9(c) - Data Protection and Confidentiality

Section A - WHAT INFORMATION IS CONSIDERED "SENSITIVE"?

2.1 For information to be 'held' it must either be known to you (even by accidental disclosure), or stored by the police department. Knowledge and record of sensitive information is to be kept in confidence. The line manager for the division holding the respective information is responsible for authorising access.

2.2 Personal Data - Information held pertaining to police personnel and witnesses is considered sensitive. This excludes name and rank, unless a safeguarding reason also protects this (e.g. whistleblower/kept anonymous).

2.3 Records - Information held pertaining to internal investigations, complaints, and disciplinary records are considered sensitive. Everyone has the right to share their own record as long as this is done without malicious intent and the issuer of an infractions is kept anonymous.

2.4 Restricted Information - Information held which has been restricted to a number of authorised individuals/ranks/divisions, etc.

2.5 Communications - Private communications relating to the department via the PLPD.Online helpdesk, internal affairs feature and/or forum are protected by a confidentiality agreement between the submitter and those who access it. The submitter is welcome to breach their own confidentiality so long as there is no adverse effect on the department, that no other restricted information is disseminated, and should take care as certain disclosures may be considered as misconduct (e.g. disclosure to inflame a situation).

Section B - WHEN AND HOW SHOULD I ACCESS/USE SENSITIVE INFORMATION?

3.1 You must not access sensitive information to which you are not cleared to access (if it does not fall under your remit in the police hierarchy and responsibilities, you should seek approval from the appropriate line manager responsible for the information; see Section D: Data Cooperation).

3.2 You must only access or discuss sensitive information with a valid reason.

3.3 You must only access or discuss sensitive information in an appropriate capacity (e.g. it would be inappropriate to discuss an IA complaint in earshot of other officers).

Section C - WHAT SHOULD I DO IF I'M AWARE OF A CONFIDENTIALITY BREACH?

4.1 Confidentiality of sensitive information is to be respected at all times. If there is some possibility, or certainty that unauthorised individual(s) may have accessed confidential information, it is considered a breach.

4.2 In this case, it is important to notify the line manager responsible for the information, and any other relevant individuals who are working with the data immediately with details of the nature and scope of the breach.

4.3 The line manager should take steps, potentially sanctioning disciplinary action, to ensure that the breach is corrected and is unlikely to occur again.

Section D - DATA COOPERATION

5.1 It is recognised that information, including sensitive information must sometimes be shared between divisions in the department.

5.2 Large amounts of data, or specific cases, can be shared so long as justified and approved by the respective line manager.

5.3 Where appropriate, this data must be anonymised and only contain relevant information that is fit for purpose.