Privacy policy.

This policy is to ensure that all Service Users are protected from having information about them passed to others without their knowledge or consent. It however is not limited solely to Service Users but extends to records containing confidential information regarding any person connected with Aspect Housing including staff and volunteers.
Aspect Housing recognises its common law duties to safeguard the privacy of the personal information which it holds about Service Users and employees. Confidential information is that which is regarded as ‘personal’. It is information which is told to an individual, or a group of people, and is not meant for public or general knowledge. It is the duty of all employees of Aspect Housing not to reveal to any other person, outside the specifically expressed person(s) within the organisation, any matter which becomes known to the individual via their involvement with the organisation.

What is ‘Personal Information’?

‘Personal Information’ is that which is defined by the individual, but should always include status, name, address, sexual orientation, personal lifestyle and relationship and financial situation.

Wherever Aspect Housing is considering disclosure of confidential information to another person or body, it will always check that such disclosure is lawful under the Data Protection Act (DPA).

All Employees will be made aware that the DPA applies to the processing of all personal data, both in manual files and by electronic means. Processes and procedures have been installed for ensuring the secure and confidential storage and transfer of personal information held about Service Users and others; failure by staff to observe those processes and procedures will be regarded as a disciplinary matter.

Processes of Data Storage

  1. All confidential information will be kept in a secure locked cabinet.

  2. All files and records concerning Service Users will be returned to the locked cabinet at the end of the working day.

  3. All documentation identifying service users will be disposed of using the confidential waste system (Shredder).

  4. Electronic records will only be kept on designated office computers.

  5. Electronic hard copies will be kept in a secure locked cabinet.

  6. Case files remain the property of Aspect Housing Ltd although service users can be given access and photocopies of their own case records on request.

  7. Records will be kept in Aspect Housing Ltd for at least 6 years after which time they will be confidentially disposed of.

  8. No information will be shared with a third party without the consent of the person concerned.  This includes telephone numbers and addresses.

  9. Email messages sent via the internet can be intercepted, read and changed relatively easily. Consequently, staff will not use the internet to pass on personal identifiable information about Service Users unless a secure or encrypted connection is in place.

  10. Aspect Housing Ltd recognises that information may be given out through staff informally discussing cases. All staff should ensure that no discussions identifying individual service users of the service take place outside of the service.

  11. Aspect Housing Ltd recognises that service users need to feel secure in using the service in a confidential manner. Aspect Housing Ltd will ensure that service users are offered confidential interview space if requested by the service user.

Confidentiality Statement

Aspect Housing Ltd is committed to providing a confidential advice service to its service users. Aspect Housing Ltd believes that principles of confidentiality must be integrated across all aspects of services and management. Aspect Housing Ltd believes its users deserve the right to confidentiality to protect their interests and safeguard Aspect Housing Ltd.’s services. The following will be displayed in each house and office premises.

“Aspect Housing Ltd offers a confidential service - nothing you tell us will be shared with anyone outside the service without your permission. With your permission we will contact relevant organisations and individuals in order to assist you. We will not contact anyone you expressly ask us not to. We are unable to ensure confidentiality in the reception area - if you do not wish to be overheard please ask for a private space to be made available.”

Consent to Data Sharing

When Aspect Housing Ltd completes an initial service user assessment prior to a service being offered our Client Needs Assessment Form (CNAF) ends with a “data disclosure waiver”, which allows the service user to consent to Aspect Housing Ltd sharing information (“personal data”) about them with third parties directly involved in the support of the service user in question.

It is the responsibility of staff members to ensure that where action is agreed to be taken on behalf of a service user, that service user must firstly have been asked if there is anyone, they do not wish Aspect Housing Ltd to contact. The service user's response will be recorded in their case file. Service users should be advised that Aspect Housing Ltd cannot guarantee to maintain confidentiality in case of criminal or abusive circumstances.

The staff members are responsible for checking with service users that it is acceptable to call them at home or work where applicable in relation to their case. All staff must ensure they make no reference to Aspect Housing Ltd to third parties when making telephone contact with service users.

The staff members are responsible for checking with service users that it is acceptable to write to them at home or work in relation to their case. All details of consent or requests not to disclose information must be recorded in the Support plan.

Breach of Confidentiality

Aspect Housing Ltd recognises that occasions may arise where individual staff members feel they need to breach confidentiality. Aspect Housing Ltd recognises, however, that any breach of confidentiality has to be treated very seriously and the following steps must be taken.

  • The support worker should where possible discuss the potential breach with the service user.

  • The support worker should raise the matter immediately with the Senior Support Worker (SSW).

  • The SSW will make written notes of the issues involved in the case which will be added to the service users file.

  • The SSW will be responsible for making the decision on whether confidentiality should be breached. If it is decided that confidentiality is to be breached the SSW should contact the Chairperson and should brief them on the full facts of the case.

  • The SSM should seek authorisation to breach confidentiality from the Directors.

  • If the breach of confidentiality is authorised, a full written report on the case should be made and any action agreed undertaken and a copy included in the case file.

  • If the Chairperson does not agree to breach confidentiality, then this will be the final decision.

Circumstances When Confidentiality May Be Breached

These circumstances relate to the following:

  • Attempted suicide where the support worker believes there is a serious or imminent risk of death.

  • Physical violence against oneself (self-harm) where Support Worker believes there is a serious or imminent risk of death.

  • Physical violence against others where Support Worker believes there is a serious risk of death.


Child Protection: 
Illegal acts against minors (child abuse):

  • Information relevant to child protection will be about:

  • Health and development of a child and her/his exposure to possible harm

  • A parent/carer who is unable to care adequately for a child

  • Other individuals who may present a risk of harm to the child

Children Act 1989 also imposes a duty on public bodies, i.e. all agencies, to assist Social Services in the exercise of their functions e.g. child protection if requested to do so and if it is not prejudicial to the discharge of their own function. Further, s.47 provides the duty for police and Social Services to investigate children at risk of significant harm and provides the power for agencies to share information in respect of children in need.

Consent - consent should always be sought from the service user before disclosing information to a 3rd party. However, there are instances where consent is not ultimately required:

  • Prevention of Terrorism - disclosing information to a 3rd party about acts of terrorism will not require the consent of the service user. This does not constitute a breach of Aspect Housing Ltd.’s confidentiality policy.

  • Risk of harm or death to self or others - In situations relating to a risk of harm or death to others, as defined in 2 & 3, the service user's consent is not required. The Support Worker will need to make a judgement as to whether or not the situation is serious enough to warrant breach of confidentiality with or without consent.


If a breach in confidentiality is to be considered it must be remembered that;

  • These occasions will be extremely rare

  • A decision to breach confidentiality will not be taken by one individual alone

  • Breaching confidentiality is a last resort, and should be as limited as possible

  • Records about the circumstances under which confidentiality is breached should be completed fully

  • All Aspect Housing Ltd staff must work within the law

Relevant third parties are;

  • Police

  • Social Services

  • NHS Services

  • Home Office


When a staff member feels confidentiality should be breached the following steps must be taken:

  • The staff member should where possible discuss the potential breach with the service user.

  • The staff members should raise the matter immediately with the Project Manager.

  • The staff member will discuss with the Project Manager the issues involved in the case and explain why they feel confidentiality should be breached and what would be achieved by breaching confidentiality. The Project Manager will make written notes of the discussion, which will be added to the service users file.

  • It is the responsibility of the Project Manager to discuss the available options for each case with the staff member.

  • The Project Manager is responsible for making decision on whether confidentiality should be breached. If it is decided that confidentiality is to be breached, then the following steps are to be taken:

  1. Aspect Housing Ltd Project Manager should contact the Chairperson and should brief them on the full facts of the case. The Project Manager should seek authorisation to breach confidentiality from Directors.

  2. If the branch of confidentiality is authorised, a full written report on the case should be made and any action agreed undertaken and a copy included in the case file.  The Project Manager is responsible for ensuring that all activities are actioned.

  3. If the Chairperson does not agree to breach confidentiality, then this will be the final decision.  Under no circumstance should any breach of confidentiality be discussed with anyone who would be in a position to investigate a complaint against Aspect Housing Ltd. This is to ensure that any future complaints or investigations arising from the breach in confidentiality can be carried out in an independent manner.

  4. If the decision is urgent and the Project Manager is absent, all the staff members will be collectively responsible for making a decision and taking the matter to the Chairperson where necessary.

Legislative Framework

Aspect Housing Ltd is mindful of its responsibilities to staff and service users under Article 8 of the Human Rights Act 2000 (the right to privacy). We are also mindful or the requirements of the Public Interest Disclosure Act 1998 the implications of which are comprehensively covered in our “Protection from Abuse” policy and procedure and the Data Protection Act 1998 to which we refer below.

Aspect Housing Ltd will monitor this policy to ensure it meets other statutory and legal requirements including the Rehabilitation of Offenders Act, Social Security Administration (Fraud) Act and Prevention of Terrorism Act.

Ensuring the Effectiveness of the Policy

All staff members will receive a copy of this Policy, which is also available to individuals and organisations with whom Aspect Housing Ltd works. The policy will also be explained to service users. Existing and new Staff members will be introduced to the Privacy Policy via induction and training. The policy will be reviewed annually, and amendments should be agreed by the Directors. All members of staff will be asked to read and sign a copy of this policy agreeing to abide by its terms. A copy of the signed agreement will be held on Aspect Housing Ltd staff files. 

Any questions relating to this notice and our privacy practices should be sent to info@aspecthousing.org.uk.