1. Policy Statement
Family Promise of Puget Sound is deeply committed to protecting the privacy and confidentiality of all individuals served, former individuals, staff members, and volunteers. This commitment is not only to comply with all applicable state and federal privacy laws but also to foster an atmosphere of professionalism, trust, and safety within our organization and with those we serve. Unwarranted disclosure of confidential information can severely damage our relationships with individuals, undermine trust, and impede our ability to provide effective support. Therefore, all employees and volunteers are strictly prohibited from sharing confidential information about individuals served, former individuals, staff, or volunteers with anyone outside of the authorized scope of their duties without proper authorization.
2. Scope
This policy applies to all directors, officers, employees (paid and unpaid), and volunteers of Family Promise of Puget Sound. It covers all confidential information obtained or maintained by FPOPS, regardless of its format (e.g., oral statements, written notes, electronic files, photographs, or other personal data).
3. Guiding Principles
* Privacy Protection: Uphold the fundamental right to privacy for all individuals, staff, and volunteers.
* Trust and Professionalism: Foster an environment of trust and professionalism through responsible handling of sensitive information.
* Legal Compliance: Adhere strictly to all applicable state and federal privacy laws and regulations.
* Ethical Conduct: Operate in accordance with the highest ethical standards, including those outlined in the National Association of Social Workers (NASW) Code of Ethics, which FPOPS endorses.
* Limited Disclosure: Confidential information will only be disclosed when legally required, ethically mandated, or with proper authorization.
* Service Coordination: Recognize the necessity of information sharing for effective service coordination, balanced with privacy protection.
4. Definitions
* Confidential Information: For the purposes of this policy, “confidential information” includes, but is not limited to:
* Individuals’ served and former individuals’ names, contact details, case histories, financial records, health records, legal documents, photographs, oral statements, and other personal data maintained by Family Promise in the form of notes, files, computer records, or similar materials.
* Personal information relating to FPOPS staff members and volunteers (e.g., personnel records, performance reviews, health information).
* General information, policy statements, or statistical data that is not identified with any individual or family is not considered confidential.
* Proper Authorization: Means:
* Written consent from the individual (or their legal guardian) for individual-specific information.
* Written consent from the staff member or volunteer for their personal information.
* By direction of a supervisor, when such disclosure is necessary for the provision of services, required by law, or ethically mandated, and consistent with this policy.
5. Confidentiality Requirements
5.1. Individuals and Former individual Information
* No employee or volunteer may share confidential information about individuals or former individuals with anyone outside of Family Promise of Puget Sound without proper authorization.
* Confidential information will not be disclosed (even to family or household members not directly involved in the FPOPS program) without the individual’s written authorization, subject to disclosures permitted or required by law.
* Individual Authorization for Service Coordination: In an effort to provide all the services for which individuals are eligible, it is necessary that FPOPS has individual authorization to release information to other participating agencies/entities/persons involved in providing program services. This information may be entered into a computer database that other social service agencies are able to access. Program services may be contingent on the program’s ability to share information with these other agencies/entities/persons. Individuals will be asked to sign an authorization form stating: “I understand that confidential information may be shared with other agencies/entities/persons, and that such agencies/entities/persons may share confidential information with Family Promise of Puget Sound, for the purpose of providing program services.”
5.2. Staff and Volunteer Information
* Staff members are responsible for maintaining the confidentiality of information relating to other staff members and volunteers. This includes, but is not limited to, personnel records, performance information, and any personal data shared within the workplace that is not public knowledge.
6. Permitted and Mandated Disclosures
Nothing in this policy is intended to prevent an employee or volunteer from reporting a crime, child abuse or neglect, or other legally mandated disclosures to appropriate state and law enforcement agencies. FPOPS endorses the National Association of Social Workers (NASW) Code of Ethics, which outlines mandated reporting requirements for:
* Intent to harm self or others (duty to warn).
* Child abuse or neglect.
* Elder or vulnerable adult abuse or neglect.
* As otherwise required by law (e.g., court order).
In such situations, staff and volunteers should follow established FPOPS protocols for mandated reporting and consult with their supervisor immediately.
7. Consequences of Violation
Any violation of this policy may result in severe disciplinary consequences, up to and including:
* Termination of employment for staff.
* Termination of service for volunteers.
* Violation of state and federal laws regarding confidentiality of records may also result in criminal penalties and/or civil liability for the individual and/or the organization.
8. Responsibilities
* All Directors, Officers, Employees, and Volunteers: Are responsible for understanding, adhering to, and upholding the principles and procedures outlined in this policy. This includes exercising sound judgment and seeking clarification from supervisors when unsure about information disclosure.
* Supervisors: Are responsible for training their teams on this policy, ensuring compliance, and providing guidance on complex confidentiality issues.
* CEO and Program Directors: Are responsible for ensuring the overall implementation and enforcement of this policy and for addressing any systemic confidentiality concerns.
9. Policy Review and Revision
This policy will be reviewed annually by the CEO and Board of Directors, or more frequently as needed, to ensure its continued relevance, effectiveness, and alignment with current laws, best practices, and the evolving needs of Family Promise of Puget Sound. Any revisions will be communicated to all relevant personnel.