UK contact office: 25 Southampton Buildings, London WC2A 1AL. Routine enquiries: guardian@intergreat.com.
Introduction
At InterGreat Education Group, we prioritise the safety, well-being, and protection of the children and young people under our care in all decisions made by our staff, volunteers, and homestays regarding confidentiality. Sharing information appropriately among colleagues is vital to ensure the well-being and safety of our children and young people.
Establishing trust is fundamental to the principles of our company, allowing children, young people, parents, staff, volunteers, and homestays to seek help within or outside the organisation. Our goal is to minimise the instances in which personal information is shared to provide support and safety for children, young people, parents, staff, volunteers, and homestays.
It is crucial for staff, volunteers, and homestays to understand the boundaries of confidentiality to create a safe and comfortable environment for discussing personal issues and concerns, including matters related to sex and relationships.
We strive to make InterGreat Education Group's confidentiality principles clear and easily accessible, ensuring that everyone can trust the confidentiality boundaries within the company.
Personal information, including matters related to sex and relationships, can emerge at any time. Everyone associated with the InterGreat Education Group should understand that absolute confidentiality cannot be guaranteed. It is important for everyone involved with InterGreat Education Group to be aware of the limitations of confidentiality provided by individuals within the organisation, enabling them to make informed decisions about the most suitable person to discuss any health, sex and relationship, or other personal issue with.
Related Guidance
This policy is based upon the following guidance:
Keeping Children Safe in Education – statutory guidance for schools and colleges, 2026 Keeping Children Safe in Education 2026 (from its commencement; until then the 2025 edition remains operative) (publishing.service.gov.uk)
Working Together to Safeguard Children, 2026
Information Sharing: Advice for practitioners providing safeguarding services to children, young people, parents and carers (2018)
Definition of Confidentiality
Confidentiality refers to private information entrusted by one individual to another. Those sharing confidential information expect it to be kept secret.
Offering absolute confidentiality means committing to keeping a conversation completely secret and not discussing it with anyone else. However, in practice, there are no circumstances within the InterGreat Education Group where absolute confidentiality can be guaranteed. Our aim is to balance the safety, well-being, and protection of children, young people, parents, staff, volunteers, and homestays while fostering a culture of trust, allowing individuals to seek help when needed. We prioritise following safeguarding practices and child protection guidelines when it becomes necessary to share personal information.
In practice, we provide limited confidentiality. The content of a conversation may be discussed with professional colleagues, but the individual sharing the information will not be identified, unless under specific circumstances.
It's important for staff, volunteers, and homestays to outline the limits of confidentiality at the onset of the conversation. These limits are in place to ensure the safety and well-being of children. If confidentiality must be breached for these reasons, the child or young person will be informed and involved in the sharing of information.
One-to-one disclosures to members of staff, schools, volunteers or homestays
All staff, schools, volunteers, and homestays within InterGreat Education Group must understand the boundaries of confidentiality they can provide to children and parents, along with the necessary steps and available sources of additional support or assistance, both within the organisation and from other appropriate agencies.
While employees, schools, volunteers, and homestays associated with InterGreat Education Group promote open discussion between children, young people, and their parents or guardians, the well-being of the child or young person is of utmost importance. InterGreat Education Group does not automatically disclose information about the child or young person to their parents unless it is deemed to be in their best interests.
The seven golden rules to sharing information
Keep in mind that the Data Protection Act 2018 and human rights law are not obstacles to justified information sharing; rather, they establish a framework to ensure appropriate sharing of personal information about living individuals.
From the start, openly and transparently communicate with the individual (and/or their family, if appropriate) regarding why, what, how, and with whom information will be or could be shared, and seek their consent, unless doing so is unsafe or inappropriate.
If uncertain about sharing specific information, seek guidance from colleagues and practitioners without revealing the individual's identity whenever possible.
When suitable, share information with informed consent, and if feasible, honour the preferences of those who do not consent to share confidential information. In cases where safety may be at risk, you may share information without consent based on your judgement of the circumstances. When sharing or requesting personal information, be clear about the basis for doing so, and be mindful that an individual may not anticipate information being shared, even with consent.
Prioritise safety and well-being: Base your decisions about sharing information on considerations of the individual's safety and well-being, as well as others who may be affected by their actions.
Necessary, proportionate, relevant, adequate, accurate, timely, and secure: Ensure that the information you share is necessary for the intended purpose, shared only with individuals who require it, accurate and current, shared promptly, and handled securely (refer to principles).
Maintain a record of your decision and the rationale behind it, whether you choose to share or withhold information. If sharing, document what has been shared, with whom, and for what purpose.
Principles for sharing information
The following principles are designed to assist staff, volunteers, and homestays working with children, young people, and parents in exchanging information across organisations.
Employees, volunteers, and homestays should exercise their discretion when deciding what information to share, relying on InterGreat Education Group procedures or seeking advice from a senior staff member when uncertain.
The primary focus should be on whether sharing information is likely to ensure the safety and protection of a child or young person.
Necessary and proportionate
When deciding what information to share, it is important to consider the extent of information required. According to the Data Protection Act 2018, the impact of divulging information on the individual and any relevant third parties must be taken into account. The information shared should be proportionate to the necessity and level of risk.
Relevant
Information that is pertinent to the intended purposes with those who require it. This ensures that others can effectively perform their duties and make informed decisions.
Adequate
Information should be sufficient for its purpose, ensuring it is of a quality that can be understood and relied upon.
Accurate
Accuracy Ensure that information is accurate, up-to-date, and clearly distinguishes between fact and opinion. If the information is historical, this should be clearly indicated.
Timely
Information should be shared promptly to minimise the risk of harm, particularly in emergency situations. In situations where seeking consent for information sharing could cause delays and potential harm to a child, it may not be appropriate to delay. Staff, volunteers, and homestays should ensure that adequate information is shared, considering the urgency of sharing.
Secure
Information in a secure manner whenever possible. Staff, volunteers, and homestays should always adhere to the organisation's security policy for handling personal information.
Record
Documentation Decisions regarding information sharing, whether to share or not, should be recorded in compliance with company procedures. If a decision is made to share, reasons should be provided, detailing what information was shared and with whom. If the decision is not to share, it is advisable to record the reasons and discuss them with the requester. Information should not be retained longer than necessary in line with InterGreat Education Group's retention policy, and in some cases, there should be a review process even if retention is indefinite.
When and how to share information
When requested to share information, it's important to contemplate the following questions to aid in determining whether and when to share. If the decision is made to share, it is crucial to consider the most effective way to share the information.
When
Is there a clear and justified reason for sharing the information?
Yes - proceed to the next question
No - refrain from sharing
Does the information enable the identification of an individual?
Yes - proceed to the next question
No - sharing is acceptable, but consider the method
Is the information deemed confidential?
Yes - proceed to the next question
No - sharing is acceptable, but consider the method
Do you have consent?
Yes - sharing is acceptable, but consider the method
No - proceed to the next question
Is there another valid reason to share the information, such as fulfilling a public function or safeguarding the vital interests of the individual?
Yes - sharing is acceptable, but consider the method
No - refrain from sharing
How
- Determine the appropriate amount of information to share
- Differentiate between factual details and opinions
- Ensure that the correct information is provided to the intended recipient
- Whenever feasible, share information in a secure manner
- Notify the individual if the information has been shared, as long as doing so does not create or escalate the risk of harm
All decisions and justifications related to sharing information must be documented according to InterGreat Education Group procedures. When uncertain about how or when to share information, seek advice, and ensure that the outcome of the discussion is recorded.
In the event of concerns regarding a child or young person experiencing or likely to experience harm, promptly adhere to the relevant Safeguarding procedures.
Practical Guide to Sharing of Information
InterGreat Education Group must share specific information as part of our daily operations to ensure the highest standard of service for our students. These encompass, but are not restricted to:
- Details regarding travel and half term/holiday plans
- Essential welfare-related information
- Academic reports or concerns
- Personal documentation aiding academic or related services (passport/visa details)
To provide clarity on our procedures, we have outlined below the protocols for handling each of these scenarios, as well as the staff or external parties who may be involved in each situation.
Information on travel and holiday plans
- Coordinate arrangements with the school so that they are appropriate to the student.
- Confirm dates with the homestay or boarding house.
- Arrange transport in accordance with UK safeguarding requirements.
- Obtain confirmation from the student and parents, and any necessary parental authorisation.
Information on urgent welfare matters
- Communicate with the school’s DSL.
- Share relevant information with the homestay or accommodation provider where the situation needs monitoring at home.
- Send a confidential Cause for Concern to IEG’s DSL, who coordinates any additional support with the DDSL and student support team.
- Where it is in the child’s best interests and lawful to do so, share necessary welfare information with parents, the local safeguarding partnership or relevant public services.
School Reports or other Academic Concerns
School Reports and Academic Concerns
If additional tutoring or private lessons are arranged, pertinent details from school reports would be conveyed to the tutor to ensure that lessons are customised to meet the students' requirements.
If translated by Student Management at InterGreat, any ensuing issues will be brought to the attention of the Academic Director for further assistance. Should any safeguarding concerns be raised, they will notify the Designated Safeguarding Lead.
Parents and students will receive a copy of the school report (either in English or Chinese as appropriate), and any academic apprehensions will be addressed through discussions involving all concerned parties to find a resolution.
Engaged in discussions with the school and pertinent educators to obtain a comprehensive grasp of school reports.
Personal Documents to Aid Academic or Other Services (ID, Visa etc)
Personal Documents
In instances where safeguarding laws mandate information sharing (e.g., with medical or emergency services), personal documents may be disclosed to the relevant authorities by the Designated Safeguarding Lead.
Information is stored and accessed by Student Management and the InterGreat Leadership Team as per role-specific access requirements. Information is held in access-controlled systems and shared only with authorised staff who need it for their role.
Coordinated with the university or a third-party agent to facilitate student applications (Clearing/Application Process).
Engaged with the school to advocate for the student's right to study in the UK.
Information-sharing decision process
- Establish a clear and legitimate purpose. If there is no legitimate purpose, do not share; if unsure, seek advice.
- Consider whether a person can be identified and whether the information is confidential. Identify the lawful basis and any additional condition needed for sensitive information.
- Where confidential information is involved, consider consent and whether another lawful justification, including an applicable safeguarding or public-interest condition, permits sharing without consent. Seek advice if unsure.
- Share only the information needed, distinguish fact from opinion, check the recipient and transmit the information securely.
- Tell the person about sharing where appropriate, unless this could create or increase a risk of harm or another lawful reason prevents it.
- Record the decision to share or not share and the reasons.
If a child may be at risk of significant harm, follow the safeguarding procedures without delay. Seek advice when needed and record the outcome.
AEGIS inspection information sharing
Where required for AEGIS accreditation or re-accreditation, IEG may share the minimum necessary contact and service information with the AEGIS office and appointed inspectors. This may include information relating to students, parents, homestays, partner schools, staff and local coordinators. IEG will notify the individuals concerned, obtain permission where required, use an appropriate lawful basis, transfer information securely and retain a record of what was shared and why.