People and Animal Learning Services (PALS) Confidentiality Policy
The PALS Confidentiality Policy defines how Staff, Volunteers, Clients, and Board Members are expected to treat confidential information. These groups will unavoidably handle personal and private information about clients, partners, and PALS. It is imperative that this information is well-protected and not shared with those who do not need it. We must protect this information for two reasons:
- PALS handles sensitive medical information that may be subject to the Health Insurance Portability and Accountability Act (HIPAA). This should not be shared without proper authorization.
- PALS handles contact information that may create a safety issue if improperly shared and should not be released without proper permission.
Examples of confidential information include, but are not limited to:
- Unpublished financial information, such as anonymous donations, donor contact information, and donation amounts.
- Data for Clients, Volunteers, Staff, and Board Members.
- Data entrusted to PALS by external parties such as health care providers.
- Documents and processes explicitly marked as confidential.
PALS Staff has the primary role in protecting confidential information. All PALS staff should:
- Lock or secure confidential information at all times. Medical and contact information must be available when the facility is open in case of an emergency.
- Shred confidential documents when they’re no longer needed.
- Ensure confidential information is only viewed on secure devices and is properly password protected.
- Disclose information to others only when it is necessary and authorized by the PALS Executive Director. All information that must be transmitted outside of PALS will be done by FAX to prevent a potential breach of confidentiality by sending via email or text.
- Keep confidential documents inside the PALS premises unless it is deemed absolutely necessary to remove them.
- Board Members and Volunteers play a significant role in bullets 3-5 above.
PALS Staff, Board Members, and Volunteers should never:
- Use confidential client, volunteer, donor, or staff information for any personal benefit or profit.
- Disclose confidential information to anyone outside of PALS without proper authorization.
- Replicate confidential documents and/or store them on insecure devices.
When Staff are no longer employed by PALS, they must return any hard copies of confidential documents and delete digital copies from all personal devices.
Exceptions
Confidential information may occasionally have to be disclosed for legitimate reasons such as, but not limited to:
- In the case of an emergency, confidential information may need to be released to medical response personnel.
- If requested by a regulatory agency as part of an investigation.
- If requested by PATH auditors for recertification audits.
Disciplinary Consequences
Any breach of this policy will be investigated. Anyone who knowingly breaches confidentiality guidelines will be subject to disciplinary action up to and including termination, dismissal from the program, or removal from the Board. Violation of this confidentiality policy may also result in legal action.
All Staff, Volunteers and Board Members are expected to review and sign this document annually.
