ADA and Web Accessibility Guidelines for Nonprofit Websites in 2019

Signed into law in 1990, the American Disabilities Act (ADA) prohibits discrimination against people with disabilities and is aimed at making all public spaces inclusive and accessible to everyone. The ADA Amendments Act of 2008 later clarified the "definition of 'disability' to ensure that [it] would be broadly construed and applied without extensive analysis."

Let's take a look at how the ADA has affected websites in recent years, as well as what compliance entails for nonprofit organizations.

Until recently, organizations with websites were encouraged to comply with established Web accessibility standards, although compliance is not mandatory. The details of compliance were a hot topic of discussion as recently as June 5, 2018, within the World Wide Web Consortium (W3C), a private organization that recently released updated guidelines for its Web Accessibility Initiative (WAI).

The primary goal of WAI is to make the Internet a place where anyone can get involved "regardless of cognitive, neurological, visual, speech, physical, or auditory disabilities they may be burdened with." The guidelines developed by the initiative — with the help of disability organizations, government resources, and research labs — are known as the Web Content Accessibility Guidelines (WCAG), the latest version of which is WCAG 2.1.

A Top-Down View of What WCAG Compliance Entails

Adoption of WCAG includes providing text options for non-text content, clear titles for Web pages, "disability-considerate colors," and straightforward site structure so that people with focus-related disorders can navigate the site. It's worth noting that many websites were already compliant with the guidelines.

WCAG 2.0 outlined three additional levels of compliance. From low to high: Level A, Level AA, and Level AAA. Compliance at the lower levels is independent of compliance at the highest level, and WCAG does not recommend making AAA compliance a general policy requirement — for the simple reason that not all content can be modified to satisfy the criteria.

WCAG 2.1 builds on WCAG 2.0 guidelines and includes seventeen new criteria related to:

• technological advances in mobile devices
• visual disabilities such as color blindness and low vision
• learning and cognitive disabilities such as Attention Deficit Disorder (ADD) or age-related cognitive decline

WCAG 2.1 added five new success criteria to Level A, seven to Level AA, and another five to Level AAA. It's recommended that WCAG 2.0-compliant sites review WCAG 2.1 and make adjustments where possible to ensure that the site remains compliant with the latest guidelines. Though some of these new criteria require fairly serious programming knowledge, others involve simple formatting changes that can be performed with basic text editing tools.

An example of a text-related addition to Level AA is Success Criterion 1.4.12. Intended to ensure that readers "can override author specified text spacing to improve their reading experience without any loss of content or functionality," the criterion details the minimum amount of available adjustments for line height (line spacing), spacing after paragraphs, letter spacing (tracking), and word spacing. An example of non-compliance with the spec would be if a portion of text were to get cut off or become no longer visible when the page was enlarged.

As of July 24, 2018, the Department of Justice (DOJ) had not yet adopted WCAG 2.0 as the standard for the private sector, despite numerous private and governmental plaintiffs urging the government to make Level AA WCAG 2.0 compliance the standard for website accessibility.

ADA and the Ninth Circuit: The Most Recent Case With Big Implications

Since the inception of the ADA, numerous claims of inaccessibility have been brought before the United States Court of Appeals for the Ninth Circuit. Although many of the rulings against websites and the companies that operate them eventually are overturned, the process is time-consuming and costly, both financially and in terms of public sentiment.

It's been especially tricky since DOJ — after nearly eight years of review — decided to withdraw its proposed ADA rulemaking, leaving all ADA-related decisions up to the discretion of Ninth Circuit courts. The department's reasoning was based on the general sentiment that waiting for a DOJ ruling would cause plaintiffs "undue delay" and that "courts are perfectly capable of interpreting the meaning [of] 'equal' and 'effective.'"

Indeed, the Ninth Circuit court decision in Robels v. Domino’s Pizza was a boon for ADA website accessibility suits. After a California district court initially dismissed the case, stating that company websites cannot be deemed to have violated the ADA before the DOJ provides specific guidelines, the case was taken up by the Ninth Circuit for the previously stated reasons regarding "undue delay."

While the Ninth Circuit didn't rule that failure to comply with WCAG necessarily violates the ADA, its ruling did state that "the district court can order compliance with WCAG 2.0 as an equitable remedy, if after discovery, the website and app fail to satisfy the ADA." The Ninth Circuit does hold that covered sites be granted "maximum flexibility" in terms of meeting the requirements. Practically speaking, this means that any ADA-covered website could be ordered to become WCAG-compliant.

How Does This Affect Nonprofits?

Because courts cannot agree on whether a public accommodation refers only to a physical location, cases like Robels v. Domino's Pizza could mean increased risk for nonprofit websites. In fact, some courts deem websites to be public accommodations, even if they are not associated with an actual physical location. Until DOJ provides detailed guidelines, it seems these matters will be left entirely to the discretion of Ninth Circuit courts.

Although it's not technically required that nonprofits fully conform to WCAG guidelines to receive a Level AAA rating, investment in achieving Level AA compliance has considerable potential for saving organizations time and legal fees. This is especially true while we continue to wait on DOJ to specify legal requirements for ADA-covered organizations, companies, and websites. For the typical nonprofit, reaching the broadest possible audience is key to advancing its mission and goals. And the best way to do that is to ensure that anyone and everyone is able to actively engage with your content online.

Eric Van Buskirk is the publisher of Dopa, a W3C accessible website focused on mental health and psychological disorders. An expert on Internet search engines, he also oversaw some of the largest big-data studies on how Google ranks webpages.

Building Nonprofit Sustainability Through Digital Apps

Product-based income strategies are challenging for nonprofits because of the costs associated with inventory. Either your organization has to shell out significant capital to keep the products you hope to sell in stock, or you have to partner with a company that will manage the inventory for you. In most cases, the company will take a portion of your sales to cover their costs and turn a profit before turning over the remainder of the proceeds (if any) to you – in effect, turning your carefully cultivated army of volunteers into a second sales team working to boost its own P&L statement.

With a digital product like an app, on the other hand, a nonprofit bears the one-time cost of product development and then is able to sell the product in perpetuity – or what passes for perpetuity in the digital age -- without having to worry about costs associated with building and maintaining inventory. In the digital marketplace, once an app has been created, selling a hundred thousand copies doesn't cost you any more than selling ten thousand copies.

What's more, having an app on a supporter's mobile device creates a new channel through which you can communicate with that supporter as conveniently as you can with email but without the "noise" created by the hundreds of emails most of us receive on a daily basis. Push notifications that directly target users of an app can quickly mobilize your user base, alerting them to new petitions, challenge grant opportunities, and other kinds of events designed to deepen donor engagement. (Note: while nonprofits are allowed to make money from the sale of digital apps, they cannot collect donations through an app. If you want to use the app to generate donations, you need to get potential supporters to click a "Donate" button that sends them to a mobile-friendly Web page where the transaction can be completed.)

So how much does it cost to develop an app? In 2014, when the team at RedRover first hit on the idea of building a digital version of our RedRover Readers program, we didn't have a clue. And asking a developer how much it costs is like asking an architect how much a new house will cost – the answer can range anywhere from hundreds of dollars to hundreds of thousands of dollars, depending on what you want the app to do. The more complex the functionality, the more it's going to cost.

Designing a Responsive Granting Process

(Parker Mitchell co-founded and for ten years was co-CEO of Engineers Without Borders Canada. He recently moved to New York and joined, as an expert-in-residence, the Blue Ridge Foundation, which funds and incubates new technology-based ventures that advance opportunity and upward mobility. This post originally appeared on the Foundation Center's GrantCraft blog.)

We began with two questions:

• Are leading nonprofits fully making use of the explosion of digital and online platforms to find new ways to up-end their program models, scale, and radically remake their programs so that they are more effective?
• And if not, could we bring the investing principles of the technology world to help leading nonprofits find the time, money, and resources to experiment with digital platforms to change their program model?

Three months ago, Blue Ridge Foundation New York teamed up with leading software firm ThoughtWorks and the Parsons School of Design to create a grant program for poverty-related nonprofits that would try to bridge the effective organization/technology adoption gap.

We began by offering a package of support that included a combination of funding, incubation services, in-kind software support and design, and design thinking consulting. Each package was worth roughly $150,000. But we also knew we didn't have all the answers and wanted to design a transparent, responsive granting process that would help us pin-point nonprofits’ digital technology needs.

What is this gap, and why should funders care?

Finding Hope in a Cause

(Derrick Feldmann is CEO of Achieve, an Indianapolis-based creative fundraising agency. In his last post, he argued that the annual report is yesterday's news.)

Five years ago I joined with a few others to start Achieve. During the formation process, I looked into obtaining "key man" insurance, which provides financial relief to a company if something unexpected happens to one of its key leaders.

As with any life insurance policy, I had to pass a physical exam and submit to a battery of blood tests. A week after the exam, my insurance agent called to discuss an "odd reading" from one of the tests that pointed to an anomaly in my liver function. He then told me it could have been caused by me having a drink or two the night before. When I assured him I hadn't, we agreed it was a fluke.

A few days later, after visiting my doctor and submitting to another blood test, my insurance agent called me with some perplexing news. "I know this sounds crazy," he said, "but your liver enzymes are high again and the underwriter won't insure you." He then suggested I get a note from a doctor saying the test result was incorrect and that I was the picture of good health.

I waited a couple of weeks but finally went to see a specialist. While he was flipping through my medical records and charts of my blood work, he looked at me and asked, "How long have you been scratching your legs?"

"What?" I must have looked confused.

"Did you know that the whole time I've been sitting here going through your records, you've been scratching your legs?" Then he pulled up one of my pant legs. There were scratch marks all over my leg. I hadn't even realized I was doing it.

A couple of weeks later I had minor exploratory surgery. After the procedure, he sat me down to confirm what he had suspected: I had a chronic condition called primary sclerosing cholangitis, or PSC -- an autoimmune disease that causes inflammation and subsequent obstruction of the bile ducts. The itching was caused by bilirubin, a byproduct of normal metabolic processes, that had entered my blood stream because my bile ducts were completely closed.

Dear Fundraisers: The Annual Report Is Yesterday’s News

(Derrick Feldmann is CEO of Achieve, an Indianapolis-based creative fundraising agency. In his last post, he wrote about the importance of differentiating between your "sophisticated" and average donors.)

When I headed off to college for the first time, I had no idea what I wanted to study or what kind of career I would pursue after graduation. Like so many other "undecideds," I took classes from lots of different departments and hoped something would click.

Then, in my junior year, I discovered criminal justice. I had always enjoyed crime novels, detective stories, and hearing about unsolved mysteries, and after I took a few classes in the field, I convinced myself that maybe the law was my calling. Eventually, I marched into my advisor's office and declared my major: pre-law.

Well, as a pre-law major, I needed to take the LSAT in order to be able to apply to law school. But unlike just about everyone else taking the test, I didn't bother to study until the night before. Don't ask me why.

So, I took the test and, thinking I might have done okay (or even a little better than okay), I settled in at home and waited for the results. I checked the mailbox every day for an oversized envelope, and as days turned into weeks, my thoughts ran every which way. Law? What had I been thinking? The second part of the test wasn't so hard, though, and I'm pretty sure I did okay on the third part. Who knows? And, hey, I do love a good mystery.

How RWJF Tackles the 'Social Media, So What?' Question

(Debra Joy Perez [@djoyperez] currently is serving as interim vice president of research and evaluation at the Robert Wood Johnson Foundation, the largest healthcare philanthropy in the country. The following Q&A was conducted by our colleagues in the Foundation Center's San Francisco office and originally appeared on Transparency Talk, the Glasspockets blog.)

Last year, after Steve Downs, chief technology and information office at the Robert Wood Johnson Foundation, shared a post on Transparency Talk detailing the foundation's social media strategy, we conducted a series of interviews (here, here, and here) with RWJF staff members that explored how social media and, more broadly, the transparency and participation they offer was adding a new, critical dimension to their work.

The latest Q&A in the series, featuring Debra Joy Perez, the foundation's interim vice president of research and evaluation, explores how RWJF's use of social media, which has become essential to its communication efforts, can be measured to reflect the impact of that work in the context of achieving the foundation's larger social change goals.

TT: Give us a quick overview of your work at the foundation in light of these new technologies. Why are social media metrics important to RWJF?

DJP: RWJF has a forty-year history of developing evidence-based programming. We're known for our research and evaluation work nationally and internationally. But as efforts to advance our goals in health and health care have become more reliant on technology, we've struggled with measuring success and accountability.

Since 2009, RWJF has been incorporating Web 2.0 technology into our everyday work, and with the September launch of our redesigned Web site, we now have more social sharing facilitation tools on the site. We're also doing more on on Twitter and Facebook to invite conversation about how to advance health and health care and are producing content to serve the needs of various online communities.

All that activity allows us to clearly see the present and future value of social media, which we believe can help us create social change and build movements around the causes we care deeply about. And, guided by the principles of openness, participation, and decentralization, we have learned a number of important lessons from that work. They include:

• Personal outreach matters;
• Responsiveness to requests for engagement is important;
• Criticism can lead to healthy dialogue;
• Engagement needs to be easy and simple; and
• Real engagement requires work and dedicated resources.

These takeaways underscore the importance of ongoing conversation about the policies and processes needed to achieve our goals. For instance, with each social media campaign, we have to be explicit about our expectations. Metrics are an essential part of that effort. Measurement allows us to see how we're doing against those expectations and to improve our use of social media to achieve our broader goals.

[Infographic] 2013 eNonprofits Benchmark Study

Here in the Northeast, spring has sort of arrived, and that means it's time to share a new infographic from M+R Strategic Services and NTEN highlighting key findings from their annual eNonprofits Benchmark Study.

Now in its seventh year, the study examines trends in nonprofit online fundraising and advocacy, in sectors ranging from human rights to environmental issues. Based on data gathered from 55 nonprofits, this year's report analyzed 1.6 billion e-mail messages sent to 45 million list subscribers, 7.3 million advocacy actions, and more than $438 million in online donations from over 6.5 million online gifts.

As impressive as that is, the picture painted by the report is...well...mixed.

For instance, the study reported a 21 percent year-over-year increase in online revenue, with only International groups seeing a decline in online giving. But it also found a sharp decline in certain key e-mail metrics, including a 14 percent decline in click-through rates for advocacy messages and a 27 percent decline in click-thru rates for fundraising messages overall.

The report also found that:

●     Online monthly giving grew by 43 percent -- more than twice as fast as one-time giving.

●     E-mail list sizes continued to grow for all sectors and sizes, up some 15 percent overall in 2012.

●     Growth of social media audiences outpaced e-mail list growth, up an average of 46 percent on Facebook and 264 percent on Twitter.

There's a lot more in the report, which is available as a free download (registration required) here.

-- Mitch Nauffts

Welcome to the New World of Fundraising

(Dave Boyce is the chief experience officer at Fundly, a widely adopted crowdfunding platform for social good that to date has enabled more than thirty thousand nonprofit organizations, volunteer groups, and individual fundraisers to raise over $300 million.)

Meet NaaLamiley, a fifteen-year-old sophomore at Chapel Hill High School in North Carolina who describes herself as a "sea nerd and a shark geek, pretty much more at home on the water than on land."

When NaaLamiley learned she was accepted to the prestigious Class Afloat program, which  exposes academically gifted high school juniors and seniors and college freshmen to a rigorous, one-year curriculum at sea, she was both exhilarated and disheartened. Exhilarated, because this was a dream opportunity to advance her future career in ocean conservation. Disheartened, because she knew that even though she had made it through the rigorous selection process, neither she nor her family could afford the $50,000 tuition.

But NaaLamiley is a member of a new generation -- one that simultaneously distrusts traditional institutions and places great value in social networks. No scholarship agency was going to swoop in and hand her a check for $50,000. She couldn't depend on her public high school, a federal grant program, or any other institutional source of support. Without sufficient family resources, she was left to her own devices.

Enter crowdfunding.

NaaLamiley was so proud of being accepted to the program, she was ready to shout it from the rooftops. And when teenagers shout, they use social media. NaaLamiley knew that if she told enough people about her incredible opportunity, they would rally to her side. So she set up a crowdfunding campaign, worked diligently for several months to promote it, and successfully raised the $50,000 she needed to set sail with Class Afloat.

Why did it work?

Using Social Media to Expand Networks: A Q&A with Susan Promislo, Robert Wood Johnson Foundation

The following Q&A with Susan Promislo, senior communications officer for the Vulnerable Populations Portfolio at the Robert Wood Johnson Foundation, originally appeared on the Foundation Center's Transparency Talk blog. The post is the fourth in a series featuring RWJF staff talking about the foundation's social media efforts. In January, Steve Downs helped launch Transparency Talk with a great overview of RWJF's social media strategy. That was followed by Q&As with Jane Lowe, senior program officer and team director for RWJF's Vulnerable Populations Portfolio, and Mike Painter, senior program officer on the foundation's Quality/Equality Team.

Transparency Talk: Let's start with a glimpse into a day in the life of a communications officer at the Robert Wood Johnson Foundation. How has Web 2.0 changed your job? And how is it changing your relationship with grantees and the wider community?

Susan Promislo: As the former communications officer for the Pioneer Portfolio, I think I was the first staff member at the foundation to manage a blog and one of the first to use Twitter. In part, it was because of our involvement in conferences like TED and communities like Health 2.0 that are further out in front with technology and social networking. But we also knew that a broadcast strategy was not going to work for Pioneer, which focused on finding transformative ideas from within and outside of health and health care. We had to pursue a networking strategy, had to be learning, had to be open to ideas from all avenues.

It helps affirm that we're connecting beyond our usual suspects, and that social media has empowered us to build stronger, more diverse networks. It has helped program staff raise their profiles and gain greater presence in new fields, paving the way to build relationships with key thinkers and actors that they might not otherwise have developed.

So I learned by jumping in and feeling my way, listening to what was going on, and learning from others. And social media became not only another way to promote RWJF and our grantees and engage others in our work, but also a way for me to deepen my learning on key issues and make valuable connections.

Twitter, in particular, has been really instructive. As I began to follow more people and have more people follow me, and see those networks blossom, I became more comfortable as a voice on the issues we care about and as a connector who could share information that others might find valuable.

As far as our grantees, we provide resources to help them be more effective in their use of social media. But we also leverage RWJF's platforms, voice, and reach to lend further power to their work.

8 Trends That Will Shape Fundraising

(Derrick Feldmann is CEO of Achieve, an Indianapolis-based consulting firm that works with nonprofits.)

When I was working in development for a nonprofit, I was expected to provide my executive director with annual fundraising goals for my department -- goals that were based on donor history, prior-year results, and the likelihood that a certain number of prospects would give for the first time.

In addition to our baseline goal, we always established a stretch goal or modeled a best-case scenario for our efforts. Early in my career we never seemed to hit the stretch goal, in part because I didn't know our donors that well and because we based our predictions on what the organization needed, rather than on our donors' willingness to give.

Over time I realized that to make our stretch goal, we had to alter our approach. And so, in addition to market research and data mining, we came up with three questions to help guide our efforts.

1. What is causing donors to engage with us now?
2. Which fundraising approaches are still relevant and why?
3. What forces will influence donor behavior in the future?

In my opinion, these three questions should be the starting point for anyone trying to determine the long-term impact of their fundraising efforts (not to mention the future of fundraising itself). Recently I had a chance to sit down and revisit the questions, and I came up with the following eight trends that I believe will shape the fundraising industry and the relationship between donors and nonprofit organizations in the future.

Facebook as Catalyst for Collaboration: A Q&A with Mike Painter, Robert Wood John Foundation

(Mike Painter is senior program officer on the Quality/Equality Team at the Robert Wood Johnson Foundation. A version of this post appears on the Foundation Center's Transparency Talk blog. For more about the Robert Wood Johnson's Foundation's social media strategy and how it has evolved over the last two years, click here and here.)

Foundation Center: Let's start with a glimpse into a day in the life of a senior program officer at a major foundation. How is Web 2.0 changing your job and your relationships with grantees and the broader community you serve?

Mike Painter: I'm Mike Painter, and I'm an avid social media user -- although I don't think I need a twelve-step program quite yet. Don't get me wrong, I certainly like and use e-mail, telephone, and video-conferencing a great deal. In my work at RWJF, though, social media, including tools like Twitter, Facebook, and LinkedIn, add an important and rich layer of capabilities and collaboration power to my tool set. Before I came to the foundation, I was an RWJF Health Policy Fellow for a year on Capitol Hill. While in that position, I soon realized that there were interesting things happening in our office that I wanted to share with others. We didn't have social media tools at the time to power that sharing, so instead I manually put together e-mail distribution lists to help keep people informed. That experience demonstrated to me the power of collaboration technology -- even something as simple as an e-mail distribution list. To me, social media is an obvious logarithmic enhancement of that rudimentary sharing and collaboration capability -- one that dramatically increases the reach and magnitude of my old distribution-list efforts.

On Building Community Online: A 'Flip' Chat With Paull Young, Director of Digital, charity: water

(This video was recorded as part of our "Flip" chat series of conversations with thought leaders in the nonprofit and philanthropic sectors. You can check out other videos in the series here, including our previous chat with Helena Monteiro, executive director of the Worldwide Initiatives for Grantmaker Support.)

There are currently 800 million people living without the very thing most of us take for granted: safe, clean drinking water.

Founded by former nightclub promoter Scott Harrison, charity: water has helped bring that precious commodity to two million people in the developing world. How? For starters, it has perfected the art of collaborating with local partners who know the language and customs of the target population and have mastered the logistical challenges of working in local communities.

The New York City-based nonprofit is also brilliant at fundraising and, largely through innovative digital outreach efforts like its birthday campaign, has raised more than $60 million for water projects in the developing world since it was founded in 2006.

What explains charity: water's phenomenal success? According to the organization's director of digital, Paull Young, it boils down to the following:

1. Be positive. Powerful stories with positive messages are more effective than stories that make people feel guilty.
2. Don't ask for money. What works with direct mail often doesn't work online. Instead of making an ask every time you communicate with your donors and supporters, give people a chance to learn about the "cool stuff" your organization is up to.
3. Give. Raise. Influence. Focus on building relationships with your donors and supporters that enable them to see how they can maximize their ability to give, fundraise, and influence others over a period of years.
4. Do it wrong quickly.
5. Help donors and supporters see their impact. People are more generous if they understand clearly how their money is being used.

Recently, I had a chance to chat with Young before he addressed a 501 Tech NYC event about the organization's birthday campaign, the metrics it uses to evaluate its online fundraising efforts, and a few of the fundraising lessons he and his colleagues have learned over the years.

(If you're reading this in an e-mail, click here.)

 

(Running time: 8 minutes, 8 seconds)

Have a thought or comment you'd like to share? Use the comments section below....

-- Regina Mahone

Emoti-Con!: Digital Learning Comes to NYC

(Laura Cronin is a regular contributor to PhilanTopic. In her last post, she chatted with Kimberleigh Smith, board president of the New York City-based Paul Rapoport Foundation, about the foundation's decision to spend down by 2015 and what the foundation is doing to help grantees navigate that transition.)

What if a bunch of nonprofits and funders found ways to work together on new projects that furthered their respective missions while also creating outcomes that were larger than the sum of the new parts?

Productive collaboration among organizations is one of those textbook goals that funders love to promote. Many an executive director has heard from a major funder about some like-minded nonprofit she should find a way to work with, sometime in the future. But too often, such suggestions lead to circular conversations, mission drift, and/or wheel spinning.

Lately, however, several New York City nonprofits have discovered that young people's interests are a key that can unlock the secrets of successful, mission-driven collaboration.

Hive Learning Network NYC is a coalition of youth-serving organizations that encourages young people to explore their interests and further their learning through the use of digital media and technology. Fueled by grants from the New York Community Trust, MacArthur Foundation, and others, students from all five boroughs participate in a lively system of out-of-school time (OST) programs that use digital tools to help them dig deeper into subjects they're passionate about, from science and art to creative writing and filmmaking.

Philanthropy’s Data Dilemma

(Bradford K. Smith is president of the Foundation Center.)

When McKinsey & Co. released its seminal study Big Data: The Next Frontier for Innovation, Competition, and Productivity, the firm confidently predicted that the world was "on the cusp of a tremendous wave of innovation, productivity, and growth, as well as new modes of competition and value capture -- all driven by big data as consumers, companies, and economic sectors exploit its potential." While the study covered every segment of the economy, from "accommodation and food" to "wholesale trade" and even government, philanthropy -- an industry that, in America, controls over $600 billion in assets and makes close to $47 billion in grants every year -- wasn't even mentioned, most likely because no one thought to include it.

It's not that philanthropy doesn’t have anything to bring to the Big Data party. Think about it. Foundations possess resources, something most people do not. And they possess something even fewer people have, flexible resources. As a consequence they are surrounded by those hoping for their support, an endless stream of the brightest and most committed talent on the planet, people with amazingly creative ideas about how to solve the world's pressing social, economic, and environmental problems. But what's visible to the outside world -- the rare project that is actually approved and whose one-line description eventually makes it on to a foundation tax return and (maybe) a foundation Web site -- is merely the tip of the iceberg. (And a surprising number of foundations don't have Web sites at all.) Moreover, most of the (increasingly digitized) concept notes, project proposals, progress reports, evaluations, research, and strategy deliberations produced by foundations are unavailable for mining within individual foundations, across the field, or by anyone else interested in understanding philanthropy's immense contribution to making a better world.

‘Fair and Square’ and Philanthropic

The JCPenney Company, which was founded over a hundred years ago by James Cash Penney on the principle of treating customers "fair and square," recently launched a new charitable giving program called jcp cares that aims to build stronger communities across the country.

Through the program, the company plans to support a different cause or charity each month, for at least the next six months, with direct contributions and donations from customers. The first six charities selected to receive support through the program are the USO (July), 4-H and the Boys & Girls Club of America (August), Teach for America (September), the Breast Cancer Research Foundation (October), Share Our Strength (November), and the Salvation Army (December).

As someone not privy to the closed-door discussions that led to the selection of the six charities, I find myself wondering how the company came up with its list. Okay, some of the choices are obvious. This month's charity, the USO, supports military personnel and their families -- an entirely appropriate choice in a month that includes Independence Day. Similarly, Teach for America is an obvious choice for everyone's favorite back-to-school month, and what could be more appropriate than supporting the Salvation Army's Red Kettle campaign in December.

But in an era when companies, like almost everybody else, need to compete for the dollars and attention of consumers, you might expect JCPenney to be a little more creative about how it engages customers in its philanthropy. For example, what about asking customers for nominations of organizations deserving of the company's support via Facebook or Twitter? Or, taking it a step further, being more transparent about the actual selection process it did employ?

The company has said that, from July 23 to July 31, it will donate $1 -- up to $50,000 -- to its July partner, the USO, for every customer that checks in at a JCP location via foursquare. It has also launched a dedicated page on BroadCause where customers can share their personal stories and has said in its press release that it will engage charitably minded customers through the Facebook game WeTopia. I just hope the company has a long-term vision for its corporate giving that goes beyond "clicktivism."

What do you think? Am I being grumpy, or should the company be doing more to engage its customers in its new charitable giving program? Share your thoughts in the comments selection below.

-- Regina Mahone