OF INTEREST
Description: The policy covers all applicants who are known to AGCI or determined to be a connected party to AGCI, who wish to pursue the adoption of a child through AGCI.
Purpose/Rationale: To provide all parties with AGCI’s expectations around conflict of interest and when it applies.
Applicability: All AGCI employees, volunteers, interns, board members and other connected parties.
AGCI has a responsibility to ensure that all adoption activities are consistent with AGCI mission and values, ethics and policy of our licensing and accrediting bodies, and the laws of the United States, the Hague Convention on International Adoption and foreign governments.
In our desire to assist those seeking to adopt, it is our ethical obligation to ensure that the best interests of the primary client are our first consideration followed by the confidentiality of the secondary client. To that end AGCI has established that all persons known to AGCI or viewed as connected parties will require review of their adoption application by the Special Consideration Committee.
If an applicant is determined to fall within this policy, the applicants will be asked to sign a memo of understanding regarding the policy and the following procedures will be followed in their adoption process.
Conflict of Interest: The entanglement of an individual’s private interests with professional obligations, such that an independent observer might reasonably question whether the individual’s professional actions or decisions are improperly influenced by considerations of self-interest, a prior commitment, competing loyalties, an inability to be objective and/or personal financial impact.
Primary Client: The child who will be adopted.
Secondary Client: The adopting parent(s).
Persons Known to AGCI: Past and current employees; past and current interns/volunteers; and/or former board members (at least six months from end of board commitment).
Connected Parties to AGCI: Family members, friends or other close relationships of the above defined “persons known to AGCI,” as determined by the Special Consideration Committee.
Family Member: Spouse, child or any relative by birth, marriage or adoption.
Special Consideration Committee: A three-member committee; in the case that one of the committee members is the applicant or related to the applicant, that committee member will excuse themselves from the committee and be replaced by an impartial member.
1. Applicants will be asked to adopt through a program where they have no connection to the program director(s).
2. When the applicants are connected to the Post-Adoption Coordinator, the Director of Adoption or the Adoption Paperwork Coordinator will conduct post adoption follow-up and monitoring or will be CC’d on all communication and monitor the case more closely.
3. When the applicants are connected to the President, Vice President of International Programs or Vice President of Adoption, that AGCI employee will assist the Special Consideration Committee in determining if the policy applies.
4. Employees will be asked to sign a memo of understanding if an applicant is known to that employee.
5. All applicants will have the option to appeal the decision of the special consideration committee. If such an appeal is requested the applicant will be provided with the procedure for filing an appeal.
6. Employees or board members may request that the Special Consideration Committee decline an applicant based on the relationship with that employee or board member. This request will be held in confidence.
1. Employees will adopt through a country where they do not have a direct connection.
2. All employees are strongly encouraged to choose a Hague program to avoid the appearance of preferential treatment.
3. Employees are asked to sign a memo of understanding that they will not discuss their adoption during business hours.
4. Employees should refrain from putting colleagues into a compromising position by discussing their adoption outside of business hours.
5. Employees may not use any working hours to conduct adoption-related business/calls.
6. Employees will need to request PTO hours from their supervisor for all adoption related calls/business.
7. Employees who do not follow the policy will be subject to disciplinary action, including but not limited to, a verbal or written warning.
The Special Consideration Committee will review the application based on the current adoption guidelines and will determine if the applicants are eligible to adopt. During the review of the application all information included on the application, in addition to all information known to the Special Consideration Committee members through the applicants’ relationship to the agency may be considered in determining eligibility.
Once general eligibility is determined, the Special Consideration Committee will determine applicants’ eligibility for specific program(s). If applicants qualify for a country that operates under the Hague convention, the Special Consideration Committee will strongly recommend the applicants adopt through this program to further reduce the perception of preferential treatment.
1. Add to Pre-App and Application the following question: Do you have any past or current personal and/or professional affiliation with AGCI staff, volunteers, interns or board members?
a. This question will trigger a special consideration of the application by the Inquiry Coordinator.
2. Inquiry Coordinator will receive pre-app or application and send out memo of understanding.
3. Inquiry Coordinator notifies Vice President of Adoption that a “special consideration” application has been received.
4. Vice President of Adoption will designate who will “lock” the applicants file in SAM to only the designated staff members.
5. The Special Consideration Committee is convened by the Vice President of Adoption within five business days of receiving the application and/or supporting documents.
6. The Special Consideration Committee determines the applicants’ agency and program eligibility and notifies the Inquiry Coordinator of the decision.
7. Inquiry Coordinator notifies applicant of their approval/denial and which programs they are eligible for based on the special considerations.
a. If the applicant is a staff member, the Special Consideration Committee may tell the applicant directly of the decision.
8. If the applicants are approved, the known employee will be asked by their supervisor to sign the Employee Conflict of Interest Memo of Understanding.
If the applicants reside in one of AGCI’s licensed states, the applicants will complete their home study through an AGCI-identified cooperating agency.
1. Adoptive applicants will be provided with the list of cooperating agencies in AGCI-licensed states.
2. Home study will be conducted by a cooperating agency.
3. Home study will be reviewed and approved by AGCI.
During the paperwork and waiting stage of the adoption process the potential adoptive
parents file will only be accessible to their program director, the Vice President of Adoption and the Vice President of Administrative Services.
Depending on the program, review of a specific referral may return to the Special Consideration Committee before a referral is made to the family. If adopting from a Hague country, the Central Authority in the sending country will issue the referral directly to the family.
1. Program director receives referral from non-Hague country or locates a child on the CCWAA databank in the China Special Needs Program.
2. Program director requests that the Vice President of Adoption convene the Special Consideration Committee.
3. Program director presents the referral information to the Special Consideration Committee.
a. Provide the approved parameters for the family.
b. Present the child information.
c. Provide the committee with a list of all families the child could be placed with.
d. Provide the committee with each family’s stage in the adoption process or position on the wait list.
4. Committee members will consider if the referral is in the best interest of the child.
5. Committee members will evaluate if the referral is the best fit for the family.
6. Committee members will decide if the referral to this family is fair to other waiting families.
7. The Committee will notify the program director if the referral can be given to the family.
8. If determined by committee, the program director will make the referral to family.
While the adoptive family is in country for their adoption, all calls will be addressed during business hours. Adoptive families should only contact their designated program director if issues arise during travel.
1. Adoptive families may not ask for special travel arrangements (i.e., hotel, flights, etc.), extra visits with their child or any services that may be considered preferential by other clients.
2. Applicants will sign a second memo of understanding at travel.
All post-adoption reports and support will be provided by the agency that completed the original adoption home study. At this stage the adoptive parents file will only be accessible to the Post-Adoption Coordinator, Adoption Paperwork Coordinator, Vice President of Adoption and the accounting department.