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PURPOSE
The purpose of this policy is for South Texas Public Broadcasting System (“STPBS”) to comply with Section 396(k)(12) of the Communications Act of 1934, as amended, (the “Act”) that set forth the requirements for control of donor lists and donor information that are applicable to public broadcasting stations, and codified at 47 U.S.C. Section 396(k)(12). Section 396(k)(12) prohibits the Corporation for Public Broadcasting (“CPB”) from distributing its federally appropriated funds to public broadcasting entities that rent contributor or donor names (or other personally identifiable information) to or from, or exchange such names or information with, any Federal, State, or local candidate, political party, or political committee.

POLICY & PROCEDURES
South Texas Public Broadcasting System will comply with the laws and regulations of the Internal Revenue Service, Corporation for Public Broadcasting, and with all other applicable Federal law or regulations governing political activity and lobbying.
South Texas Public Broadcasting System will not sell, rent, lease, loan, trade, give, donate, transfer or exchange its membership or donor names to, with or from any candidate for Federal, State or local office, political committees, or political parties for any purpose whatsoever, except as otherwise required by law or judicial process.

South Texas Public Broadcasting System will maintain the confidentiality of the information contained in its donor lists in compliance with all State and Federal laws, and comply with all applicable Federal and State laws and regulations regarding donor privacy and data security, as required by the CPB General Eligibility Requirements, and will not release any information contained therein unless it is released in accordance with this policy or as required by law or judicial process.

For purposes of this policy, South Texas Public Broadcasting System considers all third parties to be “non-affiliated” with the following exceptions: third parties acting on behalf of and at the request of STPBS for the purposes of the its’: fundraising development, attorneys acting behalf of STPBS, and accountants acting on behalf of STPBS.