With the Ontario general election coming up on June 7, registered charities should take a moment to review the restrictions on political activities.
It is key to remember that registered charities are totally prohibited from engaging in partisan political activities. They can only engage in non-partisan political activities, and only to a limited extent. The CRA’s Advisory on partisan political activities[i] is a succinct refresher on the existing policy[ii], and in fact expands on it a little by adding new examples of ‘partisan political activity’.
The Advisory’s examples of partisan (i.e. prohibited) political activities include:
- providing financial or material contributions to a political party or candidate
- making public statements (oral or written) that endorse or denounce a candidate or political party
- criticizing or praising the performance of a candidate or political party
- organizing an all-candidates meeting or public forum in a way that could be seen to favour a political party or candidate
- inviting candidates to speak at different dates or different events in a way that favours a candidate or political party
- posting signs in support of, or opposition to, a candidate or political party
- distributing literature or voter guides that promote or oppose a candidate or political party explicitly or by implication
- explicitly connecting its views on an issue to any political party or candidate
Volunteers, employees, and directors of a charity are allowed to help in a political campaign, as long as they do it in their personal capacity and do not suggest that they represent the charity.
There is a particular emphasis in the Advisory on appropriate ways of using social media. This should be taken as a hint that the CRA will be checking out the social media accounts of charities and of the people involved in them when looking for unacceptable political activities. Charities should make a point of bringing these guidelines to the attention of everyone in their organization, especially the board of directors and the individual(s) responsible for the social media accounts.
Here are the main points to keep in mind:
- Volunteers, employees, and directors may make public partisan political comments (including on social media) only if they make it clear they are speaking on their own personal behalf, and not as a representative of the charity.
- The charity’s own social media accounts should neverbe used to post content that includes partisan political statements (i.e. statements expressing support for or opposition to a specific party or candidate, or encouraging people to vote for or against them). This includes not linking to third-party statements that support or oppose a specific party or candidate.
- Any of the charity’s online platforms (blog, website, Facebook page, etc.) that allows comments must be monitored for partisan political statements and remove them in a timely manner.
Ensure your charity has a solid social media policy, that its accounts are run by a knowledgeable and responsible person, and that any personal accounts of its directors and employees clearly indicate that they are speaking personally and not on the charity’s behalf. Go through existing website and social media content and remove any partisan statements. If you are unsure whether a statement is considered partisan, err on the side of caution.
Remember, the CRA knows how to use Google and they are within their rights to revoke a charity’s registration for breaching the political activity rules.
[i] Available at https://www.canada.ca/en/revenue-agency/services/charities-giving/charities/resources-charities-donors/resources-charities-about-political-activities/advisory-on-partisan-political-activities.html
[ii] For full details on all the relevant policies, see https://www.canada.ca/en/revenue-agency/services/charities-giving/charities/resources-charities-donors/resources-charities-about-political-activities.html