AS-12 Guidelines for Using MCCCD Email System for Fundraising Promotions

The various Maricopa Community College locations and the District Office are often approached by entities seeking to “partner” with the institution in order to either utilize our facilities or email messaging system for their events and promotional efforts. Oftentimes, such requests come with offers for some sort of exchange (i.e., share in proceeds for the sale of goods; discounts, tickets to events, scholarship donations, etc.) if the college or District targets employees and or students with messaging.

These Guidelines serve as interpretations of already existing MCCCD Administrative Regulations such as Technology Resource Standards, Electronic Communications, Use of College Facilities, and Use of College Grounds and are meant to help assist college designees in performing a due diligence review of offers to “partner and promote.” Utilizing college resources to promote or announce outside events requires exercising great discernment. In all instances, the Maricopa Business purpose must be clearly evident and the decision to engage must be in the best interests of the stakeholders of the MCCCD and not present even the appearance of a conflict of interest. Events must be strictly sponsored or co-sponsored by an MCCCD College or the District. Likewise, these arrangements should be clearly part of our organizational mission and values.

The term “sponsor” relates to activities that are organized by employees who are acting in an official capacity as agents on behalf of the MCCCD and that have been approved through appropriate District/College administrative channels. The task should also fall within the scope of such individuals’ employment duties and responsibilities. Sponsoring involves MCCCD as the entity that is inherently involved as the primary organizer and resource provider. The term “co-sponsor” means any non-commercial activity of an educational or community nature in which MCCCD is an announced and publicized co-sponsor with another organization or organizations, must include MCCCD personnel who actively participate in the planning and managing of the activity, and the co-sponsorship must be approved at the vice president level or above.

By contrast, hosting is prohibited. The term “hosting” means a circumstance in which an outside [for-profit] entity asks MCCCD to provide facilities and other resources for an event the entity wishes to sponsor that meets all three of the following criteria:

  1. the fee that the outside entity will charge attendees for the event is significant;
  2. the targeted audience for the event is generally commercial; and
  3. the outside party requests that MCCCD facilities and, if applicable, services (such as marketing or email notices to MCCCD employees about the event) be supplied at no cost to that entity in exchange for waivers of registration fees for a certain number of MCCCD employees to attend the event.

In addition, the following standards are designed to provide guidance on determining what types of opportunities are appropriate to post using the district wide distribution lists: dl-maricopa-announcements or dl-maricopa-business:

  1. All fundraising messages proposed to be sent using Maricopa’s email system (MEMO, Gmail, other college-based email system) must be approved by College/District administration;
  2. The event must be sponsored or co-sponsored (as defined above) by the MCCCD (a College or District);
  3. Organizers who have a personal or special interest in the event should be aware of perceived conflict of interest issues and make sure that their participation is solely as an MCCCD employee and not to promote their personal self interest (i.e., consultant, solicitor, advisory committee or board member for a commercial vendor, etc.);
  4. Partnerships with the Maricopa Foundation should meet the Foundations’ standards AND have the College Administration’s approval;
  5. Benefit fundraisers should be structured and promoted in a manner that serves to focus the interests of the MCCCD (vision, mission, values). Scholarship fundraisers should be structured in a manner where the majority of the proceeds collected actually go toward student scholarships vs. for administrative costs;
  6. Appropriate cash handling procedures must be adhered to. See:
  7. The focus of email messages should be in line with the interests of the MCCCD and not on promoting third-party interests, commercial or for profit products or services;
  8. Events with ticket sales or groups selling commercial products are directed to work with the Employee Store for review of the activity against ESM vendor standards and direct distribution of the message;
  9. Raffles, games of chance, or gambling in any form are prohibited—this means that no College/District resources (including staff time, equipment, work space, telephone, computers, etc.) can be used to conduct a raffle or other gambling activity; employees may participate in such endeavors on personal time and with personal resources;
  10. Email messages may not be used to support partisan political candidates, party fundraising, or causes [under ARS §15-1408, a community college district may not "use its personnel, equipment, materials, buildings or other resources for the purpose of influencing the outcomes of elections."]
  11. Each message should contain the contact information of the sponsoring agency/department

Use of College Grounds (portions of this regulation are incorporated here for reference purposes)

In contrast to traditional public forums such as a public square, park, or right of way, Maricopa’s campuses are dedicated by law to the purpose of formal education. They are, and have been since their creation, for the use and benefit of prospective and enrolled students, the Maricopa employees who serve them, and those who are invited to campus by members of the College community to attend or participate in sponsored events. The Maricopa County Community College District (MCCCD) has a long history of regulating the time, place, and manner in which expressive activities are conducted on campuses, for the purposes of avoiding disruption or interference with its educational activities, and protecting the rights of the members of the campus community and their invited guests to express themselves and access information. While members of the general community always have been welcome to share their ideas with the campus community, they are subject to reasonable, content-neutral regulation of the time, place and manner of the event and to the institution’s mission-based priorities – including but not limited to the need to provide an environment conducive to teaching and learning.

Non-MCCCD-Affiliated User: Any non-MCCCD-affiliated entity that would, on the premises of any Maricopa Community College or Center, purport to sell or promote any product, service, or idea, but does not include such an entity that would enter the premises for the purposes of promoting, opposing, or soliciting petition signatures in connection with any political candidate or initiative, or referendum ballot.

Low-Impact, Non-Commercial Activity: Defined as 1) activities that do not seek to sell or promote a product or service for direct or indirect financial gain; 2) activities that are limited to gatherings of five people or less at any given time; and 3) activities that do not involve machinery, temporary structures, tables, chairs, displays, or electronic equipment, including amplifiers, or the distribution of food products.

This does not include such an entity that would enter the premises for the purposes of promoting, opposing, or soliciting petition signatures in connection with any political candidate or initiative, or referendum ballot. (See Petition Signature Solicitation, AR 2.4.8).

Use of the MCCCD email system to promote special events as defined by this regulation is permissible. However, solicitors requesting access to a Maricopa Community College or Center for their own purposes should not be promoted via the MCCCD email system.

Use of College Facilities (portions of the regulation are incorporated here for reference purposes)

Use of MCCCD facilities is the use of a public resource. Therefore, facilities use by non-MCCCD parties or MCCCD employees or Governing Board members for personal, business or non-MCCCD activities must be consistent with state law and Maricopa Governance policies and regulations. The following principles apply to facilities use:

  1. MCCCD is not obligated to permit facilities use for any activity that the Vice Chancellor of Business Services, College President, or that official's designee determines is contrary to public policy or the safety of persons or property, or is not in the best interest of the community or MCCCD.
  2. MCCCD employees, Governing Board members, or their relatives or associates may not use MCCCD facilities for personal or business purposes, or for non-MCCCD activities, without complying with the standards and procedures specified in this administrative regulation applicable to non-MCCCD parties. That includes compliance with the requirements for insurance coverage and the payment of rent. MCCCD-sponsored programs for employees, such as health and fitness programs, are considered MCCCD activities under this regulation. At the discretion of the Vice Chancellor of Business Services, College President or that official's designee, an MCCCD employee or Governing Board member may use facilities for an event without complying with the rent or insurance requirements of this regulation where the event meets the following limited conditions:
    1. The employee or Governing Board member actively participates in the event and is responsible for managing it; and
    2. The event is for a professional organization in which the employee or Governing Board member actively participates, and whose objectives directly relate to the employee's work at MCCCD or to the Governing Board member's MCCCD responsibilities.

      The Vice Chancellor of Business Services or College President may establish guidelines for the use of MCCCD facilities under this professional organization exception, including any reasonable reimbursement of expenses as appropriate.

  3. Before using MCCCD facilities, non-MCCCD parties must submit certificates of insurance to MCCCD covering that use. Arizona law requires that insurance coverage be provided.
  4. Non-MCCCD parties, including non-profit agencies or other public entities, must pay fair market rent unless the use relates directly to MCCCD's stated mission. Reduced rent, or no charge, is appropriate only as specified in this regulation.
  5. MCCCD will not enter into a license or lease agreement, as defined in this regulation, where facilities use is strictly for personal or business purposes, or does not have some relationship to MCCCD's mission of education and training.
  6. MCCCD classes, programs and activities for students have priority over all other activities, and other MCCCD activities have priority over non-MCCCD activities.
  7. MCCCD has the right to approve any advertising concerning a non-MCCCD party's use of MCCCD facilities.
  8. A non-MCCCD party must obtain specific authorization from the Vice Chancellor of Business Services, College President or that official's designee to operate any concession activity at MCCCD facilities.
  9. A non-MCCCD party may not alter an MCCCD facility without the prior written approval of the Vice Chancellor of Business Services, a College President, or that official's designee.
  10. Hosting is prohibited under the Use of College Facilities regulation.

Community Service Projects

Community service projects may be promoted using MCCCD’s email system as long as the events have been approved by College or District administration. Such projects should either be tied to a course or meet the definition of co-sponsorship as set forth in Use of College Facilities (AR 1.15). Promotion of charities or charitable events requesting donations, or service in lieu of donations, must also be approved by College or District administration.

Use of Logos/Marks (portions of the regulation are incorporated here for reference purposes)

The Maricopa County Community College District owns and controls its name and the names of its colleges as well as names that have become associated with them such as the “Maricopa Community Colleges,” and all logos, insignia, mascot designs, and other marks that the District or its colleges use (collectively called “Marks”). The District has registered many of these with the United States Patent and Trademark Office. See for specific criteria and restrictions, as outlined in the Use of Marks administrative regulation (AR 4.19). The purpose of our licensing regulation is to protect the integrity of the District’s Marks and to enhance the positive image of the District and its colleges through approval of the use of the Mark by licensees who adhere to District standards. This regulation provides guidance on permissible use, as well as restrictions on the use, of the Marks. It also designates responsibility for granting permission through written license agreements. An outside party’s use of the Marks without a license as required under this regulation is prohibited and may constitute trademark infringement, trademark dilution and unfair competition in violation of federal and state laws.

Use of MCCCD Marks in email advertising must meet the standards set forth in AR 4.19 and be approved by College or District administration. Third-party partners should never use MCCCD Marks without approval.


Raffles are prohibited as Arizona law prohibits all gambling unless the gambling falls within an express statutory exception. "Gambling" includes any act of risking or giving something of value for the opportunity to obtain a benefit from a game or contest of chance or skill or a future contingent event, (see: ARS § 13-3301). A raffle involves the payment of money for the opportunity to benefit from a future contingent event and therefore is considered illegal unless the raffle satisfies a narrowly defined statutory exception.

Unless a tax-exempt organization as recognized under ARS §43-1201, paragraphs 1, 2, 4, 5 ,6, 7, 10, or 11, a raffle or any other form of amusement gambling may not be conducted unless the event is registered with and approved by the Arizona Attorney General's Office, 1275 West Washington Street, Phoenix, AZ 85007, 602.542.3881. To register, you must complete a written Amusement Gambling and Raffle Registration Form for approval by the Attorney General's Office. (ARS §13-3311) If you are a tax-exempt organization as recognized under ARS §42-1201, paragraphs 1, 2, 4, 5, 6, 7, 10, or 11, then you do not need to register with the Arizona Attorney General's Office but you still have to meet the conditions of ARS §13-3302, B.

For More Information

Please review the following administrative regulations that provide primary guidance, as well as information posted at the Conflict of Interest and District Marketing websites:

Technology Resource Standards

Electronic Communications

Use of Facilities

Use of College Grounds

Use of MCCCD Marks

Conflict of Interest

Conflict of Interest (An Employee MEID is needed to enter secure site.)

Marketing Standards

MCCCD’s marketing standards can be found at These standards should be adhered to in all promotional activity. Specific marketing questions may be directed to College or District Marketing departments. Questions regarding the use of MCCCD’s email system should be referred to the Manager of the Office of Public Stewardship at (480) 731-8880.

ADOPTED August 31, 2012