Information Sharing Policy

As a registered charity, [Charity name] is committed to sharing information responsibly, lawfully, and proportionately to support its charitable purposes, safeguard individuals, and comply with legal and regulatory obligations.
This Information Sharing Policy sets out the principles and procedures governing how information is shared within the Charity and with external parties, ensuring that confidentiality, data protection, and safeguarding requirements are upheld.

The Trustees recognise that appropriate information sharing can be essential to effective service delivery, safeguarding, partnership working, and accountability.

Purpose of the Policy

1.1 The purpose of this Policy is to:

Promote safe, lawful, and effective information sharing.
Protect personal, confidential, and sensitive information.
Support safeguarding and public interest decision-making.
Ensure compliance with data protection and confidentiality obligations.

1.2 This Policy provides a framework for consistent and responsible information sharing.

Scope of the Policy

2.1 This Policy applies to:

Trustees.
Employees.
Volunteers.
Contractors and third parties acting on behalf of the Charity.

2.2 It applies to all information held or processed by the Charity, including:

Personal data.
Sensitive or confidential information.
Operational, financial, and governance information.

Definition of Information Sharing

3.1 Information sharing refers to:

The disclosure, exchange, or transfer of information between individuals or organisations, whether internally or externally, for a specific purpose.

3.2 Information may be shared in written, verbal, electronic, or other formats.

Legal and Regulatory Framework

4.1 The Charity will share information in accordance with:

Data protection legislation.
Confidentiality obligations.
Safeguarding duties.
Charity Commission guidance.

4.2 Information will only be shared where there is a lawful basis to do so.

Principles of Information Sharing

5.1 The Charity’s approach to information sharing is guided by the following principles:

Lawfulness, fairness, and transparency.
Purpose limitation and data minimisation.
Accuracy and relevance.
Security and confidentiality.
Accountability and documentation.

5.2 Information will be shared on a need-to-know basis only.

Types of Information

6.1 Information covered by this Policy includes:

Personal data relating to beneficiaries, staff, volunteers, and donors.
Special category or sensitive personal data.
Safeguarding-related information.
Confidential organisational information.

6.2 Extra care must be taken when sharing sensitive or high-risk information.

Internal Information Sharing

7.1 Information may be shared internally where:

It is necessary for individuals to perform their roles.
It supports safeguarding, service delivery, or governance.

7.2 Internal sharing must:

Be proportionate.
Respect confidentiality and access controls.

External Information Sharing

8.1 Information may be shared externally with:

Partner organisations.
Regulators or statutory authorities.
Funders or auditors.
Professional advisers.

8.2 External sharing must:

Be lawful and justified.
Be limited to relevant information only.
Follow appropriate approval processes.

Consent and Lawful Basis

9.1 Where required, consent will be sought before sharing personal data.

9.2 Information may be shared without consent where:

There is a legal obligation.
There is a safeguarding concern.
There is an overriding public interest.

9.3 Decisions to share information without consent must be justified and recorded.

Safeguarding and Public Interest

10.1 Information sharing may be necessary to:

Protect children or vulnerable adults.
Prevent serious harm or abuse.

10.2 Safeguarding considerations take precedence over confidentiality where there is a risk of harm.

Information Sharing Agreements

11.1 Where regular or significant information sharing occurs:

Formal information sharing agreements may be established.

11.2 Agreements will:

Define roles and responsibilities.
Set standards for security and confidentiality.

Security and Transmission of Information

12.1 Information must be shared securely using:

Approved systems and methods.
Appropriate safeguards to prevent unauthorised access.

12.2 Insecure or informal methods should be avoided where possible.

Recording and Accountability

13.1 Decisions to share information must be:

Documented where appropriate.
Capable of justification.

13.2 Records will be retained in accordance with the Charity’s Records Retention Policy.

Training and Awareness

14.1 The Charity will:

Provide guidance and training on information sharing.
Promote awareness of responsibilities and risks.

14.2 All individuals must familiarise themselves with this Policy.

Governance and Responsibility

15.1 The Board of Trustees has overall responsibility for information sharing governance.

15.2 Day-to-day implementation may be delegated, but accountability remains with the Trustees.

Monitoring and Review

16.1 This Policy will be reviewed:

At least annually, or
Following changes in law, guidance, or Charity activities.

16.2 Any amendments must be approved by the Board of Trustees.

Conclusion

By adhering to this Information Sharing Policy, [Charity name] ensures that information is shared responsibly, lawfully, and proportionately, supporting safeguarding, effective service delivery, and regulatory compliance while protecting confidentiality and maintaining public trust.

Signed: ………………………………………
Chair of the Board of Trustees

Date: ………………………………………

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Disclaimer:

Naail & Co provides these policy templates solely as guidelines or standard templates to assist charities in developing their own policies in accordance with Charity Commission England & Wales compliance. These templates are not intended to serve as legal or professional advice, and Naail & Co cannot be held responsible or liable for any outcomes arising from their use. It is essential that each registered charity carefully tailors and customizes these policies to reflect its specific needs, structure, and legal obligations. We strongly recommend that charities seek independent legal or professional advice to ensure compliance with all relevant laws and regulations.

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