Confidentiality
Policy
Let’s Get Sociable has a duty to ensure that information that it holds or processes is
managed appropriately and within legal requirements. In order to appropriately
manage this information and to ensure a consistent approach, all staff and
volunteers have a duty to implement the Confidentiality procedures.
Procedure
Introduction
1. Information held by Let’s Get Sociable will include the following categories:
(a) personal information relating to individual employees/volunteers/Board
members/ supporters past, present and potential / clients - e.g. phone
numbers, CVs, work performance;
(b) personal information relating to individuals in member, associate member
and supporter organisations;
(c) information relating to member/associate member/supporter
organisations - e.g. organisations’ phone numbers, monitoring by Let’s
Get Sociable employees;
(d) information relating to more general Let’s Get Sociable work - e.g.
policies on staffing and other matters, relationships with other bodies,
Board papers and minutes.
2. Such information will mostly be in written/computer form but will also include
unwritten information which has become known to Let’s Get Sociable
employees/volunteers/Board members in the course of their work. (This policy
does not cover information that becomes known to them outside their work at
Let’s Get Sociable).
General principles
Disclosure within Let’s Get Sociable
3. Within Let’s Get Sociable personal information relating to individual
employees/volunteers/Board members should be available to staff with the
responsibility for line managing others only (and to Board members to the extent
that it is directly related to their personnel responsibilities) unless the individuals
concerned have agreed to wider disclosure. Individuals have, under the Data
Protection Act 1998, a right to inspect any information held by Let’s Get Sociable
on them.
4. All other information falling within section 1 above may be freely shared between
employees/volunteers/Board members.
Disclosure outside Let’s Get Sociable
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5. Let’s Get Sociable recognises that it is a matter for individuals to decide whether
they wish their personal details to be publicly known, and similarly for
organisations whether they wish their contact details to be publicly known. In
general, therefore, such information should not be disclosed outside Let’s Get
Sociable unless the individuals/organisations concerned;
(a)
(b)
have explicitly given their consent, or have raised no objection when
informed by Let’s Get Sociable that disclosure is intended, - e.g. for
inclusion in the Consortium’s directory or annual report; or
have themselves published, or sanctioned the disclosure of the
information elsewhere, or can reasonably be regarded as having done so
- e.g. in a magazine or the organisation’s own publicity material or by
statements made in open session at a Let’s Get Sociable conference.
6. There would be nothing to stop Let’s Get Sociable disclosing/publishing any of
this information in a form where the individuals/organisations concerned could
not be identified - e.g. aggregate statistics about the membership or about
members’ work.
7. More general information about Let’s Get Sociable work may be disclosed outside
Let’s Get Sociable except where the Services Manager or the Chair of the Board
has explicitly stated that this is inappropriate.
Disclosure required by Law, Court or Tribunal
8. Disclosure of information may in certain circumstances be required by law or by a
court or tribunal - e.g. for the prevention of crime.
9. When such an approach is made to Let’s Get Sociable, Let’s Get Sociable
designated solicitor should always be consulted on whether, how and what
information should be provided. The provision of information in the light of the
solicitor’s advice must be specifically authorised by the Services Manager or the
Chair.
10. The Services Manager should tell the individual/organisation concerned as soon
as any decision to provide information has been taken.
Disclosure requested by the Police, solicitors and other authorities
11. Information requested by the police, solicitors and other authorities on
individuals (without specific legal authority as at section 8 above) should not
normally be provided unless those concerned have given their consent, Let’s Get
Sociable designated solicitor has been consulted, and disclosure has been
specifically authorised by the Services Manager or the Chair.
It is recognised, however, that there may be exceptional circumstances (e.g.
client abuse, financial irregularities) where it would be right to provide
information without the consent of those concerned being obtained or even
sought. Those concerned should normally be informed that information has been
provided.
12. Other information relating to Let’s Get Sociable work should only be provided
where disclosure has been specifically authorised by the Service Manager or the
Chair. Requests relating to another organisation should normally be referred to
the organisation concerned to deal with.
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Press and Media
13. Personal information on individuals, and contact details for organisations, should
not be provided to the Press/media unless those concerned have given their
consent and disclosure has been specifically authorised by the Services Manager
or the Chair. Requests for the disclosure of other information should be dealt
with as at section 12 above.
Security of information
14. Personal information on individuals, and contact details for organisations, must
be kept in lockable filing cabinets or secure computer files except where
disclosure is permissible under section 5 above. The same shall apply to such
other information covered by section 1 above as the Services Manager or the
Chair shall decide is appropriate. Access to all securely held information shall be
limited to such individuals and for such purposes as the Services Manager or the
Chair shall authorise.
15. The need for particular information in these categories to be held securely, and
indeed the need for it to be retained at all, shall be reviewed from time to time
by the Services Manager. Where information does not need to be retained, it
should be securely disposed of.
16. The Consortium will comply with the requirements of the Data Protection Act
1998.
Obligations on Let’s Get Sociable employees/volunteers/Board members
17. Let’s Get Sociable employees/volunteers/Board members will be required by the
Services Manager to give an undertaking that they will act in accordance with
this policy. Where future employees/volunteers/Board members are concerned,
this should be done as part of their induction.
18. Any breach of this undertaking will be subject to disciplinary action.
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