independent advocacy – ynys mon & gwynedd
Confidentiality Policy
Last reviewed: July 2025 · Next review: July 2026 · Reg Charity No: 1060826
Policy Statement
NWAAA recognises that, in the course of carrying out its business and services, employees and volunteers may have access to, and be entrusted with, information of a confidential nature. As an overarching principle, NWAAA takes seriously its responsibilities in relation to all confidential information and is committed to implementing, maintaining and developing robust processes to ensure that those responsibilities are fulfilled legally, morally and ethically. Information is considered confidential if it is commercially sensitive, relates to personal data under GDPR, or is given by or about any person seeking the assistance of NWAAA. Such information should only be shared on a need-to-know basis and, wherever practicable, with the permission of the person it relates to.
General Confidentiality Obligations
All information that is acquired during the course of employment, relates to NWAAA or those it works with, and has not been made public by NWAAA, shall be treated as confidential. Staff shall not at any time — whether before or after the termination of their employment — disclose such information to any person without prior written consent. Breaches of data protection or confidentiality are likely to be considered under NWAAA Disciplinary Procedures and may be reportable to the Information Commissioner’s Office.
Handling, Storing & Accessing Confidential Information
Right of Access
- Anyone using NWAAA services has the right to access all data we hold about them. Upon request, they will be provided with a copy of all written, electronic or imaged information relating to their case. This may exclude third-party information unless the third party consents to release.
Secure Storage
- All records are kept securely in a locked cabinet or on a secure server. Some information may be kept temporarily on a password-protected device. When working from home, staff must store sensitive electronic information on secure software linked to the NWAAA server.
Retention
- Records will be kept for an appropriate period of time and no longer, depending on the service received. The only exception is where other agencies require us to hold information for longer (e.g. HMRC). Service users will always be informed of this.
Hard Copies
- Hard copy information will only be removed from the office in exceptional circumstances. NWAAA recognises it is safer to access information remotely using a secure device than to carry around paperwork.
When Confidentiality May Be Breached:
NWAAA recognises there may be exceptional circumstances when confidentiality cannot be maintained. Individuals using NWAAA services will be informed of these circumstances at the start of their relationship with us. Circumstances include but are not limited to:
- Where there are concerns that an individual is at risk of serious harm from themselves or others
- Where a vulnerable third party is at risk (e.g. a child, a housemate)
- Where there are concerns about terrorism or serious criminal activity
- Where there is a legal requirement to disclose information (e.g. a court order, Coroner’s Office request, Health and Safety Executive, DBS)
- Where the Police, Social Services or other statutory authority formally request disclosure — each request will be considered on an individual basis
- Where it is not possible to obtain consent and there is reasonable belief that disclosure is required to prevent serious harm (vital interests or public interests)
- Where a third party discloses concerns about an individual but is unable or unwilling to pass this information to relevant agencies themselves
- Where the alleged perpetrator is an employee of NWAAA
- Where there is a likelihood that the person is not consenting due to coercive control
In all such circumstances the Management team will be consulted and all discussions and decisions documented. The individual concerned will be informed where possible and encouraged to participate fully in any information sharing process.
Confidentiality & Your Advocate
Your relationship with your advocate is confidential and private. Your advocate is there for you.
What you can tell your Advocate
- You can tell your advocate anything. They will not judge you or your points of view, and will treat everything you say in confidence — unless there is a threat to your safety, a threat to someone else’s safety, or a legal duty to inform someone else.
What your Advocate will tell others
- Your advocate will only speak to other people about your issues with your consent. They will tell you everything they say to other people about you, including copies of any letters or records of phone calls. They will not keep any information about you from you.
Information We Hold About You:
- As an advocacy-partner of NWAAA you have the right to see all information we hold about you — written, electronic, and any photos or videos
- If you want to see that information, you can ask us at any time
- All information we hold about you is kept safe and secure
- When we no longer need to keep your records, they will be professionally destroyed
Questions about your information? Contact us:
Questions about your information?
Get in touch and we will be happy to explain how we handle your data and what rights you have.