Non-Profit

Only when the program, the tool and the contract line up. If the notes come from a HIPAA covered program, the AI vendor generally needs a business associate agreement before it handles that information, and the tool must be set up under organization accounts with the agency's own settings. A free consumer AI account does not meet that bar.

No AI tool is HIPAA compliant on its own. Compliance depends on how the organization uses it: a business associate agreement covering the specific product and account type, access controls, prompts limited to the minimum necessary, and the tool's place in the Security Rule risk analysis. A vendor's consumer version may not be covered even when its business version is.

Not on the phone as a whole. A nonprofit controls its own accounts and data, not a volunteer's device. It can stop volunteers from using their organization login to sign up for AI tools, require Intune app protection before organization email and files open on the phone, and block copying organization data into personal apps. What volunteers do with personal accounts stays outside the organization's reach.

It can. Civil Code section 1798.81 requires a business to shred, erase or otherwise make unreadable customer records containing personal information when they are no longer kept, and section 1798.80 defines business to include groups not organized for profit. Whether a donor counts as a customer is a question for counsel, so many nonprofits dispose of all personal information the same way.

California's statute does not define it. In its 2016 Data Breach Report, the California Attorney General said the CIS Critical Security Controls define a minimum level of information security and that failing to implement the applicable controls constitutes a lack of reasonable security. The report is guidance rather than law. The CIS IG1 safeguards in this article come from the current version of those controls.

Card testing is when criminals run small transactions through an online form to learn which stolen card numbers still work. Donation pages are attractive targets because any amount is accepted. The charity can absorb declines, refunds, chargebacks and processor fees. Bot protection, minimum gift amounts, attempt limits and alerts on bursts of small transactions all make it harder.

Not with a personal or free account. That sends client information to a company the agency has no agreement with, under consumer terms the agency cannot control. An agency that wants AI help with notes can approve a business tool under organization accounts, decide which programs' data may go into it, and keep survivor, substance use and child welfare records out entirely.

Microsoft says the policies are not automatically disabled or deleted when the Entra ID P1 licenses behind them expire. Administrators can still view or delete them but can no longer update them. That leaves a tenant with rules it cannot adjust as staff, devices and threats change, so plan the license change before renewal rather than after.

In the Microsoft 365 admin center, open Active users, select the account and choose Convert to shared mailbox on the Mail tab. The mailbox needs a license to convert, and once it is under 50 GB you can remove that license. Microsoft notes the original username and password keep working after conversion, so block sign-in and keep the account, because it anchors the shared mailbox.

Under 2 CFR 200.414(f), a recipient or subrecipient without a current negotiated indirect cost rate may elect a de minimis rate of up to 15 percent of modified total direct costs. The rate needs no documentation to justify it and can be used indefinitely, but costs must be charged consistently as either direct or indirect, never both.

CISA's Cross-Sector Cybersecurity Performance Goals call for a defined and enforced process applied to all departing employees by the day of their departure. For a nonprofit, that means disabling email and system accounts, collecting devices, and changing any shared passwords the person knew, ideally on their last day.

Yes. Budget the price you pay today and note what the same licenses would cost at full price, so the board can see the exposure if eligibility or program terms change at renewal. Donated and discounted licenses still need a renewal date, an owner and a line in the recurring budget.

Yes, once staff or volunteers use AI with donor, client or grant information. No law requires a nonprofit AI policy by name. A one-page policy approved by the executive director or board should name the approved tool, list data that never goes into AI, require organization accounts with multifactor authentication and require review before output reaches donors, clients or funders.

Usually not. The CCPA's definition of a covered business centers on entities organized or operated for the profit or financial benefit of their owners, so most charities fall outside it, though separate tests can reach some entities tied to a covered business. California's reasonable security statute, Civil Code section 1798.81.5, still applies to nonprofits, because the related definition of business includes organizations not run for profit.

Usually not on those facts alone. California's breach statute, Civil Code section 1798.82, covers a name combined with specific elements such as a Social Security number, a government ID number, a financial account or card number with its access code, medical information or health insurance information. Names and gift amounts are not on that list. Donor promises and grant terms may still call for disclosure, so check with counsel.

The admin consent workflow is a Microsoft Entra ID setting that lets a user who is blocked from approving an app send a request to designated reviewers, who approve or deny it. Volunteers get a clear path to request a tool, and an administrator reviews every new app before it can reach organization data.

Yes. Microsoft 365 and Google Workspace both list third-party apps users have connected to their work accounts. Add a search of card and reimbursement records for AI subscriptions, browser extension lists from managed devices, web filter logs if you have them, and a short no-blame staff survey. Together these cover sign-ins, spending, devices and the tools only people can tell you about.

No, but it is discounted. As of October 2026, OpenAI for Nonprofits lists ChatGPT Business standard seats at $8 per user per month billed annually, or $10 billed monthly, and offers larger nonprofits up to 75 percent off ChatGPT Enterprise. The free consumer plan lacks admin controls, and OpenAI may train on its content unless the user opts out.

It can be. ChatGPT counts as shadow AI when staff use it for work without the organization's approval, for example on a personal account. The same tool on an organization account your nonprofit approved, with clear rules on what data goes in, is sanctioned use. What changes is oversight.

Yes. Microsoft's security defaults are available at no extra cost, including on the free tier of Microsoft Entra ID. When enabled, every user must register for multifactor authentication, administrators must use it at every sign-in, and older sign-in methods that cannot support MFA are blocked. Organizations with Entra ID P1 or P2 licenses typically use Conditional Access instead.

Yes. Microsoft offers up to 300 granted Business Basic licenses alongside discounted Business Premium at $5.50 per user per month. Both are Business family plans, and Microsoft caps an organization at 300 seats total across Business Basic, Standard and Premium, so the two counts share one limit. Organizations above 300 users move to enterprise plans.

Yes. Google includes Gemini in Workspace for Nonprofits at no cost for eligible organizations, Microsoft includes Copilot Chat in Microsoft 365 subscriptions, and OpenAI and Anthropic list discounted nonprofit pricing for their business plans. Eligibility usually requires verified 501(c)(3) status or the local equivalent. Prices and terms change, so confirm with the vendor before buying.

It should. AI assistants built into email, documents, donor databases and case management systems process the same records as a standalone chatbot. Treat each built-in feature as a tool on the approved list: an administrator turns it on deliberately, after checking how the vendor stores and uses the data, rather than letting it switch on by default.

Treat it as a prerecorded call. In February 2024 the FCC ruled that AI-generated voices are "artificial" under the Telephone Consumer Protection Act, so the same consent and calling rules apply. Those rules depend on the type of number and call, so talk to counsel before using an AI voice in a phone campaign.

It can help pay for it. Organizations approved for Microsoft's nonprofit programs can receive a $2,000 USD annual Azure Sponsorship grant, which applies to first-party Azure services but not to reserved instances, marketplace offers or support plans. The credit must be renewed each year and does not roll over, so price the workload before counting on it.

Check five things on the plan you will actually use: whether inputs are excluded from model training by default, how long prompts and files are kept and who can delete them, whether people sign in with organization accounts and multifactor authentication, whether public sharing links can be turned off, and which integrations and subprocessors receive your data. Record the plan name and the date you checked.

Often, yes. Under 2 CFR 200.453(c), computing devices may be charged as direct costs when they are essential and allocable to the performance of a federal award, even if they are not used solely for it. A device costing less than $10,000, or less than your lower capitalization level, is treated as a supply. Confirm the treatment with your program officer for each award.

A de-identified outcome table reports counts and rates by year or quarter, by county or a larger area, and by age band, with small groups combined or suppressed. It contains no names, street addresses, exact intake or exit dates, phone numbers, case numbers or free-text case notes. HIPAA's Safe Harbor list of 18 identifiers is a practical checklist for what to remove.

It depends on the account and on what you promised donors. Consumer chatbot accounts may let the provider train on what you enter, while business plans usually do not by default. A safer approach is to draft donor letters with placeholders in an approved business tool and merge real names and gift amounts inside your CRM.

Move the full giving history and acknowledgment records into the new system and confirm the totals match before you cancel the old one. Then ask the old vendor for written confirmation that your data has been deleted, delete the interim export files staff created during the move, and note the dates in your retention log.

IRS Publication 4221-PC says public charities must keep records as long as they may be needed for federal tax purposes, generally until the statute of limitations runs, typically three years after the return's due or filing date. Some records, such as the determination letter and board minutes, are kept permanently. A board-approved retention policy should set the specific periods for donor files.

Mostly, yes. In the CIS Controls, DNS filtering (Safeguard 9.2) is in Implementation Group 1, while URL filtering (9.3) and browser extension restrictions (9.4) are in IG2 and data loss prevention (3.13) is in IG3. Organization accounts with multifactor authentication, plus blocking unreviewed AI sites, cover most of a one-page policy. DLP adds control over what data reaches the approved tools.

Keep the documents behind each answer: a board-approved security policy and incident response plan, an MFA enrollment report covering every account, backup reports with the date of the last restore test, training completion records, a vendor list showing who holds client or donor data, and a device inventory showing encryption. Keep a dated copy of every questionnaire you submit and who signed it.

Yes, and it is usually the better answer when a control is not fully in place. State what is true today and the date the gap will close. Pass-through entities use these answers to set monitoring under 2 CFR 200.332(c), and monitors or single auditors may later ask for evidence. A yes the organization cannot document creates a problem at that point.

Only if it meets the definition. A health care provider is a covered entity when it transmits health information electronically in connection with a HIPAA standard transaction, such as billing a health plan. Nonprofit status does not matter. A program that never bills electronically may fall outside HIPAA, though state confidentiality laws, grant terms and funder contracts can still apply.

There is no single federal number. HHS's de-identification guidance says there is no universal minimum cell size and that the right threshold depends on who will receive the data and what they could know. A nonprofit should choose a minimum group size, write it down, combine or suppress smaller groups, and apply the same threshold to every report.

Your privacy policy needs to describe what you actually do with donor data. If an AI vendor will process donor information for you, check whether your language about sharing with third parties still holds, and update the policy before the new practice starts. Counsel can help with the wording for your situation.

No single federal rule sets seven years for most nonprofit records. IRS Publication 4221-PC ties retention to the statute of limitations, generally three years after the return is due or filed, and says employment tax records are kept at least four years after filing the fourth quarter for the year. Records such as the determination letter and board minutes are kept permanently.

Not for systems holding donor or client data. A shared login hides who did what, forces a password change every time someone leaves, and undermines multifactor authentication. Give each volunteer an individual account. For shared inboxes, use a shared mailbox with sign-in blocked, which people reach through their own accounts.

In Part IX, the Statement of Functional Expenses, which has a line for information technology. Each expense is split among program services, management and general, and fundraising, so technology that supports programs can be allocated to program services on a reasonable basis rather than reported entirely as administrative cost.

Not automatically. Part IX of Form 990 splits each expense among program services, management and general, and fundraising, so technology used to deliver programs can be reported in the program services column instead of entirely as administration. On federal awards, computing devices that are essential and allocable to a program may be charged as direct costs under 2 CFR 200.453(c).

De-identified data can no longer reasonably be linked to a specific person. NIST SP 800-188 defines de-identification as removing the association between identifying data and the data subject. HIPAA's Safe Harbor method, a useful benchmark even for nonprofits outside HIPAA, removes 18 identifier types, including names, detailed locations, dates other than the year, and case or account numbers.

In most countries, no. TechSoup says Microsoft on-premises products stopped being available to nonprofits as donations on April 4, 2022 and moved to discounted offers, with Windows Server donated only where Azure is not available. Discounted Windows Server 2025 licenses have been available through TechSoup since November 25, 2024, and most are listed without Software Assurance.

No. PCI DSS Requirement 3.3.1.2 prohibits storing card verification codes after a payment is authorized, even if encrypted, and the PCI Security Standards Council says merchants must make sure the codes are never stored post-authorization. Once a gift is processed, the code on a pledge card, phone note or event form should be destroyed.

Disable access immediately when a volunteer's departure is known, as CIS Safeguard 6.2 describes. For volunteers who simply stop coming, CIS Safeguard 5.3 calls for disabling dormant accounts after 45 days of inactivity. A monthly report of accounts with no recent sign-in, reviewed by each volunteer's staff sponsor, catches both cases.

No. Microsoft's guidance is to always block sign-in for the account behind a shared mailbox and keep it blocked. People open the shared mailbox through their own accounts, which means their own password and multifactor authentication apply and every action traces to a named person. If staff know a password for info@ or a similar address, that account needs cleanup.

Usually not. Microsoft says a shared mailbox can store up to 50 GB without a license of its own, though each person who opens it needs their own licensed Exchange Online mailbox. A license is needed to raise the limit to 100 GB, to expand the archive, or to place the mailbox on litigation hold. Removing licenses from shared mailboxes that do not need them often frees seats.

Look for a sudden burst of small gifts, a spike in declined transactions, many attempts from the same IP address or device, and gifts with mismatched names or billing details, often at odd hours. Agree in advance who can pause the form and who calls the payment processor, so your team can act within minutes.

The 2024 revisions apply to federal awards issued on or after October 1, 2024. Awards made before that date follow the rules written into their terms unless the agency amends them. Check each award's terms and any amendments, and ask your program officer when your budget year covers awards from both periods.

For awards under the 2024 Uniform Guidance revision, yes. 2 CFR 200.303 requires recipients and subrecipients to take reasonable cybersecurity and other measures to safeguard information, including protected personally identifiable information. The revised rules apply to federal awards issued on or after October 1, 2024. The rule does not list specific technologies, so agencies document their own reasonable measures.

The VAWA confidentiality provision covers personally identifying information however it is handled, and AI tools are no exception. The Office on Violence Against Women says covered grantees may not disclose, reveal or release such information, even if encrypted, and must make reasonable efforts to prevent inadvertent releases. Pasting survivor details into an outside AI tool raises exactly that risk.

Donors can check the California Attorney General's Registry of Charities and Fundraisers, whose public search tool shows a registrant's filings and status, and the IRS Tax Exempt Organization Search. The FTC also advises confirming the exact name of the organization, since some scammers use names that sound like real charities.

Often, for volunteers who only need Teams, SharePoint or shared files. A Microsoft Entra guest account lets a volunteer sign in with their own email address, keeps them separate from staff accounts, and can be set to expire on a schedule. A volunteer who needs to work in a shared mailbox needs a licensed Exchange Online mailbox instead.

Yes. Microsoft requires each person covered by an app protection policy to have a Microsoft Entra account and an Intune license, and Conditional Access requires Microsoft Entra ID P1. Microsoft 365 Business Premium includes both. Volunteers who work only from personal email accounts sit outside these controls.

It is safer if they do not. Personal consumer accounts may allow the vendor to train on content unless the user opts out, and the organization has no visibility or way to delete the data when a volunteer leaves. Give volunteers an organization account on the approved tool, with multifactor authentication, and disable it when their role ends.

Shadow AI is any AI tool used for work without the organization's approval or oversight. It includes chatbots on personal accounts, AI features switched on inside approved software, browser extensions, meeting notetakers and apps connected to a work account through a Microsoft or Google sign-in. Each one is a place organization data can go without anyone tracking it.

Cybersecurity Awareness Month runs every October. It is co-led by the Cybersecurity and Infrastructure Security Agency (CISA) and the National Cybersecurity Alliance. The 2026 theme is "Don't Make It Easy for Them," which promotes strong passwords, multifactor authentication, keeping devices updated and thinking twice before clicking.

Usually the one built into the platform the organization already runs. Nonprofits on Google Workspace for Nonprofits get Gemini at no cost, and Microsoft 365 subscriptions include Copilot Chat at no extra charge. Staying on the existing platform means sign-in, multifactor authentication, retention and admin controls are already in place, and staff and volunteers learn one tool instead of several.

No law assigns approval of a nonprofit AI policy to anyone. Many organizations take it to the board, or to a finance, audit or risk committee that reports to the board, because California directors must act with the care and reasonable inquiry of an ordinarily prudent person. Board approval, recorded in the minutes with an annual review date, documents that inquiry.

Act immediately. The FBI advises victims to contact their financial institution right away and request a recall of the funds, then file a complaint at ic3.gov regardless of the amount lost. Next, notify your IT provider so the compromised mailbox or account can be secured, and tell your insurance carrier.

Usually not. Zero trust network access is typically delivered as a cloud service with a client app on each device and a small software connector inside your network. Microsoft, for example, documents its private network connector as an agent installed on Windows Server that makes only outbound connections. Costs move from appliances to per-user licensing.