Record Keeping

All information on the Portal is classified as ‘Official: Sensitive Personal Privacy’and must be stored securely on the Portal to meet those privacy obligations. Each agency, party to the Family Safety Framework, has policies in place to support authorised FSM representatives to comply with the requirements of the Family Safety Portal User Agreement.

The risk of this level of confidential information being breached is a high risk to potential escalation of violence and endangering the lives of women and children.

The responsibility to maintain privacy and confidentiality of this level of sensitive information is paramount. The responsibility sits with DHS as custodian of the Portal and equally with each agency in terms of providing a policy environment which supports representatives to navigate this level of information security.

Each agency is responsible for the development of internal policies and procedures regarding records storage and management that adhere to the requirements of handling information classified as ‘Official: Sensitive (Personal Privacy)’.

The responsibility for handling this level of confidential information means that FSM representatives must be aware of and incorporate their participating agency’s directives in terms of handling and storing this level of information.

FSM representatives are subject to their own agency’s policies and procedures in relation to the sharing and storing of information.

Agency record keeping

It is important that each agency’s procedures are followed regarding storage of confidential information concerning clients.

It is an expectation that Family Safety Meeting representatives will be proactive and:

• Follow Agency protocol regarding actions and communications about a client in case notes/ case file.
• Initiate any internal “flagging” on agency databases stating that the individual has been referred to an FSM (whether person at risk, perpetrator, or children).
• Make sure that Domestic Violence Risk Assessment (DVRA), referral and any other information that relates to that client is in their case file.
• Do not store any information that relates to any of the other cases that were presented at the FSM within a client’s file. An individual record can be downloaded from the Portal for inclusion in or upload to the client’s file.
• If the service does not have a file for a person at risk whose case is raised at an FSM, but the agency has actions that require priority attention, the FSM representative will create a client file for that person in order for the information to be stored by their agency. Once the agency has contacted the person at risk, a worker will inform them that a file has been created and then the worker will proceed under usual agency obligations.

Audit, retention, and deletion of information

• Each agency will undertake to ensure that they will responsibly collect, process, store, and disclose all information for the purposes of the Framework.
• Agencies will ensure that all information held is accurate, relevant, and fit for the purpose for which it is intended.
• Agencies will retain copies of referrals, action plans and minutes for whatever period is in keeping with the agency’s client records management guidelines.
• Each agency will be responsible for the safeguarding of information in line with the Information Privacy Principles. When the information is no longer regarded as being relevant, the agency will be responsible for its secure disposal.
• Each agency will be responsible for ensuring that information is only accessed on a need-to-know basis by their staff in line with the user agreement and requirements of the ‘Official: Sensitive (Personal Privacy)’ classification.
• Case information should only be communicated through the Portal unless the Portal is not operational, and the FSM representative has received instructions from Office for Women or the FSM Chair to exchange information for the FSM in some other way.

Audit of Security

All information held for the purposes of the Framework must be securely stored in line with the requirements of an Official: Sensitive security classification and the Family Safety Portal User Agreement.

Agencies must regularly conduct audits of their FSM representatives (no less than annually) making sure that only those that require access to the Portal as a representative of that agency are included as a representative of that required region.

It will be the responsibility of each agency to ensure their representatives resign from the FSM when they no longer represent that agency. Agencies should also notify Office for Women when representatives need to be removed that have not removed themselves or if they identify any other security breaches.

Deletion of Information

Information cannot be edited or deleted from the Portal by users. Should a mistake be made by a representative the following steps should be taken:

1. If the mistake is minor and does not impact the ability of the FSM to form an action plan to reduce the risk of harm to the person at risk or their children, a correction should be made to the meeting notes (if the error occurred in meeting notes), contact notes (if the error was contact info) or by putting a comment on the action (if the error was in an action).
2. If the error is major (will impact the ability of the FSM to form an action plan) / cannot be rectified by a correction, the representative should email Office for Women at DHSFamilySafetyPortal@sa.gov.au as soon as possible to ensure that the error is corrected. The representatives should also inform their direct management.