DATA USAGE POLICY

Data Governance, Privacy Protection & Responsible Information Use Framework

The Shaker Foundation for American Service Heroes is committed to maintaining the highest standards of responsible data governance, privacy protection, information security, and ethical data stewardship across all institutional operations, programs, digital platforms, and affiliated systems.

Data is recognized as a strategic institutional asset requiring strict governance, controlled access, and responsible lifecycle management.

This Data Usage Policy establishes a formal governance framework governing the collection, access, storage, processing, sharing, retention, and protection of data associated with the Foundation’s activities.

The Foundation maintains a zero-tolerance policy toward unauthorized access, misuse, manipulation, disclosure, or exploitation of protected information.

The Foundation governs all institutional data under the following binding principles:

3.1 Lawful and Authorized Use

Data may only be collected, accessed, or processed for legitimate institutional purposes under authorized governance procedures.

3.2 Data Minimization

Only data reasonably necessary for operational, compliance, reporting, security, or mission-related purposes shall be collected or retained.

3.3 Accuracy and Integrity

Data must remain accurate, complete, consistent, and protected from unauthorized modification.

3.4 Purpose Limitation

Data collected for one authorized institutional purpose shall not be repurposed for unrelated or unauthorized use.

3.5 Accountability and Traceability

All material access, modification, transfer, or deletion of protected data must be traceable and subject to audit review.

The Foundation may manage multiple categories of institutional data, including:

4.1 Operational Data

Administrative records, workflow systems, governance documentation, and internal communications.

4.2 Personal Information

Identity, contact, application, beneficiary, or participant information where operationally required.

4.3 Financial and Compliance Data

Transaction records, audit logs, reporting files, and compliance documentation.

4.4 Programmatic Data

Program performance metrics, eligibility records, service delivery data, and outcome reporting.

4.5 Digital Interaction Data

System logs, access records, platform activity, and cybersecurity monitoring data.

The Foundation collects and processes data only for legitimate institutional functions, including:

Unauthorized collection, scraping, duplication, or secondary use of data is strictly prohibited.

Access to protected data is governed by strict authorization protocols based on the principle of least privilege, meaning access is limited to the minimum level necessary for authorized responsibilities.

Controls include:

Unauthorized access attempts are treated as security and compliance violations.

The Foundation does not disclose protected institutional or personal data except where:

Any approved data sharing must satisfy:

Unauthorized disclosure is strictly prohibited.

Data shall be retained only for as long as necessary to satisfy legitimate operational, governance, audit, legal, or compliance requirements.

Upon expiration of retention requirements, data must be securely:

Disposal procedures must prevent reconstruction, unauthorized recovery, or continued access.

Any suspected data breach, unauthorized access, misuse, leakage, or compromise must be reported immediately through institutional escalation channels.

Incident response includes:

Failure to report known incidents may constitute a compliance violation.

Data governance is continuously monitored through:

All data usage activities are subject to institutional audit readiness requirements.

This Data Usage Policy is subject to continuous review and enhancement based on:

This ensures long-term institutional resilience and responsible digital governance.

The Shaker Foundation for American Service Heroes affirms that responsible data governance is fundamental to institutional trust, operational integrity, security, and public confidence.

This Data Usage Policy ensures that all data entrusted to the Foundation is managed under strict governance controls, ethical stewardship, and internationally aligned best practices.

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