Confidentiality Policy
Purpose
To protect the confidentiality and privacy rights of individuals served by 211, and other service providers with whom the agency cooperates; to establish standards of client and administrative record confidentiality; to guide the conduct of employees and volunteers of 211 in their handling of client and agency information and to inform 211 employees of their obligation to protect 211’s infrastructure and information assets.
Policy
211 Palm Beach/Treasure Coast supports practices that honor everyone’s right to privacy by safeguarding all information revealed by those persons reaching out to 211 for support via phone, text, email, chat or similar methods (i.e. inquirers). The duty to protect an inquirer’s confidential communication and a staff person’s personal information extends to all who have access to that information and therefore it is expected that each employee/volunteer will adhere to such practices. Maintaining the trust and confidence of inquirers is an essential principle of 211 Palm Beach/Treasure Coast.
The Agency instructs all employees, volunteers, and others with access to confidential information to carefully note that the business and professional services rendered by 211 Palm Beach/Treasure Coast entail confidential and classified information and that they are prohibited from divulging information regarding clients or inquirers, paid or volunteer staff, location of the agency, and agency procedures with the understanding that irreparable injury could result from a breach of this code of confidentiality.
All employees, volunteers and others with such access shall sign a confidentially form indicating that they understand this policy and will abide by it (see attachments for reference). Specific approval from a full-time agency staff person is needed to disclose the location of the agency to individuals not affiliated with the agency. All individuals who volunteer at the agency, work at the agency, or visit the agency must sign a confidentiality form. Staff confidentiality agreements are signed annually.
To maintain the integrity of private information, no employee, volunteer or other will review personal data beyond what is needed to fulfill his or her professional responsibilities, nor reveal information to anyone not having proper professional use for such.
Various community partners may request information and data from 211 regarding community needs, services, and trends. When that information is provided, it is provided in aggregate in order to preserve client confidentiality, unless the organization is part of a cooperative service delivery arrangement, in which case information will be shared exclusively with that partner.
Technologies and client tracking systems are constantly evolving. 211 Palm Beach/Treasure Coast endeavors to stay abreast of these by utilizing the most efficient and effective systems reasonably available to us. Understanding the evolving nature of cyber security and cyber ethics, 211 contracts with reputable vendors who provide assurances of data security. Further, staff are annually trained in HIPPA and Data Security protocols.
The rules of confidentiality are not absolute. 211 Resource Center Specialists have ethical obligations when there are clear and specific situations where disclosure of confidential information must be made known to a professional or public entity. A client’s or inquirer’s confidential information may be shared only under the following circumstances:
It is determined that the release of information is required by law (e.g. court order).
It is determined that there is an imminent threat of death or serious harm to the client or another person. In these circumstances, communication will be limited to only those who must be informed in order to help reduce the risk.
The client or inquirer has given explicit permission for the information to be disclosed to another person or agency. The client or inquirer should specify what information may be given and to whom. Verbal permission from a client or inquirer can be used during follow-up calls, advocacy or in high-risk situations and is documented in the client record. Most of our advocacy occurs by phone. Therefore in advocacy/ care coordination situations when it is necessary to share confidential information with other providers in order to effectively advocate for the client, permission is again obtained verbally and documented prior to sharing client information to sharing such information. Written permission is obtained where appropriate, when in person home visits are conducted.
Confidentiality Policy Guidelines
In order to preserve and protect callers, staff and volunteers, the following general procedures must be observed. (Note: “Caller” applies to any person contacting 211 for assistance, and may include those contacting the agency via phone, text, chat, email, social media or through any other medium).
No details regarding caller information are to be disclosed or discussed outside of the agency. All staff and volunteers who are privy to personal information provided by a caller are mandated to safeguard the information.
All staff and volunteers must annually review the agency’s Confidentiality Policy and sign the agency’s Confidentiality Agreement to that effect. Violation of this policy/procedure/agreement shall be considered grounds for discipline up to and including immediate termination.
If a caller asks if what he/she discusses is confidential, the appropriate response is:
“What you tell me today will be held in strict confidence between you and 211.” (Not “between you and me”)
When questioned with regard to Caller ID, an appropriate response to the caller is: “We have access to Caller ID information but it is only used to dispatch assistance to people who may be in danger.”
Callers may provide verbal permission for information to be shared in some cases, e.g. to facilitate a referral, provide advocacy, etc. In such cases permission is noted in the call record.
211 staff and volunteers are not to provide their real names or personal information to callers. Specialists are expected to establish a “Line Name” and are trained to offer that name to the caller, and to ask the caller for his/her name to establish rapport.
Staff and volunteers are not to communicate on a personal basis with callers in any way. This includes face to face, by telephone, through chat, text or social media, by mail, fax, e-mail or in any other way unless dictated by the program.
Staff and volunteers are not to give out “direct dial” or 211’s administrative telephone numbers to any caller. Callers requesting the Elder Crisis Outreach, Sunshine, Help Me Grow or Special Needs programs may be warm transferred to the extensions for these programs, but the phone numbers are not to be given out.
Staff and volunteer home telephone numbers are not to be given out. If a volunteer calls in looking for the telephone number of another volunteer or a staff member, offer to call for them and give their number to the person they are trying to reach.
If a police officer or other professional is requiring your name, it is permissible to give your name along with the Supervisor Line telephone number for call back purposes. However, if on a 3-way call with a 211 client, the specialist should indicate that they are not permitted to give that information out to clients, but will return the call to the professional in order to provide that information.
211 does not provide walk-in services and therefore the location of 211’s office is not to be provided. If there is a training or tour and the address and directions are being requested, the requests should be referred to the administrative telephone number.
In general, 211’s suicide procedures should not be shared with anyone, including personnel from other agencies. There are situations where 211 is required by law to inform authorities, however our purpose is to de-escalate suicide lethality by providing counseling and support in a confidential environment.