Barnard College Barnard College
Policies & Procedures

Partisan Political Campaign and Lobbying Policy

Effective: November 1, 2024

Executive Summary:
Barnard College encourages everyone in our community to actively participate in the political process as private citizens. Members of the Barnard community are free to participate in political campaign activities and lobbying using their own personal time and resources and while making clear to the public that they are acting in their own personal capacities and not on behalf of the College.

Federal and state law absolutely prohibit tax-exempt educational institutions from participating directly or indirectly in partisan political activity or campaigns supporting or opposing candidates for public office. Because Barnard is a tax-exempt educational institution, the College, and individuals acting on behalf of the College, may not participate directly or indirectly in partisan political activity or campaigns supporting or opposing candidates for public office. In addition, federal law limits the type and amount of lobbying in which the College, and individuals acting on behalf of the College, may engage.

This policy delineates activities that are permissible and impermissible when using College resources or purporting or appearing to speak as a representative of the College or on behalf of the College. Section I sets forth Barnard’s policy to comply with Section 501(c)(3) of the United States tax code and state and local laws prohibiting the College from engaging in partisan and political campaign activity while affirming that the College may engage in and sponsor debate and discussion of political issues. Section II sets forth Barnard’s policy to comply with legal restrictions that prohibit the College and those acting on the College’s behalf from engaging in substantial activities that attempt to influence legislation (lobbying).

Reason for the Policy:
This policy ensures that: (1) members of the Barnard College community comply with federal, state, and local laws prohibiting the use of Barnard resources or affiliation for partisan political campaign activities; and (2) any lobbying on behalf of Barnard College comports with federal, state, and local laws strictly limiting the nature and volume of permissible lobbying activities conducted by nonprofit educational institutions.

Who Is Responsible for This Policy:
Office of the General Counsel

Who Is Governed by This Policy:
All members of the Barnard community, including students, faculty, staff, volunteers, members of the Board of Trustees, and alumnae who are acting on behalf of Barnard or using Barnard resources.
 

Definitions:

Political Campaign Activity:
Directly or indirectly participating in or intervening in any political campaign on behalf of or in opposition to any Candidate for elective office or the promotion or opposition to a ballot referendum. Examples of Political Campaign Activity include, but are not limited to, raising funds or canvassing for a Candidate, recruiting volunteers, distributing a Candidate’s campaign materials, or sponsoring the appearance of a Candidate for public office.

Partisan Political Activity:
Directly or indirectly participating in or intervening in activity in support of a political party, such as fundraising, soliciting, phone-banking, or distributing materials that support or oppose a political party or candidates for office.

Candidate:
A person who has filed a formal declaration of candidacy for an elected, public office or has made a public statement of their candidacy prior to the legal opportunity to declare a candidacy.

Lobbying:
Acting directly or soliciting others to act for the purpose of promoting, opposing, amending, or influencing any action or inaction by any member of the executive or legislative branch of government or any public corporation.

Political Activity:
Activities that are not campaign activities nor involve the promotion or opposition to a ballot referendum but may include voter education and registration, Candidate forums, public opinion polling, responding to constituents as a public official, and get-out-the-vote events, as long as they are nonpartisan and follow the provisions of this policy.

I. POLITICAL CAMPAIGN ACTIVITIES
  a. Permitted Activity

  • Members of the Barnard community, including students, faculty, staff, and members of the Board of Trustees, may participate in Political Campaign Activity and Partisan Political Activity in their individual capacities, provided they take precautions to ensure that their involvement is not attributed to the College and does not involve the use of College resources.
  • In their personal capacities, members of the Barnard community may attend partisan political fundraisers and may donate to political campaigns.
  • Members of the Barnard community may run for political office themselves but must notify their supervisor and the Office of the General Counsel and must ensure that no College resources are used to advance their candidacy and that their campaign does not conflict with their role or responsibilities at the College.
  • Faculty and certain staff, in their official capacity, are encouraged to research, teach, write, or engage publicly on topics that may be relevant to Political Activity and political issues of the day.
  • Members of the Barnard community may analyze, explain, and advocate for their individual views on Partisan Political Activities and Political Campaign Activities, through writing and other media, so long as they expressly state that they are sharing their individual views and analysis and not speaking on behalf of the College.
  • Members of the Barnard community may post research, published or working articles, and academic resources on websites bearing the barnard.edu name or otherwise maintained by the College so long as such posting complies with the College’s Website Governance Policy.
  • Registered student clubs may engage in Partisan Political Activity and Political Campaign Activity but only off campus and without using College resources, including the College’s name/logos/marks, services, supplies, vehicles, interoffice mail, website, printers, or email accounts and without purporting to represent Barnard College.
  • Members of the Barnard community may host issue-specific speakers, events, or other forums on College property so long as such activities support the College’s mission, adhere to the College’s Campus Events and Approval Policy, do not purport to speak on behalf of the College, and do not involve any statements in favor of or in opposition to a candidate or political party.
  • Members of the Barnard community may host an event or other forums on College property at which a Candidate appears so long as the event supports the College’s mission, adheres to the College’s Campus Events and Approval Policy, other Candidates for that office are afforded a similar opportunity to appear, and the hosts of the event present the Candidates in a neutral manner without endorsement or objection.
  • Members of the Barnard community may host an event or other forums on College property in which Candidates appear in noncandidate capacities so long as the event supports the College’s mission, no reference to the election or candidacy is made, and the College maintains a nonpartisan atmosphere at the event.
  • Members of the Barnard community may create and conduct voting information programming, or provide information and resources on the electoral process, so long as such activity is not coordinated with campaign events, does not rate Candidates, and is otherwise published in a nonpartisan and neutral fashion.
  • Members of the Barnard community may participate in Political Activity, including nonpartisan voter registration encouragement or get-out-the-vote activities, including by sending email, postcards, or texts or by using the College’s social media platforms.
  • Members of the Barnard community may assist students in the voting process, including by providing information about voter registration and absentee and mail-in ballots, clarifying the voting process, sending deadline reminders, and providing stamps or resources to assist with the process of voting.
  • The College may rearrange the academic calendar to permit faculty, staff, and students to participate in the election process so long as such rearranging is done without reference to specific campaigns or issues.
     

  b. Prohibited or Limited Activity
    Campaign endorsements, fundraising, or other material support

  • The College, or individuals acting on behalf of the College or reasonably perceived to be acting on behalf of the College, may not endorse any Candidates, make donations to political parties or any Candidate’s campaign, issue statements for or against any candidate, hold campaign rallies, host campaign announcements, or engage in any activity that would either support or oppose any Candidate for public office.
  • No political fundraising or campaigning may occur on the College’s campus, nor may individuals use the College’s resources, including the College’s name/logos/marks, services, supplies, vehicles, interoffice mail, website, printers, or email accounts, to engage in political fundraising and campaigning.
  • No content on the College website may support or oppose a Candidate, and the website may not contain any links to Candidates or campaign-related material.
  • Barnard College faculty, staff, and student employees may not perform tasks related to Partisan Political Activities or Political Campaign Activities during working hours or as part of their official duties.

Reference to a College title or use of College role

  • College officials, faculty, and staff should avoid citing or allowing citation of their professional title or affiliation with Barnard in connection with Political Campaign Activity and Partisan Political Activity, including solicitations, fundraising, and campaigning. If necessary to include a title, the title should be accompanied by a clear statement that the individual’s actions and statements are personal and do not represent the College.
  • Although students are not generally perceived as making official pronouncements on behalf of the College, they must still make clear that their Partisan Political Activities and Political Campaign Activities are personal and not representative of Barnard.
  • College officials, faculty, staff, and students may not engage in Political Campaign Activities and Partisan Political Activities at College functions, through College publications, on College letterhead, or with College email accounts.

    Signage

  • The law does not prohibit students, faculty, or staff from displaying materials related to Partisan Political Activities and Political Campaign Activities in private dormitories and office spaces. However, materials related to Partisan Political Activities or Political Campaign Activities may not be posted in shared hallways, common spaces, or other nonprivate areas, indoors or out, and they may not be visible in rooms or offices (even home offices) of instructors or other Barnard employees (including student employees while they are working for Barnard) when the space is being used for official Barnard meetings, participation in a remote meeting, or remote instruction.

II. LOBBYING

As a tax-exempt institution of higher education, Barnard may not engage in lobbying as a general matter. Federal and state law allow for limited lobbying activities by Barnard administrators on issues directly affecting the College’s mission. To ensure compliance with this narrow exception, as well as federal, state, and local regulatory and reporting requirements, all lobbying on behalf of Barnard College must be approved in advance and supervised by the Office of the General Counsel, working closely with the Vice President for External Affairs.

Members of the Barnard community who wish to lobby government officials regarding particular issues of interest to them on their own time may not use any College resources to lobby, may not use their affiliation with Barnard to advance their lobbying activities, and must make clear they are not advocating on behalf of Barnard.

Questions about lobbying should be addressed to the Office of the General Counsel.

Failure to Comply With This Policy:
Failure to comply with this policy is considered a serious infraction that could jeopardize Barnard’s nonprofit status. Violations of this policy can subject members of the Barnard community to counseling, loss of privileges, and termination of their employment or official role with the College.

Related Policies and Documents
26 U.S.C. § 503(c)(3)

Website for This Policy:
https://barnard.edu/college-policies-procedures