Data Retention Policy
Last Updated: July 2026
At Americans 4 Equality, we prioritize the privacy, security, and responsible stewardship of all personal data entrusted to us. This Data Retention Policy explains what data we collect, how long we keep it, how we protect it, and how we dispose of it.
As a grant-funded nonprofit, we maintain certain records to meet transparency and compliance requirements with local, state, and federal partners.
Also see: Privacy Policy| SMS Communications Policy | Terms of Use
1. Systems Covered by This Policy
This policy applies to data collected or stored through the following platforms and systems:
● Website and Online Forms (e.g., program sign-ups, contact submissions)
● Student Enrollment Systems
● Learning Management System (LMS) — progress tracking, assignments, credentials
● Customer Relationship Management (CRM) platform — outreach, volunteer and donor engagement
● SMS and email communication platforms
● Staff and contractor personnel records
2. Data We Collect and Retain
We collect only the data necessary to operate and improve our programs. This includes:
● Student and participant information (enrollment status, coursework, assessments, attendance, outcomes)
● Volunteer and mentor data
● Donor and partner contact and contribution history
● Staff and contractor records, including background check results
● Operational records (feedback surveys, grant compliance data)
● SMS and email opt-in records
3. Retention Periods
Unless otherwise required by law or an active grant mandate, we retain data as follows:
● Student / Participant Records (LMS, enrollment) — Retained for 2 years after last participation. May be extended by grant mandate.
● Volunteer & Mentor Records — Retained for 2 years after last engagement.
● Donor & Partner Data (CRM) — Retained for 2–7 years, in line with nonprofit audit requirements.
● Website Form Submissions — Retained for 2 years. Purged or anonymized unless needed for programmatic analysis.
● Staff & Contractor Personnel Records — Retained for 7 years after separation. Includes background check records.
● Background Check Records — Retained for 7 years after separation, per WA state employment law guidance.
● SMS Opt-In Records — Retained for the duration of program participation plus 2 years. Required for compliance documentation.
● Grant Compliance Records — Retained as required by the funder. Minimum 5–7 years typical.
● Minor Participant Records (ages 13–17) — Retained until age 18 or 2 years after last participation, whichever is later. Stored separately with additional access restrictions.
4. Security Measures
All records — particularly those related to students and minors — are protected using encryption in transit (HTTPS/TLS) and at rest. Access is role-based and logged for security oversight. Systems including the LMS, CRM, and enrollment portals are configured to meet or exceed current security standards.
Records pertaining to participants under the age of 18 are stored separately from general participant records and are subject to additional access restrictions. Only staff members with a direct program role may access these records.
5. Sharing of Data
We do not sell or trade any personal data.
As a condition of public and private grant funding, we may share records with authorized state and federal agencies, solely for program evaluation, compliance monitoring, reporting, and audit purposes. Any such disclosures are:
● Governed by strict confidentiality agreements
● Logged and reviewed for proper authorization
● Limited to the minimum data necessary
6. Data Disposal
When the applicable retention period ends:
● Digital data is securely erased using certified tools that meet NIST SP 800-88 standards.
● Physical records are destroyed through confidential cross-cut shredding.
Disposal is documented in our internal records log for audit purposes.
7. Exceptions
Retention may be extended when necessary to:
● Comply with a legal obligation or court order
● Fulfill active audit or investigative requirements
● Satisfy grant-related reporting mandates
● Respond to a pending privacy rights request
8. Your Rights
Depending on your location, you have the following rights regarding your personal data:
● Right to Access — request a copy of the personal data we hold about you.
● Right to Correction — request correction of inaccurate or incomplete information.
● Right to Deletion — request deletion of your data, subject to our legal retention obligations.
● Right to Opt Out of Communications — opt out of email or SMS at any time by replying STOP or using the unsubscribe link.
● Right to Inquire — ask how your personal data is used or shared.
Washington and Oregon Residents: If you are a resident of Washington or Oregon, you have additional rights under the Washington Privacy Act and the Oregon Consumer Privacy Act, including the right to know what personal data is collected, the right to correct or delete that data, and the right to opt out of targeted advertising. We will respond to verified requests within 45 days.
How to Submit a Request: Contact us at support@americans4equality.org or call 1 (800) 916-0368. We will acknowledge your request within 5 business days and fulfill it within 30 days, or notify you if an extension is needed.
9. Policy Review
This policy is reviewed annually, or whenever there are significant changes to our data systems, legal requirements, or operational practices. Material changes will be communicated to current participants and subscribers at least 14 days before taking effect.
Contact Us
Americans 4 Equality | The MLK Gandhi Empowerment Initiative
Address: 3120 139th Ave. SE, Ste. 500, Bellevue, WA 98005
Email: support@americans4equality.org
Phone: 1 (800) 916-0368
Website: www.americans4equality.org
Americans 4 Equality is a registered 501(c)(3) nonprofit organization. EIN: 85-2365649.