One Big Family
Helping the Homeless
Confidentiality and Information Sharing Policy
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One Big Family – Helping the Homeless, hereinafter referred to as ‘the Charity’, is committed to providing a confidential service to its users. No information given to the Charity will be shared with any other organisation or individual without the user’s expressed permission, unless in the case of vital interests or legal obligation.
For the purpose of this policy, confidentiality relates to the transmission of personal, sensitive or identifiable information about individuals or organisations (confidential information), which comes into the possession of the Charity through its work.
In line with its Data Protection Policy, the Charity holds personal data about its volunteers, trustees and clients which will only be used for the purposes for which it was gathered and will not be disclosed to anyone outside of the organisation without prior permission, unless there is an overriding vital interest or legal obligation to do so. All personal data will be dealt with sensitively and in the strictest confidence, internally and externally.
As a Data Controller, the Charity may enter into specific information sharing agreements with partner organisations and other agencies. This may be undertaken for effective provision and improvement of services, as well as to support and protect individuals. Information shared under these mutual agreements and the procedures for sharing data will be governed by clearly documented terms and conditions, and guided by information sharing principles.
The purpose of the Confidentiality Policy is to ensure that all staff, members, volunteers and users understand the Charity’s requirements in relation to the disclosure of personal data and confidential information.
All personal paper-based and electronic data must be stored in accordance with the Data Protection Act and General Data Protection Regulation 2018 and must be secured against unauthorised access, accidental disclosure, loss or destruction
All personal paper-based and electronic data must only be accessible to those individuals authorised to have access
4. Statistical Recording
The Charity is committed to effective statistical recording of the use of its services in order to monitor usage and performance. All statistical records given to third parties, such as to support funding applications or monitoring reports for the local authority shall be produced in anonymous form, so individuals cannot be recognised.
In line with the Data Protection Policy, the organisation will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure. The following measures will be taken:
· Personal data will be stored in a locked filing cabinet at the Charity’s registered address or address of the head of service in London and Yorkshire, accessible only to the trustees
· If essential for information to be taken off site, personal data will be kept safe by being securely stored in a lockable folder/ bag/ case
· Any electronic files or email attachments containing sensitive personal information will be password protected
· Personal information is not to be shared via text message, WhatsApp or other messaging system unless essential to do so. If it is shared, information must be in an anonymised form that ensures individuals and organisations cannot be identified
6. Breaches of Confidentiality
The Charity recognises that occasions may arise where individual trustees or volunteers feel they need to breach confidentiality. Confidential or sensitive information relating to an individual may be divulged where there is a reasonable belief there may be a risk of danger to the individual, a volunteer, or the public at large, or where it is against the law to withhold it. In these circumstances, information may be divulged to external agencies e.g. police or social services on a need to know basis.
Where a trustee or volunteer feels confidentiality should be breached the following steps will be taken:
• They should raise the matter immediately with one of the Charity’s trustees
• They must discuss with the issues involved in the case and explain why they feel confidentiality should be breached and what would be achieved by breaching confidentiality. The trustee approached should take a written note of this discussion.
• The trustee approached is responsible for discussing with the individual what options are available in each set of circumstances
The trustee approached is responsible for making a decision on whether or not confidentiality should be breached. If they decide that confidentiality is to be breached, then they should take the following steps:
• They should contact the other trustees of the Charity and brief them on the full facts of the case, ensuring they do not breach confidentiality in doing so
• They should seek authorisation to breach confidentiality from at least one other trustee (making a total of two of the Charity’s trustees)
• If at least two of the Charity’s trustees agrees to breach confidentiality, a full written report on the case should be made and any action agreed undertaken
The trustee originally approached is responsible for ensuring all activities are actioned.
If there is no agreement to breach confidentiality, then this is the final decision of One Big Family – Helping the Homeless.
7. Legislative Framework
The Charity will monitor this policy to ensure it meets statutory and legal requirements including the General Data Protection Regulation and Data Protection Act, Children's Act, Rehabilitation of Offenders Act and Prevention of Terrorism Act. Training on the policy will include these aspects.
8. Ensuring the Effectiveness of the Policy
All trustees will receive a copy of the confidentiality policy. Existing and new volunteers will be introduced to the confidentiality policy via training and meetings. The policy will be reviewed annually and amendments will be proposed and agreed by the trustees.
Any breaches of this policy may result in disciplinary proceedings, including the termination of the volunteering agreement. The trustees of One Big Family – Helping the Homeless are accountable for compliance of this policy. A trustee could be personally liable for any penalty arising from a breach that they have made.