This non-disclosure agreement applies to personnel in University Advancement and University Associated Organizations, a.k.a., “Advancement personnel,” as well as other University personnel who have a business need to access confidential, advancement-related information (“Confidential Information”) in the course of their work. Failure to abide by this agreement may result in disciplinary action under the policies of the University of Virginia and the Commonwealth of Virginia. This is a non-expiring agreement with an annual reaffirmation cycle intended to serve as a reminder of our roles and responsibilities around confidentiality and proper data handling.
For the purposes of this Agreement, “Confidential Information” shall consist of:
- Personally identifiable information, in any form, about faculty, employees, students, patients, donors and potential donors to the University of Virginia or the University Associated Organizations;
- Information about the University's internal planning;
- Information about giving or approach strategies;
- Methods of analyzing University needs and selecting potential donors;
- Personal health information, in compliance with HIPAA privacy rules;
- Student information, in compliance with FERPA privacy rules; and
- Data exempt from the public release provisions of the Virginia Freedom of Information Act.
The University owns, manages, maintains, and provides access to one central repository of fundraising and related-activity data collected by the University and University Associated Organizations. The central advancement data repository is subject to University data policies. The designated University official (or Data Steward) with ultimate responsibility for Advancement data is the AVP for Advancement Operations. For more information about data privacy, please read the UVA Advancement Privacy Statement.
In general, prospect or donor information obtained by Advancement personnel or other University personnel as a function of employment should not be shared outside of the normal course of business, and access to systems and records is limited to business-related circumstances. Systems, data, and other records are not to be accessed for casual browsing of donor information.
No University-owned data may be entered into any open source, large language model-enabled systems (including but not limited to tools like ChatGPT, Gemini, Anthropic Claud 3, Inflection Pi, xAI Grok, Meta Llama 2, Perplexity, and other applications enabled by these technologies) unless explicitly approved by the University of Virginia. This includes Advancement data. This also applies to all instances of Microsoft Copilot that are accessed from any login other than your UVA account. For more information, go to the AI Resource Center on the Advancement Hub.
There are certain circumstances in which non-employees may obtain permission to access certain information; non-employees must first read and sign a non-disclosure agreement and are not given access to the Advancement database of record. Anticipated ways in which information about the University of Virginia's advancement program, donors and prospects may be shared with non-employees of the University are as follows:
Personally identifiable information about faculty, employees, students, donors, and potential donors
Volunteers are sometimes provided with information regarding donors and prospects to assist them in their volunteer role. Such information may include lists of names, contact info (e.g., addresses and phone numbers), giving interests, gift club memberships and other relevant information including, but not limited to, those found in the "Volunteer Briefing.” This information may also be provided via University-approved volunteer management systems. Personal financial information (e.g., giving amounts, capacity ratings, wealth assessments) should not be provided to Volunteers. Volunteers must sign the Volunteer Non-disclosure Agreement. It is the responsibility of Advancement personnel to ensure that Volunteers who will have the privilege of using University data in any form sign the Volunteer Non-disclosure Agreement. Volunteers need only sign the Advancement Volunteer NDA once per year (regardless of how many schools or units they volunteer with). NDA completion is documented in the Advancement database of record. Please review the full policy on sharing data with Volunteers.
From time to time, the University will transmit data to third parties (usually private businesses or consultants) who provide essential services, such as: data cleansing; data analysis; and other software, tools or services that enhance the University’s ability to achieve advancement objectives. The University Advancement Technology Steering Committee shall evaluate new products and tools for the Advancement Community and make recommendations to the VP for University Advancement regarding such investments. In the event that a third party service is being considered by any school, program, unit or University Associated Organization that would result in the transmission of the University of Virginia’s advancement data, a request must be directed to the Senior AVP for Advancement Operations prior to the finalization of contracts that would commit said transmission of data to the third party. In these circumstances, contract language will be reviewed and edited to ensure non-disclosure, privacy and other data management issues meet the University’s standards.
Information about giving & approach strategies, methods of analyzing University needs, and selecting potential donors
Information about program structure, systems and strategies is often presented at professional conferences and shared among professional colleagues. This information would be general in nature, not specific to a particular donor, unless presented in case study form with a name change and data masking to protect the donor’s privacy.
Information about the University's internal planning would not be included in this general category and would in any event be available only to those involved in planning at the highest levels.
Descriptive information may be shared with volunteers to provide more complete understanding of their role within the "big picture" of the organization and to permit them to articulate informed answers to prospect or donor questions.
Data which is exempt from the public release provisions of the Virginia Freedom of Information Act (FOIA)
In the event that a request is made under the purview of FOIA, the recipient of the request shall not directly provide the data requested and should immediately contact the University’s FOIA Officer. Additional information regarding your responsibilities regarding FOIA requests can be found on the Office of the University Counsel's website.