Compliance Dashboard Guidance

Approved October 2020

Please do not download this document, since it will be regularly updated and we would like to ensure that you have access to the latest version. 

This document is not meant to be a comprehensive guide to all compliance issues, but rather to flag a number of key issues that you need to keep in mind when contributing to the DAUK website. Whenever in doubt, please contact an officer of DAUK.

Compliance Dashboard Points 

Encouraged or Yes! 

Caution – double-check or seek advice 

Prohibited or No!

General Policies 

• Ensure that your coverage of topics, language, and the range of images you use reflect the diversity of the Democratic Party and DAUK and will promote our inclusive ethos. 

• We cannot post anything that would tend to bring DAUK, Democrats Abroad, or the Democratic Party into disrepute. Material that might do this includes vulgar or abusive language or conspiracy theories.

• It is contrary to our values to promote or publish any disparaging references to such personal characteristics of a person or group as race, sex, religion, ethnicity, national origin, disability, sexual orientation, or gender identity. Be thoughtful:  if it feels wrong or like an attack on an individual or group, don’t do it. 

News and updates

We can freely post any news and updates from Democrats Abroad (DA) or the Democratic Party, policy statements by the Democratic National Committee( DNC) or Democratic Party leaders,  such as Democratic Leaders in the House or Senate, i.e. House Speaker or Minority  House Leader or Senate Majority or Minority Leader. 

DAUK can be held liable if we publish material that is libelous, defamatory or illegal.  Always verify facts, using a wide range of highly reputable media sources and authors. Remember that it is easier to bring a claim for libel and defamation in the UK than in the USA.

When we reference or link to news organizations, we should only include those that are highly reputable.

Supporting Democratic candidates

We cannot endorse or show partiality towards one Democratic candidate over another in primary campaigns. We must remain impartial throughout the Democratic Party primaries and caucuses. 

We cannot solicit funds for any Democratic candidate or for any PAC or SuperPAC. 

We can (and should) encourage all US citizens living abroad to register to vote and request their absentee ballots for both primary and general elections in the US. Always remind people that www.votefromabroad.org is the best tool to help them get their absentee ballots from abroad.

  We can speak positively about Democratic candidates running for office (post-primary), but DAUK cannot spend money to influence how the general public  should vote.

Advocacy

  We may post articles about and advocate for particular issues and policies consistent with the Democrats Abroad and Democratic Party platforms and debates. We should quote and direct people to material on the DA and Democratic Party websites. We can engage with debates within the Democratic Party on various issues but must always be careful to do so that is respectful to all members of our party and their views. 

We should be careful about advocating  policies contrary to the positions adopted by individual State Democratic Parties when discussing issues of unique state and local politics in the US.  If you are commenting on or advocating about a policy or practice of a U.S. state, check the position and views of the State Democratic Party. If you see a potential problem with your comments or reference to the State Democratic Party, consult the DAUK leadership.

  We may use quality research and quotes from reliable media sources and from Democratic ‘allies’, if compatible with DA and Democratic Party policies and values, but 

We cannot promote joining or funding third party organizations, their campaigns, or their events. 

We can, however, promote DA and DAUK webinars and events with third party groups, but we cannot promote joining or donating to these groups.

  We need to gain approval from the DAUK Chair in order to collaborate in an event with third party groups. If approved, we can promote these events but cannot promote joining or donating to these groups. 

Foreign Affairs

  We cannot comment on any foreign (non-US) government’s policies or practices – our host country or those of any other country.

See more:  It is Democrats Abroad policy to avoid communications which may jeopardize the safety and security of Americans abroad, and to avoid any action which may lead to the inhibited operation of Democrats Abroad country committees. 

Therefore, Democrats Abroad does not take policy positions on foreign government’s policies and activities, except in special circumstances where explicitly allowed by the Democratic Party Committee Abroad. If an article you are posting or an event you are promoting refers to a foreign government’s policies and practices and their impact on the US (for example, Russian interference in US elections), contact the DAUK leadership for advice about whether we can discuss this and how to frame and phrase this before publishing.     

  Advocacy on US foreign policy is complicated. Normally, it is acceptable to support formally adopted policy positions of Democrats Abroad and the Democratic National Committee about an overall approach to policy,  but you should still check with compliance advisors if there is  any doubt, and necessarily,  if it is on a topic not covered by DA resolutions or Platform  or DNC policy statements. 

  You should also avoid discussing specific countries whenever possible, especially if Democrats Abroad has a country committee there. Note  about comments on non-US governments’ policies and practices.

Sources: quality and copyright

Always fully check the sources you use or cite to ensure that the organization is highly reputable and its values are compatible with the Democratic Party.  Also, make sure that the specific research/material is well-founded and trustworthy.  It may be helpful to consult this Wikipedia guide to reliable sources. However, whenever in doubt, check with DAUK leaders.

 Using  Photos from DAUK events  

We may wish to provide more detailed guidance in a separate document drawing upon the specific advice given, but these suggestions cover the most important points 

Using DAUK photos and videos  from past events already used in DAUK social media and postings

We can use these photos and videos throughout the  website,  as long as we ensure that   the website Privacy Policy appears as  a footer on every page of the website. And that the Privacy Policy provides information about how people can contact us to request that their image be withdrawn from the site. 

  No photos of identifiable children should be placed on the site. 

 Checklist for DAUK photos at  future events: 

• Proper notification that photos or videos will be taken at the event has  been provided  in the advertising for the event (e.g. on the Eventbrite booking site and, if appropriate on tickets) and at the event itself 
• Links to the website Privacy Policy are included  in the advertising and booking for the event; the Privacy Policy  will include information on how to withhold or withdraw consent to be photographed 
• The designated  DAUK photographers are identifiable at the event and that you only use photos taken by the designated photographer

  Do not use photos taken by other people at the event

•  That the designated photographers have given consent for their photos to be used.  
• Specific issues

Do not include photos of identifiable children 

Do not include photos that may cause embarrassment or that could be perceived as revealing activities, characteristics or affiliations that people may wish to keep private. 

Ensure that the photo or video presents those photographed in a positive light. 

If someone is named in the caption to the photo, ensure that they have given consent to being named. 

Ensure that any  caption for a photograph is accurate, includes the attribution (if required)  and has a positive tone. 

Sources:  Copyright

DAUK will be liable for any violations of copyright, so please be diligent in checking the copyright for the images, videos and text that you use. 

Copyright: Ensure that images you use are owned by DAUK, copyright-free, correctly attributed, or licensed.  If in doubt, do not make use of others’ works.  Consult this DAUK guide on Images and Copyright Issues which includes sources for copyright-free images.   

Copyright: Avoid paraphrase or excessive quotations from publications; if using quotes, always provide a full citation. Whenever you use a quote or other material from another source, you may only do so if it unquestionably falls under “fair dealing” (the British version of a concept whose broader cousin in the US is known as “fair use”). If you are using a quote of another person, quote no more than is necessary and only such quotes as you are specifically discussing critically. If in doubt, don’t make use of the works of others.

  Copyright: Do not embed audio files or videos unless you have ensured that you have secured permission or a license to do so from the copy-right holder. If in doubt, do not make use of others’ work. Consult the section of the DAUK guide on Images and Copyright Issues on videos.

Finance and donations

We cannot currently arrange for donations directly on the DAUK web site. Donations require that we have donors complete a donation form and obtain evidence to satisfy ourselves as to their eligibility to donate. We also must ensure that we comply with data protection law (discussed below). We can link to the Democrats Abroad donation page or specific event donation pages so that people can make donations to the Democratic Party Committee Abroad or DAUK in an appropriate way. Discuss this with the DAUK Chair before you put any links about donating.

We cannot solicit donations for any organization other than DAUK and DA and we can only solicit donations from those eligible to donate. We cannot solicit donations for any Democratic candidate, PACs or Super PACs, or any third-party organizations.  (See above) 

DAUK can only accept and solicit donations from individuals who are U.S. citizens or Green Card holders. We cannot accept donations from any businesses or organizations -whether US or foreign owned –  or from any non-US citizens.  

We cannot promote any commercial products or services. Where we have events with the author or filmmaker, we can inform people about the name of their book, film  or the publication in which their column appears.  If an  event approved by the DAUK Chair includes  separate book or DVD sales, such events are always required to be separate from the DAUK event, e.g. outside the room and before or after the event. We cannot mention the sales or signings  on the website or in any DAUK promotions for the event. 

Third Party Associations and events

We only inform our members of non-Democrats Abroad events via our membership newsletter and we only do so when the events are held by organizations and candidates consistent with our aims and values. You must not promote or advertise events that are not hosted or sponsored by DAUK or Democrats Abroad unless given specific approval by the Chair of DAUK, who might have to seek specific approval from  the Executive Committee.

  We need to gain approval from the DAUK Chair in order to collaborate in an event with third party groups. If approved, we can promote these events but cannot promote joining or donating to these groups. 

   We cannot promote joining or funding any third-party organizations.  

Data protection

• Any use of personal data by DAUK is subject to the General Data Protection Regulation. This means that we can only collect personal data where we have the appropriate consent for its  collection and use, and that  we use the data only as authorized by the subject, and that we keep the data securely.
• There will be a DAUK Privacy Policy statement provided as a footer that will cover the collection and use of personal data via the website.
• We will be using cookies and Google Analytics that have been configured to meet GDPR requirements.
• At this stage we are not collecting any individual personal data; we only invite people to send emails to DAUK and its Committees and Caucuses 

Do not put any forms on the website to collect personal data from visitors to the website. We can only provide an official @democratsabroad.org.uk email address for people to make contact or a link to a separate website (e.g. Democrats Abroad or Vote from Abroad)

We can direct people to the Democrats Abroad membership, donation, and Vote from Abroad pages, which are stored on separate web sites. These have appropriate notices and privacy policies about their collection and use of personal  data.

Advice and recommendations 

We cannot provide professional advice or recommendations for professional services, for example, on issues such as immigration or tax. 

We can and do recommend the use of Vote from Abroad (VFA) for voter registration and ballot requests and the use of VFA for help and advice on problems with voting, as well as the DA Voter Help Desk.   

Making Contact

Always use your official @democratsabroad.org.uk accounts on the site and for communications for any correspondence. 

Always bcc all people in group messages unless they have given explicit authorization for you to share their email address with others.

Always use a GDPR statement in any contact form (not on the website)  and as a footer in all emails.

Never provide anyone’s personal email or other personal details on the website.

Connecting with social media

We should always promote links to DAUK and DA Facebook, Twitter and Instagram and any official DA or DAUK groups’ social media.

We cannot link to or promote personal feeds.

Seek advice about linking to other sources.

Other general compliance issues:

Website Disclaimers:  

The following disclaimers were approved and used on the old PAN and Film websites (and re-approved in 2017) but not reviewed since. 

General website disclaimers

Content provided on this site is solely as a service for convenience and informational purposes only. Opinions expressed on this site do not constitute approval by Democrats Abroad UK, Democrats Abroad or the Democratic Party of the United States.

Links to other organizations or publications do not constitute endorsement or approval of their products, services or opinions  nor imply association with the Democratic Party or Democrats Abroad UK. 

Democrats Abroad UK is not responsible for the policies or contents of external third party websites.

Disclaimer about Film screenings: 

 “The screening of this film does not constitute an endorsement or promotion of the film, nor of any views expressed therein or any association with The Film Committee, DAUK, Democrats Abroad or the Democratic Party. Screenings are solely conceived as educational activities: offering an opportunity for members to discuss issues.  Links to other organizations or publications imply neither endorsement of their policies nor any association with the Democratic Party or Democrats Abroad – UK.”

Disclaimer for people to accept when signing up for tax events

“I have been informed and understand that this event is run by Democrats Abroad UK, an unincorporated association based in the United Kingdom, and is not organized, endorsed, or funded by any party, candidate, or other organization.

“I have been informed and understand that all views expressed by individuals at the event, including those of guest speakers, are those of the individuals speaking and do not represent the views of Democrats Abroad UK.

“I understand that this event is meant to educate about issues of tax policy affecting Americans abroad and not for the provision of advice about any tax or legal situation or problem. I understand that I may not rely on any information given to me by Democrats Abroad UK for the purpose of any decisions that I might make in relation to a tax or legal situation. I am aware that any actions that I take in relation to my own tax or legal affairs are my own responsibility and not that of Democrats Abroad UK. 

“I am aware that if I need advice about or in relation to any legal or tax problem, then I should seek an appropriate professional advisor and conduct my own due diligence. I have been informed and understand that Democrats Abroad UK does not endorse any particular advisor or group of advisors.”

Other GDPR information 

Although the website will not send or receive emails and will not collect personal information through forms on the site,  remember that you must provide GDPR statements on all your emails and forms.  

Reminders:

Example of email footer for committee/chapter emails

“You are receiving this email because you asked to be contacted by [name of committee or chapter] of Democrats Abroad UK.

“Your information is be held by [name of committee or chapter] of Democrats Abroad UK for the purpose of contacting you about [name of committee or chapter] activities and volunteer opportunities. We will also keep data where needed to comply with campaign finance laws and ensure accuracy and completeness of membership records of Democrats Abroad and DAUK, and we may cross-reference with Democrats Abroad membership records for this purpose.

“If you would like to remove yourself from our membership list or ask about what information we have, please email us at [committee or chapter e-mail]. If you would like to know more about what information Democrats Abroad holds about you generally, please contact [email protected]”

Example of notice on membership sign-up or another form collecting personal data

“Your information will be held by [name of committee or chapter] of Democrats Abroad UK for the purpose of contacting you about committee [or chapter] activities and volunteer opportunities. We will also keep data where needed to comply with campaign finance laws and ensure accuracy and completeness of membership records of Democrats Abroad and DAUK, and we may cross-reference with Democrats Abroad membership records for this purpose.”

Useful guidance on social media from Democrats Abroad and the inspiration for using a traffic light system:   

Compiled, written and created by Elaine Capizzi  29/04/20 with edits and contributions from website team members, Comms Committee and DAUK leadership.

Reviewed and agreed by the Website Compliance Task Force on September 1 2020.

Final version approved by the DAUK Chair (Inge Kjemtrup) and Legal Counsel (Julian Becker) on September 4, 2020.

This will be a living document and so will be revised and updated, so always check for the latest version and please list authors and dates of revisions.