North County Literacy Foundation ("NCLF," "Foundation," "we," "our") is committed to protecting the privacy and confidentiality of all individuals who interact with our organization, including adult learners, family literacy participants, volunteer tutors, donors, website visitors, and community partners. This Privacy Policy explains what personal information we collect, how we use it, with whom we share it, how long we retain it, and what rights you have regarding your data.
1. Information We Collect
We collect personal information through several channels in the course of delivering our educational programs and operating our organization:
Learner Intake & Enrollment Data
When an individual enrolls in an NCLF program, we collect: full legal name, date of birth, mailing address, phone number, email address, preferred language, highest level of formal education completed, employment status, household income range (for aggregate demographic reporting only; not used for eligibility determination), country of origin, and time residing in the United States. For Family Literacy participants, we also collect the names and ages of participating children.
Assessment & Educational Records
We maintain records of all standardized assessment results (TABE 11/12 scale scores, CASAS Life and Work scores, GED/HiSET practice and official test scores), individualized learning plans, session attendance logs, formative progress notes, and program completion or withdrawal status. These records constitute educational records and are afforded FERPA-aligned confidentiality protections as described in Section 5.
Volunteer Application Data
Volunteer applicants provide: name, contact information, educational background, professional experience, availability, areas of interest, and emergency contact information. Volunteers who proceed to service also undergo live-scan fingerprint background checks processed through the California Department of Justice; we receive only the clearance determination (approved or denied), not underlying criminal history records.
Donor & Financial Transaction Data
When you make a financial contribution, we collect your name, mailing address, email address, donation amount, and payment method. Credit card and bank account numbers are processed by our PCI-DSS-compliant payment processor and are never stored on NCLF systems. We retain donor contact and transaction history for tax receipt issuance, acknowledgment correspondence, and development relationship management.
Website & Digital Interaction Data
Our website uses minimal analytics to understand aggregate visitor behavior (pages visited, time on site, referral source). We do not use advertising trackers, retargeting pixels, or third-party data brokers. Form submissions through our website (contact forms, volunteer interest forms) are transmitted via encrypted HTTPS connections and stored in our secure case management system.
2. How We Use Your Information
Personal information collected by NCLF is used for the following purposes:
- Program Delivery: To place learners in appropriate instructional tracks, develop individualized learning plans, monitor progress, and facilitate tutor-learner matching.
- Outcome Reporting: To calculate and report aggregate program outcomes (NRS level completions, GED credentials earned, employment gains) to our federal and state funders as required under WIOA Title II performance accountability. All funder-facing reports use de-identified, aggregate data unless individual-level reporting is mandated by the grant agreement, in which case data is transmitted through secure, encrypted systems designated by the funding agency.
- Communication: To contact learners about session schedules, program updates, and community resources; to communicate with volunteers about training, scheduling, and recognition; and to acknowledge and steward donor relationships.
- Organizational Improvement: To evaluate program effectiveness, inform curriculum development, guide strategic planning, and support grant applications with aggregate demographic and outcome data.
3. Legal Basis for Processing
We process personal information on the following legal bases: (a) Consent: Learners provide informed written consent during the intake process for the collection and use of their personal and educational data for program purposes. Consent may be withdrawn at any time, though withdrawal may affect program participation. (b) Legitimate Interest: We have a legitimate organizational interest in maintaining donor relationships, managing volunteer operations, and analyzing aggregate program data to improve services. (c) Legal Obligation: We are required by federal and state grant agreements to collect and report certain learner demographic and outcome data as a condition of funding.
4. Data Sharing
North County Literacy Foundation does not sell, rent, trade, or commercially distribute personal information to any third party under any circumstances. We share data only in the following limited contexts:
- Federal & State Funders: Aggregate and, where contractually required, individual-level learner data is reported to the U.S. Department of Education (via the NRS web portal) and the California Department of Education's Adult Education Office as mandated by WIOA Title II performance accountability requirements.
- Service Providers: We engage a limited number of service providers (payment processors, email platforms, database hosting) who process data on our behalf under written data processing agreements that require them to protect data at standards equivalent to our own.
- Partner Organizations: When a learner consents to referral services (e.g., referral to MiraCosta College, San Diego Workforce Partnership), we share only the information necessary to facilitate the referral, with the learner's prior written consent.
- Legal Requirements: We may disclose information when required by law, court order, or regulatory investigation.
5. Learner Data Confidentiality (FERPA-Aligned Protections)
Although NCLF is not a formal educational institution subject to the Family Educational Rights and Privacy Act (FERPA), we voluntarily adopt FERPA-aligned confidentiality protections for all learner educational records as a matter of organizational policy and professional ethics. This means that: (a) Learner educational records are accessible only to NCLF staff and volunteers with a legitimate educational need to know. (b) Learner assessment scores, progress notes, and attendance records are never shared with employers, landlords, immigration authorities, law enforcement, family members, or any other party without the learner's explicit written consent, except as required by law. (c) Learners have the right to inspect their own educational records, request corrections, and receive copies upon written request. (d) All NCLF staff and volunteers receive annual training on learner confidentiality obligations.
6. Children’s Privacy
NCLF serves adults aged 18 and older. Children ages zero through eight participate in our Family Literacy program under the supervision of their parent or legal guardian and our early childhood education staff. We collect only the child's first name and age for program coordination purposes. We do not collect email addresses, photographs, or other personally identifiable information from children. Our practices comply with the Children's Online Privacy Protection Act (COPPA), and we do not knowingly collect personal information from children under 13 through our website or digital platforms.
7. Data Retention
We retain personal information for the following periods, after which it is securely destroyed:
- Learner Educational Records: Five (5) years following the learner's last date of program participation, as required by the California Department of Education's adult education record retention schedule.
- Financial & Tax Records: Seven (7) years following the fiscal year in which the transaction occurred, in compliance with IRS record retention requirements for 501(c)(3) organizations.
- Volunteer Records: Three (3) years following the volunteer's last date of active service.
- Website Form Submissions: One (1) year following submission unless the inquiry results in program enrollment or volunteer onboarding, in which case the relevant retention schedule applies.
- Background Check Determinations: Retained only for the duration of the volunteer's active service; destroyed within 30 days of service conclusion.
8. Your Rights Under the California Consumer Privacy Act (CCPA)
If you are a California resident, you have the following rights under the CCPA and its amendments (CPRA):
- Right to Know: You may request a description of the categories of personal information we have collected about you, the sources from which it was collected, the business purposes for collection, and the categories of third parties with whom it has been shared.
- Right to Access: You may request a copy of the specific personal information we hold about you.
- Right to Delete: You may request that we delete your personal information, subject to certain exceptions (e.g., information required for legal compliance or completion of a transaction).
- Right to Opt-Out of Sale: NCLF does not sell personal information. This right is included for transparency; there is no sale to opt out of.
- Right to Non-Discrimination: We will not discriminate against you for exercising any CCPA rights. Exercising your rights will not affect your eligibility for NCLF programs or services.
To submit a CCPA rights request, contact our Privacy Officer at privacy@northcountyliteracyfoundation.org or call (760) 555-0147. We will verify your identity and respond within 45 calendar days.
9. Rights for European Economic Area (EEA) Residents
For individuals who are residents of the European Economic Area and whose personal data may be processed by NCLF (for example, international volunteers or visitors), you have additional rights under the General Data Protection Regulation (GDPR), including the right to access, rectification, erasure, restriction of processing, data portability, and the right to lodge a complaint with your local supervisory authority. To exercise these rights, contact our Privacy Officer using the information in Section 12.
10. Cookies & Tracking Technologies
Our website uses only essential first-party cookies required for basic site functionality (session management, form submission state). We use a privacy-respecting analytics solution that does not use cookies, does not track individual users across sessions, and does not share data with third parties. We do not use advertising cookies, social media tracking pixels, or third-party analytics platforms that build user profiles.
11. Security Measures
We implement industry-standard technical and organizational security measures to protect personal information against unauthorized access, alteration, disclosure, or destruction. These measures include: encrypted data transmission (TLS 1.2 or higher) for all web communications; encrypted storage for sensitive data at rest; role-based access controls limiting data access to authorized personnel; multi-factor authentication for staff access to data systems; annual third-party security assessments; and mandatory annual data privacy and security training for all staff and volunteers. While no system is completely immune to security threats, we continuously monitor and improve our security posture.
12. Contact Our Privacy Officer
For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:
Privacy Officer
North County Literacy Foundation
1847 Oceanside Boulevard, Suite 305
Oceanside, CA 92054
Phone: (760) 555-0147
Email: privacy@northcountyliteracyfoundation.org
This policy is reviewed and updated annually by the Executive Director in consultation with legal counsel. The effective date at the top of this page reflects the most recent substantive revision.