CONFIDENTIALITY AND INFORMATION SHARING POLICY

BRADFORD CITY FC COMMUNITY FOUNDATION CONFIDENTIALITY AND SHARING POLICY

Bradford City FC Community Foundation
 Confidentiality and Information Sharing Policy

Our work with children and young people will bring us into contact with confidential information which will only be used to enhance the welfare of the children and young people

Parents and schools have a right to know and be informed about the circumstances, and reasons, when we are obliged to share information and we will be open and honest and explain how, when and why the information will be shared about them and with whom. 

It is a legal requirement for Bradford City FC Community Foundation to hold information about the children and young people taking part in all our programme and the staff working at Bradford City FC Community Foundation.
the Chief Executive has undergone training on Data Protection with the EFL and the project manager has undergone training with Bradford Community and Voluntary Service

Training is provided to staff as part of their CPD training programme.

Records

Records are kept for the purpose of maintaining our business. These include health and safety records, development plans, financial records, contractual documentation, and employment records of staff, students and volunteers. We keep records on children and young people attending which include consent forms, attendance registers and application forms.

There are record keeping systems in place that meet legal requirements; means of storing and sharing the information within the framework of the data protection act.

It is our intention to respect the privacy of children and young people and we do this by following the following procedures ( which vary according to programme) 

For Short Breaks (our council commissioned project for children and young people with disabilities we:

• keep consent forms in a locked filing cabinet which is in an office locked at night
• all monitoring data is sent through Egress Secure mail
• data on the young people is entered onto a client list template and this is shared only with Bradford Council Children service staff on secure email.

For NCS (National Citizen Service) we:

• enter all data from consent forms on Salesforce . this is a secure, password protected site
• we keep consent forms in a locked filing cabinet for the duration of the relevant NCS programme and then they are shredded

For our Premier league and FLT Programmes we:

• collect children's name, school class, school postcode, year group on registers, demographic information (ethnicity, medical conditions, gender)
• keep registers in a locked filing cabinet in a locked office which is only accessed by a code pad
• they are entered on VIEWS which is a secure database and only statistics and demographics can be seen

For the Football league traineeships all the information is collected by GPS Strategies and stored securely within their systems.

For our externally funded programmes (Unheard Voices Heritage Lottery project - participant registers, consent forms are stored in a locked filing cabinet, monitoring is sent via online password protected site and information only seen by Heritage Lottery monitoring officer

Affinity Sutton youth sports project - any consent forms given to our staff are passed straight to the Affinity Sutton youth sports manager and are storing securely within their systems

Information sharing procedures

The Data Protection Act provides a framework to ensure that personal information about living persons is shared appropriately. The circumstances in which information can be shared are explained to young people and parents when joining one of our programmes and they sign a form to say that they understand the circumstances when information may be shared without their consent. We are obliged to share confidential information without authorisation from the person who provided it or to whom it relates if it is in the public interest. This is when it is to prevent a crime from being committed or intervene where one may have happened or to prevent harm to a child, young person or adult; or not sharing it could be worse than the outcome of having shared it. 
The decision should never be made as an individual, but with the back-up of the trustees and Community Foundation Manager 

The three critical criteria are:

  • Where there is evidence that the child or young person is suffering, or is at risk of suffering, significant harm.
  • Where there is reasonable cause to believe that a child or young person may be suffering, or at risk of suffering, significant harm.
  • To prevent significant harm arising to children and young people or serious harm to adults, including the prevention, detection and prosecution of serious crime.

For adults: to prevent harm to themselves or others including the prevention, detection and prosecution of serious crime.

Information shared must be accurate and up-to-date, necessary for the purpose it is being shared for, shared only with those who need to know and shared securely. We will record decisions made and the reasons why information will be shared and to whom. Our Safeguarding Policy sets out how and where information should be recorded.

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