Policy Statement:

The Firm is committed to best practices and procedure and will act responsibly and with integrity when handling personal information and data.

All clients, staff and / or volunteers will be informed of the Firm’s Confidentiality Policy at the earliest opportunity and the Firm will strive to ensure it has been clearly understood.

The Firm will only seek and keep information that is required for its clients’ specific purpose and that is adequate, relevant, up-to-date, accurate, and not excessive for that purpose and that it will be accessible only to those staff that needs it to carry out their work for the Firm.

The Firm will ensure to keep the affairs of all its clients and all information relating to them confidential, except where the Firm is compelled to disclose information by reason of a legal or regulatory obligation.

Current and former clients, staff and/or volunteers have a right to access any file about them held by the Firm upon request and to correct any inaccuracy in it.  Information can only be withheld from a client for the following reasons:

  • There is information that relates to, or is from, a third party, who has not given their consent for access to such information, or such information that is subject to legal privilege

Client information will be accessible upon request together with any organisational information that is not specifically confidential will also be openly available.

The administration of confidential information must only be carried out by employees and/or volunteers who are familiar with the Firm’s confidentiality policy.

What Information Is Confidential:

All staff and/or volunteers personal files, salary details, supervision and appraisal notes, application forms and references.

  • All clients, both current and former, including details of immigration support issues.
  • Immigration applications, interview notes and supporting information.
  • Home addresses and personal phone numbers of clients, staff and/or volunteers.

Procedures

Gathering of Information:

The Firm’s staff members are responsible for collection of relevant information on clients to assess their immigration needs and eligibility.

The Firm will only approach third parties (other agencies and/or former employees) to verify information that is relevant to:

  • supporting an immigration application;
  • supporting a staff’s job application;
  • supporting an application to volunteer with The Firm; and
  • supporting an application to join the Firm’s Management.

All applications for further information are normally made with an individual consent. It should be noted that if consent is denied, the Firm may not be able to progress with, for example, an immigration application, and that application may then fail.

Some personal information is kept on computer for service monitoring purposes and is covered under the Data Protection Act.  The Firm’s staff will hold such database for this purpose so as to limit the amount of information provided only to what is needed for administrative task.  Client database records and applications are also strictly confidential and are to be secured and kept out of view.

Personal information relating to clients is similarly of a highly confidential nature and is to be secured and kept out of view.  This includes information relating to individual’s immigration issues.

Access to Information

Current or former clients, staff members and/or volunteers have the right to reasonable access to any file held about them by the Firm.  Requests for such access should be made in writing and will be dealt with within 2 working weeks from the date of application.

Information received from or about, third parties will be kept separately within the clients, staff members and/or volunteer’s personal files.  Some third parties may have specifically given the information with the proviso that it was not to be disclosed to the person it referred to, and this is to be respected.

Individuals with a right to access may request access to their files verbally. The file may be viewed once the third party’s information has been removed. If the individual wishes to have access to the third party’s information, the Firm will make contact in writing with the relevant parties and seek their permission to disclose the information.

Disclosure of Information

At the beginning of a relationship with a client, the Firm’s staff will explain the company’s policy on confidentiality. It will be made clear that there are exclusions from the general policy of not disclosing information without the client’s permission.

Information will be shared between the agency’s representatives purely on a ‘need to know’ basis, i.e. information that is required to fulfil specific immigration requirements.  As such, there will be different levels of disclosure.

In order that the Firm’s staff are fully supported and supervised, confidential information disclosed to its staff is to be shared only with the staff dealing with the client.  Generally, disclosure to other persons or agencies will only be made with the informed consent of the client to whom the information relates.

If the health, safety, security or welfare of the client or others is seriously compromised, the Firm will ensure that all client information will be kept confidential except where the adviser is compelled to disclose information by reason of legal obligation.
 
Storage of Information

All application forms and supporting information, including former clients, where any advice or services have been provided, regardless of whether a case is seen to its conclusion will be maintained for a minimum of six years.

Computerised information on clients will be kept indefinitely as this enables the Firm to monitor its services from year to year and to identify trends.  Database forms will be destroyed at year end to which they relate.

The Firm’s staff records and management information will be kept indefinitely as a management resource.

OISC Supervision

Inspection of Files and Quality Standards

The Office of The Immigration Services Commissioner may need to access your file whilst checking my competence. The OISC does not require permission to inspect my clients’ files. Please be assured that they will maintain your confidentiality at all times.

Organisational Structure

At the moment, the firm is a sole trader in England and Wales.Our Dr Cosmas Ikegwuruka would be responsible for all matters. Given his training and track records in immigration matters, we are confident we will be the firm to beat in South East as our products will speak volumes. We aim to bring in other fully qualified and trained immigration advisers.