6605 - CROWDFUNDING

West Clermont Local School District

Administrative Guidelines

6605 - CROWDFUNDING

The following procedures must be complied with for all crowdfunding campaigns that are conducted or overseen by Board of Education employees for activities that relate to or are undertaken as a part of their job assignments. These procedures do not apply to crowdfunding campaigns that a staff member may pursue for non-District related activities, in which case the employee’s affiliation with the District may not be referenced and District resources may not be used. Staff members are prohibited from using the District’s or School’s name or any identifying features unless the staff member fully complies with the procedures outlined below.

Crowdfunding Platform Approval

The Superintendent shall pre-approve any crowdfunding website or service that a staff member intends to use for a District-affiliated crowdfunding campaign. Such websites must contain terms and conditions that are acceptable to the Board and consistent with Board policy and applicable laws and regulations. In determining whether to approve a specific crowdfunding service, the Superintendent shall take into consideration whether the website specializes in or has special expertise or experience in managing crowdfunding campaigns involving educational institutions. The Superintendent should also consider the amount of fees charged by the service to host/run the crowdfunding campaign, including any penalties associated with the failure of the campaign to reach its established target. For services that have 501(c)(3) designation, the underlying organization must affirm that it files all appropriate reports, including required registrations, with applicable governmental entities in states where donors reside. Staff members may only use websites/services that send the donated funds and/or purchased items directly to the District/School, and not the staff member.

Applications & Pre-Approval of Content

Prior to beginning a campaign and making the initial posting of the project on an approved crowdfunding site, the staff member must submit and obtain approval of an application to the Principal that includes the following information:

	A	A budget for the project that the campaign will be raising the funds or supplies and equipment for, and a description of how the project will be administered. If salaries are included, applicable fringe benefits must also be listed.

	B.	A copy of any narratives that will be submitted as testimonials or in order to solicit the funds on the website along with any photos that the staff member wants to use on the crowdfunding site. Postings that describe the purpose and rationale for conducting the crowdfunding campaign may not negatively reflect upon the District, its programs and services, or its staff and students. When describing the purpose of the crowdfunding project, staff members are prohibited from identifying specific students and/or their areas of disability or need. Additionally, postings should in no way state or imply that the funds and/or equipment/supplies received through the crowdfunding campaign are necessary in order for students to be appropriately served and educated. Any photos and any information contained in the narratives must protect student privacy and comply with FERPA.

		Postings may not include identifiable student images; staff should limit pictures to empty classrooms, the staff member, and/or photos of students when the students are not identifiable (e.g., the back of their heads or hands).

	C.	A copy of the biographical information or personal profile that will be utilized by the staff member on the crowdfunding site.

	D.	Confirmation that the funds raised and/or the items purchased by the crowdfunding site will go directly from the crowdfunding site to the Principal of the school that will be benefitted by the funds/items.


	E.	A description of any rewards, perks, or thank you gifts that will be provided to donors, including the cost and source of the reward, perk or thank you gift.

	F..	If feasible, the staff member shall include in the posting a link to this Board policy/guideline.

The Principal will review the application along with the text that will be utilized in any crowdfunding materials to verify the proposed project and posting (1) will not create any legal liabilities, (2) complies with Board policy and guidelines, and (3) does not violate State and Federal laws and regulations. The Building Principal should pay particular attention to verify the posting does not infringe on student privacy rights and intellectual property laws.

If a Principal identifies an issue that may have legal implications, he/she is required to notify the Superintendent so that the District’s legal counsel may be consulted prior to the Building Principal rendering a decision on the proposal or posting.

The Superintendent shall have final decision-making authority on granting permission for a crowdfunding proposal or posting.

Once the project and its materials are approved, the posting may be submitted to the crowdfunding site and the campaign commenced.

Unless required by the Fair Labor Standards Act, staff members are not entitled to additional compensation for their work on crowdfunding campaigns.

Campaigns will be limited in duration, as set forth in the application.

When the project is approved, the staff member/sponsor will provide the Superintendent with any information needed for the District to receive donated funds directly from the crowdfunding site. The staff member is responsible for verifying that the crowdfunding site is a charitable organization (i.e., a 501(c)(3) entity) so that contributions to it are tax-deductible to the donors. If the entity selected is not a 501(c)(3) organization, the staff member must include in the posting a clear statement that donations to the fundraising project are not guaranteed to be tax-deductible and that donors should take individual action, including consulting with a tax professional, to determine their tax obligations and/or consequences of their donation. Under no circumstances will the District issue documentation to donors to the crowdfunding site concerning the tax implications of any donations to the site.

The staff member must keep the Principal informed of the status of the campaign as it progresses and at its conclusion.

The staff member is responsible for then making sure any awards, and/or appropriate recognition are sent to the appropriate donors.

Once the funds or supplies/equipment purchased by the crowdfunding site with the proceeds of the campaign are received, they will be made available to the staff member for the express purpose of fulfilling the stated purpose of the project. The staff member, in conjunction with the Principal, is responsible for making sure any funds received are used for the express purpose for which they were raised; the employee must submit to the Principal documentation of any expenditures of the funds, including any purchases made with those funds. Such documentation must be submitted within seven (7) to ten (10) days of the expenditure. All funds raised and materials donated are considered the property of the District and shall remain in the District in the event the staff member who ran the crowdfunding campaign terminates his/her employment with the District.

The staff member must submit a final report on the project to the Principal and Superintendent. Failure to publish a final report will jeopardize the employee’s ability to engage in crowdfunding in the future. A copy of the report may be sent to the donors via email and the results of the campaign on the crowdfunding site may be posted if approved by the Principal.

A staff member who violates this policy/guideline is subject to disciplinary action.

The preceding guidelines also apply to parents, District-affiliated organizations (e.g., PTA/PTO, Athletic/Band Booster Groups) and/or students who wish to raise funds for a specific classroom, school, or school activity through a crowdfunding campaign.