1. Aim
1.The aim of this policy is to set out clearly for staff, volunteers, trustees, schools and any others with whom ABC to read may interact how confidential information will managed by ABC to read
2. Introduction
ABC to read’s confidential policy/procedure is set out below. All staff, volunteers and trustees are expected to abide by this policy.
ABC to read is committed to maintaining high standards of confidentiality in all aspects of its work. This includes records and information pertaining to staff, volunteers, schools and children and prospective staff, volunteers, schools or children. In the case of staff, any breaches of this policy may be dealt with according to ABC to read’s disciplinary policy; in the case of volunteers this may lead to the termination of their placement.
3. Information relating to children
3.1 All information about individual children is confidential and should only be sharedwith authorised persons. (These may include the child’s teacher, the Head Teacher, the school’s Designated Safeguarding Lead, , a social worker assigned to the child, a police officer, the CEO of ABC to read, a volunteer’s Fieldworker or ABC to read’s Safeguarding Trustee.
3.2 All children have a right to the same level of confidentiality irrespective of
gender, race, religion, medical concerns and special educational needs.
3.3 Photographs of children should not be taken, stored or distributed without the express permission of the school or parents/carers. If such permission is given at no time should the child’s name be used with a photograph.
3.4 All Staff and volunteers are expected to adhere to the principle that all or anything they are told, see or are given about a child remains confidential outside those specified in 3.1, above, and should not be discussed with anyone not directly involved, especially where that issue relates to individual children.
3.5 In cases where there are concerns relating to the welfare of children ABC to read’s child protection policy will apply.
4. Information about staff
4.1 In all but specific circumstances (eg disciplinary procedures), the decision as to who should be given of a piece of confidential information is one for the member of staff to whom it applies.
4.2 Where such consent is sought, it is necessary to tell the member of staff why there is a need to disclose information and to whom. The member of staff should be told of the likely consequences of their agreeing or not agreeing to this.
4.3 Any consent given should be written, dated and signed specifying exactly what information may be disclosed.
4.4 Once consent has been obtained, it is the responsibility of the person passing on any information to ensure that this is only done on the terms agreed.
4.5 Unless previously authorised, a request for a staff home address, telephone number or email address will always be referred to the individual before any information is disclosed.
4.6 In some cases, there is an automatic right of access to certain parts of staff information eg Inland Revenue or Charity Commission.The staff member will be notified of any legal requirements whereby ABC to read is obliged to provide such information.
4.7 A staff member should never divulge another staff member’s or volunteers’ personal circumstances or information to anyone without the express permission of the other person.
5. Information about volunteers and trustees
5.1 In all but specific circumstances (eg serious complaints), the decision as to who should be given of a piece of confidential information is the volunteer or trustee to whom it applies.
5.2 Where such consent is sought, it is necessary to tell the volunteer or trustee why there is a need to disclose information and to whom. The volunteer or trustee should be told of the likely consequences of their agreeing or not agreeing to this.
5.3 Any consent given should be written, dated and signed, specifying exactly what information may be disclosed.
5.4 Once consent has been obtained, it is the responsibility of the person passing on any information to ensure that this is only done on the terms agreed.
5.5 A volunteer and trustee should never divulge another volunteers’ personal circumstances or information to anyone without permission of the other volunteer or trustee.
5.6 In some cases there is an automatic right of access to certain parts of volunteer or trustee information eg Charity commission. The volunteer or trustee will be notified of any legal requirements whereby ABC to read is obliged to provide such information
6. Files – Staff, volunteer, school and children
6.1 No staff member, volunteer or trustee party has the right to view any other parties’ file except as specifically provided for in this policy.
6.2 All information relating to staff, volunteers, trustees, schools and children will be stored separately; all computer records will be password protected and only accessible as follows:
- Staff files – accessible by the CEO through the office manager
- Volunteer files – accessible with permission from the CEO by field workers through office manager
- Trustee files – accessible by the CEO through the office manager and Chair of trustees
- School and children files – accessible by the CEO, fieldworker through office manager, although no children’s personal data is held by ABC to read in line with our safeguarding policy.
7. General information about confidential information
7.1 Make sure any discussion relating to information of another person, takes place in an appropriate venue, eg not in a place where others, who are not entitled to know, can hear about it.
7.2 Do not gossip about other staff, volunteers, trustees, schools or children with other staff, volunteers trustees or schools.
7.3 Do not write anything derogatory about a member of staff, volunteer, trustee school or child in a file or anywhere else.
7.4 Do not leave information lying around or visible on screen; replace it in the appropriate place, e.g. a locked filing cabinet or close the document on screen ensuring it can only be re-opened with a password.
8. Record Keeping
8.1 All staff and trustees will be given a copy of this confidentiality procedure as part of their induction. The implications of the procedure for their work will be explained.
8.2 All volunteers will have signed and be given a Volunteer Policy Document and Agreement which details the core aspects of confidentiality requirements. Additionally all volunteers will be given the Volunteer Policy, Procedures & Guidance which directs them specifically to this policy which is on ABC to read’s website and available on request.
8.3 Access to personal files of staff, volunteers or trustees can be arranged with the the CEO and will be given only in the circumstances outlined above in sections 3, 4 and 5 above.
8.4 Application forms, interview records, medical information and monitoring forms are confidential to ABC to read.
8.5 Equal opportunity monitoring forms will be detached from application forms on receipt and kept separate from application forms.
8.6 References – when seeking references for a new staff member, volunteer or trustee it is made clear to the referees that information is sought in confidence.
8.7 Probationary reviews and appraisals of staff will only be available to the the CEO, unless there are performance issues in which case the information may be available to the Trustees too. Reviews of volunteers will only be available to the fieldworker who undertook the review, the volunteer, and the CEO unless there are any issues in which case the information may be available to the Trustees too. Any records, notes relating to a trustee will only be available to the the CEO and chair of trustees unless they relate to the Chair in which case it will be the vice chair or other nominated trustee.
8.8 Any medical records will be held on personal files in a sealed envelope or in a secure, password-protected digital file. Copies of medical certificates and self-certification forms will be placed on such personal files after action for payroll purposes.
8.9 All personal information is protected under the Data Protection Act 1988
8.10 Information will be kept for six years once a staff member or volunteer has left ABC to read. It will then be destroyed or archived.
8.11 Unsuccessful staff, volunteers or trustees – ABC to read may wish to monitor all applications and to keep information about applicants. Only the most relevant information should be kept, e.g. equality monitoring -race, sex, sexuality, and the rest destroyed.
8.12 Breaches of confidentiality by staff will normally be treated within the remit of ABC to read’s disciplinary and grievance procedure. Breaches of confidentiality by volunteers will normally be treated within the remit of ABC to read’s Complaints against Volunteer’s procedure. Breaches of confidentiality by trustees will normally be treated by the the CEO and Chair of trustees, unless they relate to the Chair in which case it will be the vice chair or other nominated trustee. The nature of any breaches of this procedure will determine the level of any action.
9. Schools
9.1 All existing schools will be informed of this procedure and can be provided with a copy if requested.
9.2 A file concerning each school will be kept by ABC to read. The information recorded will be factual and where an opinion is recorded it will be clear that this is opinion and what this is based on.
9.3 This information should be kept in a filing cabinet, which is kept locked. All files must be returned to the cabinet after use.
9.4 If a school asks to see their file, the relevant fieldworker or the CEO should organise this and answer any questions about it and explain what has been written.
9.5 All school information is protected under the Data Protection Act 2018.
9.6 Information will be kept for six years (or longer, if required by current legislation) after a school has left ABC to read. It will then be destroyed or securely archived.
10. Trustees
10.1 New Trustees will be sent a copy of the confidentiality procedure and asked to take responsibility for implementing it.
10.2 All Trustee board papers of a confidential nature will be marked ‘Private and Confidential’ and not included in the papers that are made public or widely available within ABC to read. These will be stored securely.
10.3 Volunteers, staff and schools, will not normally be referred to by name, and discussion of their personal details at Trustee meetings will be only as necessary.
11. Partnerships with other organisations
11.2 ABC to read may be working in partnership with other bodies. Where specific information-sharing protocols exist that affect particular schools, all concerned should be aware of this.
11.3 ABC to read will give all partnership agencies a copy of the confidentiality procedure and will explain the requirements it places on the partnership organisations.
11.4 It will be agreed, at the outset, which staff in the partner organisation will have access to information and in what circumstances.
Any agreements with other organisations will state that breaches of confidentiality by either party will be treated as a breach of the agreement.
12. Training
Training on the confidentiality policy and its implications will be a required part of induction procedures for staff, volunteers and Trustees.
Marcia Rowlinson
May 2013
Reviewed Nov 2017 and March 2023
Appendix: Privacy Statement and General Data Protection Policy