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Learning For Life Confidentiality Policy
Learning For Life Confidentiality Policy
Policy
The Sandra Sullivan Learning for Life Program of the West Side Catholic Center aims
to ensure that, as far as possible, appropriate support is offered to adult students
and volunteers to meet their needs and enhance their education or service. To meet
this end, adult students and volunteers will be asked to disclose information that
may be deemed sensitive, including being encouraged to disclose any disability to
help us make the necessary adjustments to support their education or service.
Informed Consent
1) Program participation information on both students and tutors like registration
status, attendance, progress, and assessment scores may be released to or
collected from outside organizations if requested using the Release of Academic
Information form, Student Verification form, or other official forms requested by
the third party institution with the consent of the student or volunteer. Oral
consent may be given by phone if the person can verify his or her identity using
date of birth and last four digits of Social Security Number. It will be made clear
to the student or volunteer to whom their program participation information will
be disclosed. Apart from the agreed people, the information will remain strictly
confidential.
2) Sensitive personal data (including disability status) will only be released within
the Learning for Life Program if two criteria are met:
3) The student or volunteer will be informed why there is a need to disclose the
information, who will have access to that information, and what the likely
consequences are of giving or withholding consent. Written permission must be
obtained from the student before any information regarding sensitive personal
data can be shared with a third party (with the exception of the circumstances
listed below under Exceptional Disclosures).
Disclosure
4) There is no duty on a student or volunteer to disclose a disability or other
sensitive personal information. The Learning for Life Program will take
reasonable steps to find out if a student is disabled so that the appropriate
action can be taken (e.g. screening all new students using the Learning Needs
Screening Tool). Students or volunteers cannot be denied entry to a program for
refusal to disclose sensitive personal information or based on any personal
information that is disclosed (with the exception of the circumstances listed
below under Exceptional Disclosures).
Confidentiality Request
1) A student or volunteer has the right to request that their program participation
information and sensitive personal information (i.e. disability status) be treated
as confidential. Also, the Learning for Life Program will continually endeavor to
meet the requirements of students and volunteers with special needs. On
occasion it may be necessary to make an additional adjustment when the
student has requested confidentiality to ensure that the disclosure remains
private. In determining whether it is reasonable to make an adjustment, the
University must have due regard to the extent that making the adjustment is
consistent with a disabled student's request for confidentiality. In some cases,
this might mean that reasonable adjustments have to be provided in an
alternative way to ensure confidentiality or that no reasonable adjustment can
be provided.
Exceptional Disclosures
1) The Learning for Life Program has a duty not only to disabled students and
volunteers, but also to other staff, volunteers and students. Certain exceptional
circumstances may allow for the release of personal sensitive data. These
include:
a) Where there is an immediate and serious threat to the personal safety of the
student or volunteer concerned;
Data Protection
1) Information relating to physical or mental health constitutes sensitive personal
data. Explicit permission from the data subject must be sought before this type
of information is passed on to a third party, unless there is a legal obligation to
provide the information.
a) Enrollment status
b) Attendance information
d) Birth date, last four digits of social security number, or other identifying
personal information
e) Administrative Staff
Remember a student or volunteer may be happy for his or her special needs to be
disclosed to staff and tutors who will need to make reasonable adjustments, but this
does not mean that they want everyone to know.