COGENCY Member Agency Portal pilot terms and privacy notice
- Version
- 2026-10-28.1
- Status
- Approved by Mohsin Sardar on 2026-10-28
These terms explain how COGENCY IPA, Inc. runs the Member Agency Portal pilot, what you may and may not put in it, how your information is handled, and who to contact. They apply to every person who signs in, including COGENCY staff.
What you agree to at first sign-in
This pilot portal is for agency-level grant and quality-improvement work only. Do not enter client names, dates of birth, addresses, medical record numbers, or any other identifying client information. AI-assisted outputs are working drafts and must be checked against the funder’s official instructions and approved agency sources before use. Forum content may be moderated or removed under COGENCY’s pilot policy. By continuing, you agree to the pilot terms and privacy notice.
1. What the portal is for
The portal is for agency-level work by COGENCY member agencies: finding and tracking funding opportunities, planning and preparing grant applications, reviewing aggregate quality-improvement measures, and working with other member agencies and COGENCY staff.
Use it only for your agency's work and only within the role COGENCY gave you. Do not use it for personal matters, for clinical care, or for any work for an organization that is not a COGENCY member agency.
2. No client information (no PHI)
The portal is not a clinical or client record system and is not covered by a business associate agreement. Never enter protected health information or anything that identifies a client.
- Do not enter client names, initials tied to a case, dates of birth, addresses, phone numbers, email addresses, Medicaid or insurance numbers, medical record numbers, case numbers, photos, or any other detail that could identify a client.
- Do not upload client records, case notes, intake forms, incident reports, or files exported from an EHR or care-management system.
- Use aggregate numbers only (for example, "we served 1,240 adults last year"). Small counts that could point to a person should be left out.
- The portal screens some text and uploads for identifiers and refuses what it finds, but the screen is a safety net, not permission. You remain responsible for what you enter.
- If you enter client information by mistake, stop, do not copy it elsewhere, and tell the incident contact (section 8) the same day so it can be removed.
3. AI assistance and human review
Some features use an AI model (Anthropic's Claude) to extract requirements from solicitations, pull facts from documents you add to your agency's evidence vault, and draft application sections.
- AI-assisted outputs are working drafts. A person at your agency must check every output against the funder's official instructions and your agency's approved sources before it is used or submitted.
- The portal never submits anything to a funder. Submission is always done by your agency, outside the portal.
- Text sent to the AI model is processed by Anthropic under its standard commercial API terms. COGENCY does not have a zero-data-retention agreement with Anthropic. Under the standard terms Anthropic deletes API inputs and outputs within 30 days (with limited safety and legal exceptions) and does not train on them by default.
- Never upload client records or any client information to the evidence vault or paste it into an AI feature.
4. Forum and Network Pursuits conduct
The forum and Network Pursuits are shared with staff from other member agencies and COGENCY. Keep posts professional, accurate and about agency-level work.
- No client information, no personal contact details of clients or third parties, no confidential funder information you are not allowed to share, and no harassment, discrimination or advertising.
- You can correct or remove your own posts. A removed post becomes a content-free tombstone: the title and text are cleared and only a note that it was removed remains visible.
- Any member can report a post, reply or pursuit update to COGENCY. COGENCY moderators review reports and may hide, pin, or remove content that breaks these terms. Moderator removals also leave a content-free tombstone.
- COGENCY keeps the prior text of an edited or removed post in an admin-only history so that moderation decisions can be reviewed. That history is not shown to members.
5. Authorized users and role duties
Accounts are personal and by invitation only. Do not share your sign-in, and do not let anyone else use your session.
- Members: use the portal for your own agency's work and follow these terms.
- Agency admins: invite only current staff of your agency who need access, give them the lowest role that works, and remove people promptly when they leave or change jobs.
- COGENCY admins: manage agencies and roles, moderate community content, and respond to incidents. COGENCY admins can see every agency's portal for support and network work.
- Everyone: tell the incident contact (section 8) at once if you think your account, a colleague's account, or any data in the portal has been misused or exposed.
6. Access changes and revocation
- COGENCY or your agency admin can change your role or remove your access at any time, for example when you leave your agency, when your agency leaves the pilot, or if these terms are broken.
- Removal ends your sessions; your next page or request is refused.
- Content you created for your agency stays with your agency's workspace after you leave, unless your agency asks for it to be deleted under section 7.
7. Retention and deletion
This is the proposed pilot schedule. Purges are run by COGENCY (not yet automated) and recorded in the release log.
| Data | Keep | Then |
|---|---|---|
| Member work (workspaces, grant profiles, dispositions, forum, Network Pursuits, pipeline) | While the agency is a member | Delete within 90 days of an agency leaving, on request |
| Evidence-vault documents, text and extracted facts | Until the agency deletes them, or while the agency is a member | Deletion removes the file, its text, search index and AI-extracted facts together; database restore history keeps a copy until it expires |
| Audit trail (who did what, never content) | 2 years | Delete |
| Pilot-terms acceptance records (user id, version, time) | 2 years, like the audit trail | Delete |
| Client-error records | 90 days | Delete |
| Pilot usage events (no personal data) | Pilot + 12 months | Aggregate, then delete the raw events |
8. Incident and support contact
For support, to report a suspected incident or exposure of information, or to report a mistake such as client information entered by accident, contact Mohsin Sardar at msardar@cogencyipa.com. Mohsin Sardar is the incident and support contact for the pilot.
9. Privacy notice
What COGENCY collects about you: your name, work email, agency and role (from your invitation), sign-in and session records kept by our sign-in provider, and an audit trail of actions you take in the portal (who, what, when and the outcome, never the content you wrote). When you accept these terms COGENCY records your user id, the policy version and the time (UTC).
What your agency stores: grant work, profiles, documents and posts that you and your colleagues enter. This is agency information, not client information.
Why: to run the portal, keep it secure, support member agencies, and measure the pilot. COGENCY does not sell your information or use it for advertising.
Who sees it: people at your agency with portal access, COGENCY admins, other member agencies for content you post in shared spaces (forum and Network Pursuits), and the service providers in section 10, only to provide their service.
Your choices: you can ask the contact in section 8 for a copy of your account information or to correct or delete it, subject to the retention schedule in section 7.
10. Service providers
The portal runs on these providers. None of them has a business associate agreement with COGENCY, which is another reason client information must never be entered.
| Provider | What it does | What it receives |
|---|---|---|
| Netlify | Hosting, server functions and file storage | All portal data in transit; uploaded vault files and some records at rest |
| Neon | Database (system of record for member data in the pilot) | Agency work, vault text and facts, audit trail, acceptance records |
| Clerk | Sign-in, accounts and sessions | Your name, work email, password and MFA factors, agency and role, session and device data |
| Cloudflare Turnstile (through Clerk) | Bot protection on sign-in, when enabled | Browser and device signals during sign-in |
| Anthropic | AI extraction and drafting | The solicitation text, document excerpts, facts and answers needed for each AI request |
| Resend | Email delivery (alerts to COGENCY; member notifications only if enabled) | Recipient work email and the message |
| Owner-chosen alert webhook | Paging COGENCY about outages | Operational alert text only, no member content |
| GitHub | Source code and automated testing (not member-facing) | No member data |
| Public government and foundation websites | Funding-opportunity discovery | Search queries only, no member data |
11. Pilot term and termination
- The pilot runs from November 16, 2026 to February 26, 2027, for five COGENCY member agencies (Lower Eastside Service Center, Transitional Services for New York, Educational Alliance, Association to Benefit Children, and VIP Community Services), unless COGENCY extends or ends it earlier.
- COGENCY may change these terms. A new version is shown to you at your next sign-in and must be accepted before you can continue.
- COGENCY may suspend or end the pilot, or an agency's or person's access, at any time. Your agency may leave the pilot at any time by telling the contact in section 8.
- When the pilot ends, agency data is kept or deleted as described in section 7; COGENCY will tell agencies in advance how to export their work.
Questions: Mohsin Sardar, msardar@cogencyipa.com. Back to the portal