Established: September, 2012
Date Last Revised: March, 2020
Posted: September, 2020
Approved by: Officers
Responsible Office: President's Office
Responsible Senior Staff Member: The President, the Dean of the Faculty, the Dean of Students, the Vice President for Finance and Administration, and the Vice President of College Relations
Scope / Responsibilities
All Mount Holyoke community members - students, faculty and staff - must comply with the policy on activities related to political campaigns.
- Questions on whether planned activities are consistent with the College's obligations should be addressed to the Dean of the Faculty, the Dean of Students, the Vice President for Finance and Administration, and/or the Vice President for College Relations.
- The above individuals and their designees will interpret and apply these policies and guidelines and may consult with the director of government and community relations, the President and/or legal counsel as needed
- Students and student groups planning activities related to political campaigns should discuss their plans with the Dean of Students or their designee. Faculty should discuss with the Dean of Faculty or their designee. All other staff and employees should discuss with the Vice President for Finance and Administration or their designee.
Mount Holyoke College is a charitable, tax-exempt entity subject to federal, state and local laws and regulations regarding activities related to political campaigns. By law, “Organizations that are exempt from income tax under section 501(a) of the Internal Revenue Code as organizations described in section 501(c)(3) may not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of (or in opposition to) any candidate for public office.” (Rev. Rul. 2007-41, 2007-25 I.R.B. June 18, 2007)
This policy statement, which addresses campaigns for political office and related activities, articulates ways in which the Mount Holyoke College community can avoid having their personal opinions appear to be those of the College as an entity. The following specific guidelines are intended to aid all Mount Holyoke College community members in acting consistently with the legal requirements placed on the College.
The prohibitions on participating or intervening in a political campaign, including the use of College resources, apply only to the College and its representatives or agents authorized to speak or act on the College’s behalf. Those prohibitions do not apply to Mount Holyoke students, employees, or others when they are speaking or acting in their individual capacities or as the members of associations other than the College. Individuals taking political positions for themselves or groups with which they are associated should clearly indicate, by words and actions, that their positions are not those of the College and are not being taken in an official capacity on the College’s behalf (specific disclaimer language can be found in the policy’s guidelines).
There is no restriction on discussion of political issues or teaching of politics, campaign-related topics or the electoral process. Specific campaign-related statements, such as endorsement of a particular candidate, should not be made in the classroom. Non-partisan voter registration efforts are encouraged as well as the conduction of public opinion polls and debates where all sides and positions are represented.
In addition, all members of the Mount Holyoke College community are free to express their individual political opinions and engage in political activities. Students, employees and others may support candidates for office or speak in furtherance of political causes, both on campus and elsewhere, subject to the limitations outlined below. In doing so, it is important that members of the Mount Holyoke community speak only in their individual capacities and that they avoid even the appearance that they are speaking or acting for the College in political matters.
Distribution of Policy
All students receive a copy of this policy electronically from the Dean of Students' office or designee, via the Student Handbook notification. All recognized student organizations receive a copy of this policy electronically from the office of student involvement, via email.
All employees receive a copy of this policy electronically from the College, which will be coordinated by the Communications Office, via email at the start of each academic year.
Questions on whether planned activities are consistent with the College's obligations to this policy should be addressed to the Dean of Students for students and student groups, and to the Dean of Faculty for faculty, academic departments, and all staff. Those individuals and their designees will interpret and apply these policies and guidelines in consultation.
Policy Violations (if applicable)
Violations of this policy will be taken seriously, as they could jeopardize the College’s tax-exempt standing. Outcomes of any confirmed violations can include, but are not limited to:
- The loss of the ability for an individual or group to use campus space or other College resources for an extended period of time.
- Student disciplinary action taken by the Dean of Students office or designee with a record kept on file.
- Employee disciplinary action taken by the Dean of Faculty, Human Resources, and or designee with a record kept on file.
Activities Requiring the Use of Facilities or Open Areas on Campus
Members of the Mount Holyoke College community may not:
- Hold fundraisers or host a phone bank for political candidates on College-owned and managed property. Social areas such as the Community Center may be used for distribution of information about political activities and campaigns by the Mount Holyoke community.
- Provide a candidate for public office an opportunity to speak on campus or use College-owned facilities unless authorized by the Events Oversight Committee. In most cases, all legally-qualified candidates (at least) for that office must be offered equal access and opportunity to speak on that or a separate occasion.
- Allow a candidate or political party to conduct a rally or other political event on college-owned and managed property unless authorized by the Events Oversight Committee. This includes campaign-related press conferences.
- Post signs or other campaign-related materials on the grounds or external facings of College-owned and managed property. Such materials also may not be posted by anyone in windows, in common spaces of the workplace, on office doors, etc.
- Students living in residential buildings may post such materials in their personal rooms as long as residence halls policies are followed.
Political Activity and Recognized Student Organizations
Student organizations, including political organizations, officially recognized by the College via the Office of Student Involvement may invite candidates or campaign representatives of their choosing to speak on campus.
- In most cases, all legally-qualified candidates (at least) for that office must be offered equal access and opportunity to speak on that or a separate occasion.
- The date, length, and format of the program and all other aspects of the program should be determined solely by the officially recognized student organization, with no involvement by Mount Holyoke College, except that any College policies and rules generally applicable to all events sponsored by officially recognized student organizations would apply.
- Fundraising at such events is prohibited. Mount Holyoke College is a 501(c)(3) organization and may not sponsor political events that are expressly partisan or provide support to individual candidates running for office.
- The officially recognized student organization and its planners must state expressly, in writing and orally before an event, that they are not speaking or acting on behalf of the College and that the positions expressed are solely their own and do not reflect the positions of the College or its trustees. If a specific candidate is referenced, then the disclaimer should state expressly that Mount Holyoke does not support or oppose the candidate and takes no position on the candidacy.
- All posters, social media, emails, and websites advertising any such event should include the disclaimer: “This student group is not speaking or acting on behalf of the College and the positions expressed at this event or program will be solely our own and do not reflect the positions of Mount Holyoke College or its trustees."
- The Mount Holyoke College seal, logo or other brand assets may not be used in any promotional materials, electronic advertising and/or social media advertising the event.
- Finally, facilities must be available to any officially recognized student organization on an equal basis.
Note, any group of individual students that are not an officially recognized student organization and wish to endorse and or campaign for a specific candidate on campus may do so as long as they follow the guidelines laid out in this policy and in the manual for the use of campus spaces. Particular items that apply:
- When utilizing common spaces in the residence halls, all students must follow the common space policy and procedure.
- Social areas such as the Community Center may be used for distribution of information about political activities and campaigns by the Mount Holyoke community. If a group of individual students wants to utilize the tables in the Dining Commons lobby, they should connect directly with the Office of Student Involvement.
- On any media (social media, physical materials, etc.) it must be clear that said group is student driven and not endorsed by the College nor is it representing the opinions of the College. The College name may not be used. It must be stated expressly, in writing, that they are not speaking or acting on behalf of the College and that the positions expressed are solely their own and do not reflect the positions of the College or its trustees. If a specific candidate is referenced, then the disclaimer should state expressly that Mount Holyoke does not support or oppose the candidate and takes no position on the candidacy.
Political Activity and Student Publications
Student publications may run editorials expressing the editor’s views on candidates for public office, provided that the publication’s editorial policy is free of editorial control by Mount Holyoke administrators or faculty advisors. A statement on the editorial page must indicate that they are not speaking or acting on behalf of the College and that the positions expressed are solely their own and do not reflect the positions of the College or its trustees. If a specific candidate is referenced, then the disclaimer should state expressly that Mount Holyoke does not support or oppose the candidate and takes no position on the candidacy.
Use of the Mount Holyoke Name and the Seal
The College’s name, logo, seal (includingCollege or departmental letterhead) may NOT be used on letters or other materials intended for political campaigns or partisan political purposes.
Use of Mount Holyoke Resources
Members of the Mount Holyoke College community may not use College resources to support candidate endorsements or other similarly-focused political activities Resources include, but are not limited to:
- Mount Holyoke’s website, social media pages or other electronic spaces hosted or maintained by the College.
- College photocopiers or fax machines for the reproduction of campaign literature.
- College office addresses and e-mail addresses as a return mailing address for partisan political mailings.
- College-owned telephones for phone-banking on behalf of a candidate or for other similarly significant partisan political uses. Campus residential telephone services (e.g. in student residence hall rooms or in College-owned faculty/staff rental apartments) may be used for these purposes as well as personally-owned telephone accounts.
- College services, such as interdepartmental mail, e-mail lists and listservs, mailing lists, campus listservs, equipment such as duplicating machines, computers, and facsimile machines, or supplies for partisan political purposes.
- Community members are encouraged to use their personal email accounts for campaign related activities. However, if their College email account is used to support or oppose candidates for political office they should follow the other guidelines in this policy (i.e. not speaking on behalf of the College, not doing so during work hours, not using the College logo, utilizing a disclaimer at the start of their message, etc.).
- In addition, individuals may not request that a College employee, as part of their job, perform tasks in any way related to partisan political purposes.
Distinct from political campaign activities, lobbying consists of activities designed to influence decisions of legislators for or against a particular issue.
The College may at times choose to lobby on a particular issue or topic, in alignment with the College’s mission and values. In these instances, lobbying cannot and will not be conducted on behalf of the College unless authorized by the President or their designee and in consultation with legal counsel.
In accordance, members of the Mount Holyoke College community may not:
- Lobby or attempt to influence federal, state, or local legislative action or a legislative or administrative official or staff member on behalf of College unless authorized by the President or their designee. Any lobbying activity, even when authorized, must be conducted in compliance with applicable law.
- Use federal funds, including contract or grant money, received by the College for lobbying activities.
Note, however, that individuals may individually attempt to influence the legislative process and use their College title for identification so long as such actions or writings are accompanied by a statement that the person is speaking as an individual and not as a representative of the College. (e.g. “The positions expressed in this letter are those of the individual(s) signing below and not an official position of Mount Holyoke College or its trustees.”). If a specific candidate is referenced, then the disclaimer should state expressly that Mount Holyoke does not support or oppose the candidate and takes no position on the candidacy.
Employee Campaign Participation
Employee participation in campaigns of candidates for public office is permitted when it is outside normal work hours, during work hours but allocated to leave or other non-work time, does not involve College funds or other resources and includes an express disclaimer (see disclaimer above under lobbying).
Frequently Asked Questions Related to the Policy
How does the College respond to misperceptions?
If a member of the Mount Holyoke community were to make a statement that gives the impression or is perceived as that person speaking on behalf of the College, the College may issue a statement that makes clear that the statement(s) said by the individual do not represent the position of the College nor does the individual speak on behalf of the College. Then as per the policy violation section of this policy, the individual could face disciplinary action and or other outcomes.
What’s the difference between partisan activities?
There is a difference between election-based and issue-based partisan activities. However, it is important to be aware of not linking lobbying for a political issue with a political campaign. (ie: We support this issue and therefore you should vote for this particular candidate. Or we support this issue and here is a poster with a candidate's image on it.)
- The College, and those speaking on its behalf, should follow the guidelines laid out in this policy related to lobbying.
- A student group wanting to lobby for a particular issue should discuss their plans with the Dean of Students or their designee.
How and when should disclaimers be used?
Disclaimers should be used any time the event or activity could reasonably be perceived as College-endorsed. Examples include:
- A professor stating that they are a professor at the College and they endorse a specific candidate. A disclaimer should be used in this instance.
- The President of the College writing an op-ed related to a political issue:
- If the President is authorized to speak on behalf of the College, a disclaimer is not needed.
- If the President is speaking as an independent party, a disclaimer should be used.
What disclaimers should be used on social media?
Here is an example of an appropriate disclaimer, for social media channels: “The statements posted here reflect only the positions of the parties speaking and should not be considered an endorsement by Mount Holyoke College.”
Can MHC use images of candidates?
If a candidate has previously spoken on campus and the College wants to use photos, videos, etc. for communications purposes, that is OK as long as the images. are contextualized. For instance, a photo of a now candidate giving a book tour could be captioned as “Candidate joined the Mount Holyoke community in 2016 for …”
Can I have a campaign-related mug or bag?
While you are not allowed to post campaign-related materials on your office wall, campaign-related personal property, such as a mug or work bag, can be displayed in one’s work space.
- Events Management Policy
The Events Management Policy has been established in order to be sure that events held on campus are properly vetted, approved and resourced (financial and staff) appropriately.
- Manual for the use of campus spaces
The Campus Facilities Use Manual provides detailed policies and procedures for use of space at Mount Holyoke College.
- Media Access Policy
- Recognized Student Group Handbook
Includes policies and procedures as they apply to recognized student organizations, including the student event policy and procedures.
- Student Event Policy and Procedure
This policy applies to all Mount Holyoke student sponsored events and programs, including those held by recognized student groups, that occur on-campus.