Confidentiality Policy

Deese Marketing Association


  1. General principles
    • Deese Marketing Association recognizes that employees, volunteers and trustees gain information about individuals and organisations during their work or activities. In most cases such information will not be stated as confidential and colleagues may have to exercise common sense and discretion in identifying whether information is expected to be confidential. This policy aims to give guidance but if in doubt, seek advice from your line manager.
    • Colleagues can share information with their line manager in order to discuss issues and seek advice.
    • Colleagues should avoid exchanging personal information or comments (gossip) about individuals with whom they have a professional relationship.
    • It is not appropriate to discuss a person’s sexuality (i.e. ‘outing’ a gay person) without their prior consent.
    • Colleagues should avoid talking about organisations or individuals in social settings.
    • Information given to staff members or volunteers acting on behalf of Deese Marketing Association is given to Deese Marketing Association as an agency rather than to the individual staff member or volunteer.  In order to give the best possible service to users of Deese Marketing Association services, it is sometimes desirable to share information with other colleagues in the organisation.
    • Constructive liaison with other agencies is sometimes essential if individuals and groups are to be offered an effective service by Deese Marketing Association.  However, confidential matters must not be discussed outside of Deese Marketing Association without the prior permission of the individual or organisation.
    • Where there is a legal duty on Deese Marketing Association to disclose information, the person to whom the confidentiality is owed will be informed that disclosure has or will be made.
  1. Why information is held
    • Most information held by DEESE MARKETING ASSOCIATION relates to clients, voluntary and community organisations, self-help groups, volunteers, employees, trustees or services which support or fund them.
    • Information may be kept enabling DEESE MARKETING ASSOCIATION to understand the history and activities of organisations in order to deliver the most appropriate services.
    • DEESE MARKETING ASSOCIATION has a role in putting people in touch with voluntary and community organisations and keeps contact details which are passed on to any enquirer, except where the group or organisation expressly requests that the details remain confidential.
    • Information about ethnicity and disability of users is only kept for the purposes of monitoring our equal opportunities policy and for reporting back to funder.
  1. Access to information


    • Information is confidential to Deese Marketing Association as an organisation but may be passed to colleagues, line managers or trustees to ensure the best quality service for users.
    • Where information is sensitive, i.e. it involves disputes or legal issues, it will be confidential to the employee dealing with the case and their line manager. Such information should be clearly labelled ‘Confidential’ and should state the names of the colleagues entitled to access the information and the name of the individual or group who may request access to the information.
    • Colleagues will not withhold information from their line manager unless it is purely personal.
    • Users may have sight of Deese Marketing Association records held in their name or that of their organisation. The request must be in writing to Deese Marketing Association giving 14 days’ notice and be signed by the individual, or in the case of an organisation’s records, by the Owner/CEO. Sensitive information as outlined in para 3.2 will only be made available to the person or organisation named on the file.
    • When photocopying or working on confidential documents, colleagues must ensure they are not seen by people in passing. This also applies to information on computer screens.
  1. Storing information
    • Deese Marketing Association keeps non-confidential information using paper files and computers. Confidential information is maintained with an appropriate level of security, in accordance with the Data Protections Act and this policy, which will adequately protect information about individuals that is held in the systems.
    • Information about volunteers and other individuals will be kept by the colleague directly responsible. These colleagues must ensure line managers know how to gain access.
    • Employees’ personnel information will be kept in filing cabinets and will be accessible to Deese Marketing Association or to those who are entitled to see it as part of their duties.
    • In an emergency, Deese Marketing Association may authorize access to files by other people.
  1. Duty to disclose information
    • There is a legal duty to disclose some information including:
    • Child abuse will be reported to the Children, Schools and Families Departments, as well as Civil Authorities (e.g. Police).
    • Drug trafficking, money laundering, acts of terrorism or treason will be disclosed to the police.
    • In addition, a colleague believing an illegal act has taken place, or that a user is at risk of harming themselves or others, must report this to the Administrative Department ( who will report it to the appropriate authorities.
    • Users should be informed of this disclosure. Unless Restrained by court or civil orders.


  1. Disclosures


6.1       Deese Marketing Association complies fully with the CRB Code of Practice regarding the correct handling, use, storage, retention and disposal of Disclosures and Disclosure information.

6.2       Disclosure information is always kept separately from an applicant’s personnel file in secure storage with access limited to those who are entitled to see it as part of their duties. It is a criminal offence to pass this information to anyone who is not entitled to receive it.

6.3       Documents will be kept for a year and then destroyed by secure means.  Photocopies will not be kept. However, Deese Marketing Association may keep a record of the date of issue of a Disclosure, the name of the subject, the type of Disclosure requested, the position for which the Disclosure was requested, the unique reference number of the Disclosure and the details of the recruitment decision taken.


    7. Breach of confidentiality


7.1.      Employees who are dissatisfied with the conduct or actions of other colleagues or Deese Marketing Association should raise this with their line manager using the grievance procedure, if necessary, and not discuss their dissatisfaction outside of Deese Marketing Association.

7.2.      Colleagues accessing unauthorized files or breaching confidentially will face disciplinary action.  Ex-employees breaching confidentiality may face legal action.


   8. Whistle-blowing


8.1       Where the finance officer has concerns about the use of Deese Marketing Association funds, he or she may refer directly to the Owner/CEO outside the usual grievance procedure. In a case which may involve Owner/CEO, Whistle-blower have ABSOLUTE right to file complaint with an Independent team specialize and appointed by legal entities. ONLY the court shall appoint a take-team for removal of data and documents for legal review for criminal wrong-doing.

This policy is to be read in conjunction with the following policies/documents:

  • Confidentiality Policy
  • Data Protection Policy
  • Social Media Policy
  • Whistle-blowing Policy
* The Designated Person would normally be the most senior paid staff member or nominated Trustee


Review date: 11/21/2020