Confidentiality Procedures Policy Number and Last Update
(01.05.11e/01-2011)

This policy is effective July 1, 1998, and continues in effect until revised or rescinded.

The privacy and trust of the person who is the subject of the information to be shared, either verbally or in writing, is to be maintained at all times. No records shall be accessible to unauthorized persons. Information, which is to be released or shared, must be limited to that which is necessary for the proper delivery of services.

Employees:

  • Only information that is factual and directly pertinent to work will be collected or disclosed. Personal or private data is not to be pried into nor discussed by the employer.
  • Relevant information will be disclosed only to those who need to know it for some management function.
  • Employees are not to be denied access to their own personnel files.
  • Require a subpoena for specific materials requested by any persons or organization (police, F.B.I., attorneys).
  • The following documents are considered confidential and, as such, will be accessible only to supervisory staff on a need-to-know basis: information contained in staff personnel files (records of medical findings in sealed envelope in file), staff rosters, staff training records, emergency contact data.
  • The following documents may be posted using first name and last initial only: time cards, volunteer lists, staff schedules, center organizational chart, other personally identifiable lists, documents, charts, etc.
  • Any person infected with the HIV virus must have every protection made available to persons with disabilities. This includes confidentiality of all information related to the condition.

Children:

  • Do not post in the classroom any identifying data, including: name of child, parents, or family members (only first name and last initial are acceptable), address or telephone number of the child, social security number, list of personal characteristics or other identifying information. Any such information must stay in locked files and maintained according to IMSHSP filing procedures.
  • Do not leave children's records on tables, desks, or other places in classrooms or offices where others may have access to them. Establish a place in rooms that will ensure confidentiality of records.
  • Do not discuss a child's disability or other personal or family data, except in a formal setting, on a professional basis. Never discuss any such information in front of children. Never divulge any such information to families, friends, community members, or members of the board of directors. Never divulge such facts to grantee staff unless necessary and requested by them.
  • Classroom staff will be informed of any and all findings that they need to understand, support, and work with every child in their care. This may or may not include the diagnosis of a child's disability. Teachers participate in writing and carrying out educational goals of the IEP/IFSP.
  • All children's medical, educational, and family records are considered confidential, and, as such, will be accessible only to staff on a need-to-know basis.
  • When going outside the center (i.e., field trips, medical appointments, etc.) use center name and telephone number only. Do not display children's names.
  • The center shall have a release-of-information (Parent Permission to Reveal Confidential Information) signed by the parent(s) which specifies the party to whom the information may be released and how long the release form is valid before divulging any data. No confidential information shall be released by phone.
  • Staff will coordinate with other Head Start programs, and schools, to transfer relevant child-records, in order to streamline services. Transfer of records, by phone, computer, or mail, must follow confidentiality procedures.

The out-card system or similar sign-out system will be used by the center for examination of records by authorized staff. The out-card must include the name of the file removed, initials of the person using it, date and time pulled, and date and time replaced.