Targeted Provision - Confidentiality Policy

1. Purpose, scope and status

This policy sets out how everyone who works with Targeted Provision Ltd must keep information about children, young people and their families confidential, and when and how to share it to keep them safe.

It applies to:

• employees: people employed by Targeted Provision;

• workers: people engaged under a worker contract who are not employees; and

• contractors: self-employed tutors, mentors and other professionals engaged under a contract for services.

In this policy, "everyone who works with us" means all three.

For contractors, the obligations in this policy arise from Targeted Provision's duties under safeguarding legislation, data protection law, Keeping Children Safe in Education 2026 and its contracts with commissioning local authorities. They form part of the contract for services, and do not create an employment or worker relationship.

2. Sharing information to keep children safe

Our first priority is a quick and thorough response to safeguarding and child protection concerns. Sharing information promptly with the right people is often essential to keeping a child safe.

UK GDPR and the Data Protection Act 2018 do not prevent information being shared to safeguard a child. Do not let worries about data protection or confidentiality get in the way of keeping a child or young person safe.

In particular:

• Never assume someone else will pass on a concern. If you are worried about a child, report it yourself.

• Share concerns quickly and clearly, so the DSL and anyone else involved can understand, assess and respond.

• Only seek consent where it is safe to do so. Do not ask for consent to share information if doing so could increase the risk of harm to a child, or compromise an investigation.

• Share only what is needed, with the people who need it, accurately and securely.

3. How to share safeguarding information

1. If a child is in immediate danger, call 999 first, then tell the DSL or a deputy as soon as possible.

2. In every other case, report the concern to the DSL or a deputy straight away, using the red button or the safeguarding contacts in section 5.

3. The DSL decides what is shared outside Targeted Provision, with whom, and on what basis, and records the decision and the reasons. The DSL will inform the Chief Strategy Officer where appropriate.

4. Do not share safeguarding information outside Targeted Provision yourself, except with the emergency services in an emergency.

Where there is no safeguarding concern, information about children and young people is shared within Targeted Provision on a need-to-know basis only. If you are unsure whether something can be shared, ask the DSL or a deputy.

4. Keeping information confidential day to day

Everyone who works with us must:

• use information about children, young people and their families only to deliver and report on the services they provide through Targeted Provision;

• not discuss a child or family with anyone who does not need to know, including in public places or on social media;

• keep information secure, whether on paper or on a device, and use Targeted Provision's systems for session records and reports;

• not keep children's personal information or images on personal devices, or put them into generative AI tools;

• report any loss or suspected breach of children's information to the DSL and the Head of Education without delay (see the Online Safety Policy); and

• continue to keep information confidential after their employment or engagement ends.

Breaches of this policy may lead to action under the Disciplinary Procedure (employees and workers) or the contract for services (contractors), and may be a safeguarding matter.

5. Contacts and review

This policy is reviewed every six months, and updated to reflect changes in law, statutory guidance or good practice.