Gettysburg College Partisan Political Activity Policy

Administrative Policies

Gettysburg College Partisan Political Activity Policy

Purpose of Policy

Gettysburg College, as a tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code, is prohibited from participating or intervening in any political campaign on behalf of or in opposition to any candidate for public office. Political intervention includes financial contributions and the publication or distribution of written or oral statements on behalf of or in opposition to a particular candidate or political party. There are no exceptions to this prohibition.

At the same time, the College is dedicated to the pursuit of truth and acquisition of knowledge through the free expression of ideas, and it encourages students, faculty, and staff, in their individual capacities, to participate fully in the political process during campaigns for public office as long as they do not involve the College.

Scope of Policy

This policy applies to all members of the College community, including but not limited to faculty, administrators, other employees, trustees, students, retirees, alumni, contractors, vendors, and volunteers when representing the College, using College resources, or when their actions could reasonably be construed as representing the College’s position.

In order to encourage the open exchange of ideas during partisan political campaigns for public office without jeopardizing the College’s tax-exempt status, all members of the College community must comply with the provisions of this policy with respect to their participation in national, state or local political campaigns.

Definitions

College Department: Any academic or administrative department, program, or office operated directly by the College.

College Resources: Any funds, services, systems, or images managed by the College, including but not limited to the College’s name, seals, trademarks, mottos, operating budgets, grants, donated funds, agency accounts, mailing lists, email accounts, email lists, list serves, online platforms, digests, copiers, supplies, and phone, mail or facsimile systems.

Designated Posting Areas: Corkboards, bulletin boards, and similar surfaces where community members are permitted to post flyers or similar items as outlined in the College’s Policy and Guidelines for Public Expression, Invited Speakers, and Distribution of Written Materials on Campus.

External Organizations: Any organization or person that is not a College Department or a Registered Student Organization.

Facilities: Any building or outdoor space that is owned, leased, or otherwise controlled by the College.

Registered Student Organization: A student group or organization that has completed the registration process through the Office of Campus Life.

Policy Description

4. A General

All individuals within the scope of this Policy are free to express political opinions and engage in political activities in their individual capacities and without suggesting that they are speaking or acting on behalf of the College. 

Political Fundraising is strictly prohibited on campus and at all College events. College funds or funds managed by the College, including Student Senate allocated funds, may not be contributed to or donated to any political campaign or candidate. College Resources cannot be used to support any political campaign or candidate or for issue advocacy undertaken for the purpose of supporting or opposing a candidate or party in a political campaign, except as expressly provided in this policy. 

4. B Political Activities of Individual Campus Community Members

All members of the College community are permitted and encouraged to engage in political activities in their individual capacities. When endorsing or opposing a candidate for political office, or taking a position on an issue for the purpose of endorsing or opposing a candidate for political office, individuals and groups within the College community must not mention their affiliation with the College or, if that affiliation is mentioned, must also make it clear that the views expressed are their own and not the views of the College. This is particularly important for those who frequently speak for the College in their official capacity.

Community members may not use College Resources, Designated Posting Areas, or Facilities to conduct political activities on behalf of an External Organization, including but not limited to campaigns, political action committees, and political parties, except when students establish local chapters or branches of those organizations as a Registered Student Organization. Individual students may use Designated Posting Areas to express personal political views as long as those postings comply with the College’s Policy and Guidelines for Public Expression, Invited Speakers, and Distribution of Written Materials on Campus, but may not post materials on behalf of or created by External Organizations.

4. D Activities of Registered Student Organizations

1. Registered Student Organizations are subject to the general prohibitions against political fundraising on campus and the prohibition against donating or contributing College Funds to a political campaign or candidate. Registered Student Organizations are free to engage in other partisan political activities so long as their activities are not construed to express the viewpoint of the College. The College may require Registered Student Organizations that are engaged in political activities to expressly state that their activities do not express the viewpoint of the College.
2. Registered Student Organizations may invite and host candidates for public office to speak on campus on topics of interest to the campus community for non-campaign-related reasons and may use College Resources for such events, provided that:

(a) the individual is chosen to speak solely for reasons other than their candidacy for political office;

(b) the individual speaks in their non-candidate capacity;

(c) the event is structured to serve a genuine educational purpose with content focused on policy, governance, or issues other than electoral advocacy or issue advocacy for the purpose of supporting or opposing a candidate or party in a political campaign;

(d) no reference to the election, including statements of support or opposition to any candidate, is made, either by the individual or the Registered Student Organization at the event or in the communications announcing the event;

(e) the Registered Student Organization hosting the event takes reasonable steps to maintain a nonpartisan atmosphere at the event; and

(f) The event complies with the College Event Sponsorship Policy and the College Policy and Guidelines for Public Expression, Invited Speakers, and Distribution of Written Materials on Campus.

If a Registered Student Organization hosts a candidate for public office at such an event and does not extend an invitation to all other legally qualified candidates, they must document the educational rationale for not doing so when submitting the external speaker approval forms outlined in the Policy and Guidelines for Public Expression, Invited Speakers, and Distribution of Written Materials on Campus.

iii. Registered Student Organizations may use College Facilities to host a political candidate for a campaign event or for any event that will mention the candidate’s campaign for public office, only if the following conditions are met:

(a)The event is conducted in a manner that makes clear that the views expressed during the event are those of the Registered Student Organization and not of the College.

(b) The event complies with the College Policy and Guidelines for Public Expression, Invited Speakers, and Distribution of Written Materials on Campus.

(c) The event is not held in a public space, including but not limited to outdoor spaces, The Junction, or building lobbies.

(d) The event is authorized and supervised by the College.

(e) The event is not conducted as a political rally or fundraiser.

For such events, College Resources, including funds distributed through the Student Senate, may not be used to compensate a candidate, contribute to a candidate's campaign, otherwise cover costs that the candidate or campaign are responsible for, or support political fundraising. College Resources, including Student Senate funds and other student organization funds managed by the College, can be used for ordinary event needs and expenses such as food, printing advertising flyers, and room setup.

1. Registered Student Organizations are permitted to advertise their events in Designated Posting Areas in a manner that is consistent with how other events on campus can be advertised. Registered Student Organizations may also use Designated Posting Areas for political materials developed by the organization, or that are provided by External Organizations they are formally affiliated with, provided those postings comply with the College’s Policy and Guidelines for Public Expression, Invited Speakers, and Distribution of Written Materials on Campus.
2. Registered Student Organizations are permitted to post partisan political materials, including those that promote or oppose candidates in a political campaign and those focused on issue advocacy undertaken for the purpose of supporting or opposing a candidate or party in a political campaign, in Designated Posting Areas. College funds, including Student Senate funds and other student organization funds managed by the College, may not be used for costs associated with creating or printing these materials.

4. E Instructional Activities of Faculty Members

Consistent with the principles of academic freedom, faculty members are not prohibited from making partisan political commentary to the extent that such commentary relates to the subject of instruction and is aimed at developing students’ complete understanding of an issue. Nonetheless, in these instances, faculty members must make clear that the views expressed are those of the faculty member and not of the College.

Because of Internal Revenue Code requirements applicable to the College, faculty members must avoid the persistent intrusion of partisan political commentary having no rational bearing on the subject of instruction. Buttons, slogans, or signs supporting a candidate or a political party, when unrelated to the subject of instruction, are not permitted during instruction. 

Faculty members are strictly prohibited from:

(i) penalizing or negatively assessing a student for expressing a political viewpoint that is contrary to, or critical of, the political viewpoint of the faculty member; and

(ii) rewarding or otherwise preferentially assessing a student for expressing a political viewpoint that is in agreement with, or supportive of, the political viewpoint of the faculty member.

A faculty member may provide instructional opportunities to speak on an equal basis to all legally qualified candidates for a public office, provided that the lecture is conducted in a manner that makes clear that the views expressed during the event are those of the speaker and not the College; the lecture is conducted for the purpose of educating students and not as a campaign rally or event; and the lecture relates to the subject of instruction in the course and is aimed at developing students’ complete understanding of an issue. Candidates may not receive financial remuneration from the College or the faculty member for their instructional appearance during a political campaign.

4. F Activities of College Departments

A College Department may conduct a public forum to which all legally qualified candidates for a public office are invited and given equal opportunity to speak. If a College Department extends an invitation to a candidate to speak in their capacity as a candidate, it must take steps to ensure that all legally qualified candidates are invited to a substantially similar event. Such events must be conducted in a manner that makes clear that the views expressed during the event are those of the speakers and not of the College Department or the College; the event must be conducted for the purpose of educating students (and not as a campaign rally or fundraising event); and the format and content of the event must be presented in a neutral manner that does not favor any candidate over the others.

Candidates may not receive any financial remuneration from the College for their appearance during a political campaign.

College Departments may invite a candidate for public office to appear at a College event for non-campaign-related reasons and without inviting all other qualified candidates, provided that:

(i) the individual is chosen to speak solely for reasons other than their candidacy for political office;

(ii) the individual speaks in their non-candidate capacity;

(iii) no reference to the election is made, either by the individual or the College Department; and

(iv) the College Department hosting the event takes reasonable steps to maintain a nonpartisan atmosphere at the event.

Campaigning at any such event is prohibited. The College Department hosting the event must clearly indicate the capacity in which the individual is appearing, and no mention of the upcoming election is permitted, whether at the event or in communications announcing the event. The College Department hosting the event must make the following announcement at the beginning and conclusion of the event, "As part of the College’s educational mission and commitment to a liberal arts education, Gettysburg College is pleased to provide this forum for respectful discussion. Gettysburg College does not support or oppose [candidate’s name] or any other political candidate, and the opinions or viewpoints of the speaker are the speaker’s own and do not represent a statement of the College’s opinions or viewpoints. Please remember this is an educational opportunity for students and community members. It is not a political rally and political fundraising at this event is prohibited.” This announcement must also be included in any advertisements for the event.

External Organizations may rent College Facilities, subject to availability and the College Event Sponsorship Policy, to host partisan political activities, provided that partisan political fundraising is strictly prohibited at the event. The College will charge market rental rates, as determined by the College, for such events.

Policy Management

The Office of Human Resources (HR) and College Life are jointly responsible for implementing this policy. HR oversees enforcement for employees, and College Life oversees enforcement for students

Related Materials

Links to relevant federal, state, or local laws or ordinances, links to relevant bylaws or rules, and material directly related to policy implementation

 IRC 501(c)(3): 26 U.S. Code § 501 - Exemption from tax on corporations, certain trusts, etc. | U.S. Code | US Law | LII / Legal Information Institute

 FAQs published by the IRS:  Frequently asked questions about the ban on political campaign intervention by 501(c)(3) organizations | Internal Revenue Service

 Guide Published by the American Council on Education:  Student-Voting-and-College-Political-Campaign-Activities-Issue-Brief.pdf