CONFIDENTIALITY POLICY
Confidentiality Statement
First Housing Aid and Support Services is committed to providing a confidential service
to staff stakeholders and service users. First Housing Aid and Support Services believe
that principles of confidentiality must be integrated across all aspects of services and
management. We believe that staff and service users deserve the right to
confidentiality, to protect their interests and safeguard First Housing Aid and Support
Service’s services. In the case of Child Protection concerns a balance between
protecting children and respecting parents’ wishes is necessary but when these are in
conflict, the child’s welfare and interests come first”
Definition of Confidentiality
 First Housing Aid and Support Services understands confidentiality to
mean that no information regarding a service user shall be given directly
or indirectly to any third party which is external to the Staff and Manager,
without that service user’s prior expressed consent to disclose such
information.
 First Housing Aid and Support Services recognises that all users should
be able to access First Housing Aid and Support Service’s services in
confidence and that no other person should ever know that they have
used our services.
 First Housing Aid and Support Services recognises that information may
be indirectly given out through staff informally discussing cases. All staff
should ensure that no discussions relating to an individual user of the
services take place outside of First Housing Aid and Support Service’s
premises. The Board of Directors will not receive details of individual
users or their case.
 We recognise that users need to feel secure in using First Housing Aid
and Support Service’s services in a confidential manner. First Housing
will ensure all users are afforded confidential interview space and will
ensure blinds, radios and other mechanisms are used to ensure no
breach of confidentiality can occur inadvertently.
 First Housing Aid and Support Services will not confirm the user’s
presence in our projects without obtaining the user’s consent.
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Statistical Recording
 First housing Aid and Support Services is committed to effective
statistical recording of service users to enable us to monitor take-up of
service and to identify any policy issues arising from providing services to
people who are homeless or threatened with homelessness.
 All statistical records given to third parties, such as to support funding
applications, monitoring reports for the local authority shall be produced
in anonymous form, so individuals cannot be recognised. Weekly
Housing Benefit Reports to the Housing Executive will have names and
start dates indicating that claims for Housing Benefit have commenced.
This is not regarded as a breach of confidentiality given that claimants
have already submitted their housing benefit form to the statutory
authority and signed it off themselves.
Case records
 All case records are kept in locked filing cabinets. All case records must
be locked away at the end of each working day. All information relating to
service users will be kept in locked drawers. This includes notebooks,
copies of correspondence, calculation sheets and any other sources of
information.

Expressed Consent To Give Information.
 It is the responsibility of the staff member to ensure that where any action
agreed to be taken by First Housing on behalf of a service user, the
service user must first sign an authorisation form. This should be placed
on the client's file.
 First Housing employees are responsible for checking with clients if it is
acceptable to call them at home or work in relation to their case. All staff
must ensure they make no reference to First Housing Aid and Support
Services when making telephone contact with clients.
 All details of expressed consent must be recorded in the service users
file.
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Information Sharing
It is your responsibility to keep confidential all information that is or has been acquired
by you during and in the course of your employment, or has otherwise been acquired
by you in confidence. You are to exercise reasonable care to keep all information
confidential and save in the course of our business or as required by law you shall not
at any time, whether before, or after the termination of your employment disclose
information to any person without the consent of First Housing. Staff members are
obliged to exercise reasonable care to keep safe all documentary or other material
containing confidential information, and shall at the time of termination of your
employment with us or at any other time upon demand, return to us any such material
in your possession.
Statements to the Media
Only the Board of Directors The Chief Officer or a nominated representative will give
any statements to reporters from newspapers, radio, television, etc. in relation to our
business.
Breaches of confidentiality
First Housing Aid and Support Services recognises that occasions may arise where
individual workers feel they need to breach confidentiality. First Housing Aid and
Support Services recognises, however, that any breach of confidentiality may damage
the reputation of First Housing. Any intent to breach confidentiality should be first of
all discussed with the line manager to determine the best course of action.
On occasions where a worker feels confidentiality should be breached the following
steps must be taken:
1. The worker should raise the matter immediately with their Line Manager.
2. The worker must discuss with the Line Manager the issues involved in the case and
explain why they feel confidentiality should be breached and what would be
achieved by breaching confidentiality. The Line Manager should take a written note
of this discussion.
3. The Line Manager is responsible for discussing with the worker what options are
available in each set of circumstances.
5. The Line Manager should contact the Director of Operations in the first instance, or
the Chief Officer and seek authorisation to breach confidentiality. The Line
Manager should brief the Director of Operations/ Chief Officer on the full facts of the
case, ensuring they do not breach confidentiality in doing so.
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6. If the Director of Operations / Chief Officer agrees to breach confidentiality, a full
written report on the case should be made and any action agreed undertaken. The
Line Manager is responsible for ensuring proper records of decisions to breach
confidentiality are actioned and maintained.
7. If the Director of Operations / Chief Officer does not agree to breach confidentiality
then this is the final decision of First Housing Aid and Support Services.
Disclosure of a Crime
 There may be instances when users confide that they have
committed/are about to commit a crime. In English Law there is no duty
to disclose a criminal offence so being aware of the crime is not assisting
in that crime.
 The exception to this is under The Prevention of Terrorism (Temporary
Provisions) Act 1989, which makes it an offence to fail to give information
that may help to prevent acts of terrorism or apprehend a terrorist.
 It is however, an offence to aid, abet, counsel or procure the commission
of an offence. It is therefore important that the staff member makes sure
that s/he does not give, or in any way can be seen to be giving,
encouragement or assistance in any way.
 Do not destroy the relationship you are developing with the user by
alarming them but ensure that if you have concerns about the
information the user is disclosing, you tell them:
 That what they are saying/about to say could break the law;
 That you can assure them of confidentiality but need to warn
them not to give any further details and they should seek
advice from a solicitor;
 You may be later summonsed as a witness.
Police attending First Housing Services
The police may approach First Housing to gather information about a user. If you have
advance warning of the visit adopt the following procedure:
Inform the police that you operate a confidentiality policy and offer to go through its
contents. Ensure all workers and users are aware that the police will be attending the
service - thereby giving users the option to leave. The police officers should not be
allowed to enter any room where records are kept.
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Providing Information to the Police
 If you feel under pressure to reveal information to the police e.g. you are
threatened with arrest, the following is the legal position:
 The police have powers under the Police and Criminal Evidence Act
1984 (PACE). This provides general powers to police officers, lawfully in
any premises, to seize anything they reasonably believe is evidence in
relation to an offence under investigation, which might otherwise be
concealed, lost, altered or destroyed. Preventing access to a room
where records are kept forestalls the use of these powers. It is important
to note that PACE only allows access to materials, which would have
been available to the police before 1986, and personal, confidential case
records were not included.
 The police can summons an employee as a witness. Failure to attend
may result in the Court issuing a warrant to arrest and bring the witness
before the Court. Failure to do so could result in a fine or committal to
prison.
 Staff members can negotiate with the police, or when attending the
magistrates court and explain case records are confidential. First
Housing should inform the service user that the summons has been
received and the penalties that may be levied. Workers should not
discuss the evidence to be given with the user.
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Breach of Security at First Housing Premises
Unfortunately, break-ins are a common occurrence in projects and offices. If police are
called following a break-in, care should be taken to ensure that cases are in locked
cabinets, though you will not be able to disturb evidence.
If case records have been stolen the police should be told that they are confidential
and should be returned unread if possible. If you need to call the Police because of a
crime committed in projects or offices under the control of First Housing e.g. theft from
the waiting room, follow the steps outlined in the previous section on “Police attending
in response to a break-in.
Legislative Framework
First Housing Aid and Support Services will monitor this policy to ensure it meets
statutory and legal requirements including the Data Protection Act, Children’s Act,
Rehabilitation of Offenders Act and Prevention of Terrorism Act.
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Approval
This Confidentiality Policy has been updated June 2012 and has been approved by
The Board of Directors and authorised by:
Kevin Wright
(Name)
Chief Officer
(Position)
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