Governance & Legal Disclosures
How the Dual Mission Stays Inside the Charity Rules
Operating international trauma recovery and a government-facing public health system under one 501(c)(3) requires a documented legal path. This page states that path in plain language.
| Regulatory Discipline | Legal Requirement | Global Hands Compliance Path |
|---|---|---|
| IRS 501(c)(3) tax exemption | Exempt purpose and UBIT (IRC 501 / 513) | Lessening the burdens of government and charitable recovery work |
| Corporate tech partnership | Private inurement rules | Royalty-free license concession; at or below fair-market maintenance |
| Government procurement | Competitive bidding rules (FAR / 2 CFR 200) | $0 software license; pass-through hosting; cooperative agreement path |
| Health data and privacy | 45 CFR § 164.512(b) | Public health exception plus BAA where Global Hands handles identifiers |
1. IRS 501(c)(3) mission scope and UBIT
Assisting municipal, state, and federal health departments with early outbreak detection fulfills the exempt purpose of lessening the burdens of government under Treas. Reg. § 1.501(c)(3)-1(d)(2). Trauma recovery, anti-trafficking counseling, and field missions remain the original charitable program.
The software license is provided at $0.00, so there is no commercial sale of software. Snowflake hosting is structured as a direct pass-through reimbursement without markup. Maintenance billed to agencies is treated as program service revenue related to the public health mission (IRC § 513(a)), not unrelated business income.
2. Private inurement and the technology concession
501(c)(3) assets must not improperly enrich a private entity. Global Hands operates Salus Agentic under a royalty-free technology concession from Salus Agentic, Inc. for public-sector and non-profit deployments. Any fees collected for system maintenance are kept at or below fair market value for technical labor. Cloud compute is billed at non-profit utility rates with no Global Hands markup.
3. Public health procurement
Because the core software license is $0.00, agencies are not purchasing licensed software at a price that typically triggers a full competitive software RFP. Cloud hosting and maintenance can proceed as pass-through cost recovery, a cooperative agreement, or a sole-source non-profit grant, subject to each agency's own procurement counsel.
4. HIPAA, HITECH, and public health exceptions
Laboratories and clinical providers may disclose protected health information to public health authorities and their designated agents for disease monitoring without individual patient authorization under 45 CFR § 164.512(b).
Where Global Hands processes data containing direct identifiers on behalf of a covered entity, Global Hands executes an HHS-style Business Associate Agreement. Deployments are designed for dedicated Snowflake instances, including Snowflake Government Cloud / FedRAMP Moderate authorized infrastructure when the agency requires it. Global Hands does not claim a standalone FedRAMP authorization for itself.
5. International humanitarian accountability
Field work in Mexico, Brazil, and the United States is conducted as charitable program activity. Financial disclosures live on the transparency page. We do not publish invented impact statistics. Program descriptions stay qualitative unless independently documented.