Consent is the mechanism this policy relies on most heavily, because so much of what the Academy does turns on a single question: is it acceptable to make this specific, identifiable piece of information about a real person visible outside the small circle of staff running the program? Where the answer touches a vulnerable beneficiary, a donor's public identity, or a partner organization's public association with the Academy, we do not infer consent, assume it, or treat silence as agreement. We ask.
9.1 What counts as valid consent
To be valid under the NDPA, consent must be:
- Freely given — never a condition of receiving program benefits, a donation being accepted, or a job placement going ahead.
- Specific — covering a stated purpose (e.g., “your name and photo may appear on the Academy's Impact page”), not a blanket “we may use your information.”
- Informed — given after the person understands what will be shared, where, and for how long.
- Unambiguous, by a clear affirmative act — a signature, a ticked box, or an equivalent opt-in. Pre-ticked boxes, inactivity, or “unless you object” framing do not count.
- Freely withdrawable — at any time, as easily as it was given, without needing to justify the decision and without penalty (see Section 9.7).
9.2 Beneficiary consent — public visibility
Every beneficiary record carries a single, explicit consent flag governing public visibility, and it defaults to No. Nothing about a beneficiary — name, photo, story, or any other identifying detail — may appear in any donor-facing or public context unless that flag has been switched to Yes, and it is only switched to Yes after a signed consent form is on file (Appendix A). Internally, staff can still see full names and details in order to run the program; the gate applies to anything leaving that internal, staff-only environment.
Where a beneficiary is a minor (see Section 16), the consent form must be signed by a parent or legal guardian, and the Academy additionally seeks the young person's own age-appropriate assent wherever practical — a minor's discomfort should stop a public feature even where a guardian has formally consented.
Even with consent on file, public and donor-facing views default to aggregate and anonymized reporting — counts, rates, and cohort-level outcomes — rather than individual profiles, and any breakdown small enough to identify a specific person (for example, “1 of 2 beneficiaries in this cohort was placed”) is suppressed regardless of consent status, because a small number can identify someone even without using their name.
9.3 Donor consent — public recognition
A donor's gift is used to run the program and is reflected, in aggregate, in the Academy's transparency reporting (total raised, fund balances, what a fund paid for) without needing individual consent — that is core to how the Academy demonstrates traceability to its donor base as a whole. Naming an individual donor publicly is different and requires its own opt-in consent (Appendix B), separate from the act of giving. Anonymous donors are, by definition, treated as having declined; the Academy never publishes a donor's name by default or because no objection was raised.
9.4 Partner organization consent — public naming
A company or organization that hosts interns, hires graduates, or partners with the Academy is not named or shown publicly (logo, name, or “partner” designation) unless it has separately agreed to that (Appendix D). Employer consent is treated as genuinely optional: some organizations are glad to be named, others prefer not to advertise where their hires or interns come from, and the Academy respects either choice without treating it as a condition of the relationship.
9.5 Photo, story, and media consent
Beneficiary photos and personal stories are the highest-privacy-risk category the Academy handles publicly, because they combine identifying imagery with a personal narrative. A photo or story is used only where a specific media consent form is signed (Appendix C, which can be combined with Appendix A), separate from the general public-visibility flag described in Section 9.2 wherever the two are requested at different times. If no beneficiary has current, valid media consent on file, the relevant public page shows nothing, or an anonymized composite — never a fallback to non-consented material.
9.6 Staff, program staff, finance staff, and mentor/volunteer data
Data about people who work or volunteer for the Academy is processed on the basis of the working or volunteer relationship itself (a contractual or comparable basis), not general consent — an employee cannot “opt out” of having an account needed to do their job. Where the Academy wants to use a staff member's or volunteer's name or photo publicly (e.g., a “meet our mentors” page), that is a separate, genuine consent request, handled the same way as donor or partner recognition consent.
9.7 Withdrawing consent
Anyone who has given consent under this policy — a beneficiary, a guardian, a donor, or a partner organization — may withdraw it at any time by contacting hello@eifeneighth.org, or by asking any staff member directly. Withdrawal takes effect as soon as practicable and, at minimum:
- Any public page is updated to remove the identifying content within a reasonable operational window (target: within 5 business days of the request).
- The internal consent flag is reset to No/withheld, so future publications do not draw on the withdrawn consent.
- Withdrawal does not affect the lawfulness of anything already done in reliance on the consent before it was withdrawn, and does not require the Academy to un-happen a past donation, placement, or program outcome — it only stops future or continuing public use of the specific data covered by the withdrawn consent.