You must document any actions you have taken under the FVISS and/or CISS. This includes sharing information, or the reason why information was not shared.
What information should I document?
- The date of the:
- response; or
- pro-active sharing
- That both your organisation and the organisation receiving information are ISEs
- The specific type of information being shared or requested
- The name of the Information Sharing Entity you are sharing with
- Which information sharing scheme (the FVISS, the CISS or both)
- Whether consent is required, and relevant details. Or, whether views of relevant parties have been sought, and the relevant details
- What the purpose of sharing is, and whether it meets the approved purpose under the information sharing scheme. You should also document that the information being shared is relevant to that purpose.
- Whether you have notified the parties that their information will be or has been released
If not, why not?
- What information was disclosed?
It is important to document your role in the information sharing process, even if you do not end up sharing the information.
For example, your client may not give permission for information to be shared, which means that you cannot share information. You should make sure that you document the conversation with the client, and any relevant information about why consent wasn’t given.
Or, you may decide not to share information based on your own judgment of the circumstances. For example, if you decide that the information is excluded or that no reasonable belief could be formed that family violence is occurring. It is important to document the reason for making your decision.