Polly Helpline User Policies:
Confidentiality, Privacy Statement, Complaints Procedure
Confidentiality is an undertaking between the service and the user that identifying details of the contact will not be disclosed outside of the organisation except in exceptional circumstances outlined below. Conversations are confidential between the caller / chatter and the service, not the individual worker. It is important that Polly is felt by users to be a safe space in which to talk, and to know that their confidentiality will not be breached without their knowledge and consent except in specific and dangerous situations, as described below.
Confidentiality will only be broken in exceptional circumstances. The decision to break confidentiality is taken by the senior management team in consultation with the worker working with the user.
Confidentiality will only be broken without the consent of the user:
• When Polly understands / is told by a person that they have seriously harmed, or intend to seriously harm imminently a third party and put that person's life in danger, or know of another individual who they believe has this intent, then confidentiality would also be breached without consent, as above.
• When Polly understands / is told that an act of self-harm has escalated so that the person realises they have gone too far and their life is in danger, then confidentiality would be breached without consent, as above.
• When Polly understands / is told that a person is seriously suicidal and has a plan and is undertaking it NOW – then Polly will breach confidentiality without consent if enough information is known such that the person can be located by emergency services.
• When a caller informs Polly of an impending act of terrorism.
In all cases the decider is that there is risk of significant harm to an individual.
The actions that Polly helpline can take is confined by the amount of information provided by the caller. This remains in the caller’s control. It may be possible to learn phone numbers of incoming calls but this can only be done by senior management and cannot overrule withheld number choices for example.
Collection of Personal Data
Polly respects the privacy of women and girls using the helpline. For this reason helpline workers cannot see IP addresses or phone numbers of devices used to contact the services. Names provided are first names only and may or may not be pseudonyms.
Polly does need to evidence to its supporters and funders how their donations are used so it is necessary to provide narrative and statistical analysis of Polly’s helpline services. So we do record if possible the age and location of those who contact Polly and provide this information as well as try to gather information on themes that callers are concerned with. Withholding any of this information does not preclude use of the services.
This data is stored under the terms of General Data Protection Regulations (GDPR) May 2018 on a secure server in the UK. There are no personally identifying details collected or recorded except in a Cause for Concern emergency situation. These details are stored on paper, hand written, in the helpline main office. Any narrative used by Polly to demonstrate impact and outcomes is completely anonymised and not traceable back to any user.
Statistical data will be retained for 3 years, records from Webchat are stored for 18 months and then permanently deleted. Cause for Concern records are securely stored for 7 years.
Consent for Collection and Transfer of Personal Information for Protection of Vital Interests
If a user of Polly helpline services presents with a cause for concern, defined as being at imminent risk of serious harm or death, or reports the same situation affecting a third party, or with information pertaining to terrorism then these are the only circumstances in which detailed personal data information (name, address/location, date of birth, contact telephone) will be requested. In this instance personal data can only be obtained with the consent of the person in contact with Polly.
After this consent is received information will be gathered to pass on to emergency services or other agencies which can assist (Social Services, DV charities) so that the individual subject of the cause for concern can be reached and assisted. These agencies record and use this information according to their policies and procedures, beyond the control of Polly.
In the case of information pertaining to terrorism whatever is known will be passed on to the Terrorism Hotline, 0800 789 321. It is not considered appropriate to request further detail or consent, in this situation.
Under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA) users of Polly services have a number of rights with regards to their personal data which is only obtained in the situations outlined above. A caller has the right to request from Polly access to and rectification or erasure of their personal data, the right to restrict processing, and can object to processing as well as in certain circumstances the right to data portability.
Withdrawal of Consent
A person who has provided consent for the processing of their data has the right to withdraw that consent at any time which will not affect the lawfulness of the processing before their consent was withdrawn.
Making a Data Protection Complaint
Any user of Polly helpline has the right to lodge a complaint to the Information Commissioners’ Office if they believe that Polly has not complied with the requirements of the GDPR or DPA with regard to their personal data.
Data Protection Officer
The Data Protection Officer can be contacted at firstname.lastname@example.org.
All data is stored in line with the requirements of the GDPR (May 2018) and any Freedom of Information Requests will be handled efficiently in a timely fashion.
In the first instance the helpline worker involved in the conversation should try to explain to the user the remit of the service in closer detail. It is important to see their point of view and take a balanced viewpoint.
If this does not resolve the situation and the caller wishes to make a formal complaint:
The user can email email@example.com with the subject line ‘Complaint’. Anonymous complaints will not be processed.
All complaints will initially be passed to the Polly Helpline Manager, who will notify the complainant that the complaint has been received, and discuss the nature of the complaint with the worker involved and will write to the complainant within 5 days of receipt to discuss it further and hopefully resolve the situation. Complaints are asked for in writing so that a full record can be kept of any complaints made and how they are dealt with.
If the complaint was not resolved in this way it would be escalated to the Director and then the Trustees of Polly for resolution.
Electronic correspondence about complaints is kept securely and would be deleted after six years.