Policies > Record Access Policy

1. Purpose

Shaome Cooperative, Inc. (“Shaome”) is committed to transparency, accountability, and responsible stewardship of information. This Record Access Policy establishes clear guidelines for who may access organizational records, under what conditions, and how access is granted, while protecting sensitive information related to students, families, partners, and community members.

2. Scope

This policy applies to all records created, received, or maintained by Shaome, including:

  • Governance and Board records 
  • Financial and grant-related documents 
  • Program records (GROW, Food Forest Classrooms, Shaome Skool) 
  • Participant and partner information 
  • Communications and digital records 

This policy applies to:

  • Board members 
  • Employees 
  • Independent contractors (1099) 
  • Volunteers 
  • External stakeholders and the public 

3. Guiding Principles

Shaome’s approach to record access is guided by:

  • Transparency – Providing appropriate access to organizational information 
  • Privacy – Protecting personal and sensitive data 
  • Equity – Ensuring fair and consistent access practices 
  • Accountability – Meeting legal, ethical, and grant compliance standards 

4. Categories of Record Access

A. Public Access Records

The following records may be made available upon request or proactively shared:

  • IRS Form 990 and related filings 
  • Mission, program descriptions, and impact summaries 
  • Annual reports and high-level financial summaries 
  • General information about GROW and Food Forest Classroom programs 

B. Internal Access Records

Accessible to Board, leadership, and authorized personnel:

  • Detailed financial records and budgets 
  • Grant applications, agreements, and reports 
  • Contracts and partnership agreements 
  • Program data and operational plans 

Access is granted based on role and responsibility.

C. Restricted and Confidential Records

Access is limited to authorized individuals only:

  • Student, participant, and family data (GROW program) 
  • Personal identifiable information (PII) 
  • Sensitive partner or donor information 
  • Personnel records 
  • Legal, compliance, or investigation-related documents 

Special care is taken to protect data collected through:

  • School partnerships 
  • Food Forest Classroom sites 
  • Community-based programming 

5. Record Access Procedures

Internal Requests

  • Requests should be directed to the President/CEO or designated leadership 
  • Access is granted based on relevance to role and responsibilities 
  • Sensitive records require approval from leadership or the Board 

External Requests (Public or Partners)

  • Requests must be submitted in writing (email or formal request) 
  • Shaome will respond within a reasonable timeframe 
  • Only appropriate, non-confidential records will be shared 

Individuals seeking access to Shaome Cooperative records may submit a request in writing by emailing ethics@shaome.com. Requests should include the specific records being requested and the purpose of the request, if applicable. Shaome will acknowledge receipt of the request within 5 business days and will respond with a determination or provide the requested records within 30–45 calendar days, in accordance with this policy and while protecting confidential and restricted information. 

6. Protection of Sensitive Information

Shaome prioritizes the protection of:

  • Student and youth data from GROW programming 
  • Family and household information 
  • Community participant data 
  • Donor and partner records 

Safeguards include:

  • Restricted access permissions 
  • Secure storage (physical and digital) 
  • Data minimization practices 
  • Compliance with applicable privacy standards 

7. Grant Compliance

Shaome will provide access to records as required by grant agreements, including:

  • Financial documentation 
  • Program performance data 
  • Monitoring and evaluation reports 

All disclosures will balance funder requirements with participant privacy protections.

8. Limitations on Access

Shaome reserves the right to deny or limit access to records when:

  • Disclosure would violate privacy laws or agreements 
  • Information is confidential or legally protected 
  • The request is overly broad or burdensome 
  • The request does not align with organizational policies 

9. Record Use and Distribution

Individuals granted access to records must:

  • Use information only for authorized purposes 
  • Not share or distribute records without approval 
  • Protect confidentiality at all times 

Misuse of records may result in disciplinary action.

10. Oversight and Responsibility

  • The President/CEO is responsible for implementing this policy 
  • The Board of Directors provides oversight 
  • All personnel and partners must comply with this policy 

11. Policy Review

This policy will be reviewed periodically and updated as needed to ensure alignment with:

  • Legal requirements 
  • Grant obligations 
  • Organizational growth 

12. Board Adoption

This Record Access Policy was adopted by the Board of Directors of Shaome Cooperative, Inc. on: May 3, 2026.

If you have any questions or suggestions about our Record Access Policy, do not hesitate to contact us at ethics@shaome.com.