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Sharing Personal Information Successfully

The purpose of this brief guide is to help make the client's journey through the "employability pipeline" (Scotland's employability customer journey) as smooth as possible. By sharing personal information, with the client's consent, partners and providers can streamline and ease the client's journey, so that for example, they don't have to keep repeating their story. Referrals to other partners or providers can be made easier, and ultimately the client can be supported towards and into employment.

The guide does not give you all the information you need to know, but it gives an overview and points you in the right direction. Specifically it deals with:

  • what personal information is;
  • why sharing information is a good idea; and
  • how to make it work, including things to consider such as the Data Protection Act (DPA).

The guide also provides illustrative case studies, highlights top tips for sharing of personal information, and contains useful links. It does not deal with the sharing of data, in the sense of sharing data sets of aggregate numbers, or research and data sets/ files.

A case study on this area has been produced by North Lanarkshire Council.

If you have comments or feedback on this document, suggestions, or want to add a case study, please feel free contact us.

  • What is Personal Information?

    Personal identifiable information relates to the individual in some way, whether in personal or family life, business or profession. Information is not just what is written in formal files or held in electronic records. It includes all:

    • documents;
    • letters;
    • faxes;
    • emails;
    • photographs.

    The Information Commissioners Office (ICO) has produced a quick guide to what is considered personal information that you can access here

    Spoken communication on the phone or in person is not covered by the DPA, but comes within confidentiality and professionalism. It is therefore also important to consider how personal information is managed and shared over the phone or in person.

  • Why is sharing of personal information a good idea?

    Effective and appropriate information sharing can be crucial for successful multi agency working and can make a real difference with;

    • helping to provide a seamless service to customers and increase the opportunities for people to develop and sustain employability skills,
    • preventing clients from having to repeatedly give the same information to different providers and staff members, creating a smoother, more stream lined, and more efficient process and service for them,
    • planning, tailoring, commissioning and targeting services - including improving outcomes through more targeted service provision and helping to identify any shortfalls in provision and duplication of services,
    • helping organisations and agencies to  clarify, collect, and monitor outcome and impact information as well as to evaluate, and
    • using a system for sharing personal information can also be used to promote training and other activities.
  • How to make it work.

    In order to share information legally and effectively you, and the partners that you want to share the information with, will need to be able to answer the following questions. Each will be dealt with briefly below:

    • Why do you want to share personal information?
    • What information do you need to share?
    • Who will you share it with, and how will you share it?
    • When will you share it?
    • Are there any legal limits to what you can share?
    • How will you know if sharing of personal information is making a difference?
  • Why do you want to share personal information?

    To legally share information you need a clear reason to do so. Simply because it might be useful is not a sufficient argument. However, to stream line the client's journey through the employability pipeline towards employment and to aid referrals, would be good reasons for it. Please see also page 4 regarding legal issues.

  • What information do you need to share?

    Think about what's needed to deliver a streamlined service for clients travelling through the employability pipeline and what you need to share to help this - e.g. names, qualification levels, previous experiences and backgrounds, and if they have any particular needs, for example literacies or skills needs.

  • Who will you share it with, and how will you share it?

    You will need to think about who your partners are and who you will need to work closely with to ease the client's journey. This may be the Local Authority, the Community Planning Partnership, a college, Third sector organisations, others, or all of the above.

    Different staff grades will have different roles when it comes to information sharing according to post holders' level of responsibility, the range, sensitivity and complexity of information handled, and whether there are any risks to service users. However generally all staff should be aware of the processes of sharing personal information and what they can and cannot do.

  • Practical Guidance for frontline staff

    Much of this is common sense but it is worthwhile remembering a few things. For example, when exchanging information by phone, email or other means it is important to not leave personal employability information on recipient's answering machines; to ensure that emails or letters are directed to the correct recipient and that no personal details are mentioned in the email's subject heading. If by post consider using Special Delivery where possible to ensure a secure delivery. Avoid faxing any personal information. Also make sure you store any information safely.

  • Your responsibility to your clients

    Clients have different needs and values. What is 'sensitive' to one person may be casually discussed in public by another. Or, something which may not appear to be sensitive may in fact be important to an individual in their particular circumstances.

    Clients also have a right to know about the information held about them, how it will be used and with whom it will be shared. It is your responsibility to make sure that they are aware of this - including exactly what information you will be collating and sharing and to get their permission to do so. This can be done for example by obtaining written consent. (Please see end note ii. for examples of this).

    You should:

    • make clear to clients when information is or may be shared to others involved in their employability support;
    • make sure that clients are aware of the choices that are available to them on how their information may be disclosed and used;
    • check with clients to make sure that they have no concerns or questions about how their information will be disclosed and may be used;
    • answer any questions personally or direct clients to others who can answer their questions; and
    • respect the rights of clients and help them to access their employability records if they have asked to do this.
  • When will you share personal information?

    You may want to consider the regularity of sharing personal information. Are you going to do it ad hoc, or will you set up parameters for this. For example will you share it weekly, monthly, bi-monthly, and so forth. You will want to ensure that you share it at a time that suits you and your partner organisations, as well as your clients.

  • Are there any legal limits to what you can share?

    Many organisations can be unsure about what and how they can share personal information. Often they use the Data Protection Act (DPA) as a reason against the sharing of personal information. However, the DPA is not a barrier as long as the sharing of information is justified, necessary and proportionate - in this case in relation to sharing of clients' personal information to ease their journey through the employability pipeline and to help making referrals smoother.

  • The Data Protection Act

    The Data Protection Act (DPA) 1998 aims to strike a balance between individual concerns and the common good. It places obligations on those who process information and gives individuals certain rights of privacy regarding the information held about them.

    The Information Commissioners Office (ICO) has also produced guidance for sharing of personal information and on the Data Protection Act.

    The DPA's set of principles is key to understanding what is possible. The principles state that data be:

    • processed fairly and lawfully (Principle 1)
    • processed for limited purposes only (Principle 2)
    • adequate, relevant and not excessive (Principle 3)
    • accurate and, where necessary, kept up to date (Principle 4)
    • data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes (Principle 5)
    • processed in accordance with the rights of data subjects under this Act (Principle 6)
    • kept secure from unauthorised or unlawful access (Principle 7). 

    Data or personal information sharing must comply with Article 8 of the Human Rights Act 1998 ("Everyone has a right to respect for his/her private and family life, his/her home and his/her correspondence").  The Human Rights Act 1998 sets the rights and freedom that belong to people whatever their nationality and citizenship. The act contains 16 basic rights covering matters of life and death such as freedom from torture and being killed. But, they also cover rights in everyday life such as the right to respect for private and family life, their home and correspondence. In general, this means that individuals have the right to live their own life with such personal privacy as is reasonable in a democratic society, taking into account the rights and freedom of others. More information can also be found at the Equalities and Human Rights Commission (EHRC - Guidance by public sector area).

  • How will you know if the sharing of personal information is making a difference?

    To be able to see to see whether the sharing of personal information is working or making any difference, and what the benefits may be, you and your partners will need to consider if, and if so how, you will review your processes and any progress.

    You may even want to consider an evaluation. Further you will also need to decide what you will do if it is not working, or what steps you can take to make improvements.

  • Top Tips

    Key to the effective sharing of personal information is to establish the aims, objectives and purpose of the sharing of information, as well as intended outputs and outcomes.

    Effective sharing of personal information is about:

    • a concern for how sharing of personal information can really help the client - think "sharing clients, not sharing information"
    • good partnership practice, based on trust built on competence in managing and using personal information and keeping it secure.

    Remember that the Data Protection Act is there for good reasons - to protect the privacy of personal data and information. You can get to know the legal basics and not make the DPA an unnecessary barrier. Lots of information sharing can be done readily within the law:

    • for 'research' (and planning) purposes,
    • anonymised records,
    • and importantly, with personal consent built in.

    The following lists 'top tips' for making sharing of personal information as successful as possible:

    • Ensure you have good levels of buy in from senior partners and a good business case as to why sharing of personal information would be beneficial for the clients going through the employability pipeline - and worth the resources involved in doing so.
    • Ensure that all staff has knowledge, awareness and are confident about what can and cannot be shared, and that personal information is handled and kept in a secure manner.
    • Use pre existing multi agency forums and links and engage in informal dialogue as well - others might already be sharing personal information and may be willing to share their experiences.
    • Adopt consistent definitions with partners about the information you will share to ensure quality, e.g. are you using the same qualification levels and age groupings?
    • Develop protocols for sharing of personal information - this may be used as a means of helping to strengthen information sharing arrangements, and clarifying the process and types of information that may be exchanged. The process of developing a protocol may be very helpful in managing the potential uncertainties about what can be shared, by whom and under what circumstances. It would also clarify to whom the data/ information belong at the end of e.g. a contract, if that is applicable. Should information be returned to the contracting organisation or securely destroyed or, indeed, kept by the contractor for archival purposes?
    • Put yourself in your partners' shoes - understand the pressures on them and what is in it for them in sharing personal information.
    • Develop client tracking systems, designed to enable  sharing of client information - based on personal consent - and to underpin a seamless service.
    • If possible build the need for sharing of personal information into any data capture and IT/ database system design.
    • And most importantly, ensure clients know that you want to share their personal information, for what purposes, and
    • ensure you have their consent to do so. This is key to make progress on data sharing.
  • Available resources and data sets

    Data protection, Information Commissioner's Office, and Human Rights:

    Protocols, reports and general information:

    Available national data sets for information about national and local labour market information: