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კონფიდენციალურობა და ინფორმაციის გაზიარება


1. HERA-XXI places a high value and importance on confidentiality and respects the
confidentiality of its governing bodies, volunteers, staff, beneficiaries, complainants
and partner organizations.

2. HERA-XXI also understands the importance of sharing information where required or
appropriate in order to perform its safeguarding duties.
3. This policy is intended to set out the guiding principles and values applicable to all
elements of HERA-XXI . These guiding principles and values need to be implemented
through the relevant national policies and procedures.
Purpose and scope
4. The purpose of this policy is to provide guidance to all in HERA-XXI with regard to the
protection of confidential information and responsibilities regarding the sharing of
such information.
5. This policy applies to all volunteers, members, governing bodies and staff of HERAXXI and collaborative partners. All partner organizations working with HERA-XXI are
required to adhere to this Policy in addition to their own policies and procedures.
6. References to obligations to confidentiality are references to the need to protect
confidential information from unauthorized disclosure. Confidential information
may consist of:
i. Personal information of a private or sensitive nature;
ii. Information that is not already lawfully in the public domain or readily
available from another public source;
iii. Information that has been shared in circumstances where the person giving
the information could reasonably expect that it would not be shared with
7. For HERA-XXI, confidential information includes:
i. Internal organization information and all proprietary information not generally
known outside of HERA-XXI, and
ii. Personal information relating to volunteers, members of governing bodies,
staff, beneficiaries, and partners. Such information would include information
relating to complaints or grievances etc.
8. Obligations of confidentiality may, exceptionally, be overridden by the public interest
in disclosure. This will be the case only where a strong public interest justifies the

disclosure of information which an individual would otherwise be entitled to protect.
Disclosure will not be in the “public interest” merely because the public, or sections
of it, will be interested in the material. Any decision to override obligations of
confidentiality in the public interest is complex and must take account of both the
potential harm that disclosure may cause and the general public interest of society
in the preservation of confidentiality.
9. HERA-XXI acknowledges confidentiality is an important principle in promoting trust,
a culture of speaking up and ensuring that people feel safe to raise concerns and to
report incidents.
10. HERA-XXI recognises that confidentiality is not absolute and that sharing relevant
information, when appropriate, is vital to good safeguarding practice. HERA-XXI is
committed to being open and honest from the outset about why, what, how and
with whom information will, or could, be shared.
11. HERA-XXI is committed to taking appropriate security measures to prevent
unauthorized people from gaining access to its information technology systems and
other information.
12. Whistleblowing is not considered a breach of confidentiality. HERA-XXI’s approach to
whistleblowing includes the protection of employees who raise concerns or
complaintsabout HERA-XXI’s practices.
Information Sharing Requirements
13. There are situations where HERA-XXI’s governing bodies, volunteers, members or
staff may have a legal duty to disclose information outside of HERA-XXI, including:

i. Where it is critical to prevent serious harm or distress or in life-threatening
ii. In order to report all child abuse to the relevant statutory services;
iii. In order to report abuse of vulnerable adults and adult beneficiaries externally
in line with HERA-XXI’s Safeguarding Incident Report procedure;
iv. In order to report drug trafficking, money laundering and acts of terrorism to the
v. Where it is requested in a court order.
14. If individuals have concerns about disclosing information they may discuss this with
their line manager and/or the executive director

Confidentiality and Information Sharing in Health Service Provision
15. HERA-XXI adheres to national confidentiality legislation in relation to confidential health
records and their information sharing requirements.
Specific actions
16. Specific actions to be taken to ensure confidentiality

I. All confidential documents should be marked “confidential” before being shared
II. with the audience they were prepared for.
III. All recipients of confidential documents shall be reminded of their duty to
keep these confidential. A small heading on confidential documents which
makes thisclear can help.
IV. All confidential emails within the orgaization should be sent out with the
heading“confidential” with express request for readers to keep their content
confidential unless expressly authorized to do otherwise.
V. All confidential data containing personal information shall be password protected.
VI. Access to rooms and offices where personal or other confidential
information is stored must be controlled and doors effectively secured.
VII. Measures should be in place to prevent oversight of personal or other
information by unauthorized parties when sharing office space with others.
VIII. Care must be taken in transferring information to ensure that the method used
Reviewed& Approved Date: 2022

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