Confidentiality Policy

All staff members will be expected to respect the privacy of persons served by the Corporation of Community Action and Child Care Outlook and other related agencies and confidentiality of information regarding the persons served. At all times, both within the office and outside, it is imperative that all staff members maintain propriety and an appreciation of the importance of keeping confidential all information concerning program participants, even though some such information may become a matter of public record or reported in the media. No program participant-identifying information shall be shared with any outside organization or individual without first obtaining a written release from the program participant or his/her guardian. Program participants shall be informed of the potential for releasing information with Community Action programs.

1. Program Participant Access
   
   Program participants of Community Action shall have complete access to any files or records of which they are the data subjects. No personal or other program participant-identifying information shall in any way be hidden or protected from program participant inspection. Program participant records shall be accessible to the data subject within 2 days after written request for such record is made. Program participant-identifying information is defined as any materials such as names, addresses, social security numbers, birth dates, etc. which could be used to trace the identity of a program participant. Age and sex of a program participant shall not be construed as program participant-identifying information. Information received by an employee in the course of employment concerning program participants or other business that is confidential shall not be discussed inside or outside the office other than as part of work. Violation of this rule will result in disciplinary action and/or termination.
   
   
2. Non-Program Participant Access
   
   No individual, corporation, or agency (public or private), other than the program participant, shall have access to any program participant-identifying information without the prior written consent of the program participant, except as noted below:
   
   a. Emergency Release: In the case of emergency where some imminent harm to self or others may befall the program participant, identifying information may be released without hte prior written consent of the data subject.
   
   b. Monitoring Release: If the performance or compliance with an outside funding source requires the submission of program participant identifying information to determine program participant eligiblity or contract accountability, such information shall be submitted to the funding source in code form, with the provision that the agents or auditors of such funding sources may inspect program participant identifying information.
   
   
3. Multiple Program Participant Subjects
   
   If more than one program participant is mentioned in the same case records, memo, letter, or other document, release of material shall be contingent upon the deletion of all program participant-identifying information other than the particular program participant being sought.
   
   
4. Requests for Information Release
   
   Child Care Outlook staff shall not release any program participant-identifying information with any outside agency or individual, without the prior written consent of the program participant.
   
   
5. Court Order Release
   
   All program participant-identifying information shall be considered as privileged information, and shall not be released without the prior written consent of the program participant, except upon demand of a court order.
   
   
6. Juvenile Program Participants
   
   If a program participant is under 17 years of age, written approval for information release must be signed by the program participant's parent or court-appointed guardian unless the child has been declared legally emancipated.