Non-partisan · FEC public record

Campaign Finance data-use policy

Campaign Finance republishes public campaign-finance records in the public interest. This page states the legal basis and the hard firewall rules the pipeline enforces.

Legal basis

Campaign Finance operates as a press-like publisher of public records under the 11 CFR 104.15(c) media / publication exception, consistent with FEC v. Political Contributions Data, Inc., 943 F.2d 190 (2d Cir. 1991), which narrowly construes "commercial purpose" and treats a for-profit compiler of public FEC data as press-like. Campaign Finance does not rely on the aggregated-data advisory opinions (AO 2012-22 / 2014-07), which do not authorize individual-name display.

Statutory-use restriction (federal)

Federal law (52 U.S.C. §30111(a)(4); 11 CFR 104.15) bars using FEC contributor information to solicit contributions or for any commercial purpose. Iowa's IECDB data (Iowa Code 68B.32A(7)) is licensed CC BY-NC — stricter still. Where individual contributor data is shown, Campaign Finance posts the statutory notice and attributes the source ("Source: FEC" / "Source: IECDB").

Hard firewall rules (enforced in code)

  1. Never display individual donor street address or phone — anywhere (UI, API, export, page source, cached JSON). The permitted field set is name, city/state, employer, occupation, amount, date, recipient.
  2. Monetize the value layer, never the raw list. Campaign Finance does not sell, rent, or paywall the raw individual-contributor records, and builds no donor-propensity model (the MUR 7062 line).
  3. Fundraising firewall. Campaign Finance never uses displayed contributor data to solicit the people in it. Any Campaign Finance donation/opt-in list is built strictly from site opt-ins — never seeded from ingested data.
  4. Share cards are aggregate-only. The real defamation exposure is private donors (a negligence standard, unlike public officials' actual-malice standard). An entity-resolution false merge on a viral card is the risk, so shareable cards show aggregate figures only; named individuals appear only in the deeper table with a match-confidence indicator.
  5. No accusatory imputation. The auto-generated "notable context" line is leashed to on-page cited facts and hard-blocks accusatory/criminal terms.

v1 scope

v1 displays aggregate figures only — no individual-contributor rows are shown at all — so rules 1–4 are satisfied trivially today. They are documented here because they govern the deeper donor table shipped in a later phase, and are wired into the render layer from day one.