[PAO] Ice Bucket Challenge

[Cianciolo, Lt Col, Paul]

PAOs,

I recently received the email below from the NASA social media team about
the Ice Bucket Challenge <http://en.wikipedia.org/wiki/Ice_Bucket_Challenge>.
Some if you may have seen this going around on social media already, but
before you film dumping a bucket of icy water on your wing commander's
head, take note. Even though it's for a good cause, it is considered
fundraising. That means no Air Force style uniforms -- like on cadets doing
this on their own. Now as for CAP supporting this in other ways ... that's
up to the chain of command. *The take away here is no fundraising with
anything perceived to be Air Force.*


 We've had multiple NASA centers, programs, and missions ask about the Ice
> Bucket Challenge and doing it here. Even the NASA Administrator has been
> challenged, as have the astronauts on the ISS. We've sought out the
> guidance of our general counsel here since this is a charity fundraiser
> event. *NASA's general counsel strongly advises us against participation
> in an official capacity.* Here's counsels official reasons why:
>


 *Doing the Challenge in an official capacity as a NASA employee or in the
workplace implicates some of the legal prohibitions on fundraising.  First,
employees may not participate in fundraising activities in their official
capacity.  This means that employees may not use their NASA title,
position, or authority to fundraise.   For example, if an employee were to
identify themselves as a NASA employee in the video, this could run afoul
of the prohibition.   This could also create problems under other ethics
provisions that restrict employees from using their Government title,
position, or authority to endorse a product, service, or enterprise OR to
imply the Government sanctions or endorses their personal activities or
those of another.  In addition, participation may violate prohibitions on
engaging in fundraising activities outside of the Combined Federal Campaign
in the Federal workplace.  Finally, employees should not use official
resources, such as Agency social media accounts, to support or promote a
fundraiser.  *



*This does not prohibit employees from participating in the Challenge in
their personal capacity off-site and on their own time.  One last thing to
keep in mind is that, regardless of the context, employees must avoid
soliciting funds from subordinates or from prohibited sources, i.e.,
entities that do business with NASA or are seeking to do so.  Thus, if an
employee did participate in the Challenge, he or she should not nominate
subordinates or Agency contractors.  It is also worth noting that the 2014
CFC season will soon begin, providing many opportunities within the Federal
workplace for employees to support their favorite charities.*



This guidance has been provided by the Office of General Counsel at NASA
HQ. Figured I'd share in case you are working with your lawyers on similar
guidance at your agencies. Obviously our counsel's guidance may not apply
at your agency but it may be useful to have.




v/r
--


*PAUL S. CIANCIOLO, Lt Col, CAPPublic Affairs OfficerNational Capital Wing*

Cell: 301-751-2011 <http://www.NatCapWing.org>
Work: 202-385-9599 (@FAA)

-- 

------------------------------
Civil Air Patrol National Capital Wing
*"Citizens Serving Communities: Above and Beyond"*

CFC Charity #26757
www.NatCapWing.org

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