This section covers the following policies:
Key4Life operates a comprehensive complaints procedure. Key4Life takes very seriously complaints made by clients of the organisation and has a strategy in order to deal with them fairly and with professionally. Complaints will be dealt with as quickly as possible and are used to improve services.
• If a client feels that he has a complaint to make, he can discuss verbally with a member of staff and then write a letter stating his reasons for dissatisfaction
• In situations, where certain clients would not feel confident enough to write a complaint, staff is available to facilitate the writing of complaints
• An informal resolution between the service user presenting with a complaint and frontline staff is always the first step in dealing with the complaint. However, when this proves to be ineffective, Key4Life has in place and follows a clear procedure on dealing with complaints
• Where an informal resolution between the service user presenting with a complaint and frontline staff proves to be ineffective, the complaint will be brought up to the most senior member of staff
• The identified senior member of staff responsible for managing the complaints procedure is the project manager. In its absence, the most senior member of staff will deal with complaints
• If the project manager is involved himself/herself in the complaint, this can be presented to the Chairperson of the organisation, or another committee member
• The project manager is available to hear any complaints that a client might have with any side of the running of the organisation
• A client can present a complaint within four weeks after the incident has occurred, except in situations where this would not been possible. E.g. If a client has left the project in the meantime and then has returned back into treatment
• A complaint will be dealt by the organisation as soon as possible and always within four weeks
• Within four weeks from the date in which the complaint was brought up, the service user will be communicated, preferably in a meeting by the project manager or another senior member of staff, if the project manager is not available
• If a service user feels dissatisfied with the way the matter has been dealt with, he/she can have recourse to appeal to the Chairperson within four weeks after the date in which the meeting took place
• In this case, the Chairperson will investigate the complaint and will decide for the next course of action to take
• In cases of more serious complaints, commissioning bodies will be notified by letter, or through an official meeting with the project manager and/or the Chairperson or another committee member, or if the project manager is involved in the complaint himself/herself, with the chairperson and another member of the committee, within six weeks after the complaint has been received
• When a complaint has been presented, whether to the manager or to the Chairperson, the confidentiality of the service user will be always respected
• In those cases where a complaint involves other service users or members of staff, and confidentiality will have to be broken, in order to approach the problem, this will be done with extreme sensitivity and always with the permission of the service user who has presented the complaint in the first instance
• A handbook is kept, where all complaints are recorded, monitoring number, nature and outcome of the complaint
• Leaflets, in which the complaints procedure is explained, are distributed together with the initial information pack given to new clients. Also posters, where the complaints procedure is explained, are clearly displayed in the building in places with easy access to service users
• All staff at our organisation are trained by a senior member of staff in dealing with complaints procedures during their induction period
Updated April 2014
General principles
• Key4Life recognises that employees, volunteers and trustees gain information about individuals and organisations during the course of their work or activities. In most cases such information will not be stated as confidential and colleagues may have to exercise common sense and discretion in identifying whether information is expected to be confidential.
This policy aims to give guidance but if in doubt, seek advice from your line manager.
• Colleagues are able to share information with their line manager in order to discuss issues and seek advice
• Colleagues should avoid exchanging personal information or comments (gossip) about individuals with whom they have a professional relationship
• It is not appropriate to discuss a person’s sexuality (e.g. ‘outing’ a gay person) without their prior consent
• Colleagues should avoid talking about organisations or individuals in social settings
• Colleagues will not disclose to anyone, other than their line manager, any information considered sensitive, personal, financial or private without the knowledge or consent of the individual, or an officer, in the case of an organisation.
• There may be circumstance where colleagues would want to discuss difficult situations with each other to gain a wider perspective on how to approach a problem. The organisation’s consent must be sought before discussing the situation, unless the colleague is convinced beyond doubt that the organisation would not object to this. Alternatively, a discussion may take place with names or identifying information remaining confidential
. • Where there is a legal duty on Key4Life to disclose information, the person to whom the confidentiality is owed will be informed that disclosure has or will be made.
Why information is held
• Most information held by Key4Life relates to service users and ex-service users, volunteers and ex- volunteers, employees and ex-employees, trustees or services which support or fund the organisation • Information may be kept in order to enable Key4Life to provide its services and only for the intended purpose.
• Information about ethnicity and disability of users is only kept for the purposes of monitoring our Equalities and Diversity policy and also for reporting back to funders
Access to information
• Information is confidential to KEY4LIFE as an organisation but in some circumstances when this is needed it may be passed to colleagues, line managers or trustees to ensure the best quality service for users. This will be done always in accordance with the Data Protection Act and other relevant legislations.
• Where information is sensitive, i.e. it involves disputes or legal issues, it will be confidential to the employee dealing with the case and their line manager. Such information should be clearly labelled ‘Confidential’ and should state the names of the colleagues entitled to access the information and the name of the individual or group who may request access to the information.
• Colleagues will not withhold information from their line manager unless it is purely personal.
• Users may have sight of KEY4LIFE’s records held in their name or that of their organisation. The request must be in writing to the designated person, the Key4Life Director, Eva Hamilton, giving 14 days’ notice and be signed by the individual, or in the case of an organisation’s records, by the Chair or the designated person. Sensitive information as outlined above will only be made available to the person or organisation named on the file.
• When photocopying or working on confidential documents, colleagues must ensure they are not seen by people in passing. This also applies to information on computer screens.
Storing information
• General non-confidential information about organisations is kept in unlocked filing cabinets with open access to all KEY4LIFE colleagues
• Information about individuals will be kept in filing cabinets by the colleague directly responsible, the Key4Life Operations Manager, Lucy Masters. If for any reasons, a line manager will need to gain access to any of these documents, then he/she must contact the Key4Life Operations Manager
• Employees’ personnel information will be kept in filing cabinets and will be accessible to the designated person or to those who are entitled to see it as part of their duties
• In an emergency situation, the designated person may authorise access to files by other people.
Duty to disclose information
There is a legal duty to disclose some information including:
• Child abuse will be reported to the Social Services Department
• Drug trafficking, money laundering, acts of terrorism or treason will be disclosed to the police
• In addition a colleague believing an illegal act has taken place, or that a user is at risk of harming themselves or others, must report this to the Key4Life Director who will report it to the appropriate authorities
• Users should be informed of this disclosure.
Disclosures
• Key4Life complies fully with the Criminal Records Bureau Code of Practice regarding the correct handling, use, storage, retention and disposal of Disclosures and Disclosure information.
• Disclosure information is always kept separately from an applicant’s personnel file in secure storage with access limited to those who are entitled to see it as part of their duties. It is a criminal offence to pass this information to anyone who is not entitled to receive it.
• Documents will be kept for a year and then destroyed by secure means. Photocopies will not be kept. However, Key4Life may keep a record of the date of issue of a Disclosure, the name of the subject, the type of Disclosure requested, the position for which the Disclosure was requested, the unique reference number of the Disclosure and the details of the recruitment decision taken.
Breach of confidentiality
• Employees who are dissatisfied with the conduct or actions of other colleagues or KEY4LIFE should raise this with their line manager using the grievance procedure, if necessary, and not discuss their dissatisfaction outside of KEY4LIFE.
• Colleagues accessing unauthorised files or breaching confidentiality will face disciplinary action. Ex-employees breaching confidentiality may face legal action.
Safeguarding Vulnerable Adult Policy
• Key4Life abide to the codes and principles of its internal Safeguarding Vulnerable Adults (SVA)
Policy and the Safeguarding Vulnerable Adults Policy (SVA) of the county council for Key4Life
• Key4Life understand and accept that the principles regarding safeguarding vulnerable adults take priority over other principles and this is adopted through its practice
• Key4Life always encourages its staff to break confidentiality and report any issue that concern the safeguarding of vulnerable adults to the management. To this end all the staff at Key4Life is trained in SVA level 2
• Staff at Key4Life are always protected by our whistle-blowing policy whenever they will report any issue concerning SVA that might also involve other members of staff or volunteers.
Whistle-blowing
• Where there are concerns about the use of Key4Life’s funds, concerns may be referred directly to the designated person outside the usual grievance procedure
• If these concerns involve the designated person then these should be addressed to the Key4Life Chairperson
Key4Life has adopted the following policy in relation to the collection, storage and processing of personal information. Acceptance of and adherence to this policy forms part of your working relationship with Key4Life
Principles
In order to operate effectively and fulfil its legal obligations, Key4Life needs to collect, maintain and use certain personal information about current, past and prospective employees, service users, suppliers, donors and other individuals with whom it has dealings. All such personal information, whether held on computer, paper or other media, will be obtained, handled, processed, transported and stored lawfully and correctly, in accordance with the safeguards contained in the Data Protection Act 1998 (DPA).
Key4Life is committed to the eight principles of data protection as detailed in the DPA. These principles require that personal information must:
• be fairly and lawfully processed and not processed unless specific conditions are met;
• be obtained for one or more specified, lawful purposes and not processed in any manner incompatible with those purposes;
• be adequate, relevant and not excessive for those purposes;
• be accurate and, where necessary, kept up to date;
• not be kept for longer than is necessary;
• be processed in accordance with the data subject’s rights under the DPA;
• be kept secure from unauthorised or unlawful processing and protected against accidental loss, destruction or damage; and
• not be transferred to countries outside the European Economic Area (EEA) unless the country or territory ensures adequate protection for the rights and freedoms of the data subjects.
In order to comply with the data protection principles, Key4Life will:
• observe fully all conditions regarding the fair collection and use of personal information;
• meet its legal obligations to specify the purpose for which information is used;
• collect and process appropriate personal information only to the extent that it is needed to fulfil operational needs or to comply with legal obligations;
• ensure the quality of the personal information used;
• apply strict checks to determine the length of time personal information is held;
• ensure that individuals about whom information is held are able to exercise their rights under the DPA, including the right to be informed that processing is taking place, the right of access to their own personal information, the right to prevent processing in certain circumstances and the right to correct, rectify, block or erase incorrect information;
• take appropriate technical and organisational security measures to safeguard personal information; and
• ensure that personal information is not transferred outside the EEA without suitable safeguards.
• Overall responsibility for ensuring that the Charity complies with its data protection obligations rests with the HR & Finance Manager
• It is the responsibility of all employees to ensure that personal information provided to the Charity, for example current address, is accurate and up to date. To this end employees are required to inform the Charity immediately when changes occur.
• Employees whose role involves the collection, maintenance and processing of personal information about other employees , service users, partners, donors or any other individuals with whom the Charity has dealings are responsible for following the Charity’s rules on good data protection practice as notified.
Key4Life holds the following personal information about its employees/volunteers
Name, address, Dob, NI Number, telephone number
This information is used for payroll and administrative purposes.
We also hold the following sensitive personal information about employees:
Anyone who is the subject of personal information held by the Charity has the right to make a subject access request. Employees who wish to exercise this right should write to Finance Manager. The Charity reserves the right to charge £10 for responding to such requests. If, as the result of a subject access request, any personal information is found to be incorrect it will be amended. The Charity will deal promptly with subject access requests and will normally respond within 40 days. If there is a reason for delay, the person making the request will be informed accordingly.
This policy and guidelines are intended to help the management and staff in the prevention, minimisation and management of aggression and violence toward clients and staff at Key4Life. Also to reduce the incidence and severity of aggression related injury; to provide a safe treatment environment; to protect clients against aggressive incidents; to safeguard the health, safety and welfare of employees at work and to meet moral and ethical obligations.
• Acts of violence cannot be predicted with absolute certainty, however the risk to everyone can be minimised when behaviours that are observed are reported.
• Often threats or acts of aggression escalate to a level of violence when there is poor communication with the person and the person cannot cope under the stress.
• Threats can be direct and immediate or vague and may occur either verbally or in writing. Acts of aggression include abusive behaviour, stalking and tampering with property and are intended to intimidate, create fear, inflict harm, or destroy property. Violent behaviour is behaving in a way that poses an immediate threat to self or others by acts of physical harm.
• All staff members at Key4Life share the responsibility to report threats, acts of aggression and violence to the manager of the project, or a senior colleague if the manager is not available.
• Threats, acts of aggression, and violence are not tolerated by or toward clients, staff members or other visitors at our organisation.
• Aggressive or violent behaviour may result in disciplinary actions, up to and including expulsion and banning from the project.
• In order to maintain safety, it is our policy that at least two workers are always present in the building.
When interacting with a potentially aggressive or violent person, be aware of your reactions, report all behaviours to others, and follow the suggested guidelines:
• Remain calm, speak in a low voice and don't argue or agree with distortions.
• Let them know the consequences. For example, "I'll call my senior if you don't sit down and stop yelling. I can't help you if you don't calm down."
• Avoid invasion of "personal space". Keep a safe distance of 3-6 feet.
• Treat people with respect regardless of their behaviour and avoid being judgmental.
• Do not make promises that you cannot fulfill.
• If the person wants to talk with a colleague of yours or the manager, then so inform them. Report all behaviours to appropriate authorities, the manager or a senior colleague.
If the behaviour reaches the point of violence then:
• Remain calm. Dealing with the person calmly and confidently will help reduce further communication problems.
• If you feel under threat push the panic button, this is directly connected to the police. If you cannot do this yourself, ask someone else to do it for you.
• Do not try to physically force a person to leave.
• Do not touch the person.
• If violent behaviour is occurring, escape, hide if not already seen, or cover-up.
• Position yourself, if possible, so that an exit route is readily accessible.
• Never attempt to disarm or accept a weapon from the person in question.
• Don't argue, threaten, or block their exit.
A handbook is kept, where eventual incidents of violence or aggressions are monitored and recorded, alongside with a number, nature of the incident and outcome of the incident.
Introduction
At Key4Life we believe that the safety and welfare of our children & young people is of the utmost importance. It is the duty of all our staff & volunteers to protect each child from abuse and to be alert to the possibility of abuse.
Definition
Child protection relates to any child (under 18) who has suffered from, or maybe at risk of physical injury, neglect, and emotional or sexual abuse. A full list of definitions is attached as appendix 1.
Recognition
The first indication of concern about a child's welfare is not necessarily the presence of an injury.
Concerns may be aroused by:
• Bruises, bite marks, burns/scalds, scars or fractures on a child's body
• Remarks made by the child, another child, a parent or another adult
• Observations of the child's behaviour or reactions
• Unexplained changes in the child's behaviour or personality
• Evidence of disturbance or explicit detail in a child's play, drawing or writing
• Neglect - where lack of due care for a child is creating significant risk to their health & well being.
Designated person for child protection
The Key4Life Director, Eva Hamilton, has the designated responsibility for child protection, as appointed by the Management Committee. Anyone who has a concern about a child should contact this person on 07831 622 735 immediately. If that person is not available you should contact the deputy responsible for child protection (information available from administration office).
The designated person will:
• Liaise with Local Education Authority, Social Services, the relevant Child Protection Committee and any other agencies on individual cases of suspected or identified child abuse: • Be responsible for co-ordinating action within Key4Life on child protection issues
• Ensure that all staff & volunteers are familiar with this Policy and Procedures
• Raise awareness about child protection and arrange training as appropriate
Safe Recruitment Procedures
Key4Life recruitment policy stipulates that all staff (paid or voluntary) will have to complete an application form, detailing past work history and references. Individuals are then interviewed and references requested. Only on receipt of satisfactory references will a formal offer of employment or placement be made.
All staff and volunteers working directly with children (under 18 yrs) and any vulnerable adults, are required to have an enhanced check through the Disclosure Service – the Government’s Criminal Records Bureau (CRB) before commencement of work or placement.
Staff members (voluntary or paid) are thus required to fill out a DBS form and produce evidence as to their identity, in accordance with the Disclosure Service Guidelines. This information is then witnessed by the Designated Person responsible for child protection and signed as an acknowledgement of information produced.
Copies of all returned CRB checks and documentation pertaining to any child- protection issues will be kept confidentially and securely locked within the organisation’s administration office.
Staff can undergo training and induction whilst waiting for the checks to clear but cannot undertake any unsupervised face-to-face work until satisfactory checks have been received. This training will include mandatory child protection awareness.
The role of individual staff / volunteers
All staff & volunteers working for Key4Life must be aware that a child may be the victim of abuse. Concern about a child or young person must be discussed with the Designated Person immediately so that, if necessary, a referral can be made without delay. In urgent situations, referral must not be delayed.
Individual staff or volunteers should not investigate concerns. This is the role of the statutory agencies. However, if a child does say something, it is vital to listen carefully, so that it can be reported accurately.
Confidentiality
Our children & young people have the right to expect that all staff and volunteers will deal sensitively and sympathetically with their situation. It is important that information remains confidential and that only those with a 'need to know' should be privy to it.
Procedure - what to do:
Concern may arise from observations of the child (e.g. injury, behaviour, appearance and nature of play or work produced) or as a result of something said by the child, another child or an adult.
Do not delay:
1. Tell the Designated Person - as soon as you can. See emergency contact numbers attached to this policy and procedure.
Early referral gives more time to help the child and family before the situation becomes severe or serious. When necessary, early referral gives more time for others to protect the child.
The Designated Person may consult with the Local Education Authority, Social Services, and relevant Child Protection Committee.
2. Make written notes - as soon as you can, write down your concerns and record the facts accurately on the Child Protection Incident Form, available from admin office (appendix 3). Be clear when you are expressing an opinion and what your opinion is based on.
These notes must be given to the Designated Person immediately and will help to ensure accuracy in recalling events.
3. Concern about what the child or someone else says Listen - do not ask questions or interrogate.
Remain calm - If you are shocked, upset or angry the child will sense this and this may prevent them from talking further.
Reassure - The child has done nothing wrong - tell her / him it is all right to talk.
Do not promise to keep it secret - Tell the child that what they have said cannot be kept secret and that you will tell someone who can help.
4. Remember:
If in doubt, consult with senior staff members or Designated Person. Do not ignore concerns, even if these are vague. Your first responsibility is to the child.
5. Contact with the family
Before speaking to the child's family, you should talk to the Designated Person, who may consult outside the bounds of Key4Life.
In cases where a physical injury causes concern, it may be appropriate to discuss this with the parent or carer. If the explanation suggests the injury was non-accidental (or a failure to protect the child from harm), the parent or carer should be informed of the need to refer the matter to Social Services.
In cases of possible neglect or emotional abuse, the concern is likely to have built up over a period of time. There may have been discussion with the family about sources of help (e.g. Social Services, NSPCC), but if concerns persist, there must be an immediate referral to Social Services Referral and Assessment Team.
Where there are suspicions of sexual abuse, the Designated Person will seek immediate advice from the Social Services Department before discussing the matter with the family.
6. Concern about a member of staff or volunteer
Allegations or concerns about a member of staff or volunteer must immediately be referred to a statutory agency.
7. Requests for assistance by other agencies
Key4Life should assist local authority Social Services or the Police when they are making enquiries about the welfare of children. Information about a child must therefore be shared on a ‘need to know’ basis. When such requests are received by telephone, always maintain security by checking the telephone listing before calling back.
Always advise the designated person of this contact.
8. General issues
All staff & volunteers must observe the above policy and procedures at all times and adhere to the Key4Life Child Protection Code of Conduct (appendix 4).
Parental Consent needs to be sought for all individual children & young people taking part in any on or off site activities/events, using Registration & Parental Consent Form (appendix 5).
As part of overall good practice risk assessments should also be carried out for all on & off site activities, with staff taking full responsibility for using measures to reduce risk for activities within Key4Life.
Introduction
Key4Life C.I.O., henceforth with this document referred to as Key4Life is committed to providing a safe and secure environment for its staff and volunteer mentors.
The provision of a safe and secure environment in this policy is recognised by Key4Life as a statutory requirement to comply with the Secretary of State’s Directions.
This policy will be applied to the fair treatment of all people, regardless of their gender, race, colour, ethnicity or national origin, citizenship, religion, disability, mental health needs, age, domestic circumstances, social class, sexuality, beliefs or political allegiance. Key4Life is firmly opposed to any discrimination based on these human characteristics and values.
1. Purpose or Aim
The aim of this policy is to underline safety issues and contribute to the provision of a safer working environment for staff and volunteer mentors working alone. Key4Life has a legal duty under the Health & Safety at Work Act 1974 to ensure so far as is reasonable and practicable the health and safety of its employees and volunteers.
Under the Health & Safety at Work Act 1974, all employees have a duty to ensure the safety of themselves and others who may be affected by their acts or omissions. In terms of lone working this can be seen to mean that any employee or volunteer mentor must not put themselves or others in a position of danger by either entering a dangerous situation, failing to provide adequate information to a colleague, failing to ensure that an adequate risk assessment is undertaken or not following an agreed safe system of work. Staff or volunteer mentors who feel that there is an unacceptable level of risk when engaging in a particular visit or environment therefore have the right to refuse such a visit provided there are reasonable grounds for making that judgement.,
2. Scope
This policy shall apply to all Key4Life employees and volunteers working in isolation when:
Working in the community either through home visits or appointments at a third party premises.
Escorting service users in the community.
Staff or volunteers who see service users for individual sessions in YOI’s (Youth Offending Institutions) or prisons.
Staff or volunteers who attend residential programmes.
Travelling alone as required by work.
This list is not exhaustive.
3. Policy Statement
Key4Life believes that all staff, service users, carers and visitors should treat each other with dignity and respect and to behave in an acceptable and appropriate manner. Staff have a right to work and volunteers have a right to volunteer, as service users have a right to be treated, free from fear of assault and abuse.
Key4Life will ensure that systems are in place to provide staff with the tools to work and provide the best care for its service users. Employees failing to observe this policy and applicable health and safety regulations may be subject to action in accordance with Key4Life’s disciplinary policies and procedures (TBD).
In order to minimise the risk of violence and aggression Key4Life will work to implement its statutory duties highlighted by the Security Management Service (SMS). Key4Life also recognises that it is important, as far as is reasonably practicable, to provide and maintain equipment and systems of work and procedures that are safe and without risks to health
Safe lone working is based on robust risk assessment and plans that manage these risks effectively. This policy requires that local procedures will be made by all teams carrying out lone working and these should encompass the following principles:
Use of Key4Life’s risk screens and assessment tools (TBD)
Thorough risk assessment of the service user and the location of the interview/visit is made prior to lone working.
Individuals working alone will make their whereabouts known to an identified responsible member of staff.
Arrangements will allow for them to contact and be contacted in the event of an emergency.
Provide mobile phones to visiting staff or volunteer mentors.
Ensure there are sufficient lines into a responsible member of the staff team (if this is the way alarms are raised) to enable staff or volunteer mentors to get through to a colleague.
All staff involved will be aware of the action to be taken in an emergency (TBD)
4. Roles and Responsibilities
In order to ensure that policy objectives are achieved it is necessary to communicate the role and responsibilities of all employees at all levels. It is therefore the responsibility of each member of Key4Life to support and be familiar with this policy.
Key4Life Board
The Board is ultimately responsible for fulfilling legal requirements relating to health, safety and welfare of those employees who work, and volunteers who volunteer for Key4Life including the protection of lone workers.
The Chief Executive
The Chief Executive takes specific responsibility for:
Overall responsibility for the fulfilment of the relevant statutes.
Advising the Key4Life Board on the review of existing policy arrangements and allocation of resources to implement health and safety procedures.
Referring matters of a critical nature to the Key4Life Board for resolution and ensuring that adequate safety arrangements exist within Key4Life.
SUPPORT NUMBERS
Key4Life Office: 01458 850621
Key4Life adopts a policy in order to maintain the privacy, dignity and respect of clients. This policy, alongside with other policies, such as confidentiality policy and equal opportunity policy, is adopted to make sure that the human rights of clients who come into contact with our organisation are always respected.
• Key4Life adheres to the Human Rights Act 1998. This is to guarantee that the main human rights of the clients are always respected
• Key4Life adheres to the Race Relations Act 2000. Also adopts a comprehensive equal opportunity policy. At Key4Life clients are not discriminated in relation to their race, religion or gender
• Key4Life adheres to the Disability Discrimination Act 1995. In regard to clients with a disability, all possible routes will be tried in order to avoid any discrimination.
• Key4Life adopts a complaints procedure policy, so that clients can present a complaint in cases of dissatisfaction with our services
• Key4Life welcome and encourages freedom of expression from clients
• Clients are welcomed and encouraged to sit in staff meetings and give their suggestions. These are taken very seriously by the staff and management and used in order to foster changes and developments in the project
• Key4Life keeps neutral from any political agenda, in order to make all clients, who might have a particular political belief, welcomed and at home
• At Key4Life clients are encouraged to take an active role in their recovery. Their wishes and beliefs are respected and, although suggestions are given by the workers, they are never pushed to take steps they do not wish or are not ready to take
• Clients are always addressed by the staff by their preferred names
• During the assessment session clients are asked about their ethnicity and subsequently, when necessary, they will be addressed by using the ethnicity where they feel they belong to
• When presenting clients do have difficulties with expressing themselves using the English language, Key4Life will always try all possible routes in order to find a person who can translate or other possible ways of facilitating the treatment process for those clients
• Key4Life adopts a comprehensive confidentiality policy. In those cases where confidentiality has to be broken, clients are always told in advance and before this step will be taken, any possible route will be tried in order to avoid this
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