1.2 Confidentiality Policy and Ethical Duty to Disclose
Anyone associated with 211 Northeast Michigan (including staff, volunteers, board members, and visitors) must agree to protect information obtained while interacting with an inquirer. The client can give this information verbally or be part of the record created. The protection of the information supplied or received during an interaction with a caller or client is called confidentiality. This policy is approved by the board and reviewed annually with all staff, volunteers, and board members.
By signing this policy, you agree that:
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You will not disclose any personally identifying information (PIO) of any caller, including names, addresses, phone numbers, or other sensitive information, to anyone outside of 211 in any way. This includes community partners, other agencies, friends, and other callers.
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If you are gathering information for follow-up or advocacy purposes, you must obtain verbal permission from the caller and note that consent was given in the call record notes.
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If you share stories or experiences with others outside of 211, do not share any details about the call or situation that may reveal who the person is without their verbal or written permission, which has been documented in the record via notes or signed waivers.
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You will only take documents with the PIO of clients from the office with explicit permission from the Executive Director.
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The cloud-based software we use to manage and record calls (iCarol and inContact) containing PIO must be password protected and only open on personal computers protected by login or password.
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Please note that information obtained through automatic data collection of PIO (like a phone number) is included in this agreement but may be used in case of ethical duty to disclose (see below).
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Ethical Duty to Disclose
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If the personal safety or well-being of a caller (or someone they are calling about) might be compromised if you do not act, you have an ethical duty to disclose the circumstances and PIO of the caller to the authorities with or without their expressed, explicit, or implied permission. These situations are most often related to existing Crisis Intervention Policies and Procedures. They should not be undertaken without first informing your supervisor of your intent and getting support as needed. Circumstances that may require disclosure without permission include:
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Suspected child abuse or neglect
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Suspected elder abuse or neglect
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Suicide or homicide is potentially imminent or in progress
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DO NOT report suspected intimate partner violence to the authorities unless the caller has explicitly requested that you call on their behalf. Often, people in a controlling and violent relationship as adults can have their safety compromised when they report the situation without their permission. However, if the possibility of physical harm is imminent or in progress, call the police and use the PIO provided by the caller to get help to them (See Crisis Intervention Policies and Processes).
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Other Situations Which May Require Disclosure
If any of these situations apply to your situation, you need to consult with the executive director before proceeding.
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Another party claiming to be a community partner, medical provider, government official, or legal counsel requests information about a call or person.
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The client has explicitly permitted the information to be disclosed to another person or agency. The client should specify what information may be given and to whom.
Data Confidentiality
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Information gathered as part of the call (needs, unmet needs, and demographics) is kept secret at an individual level. These statistics are shared only as an aggregate with outside partners.
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Before sharing the PIO of our caller with partners (for example, in a CIE or other program-based collaborative), the following should be true:
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An MOU is in place between the partners that guarantees confidentiality and prohibits misuse of the information being shared (i.e., unsolicited sales or any other unauthorized contact)
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The other program either a) provides a confidentiality form that their employees and board members sign or b) agrees to have people privy to the information sign the 211 confidentiality agreement.
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