Purpose:
- To enable a timely and efficient method of gaining caseworking consent remotely for both the client and the caseworker.
- To ensure that SSAFA adheres to GDPR via a consistent, defined and recorded process.
- To encompass consent for the full caseworking process not just storing beneficiary data, therefore negating the requirement for caseworkers to gain a wet signature from the beneficiary on a hardcopy Form A and uploading the full document to Mosaic.
Who performs Verbal Consent:
Regional office employees only directly with the client. If it is not possible then consent to store basic personal data for the mosaic person summary will be gained and then the caseworker will ensure full consent via the Hardcopy Form A with wet signature
When should it be applied:
Any contact with the Regional Office that requires the storage of personal data for the purposes of opening a case, or one that may lead to the creation of a case and the beneficiary is willing to start the process.
Within Mosaic ‘Verbal Consent’ is located in section four of the COBSEO contact, and if used there is no requirement to ask the initial question at section 1 ‘Applicant Details’ as the answer to this will automatically be ‘yes’ if full caseworking consent is gained under section four.
How Regional Offices will apply Verbal Consent:
Ideally the Regional Office employees will ask these questions towards the start of the call, but it is recognised that this is not always possible or suitable, and until a ‘need’ is identified it may not even be necessary. Once it is clear that a caseworker will be required, the verbal consent process will be used.
There are four questions in Verbal Consent that cover the following areas:
1. Consent to store, contact and share data (COMPULSORY)
2. Consent to send a survey at the conclusion of a case (IF APPROPRIATE)
3. Spouse/Partner data consent (IF RELEVANT / POSSIBLE)
4. Consent for a third party to act on behalf of the beneficiary (IF RELEVANT)
a. Verbal consent for someone to act on their behalf
b. Power of Attorney
c. Registration by the SSAFA Caldicott Guardian
All information gathered from the questions will be recorded within COBSEO contact Section two ‘Details of Contact’ along with the full triage and safety check information.
‘COBSEO Notes’ is only be used for the information relevant to the Assistance Providers.
The four verbal consent questions in detail:
QUESTION 1 – compulsory
“Are you happy for SSAFA, to collect, handle and store yours and any dependant’s personal information, including special category data or conviction and sentence details, so that we can deal with your call and to manage any case we may open to support you”?
If a case is to be opened this question must ALWAYS be asked, with the script being read verbatim to the beneficiary. If they answer ‘no’, you must delete all data (this may require the support of the Mosaic Helpdesk) and end the call appropriately. If ‘yes’ then continue to read the following three statements verbatim:
“We may contact you by email, text or letter in order to progress any case which we open on your behalf.
We may also share your personal information, including special category data, with other support organisations and check your service details with the Ministry of Defence.
For further details about how SSAFA uses your personal information, please refer to the ‘How military charities will use my personal information’ document which we send when we first set up your case.”
QUESTION TWO – if suitable
"At the conclusion of your case, we may send you a survey to help us improve and promote our services. You would be under no obligation to complete this survey; it would be entirely voluntary and anonymous - are you happy to agree to this”?
This should be asked where possible – click ‘yes’ if approved or ‘no’ if unapproved or deemed not suitable to ask.
QUESTION THREE – if relevant
You may need to record special category data or conviction and sentence details on the spouse/partner of the beneficiary. Where possible, ask question one. directly to the spouse/partner. If the spouse/partner is estranged or there is a safeguarding risk do not speak to the spouse or partner to ask question one – record detail in case notes. Consent gained from spouse / partner using question one.
As the details of a partner/spouse will be taken when caseworking this should ideally be asked directly to them if they are present – this could also be performed and recorded at a future point. Every effort should be made to gain this if possible and appropriate.
If there is no partner/spouse, then this question is not relevant and you do not need to click ‘yes’ or ‘no’.
If there is a partner or spouse, then click ‘yes’ or ‘no’ depending on if you have been able to ask question one. of them.
If ‘no’ is clicked as they are unavailable at that time every effort should be made to gain their consent.
QUESTION FOUR – if relevant
a. “It may be that the beneficiary wishes for a third party to act on their behalf, to ensure consent the beneficiary should give a short verbal statement requesting this – record detail in case notes. Are you happy for me to continue to speak to [NAME] so that SSAFA can investigate supporting you?"
A beneficiary may wish a relative, friend or support worker to act for them wholly or partially. This situation can be addressed by directly asking the beneficiary if they would like [X] to act for them.
b. “Third parties calling on behalf of a beneficiary (including spouses/partners/relatives) must be the named person on the Power of Attorney (PoA) and a copy provided - record detail in case notes and attach the PoA. Has a PoA been provided and stored”?
Should a 3rd party call on behalf of a beneficiary for whom they hold Power of Attorney, a case for the eligible beneficiary can only be opened at the point where SSAFA has a copy of the document – this should be immediately attached to the COBSEO contact, and then a copy added to the ‘Assistance Required and Pledged’ step when relevant.
c. Should a beneficiary be incapable of providing specific verbal consent and no PoA exists, the Caldicott Principles should be considered – record detail in case notes. Has the Caldicott Guardian given approval?
If a beneficiary does not have the capacity to give direct consent and there is no power of attorney held by any family member or other individual then use of the Caldicott Principles might be a consideration. The process for this is laid out within COMPASS and must be followed prior to allocation and caseworking taking place.
As question four is ‘if relevant’, no action is required if a. b. and c. do not apply.
Frequently Asked Questions
• How does a caseworker complete the ‘Application for Assistance’ step two ‘Declaration’ when the Regional Office have applied verbal consent? Answer
• Where should I record any additional information in relation to any of the four consent questions? Answer
• If verbal consent is gained from the beneficiary does the caseworker need to complete a Form A? Answer
• Can a Hardcopy Form A still be used? Answer
• How long does the Verbal Consent last for? Answer
• How can physical SSAFA locations open a case for a beneficiary? Answer
• How does a branch/division open a case that comes to them directly? Answer
• Beneficiary triage via email by the Regional Office? Answer
• Consent and opening of cases for overseas branches? Answer
• Can verbal consent be gained retrospectively? Answer
• Can Prison in Reach caseworkers use verbal consent, and how do they open a case? Answer
How does a caseworker complete the ‘Application for Assistance’ step two ‘Declaration’ when the Regional Office have applied Verbal Consent?
The caseworker should click the radio button labelled ‘Verbal Consent’.
No further confirmation is required from the beneficiary and no other actions need to be performed at this step by the caseworker
Where do the Regional Office record any additional information in relation to the four. consent questions?
Within the COBSEO contact step two ‘Details of Contact’ along with the full triage information.
If it is necessary for the Account Providers (APs) to be able to view any of the information then it will also have been placed into COBSEO ‘Case Notes’ as these are pulled forward at each stage of the case and therefore visible to all with access, including the requested Assistance Providers.
If verbal consent is gained from the beneficiary does the caseworker need to complete a Form A?
The information collected on a Form A is still required for caseworking but the caseworker will no longer need to ask a beneficiary to complete the Section two ‘Declaration’ and provide a wet signature. No scanning and uploading of a fully completed hardcopy Form A with all fields completed is needed.
Caseworkers when collecting beneficiary data to upload to Mosaic can either use:
1. A print-out of the ‘SSAFA Data Collection Form’
2. A fillable PDF version of the ‘SSAFA Data Collection Form’ on a personal device
3. A standard hardcopy Form A (ignoring section two. Declaration)
4. Enter the information directly into the Application for Assistance section of Mosaic
All data collected via options 1-3 must be securely deleted/destroyed once uploaded to Mosaic.
Can a Hardcopy Form A still be used?
Yes – on the rare occasion where a client does not have the ability to give verbal consent to the Regional Office, a hardcopy Form A can be used.
This will be decided on a case-by-case basis, after discussion between the caseworker and the Regional Office, and prior to any casework taking place.
How long does the verbal consent last for?
The verbal consent script covers both the storage of personal data and the full casework process:
• Verbal consent needs to be obtained each time a new case is opened even for returning beneficiaries (as we do when signing a hardcopy Form A for each new case).
• Consent to store date within Mosaic lasts for seven years.
Therefore, the consent to store personal data on Mosaic lasts for seven years, and the consent to casework lasts as long as the current case is open.
If a previous beneficiary approaches SSAFA and a new case is required, the verbal consent process must be carried out again.
How can physical SSAFA locations open a case for a beneficiary?
Around the country there are still a few physical office locations, and caseworkers in these locations will not be able to open or close cases:
- If the caseworker is running an appointment system, the client should be given the Regional Office details and asked to make contact prior to the appointment.
2. If the client is a non-appointment ‘walk-in’ there are three possible courses of action:
a) The preferred option: the caseworker explains that a full triage and verbal consent process will be done by the Regional Office, and gives them the contact details.
b) Caseworker and client together contact the Regional Office to have a case opened. Triage and the verbal consent process will be carried out as usual.
c) If options a) and b) are not possible; the caseworker should use the‘Client Referral Form into SSAFA’ to collect the clients details. The form is sent by email to the Regional Office no later than two working days after the contact. The Regional Office then contacts the client for triage and verbal consent prior to opening and allocating a case.
How does a branch / division open a case that comes to them directly?
1. Referrals into branch from a third party must be passed to the Regional Office for triage, during which verbal consent will be gained. A case will then be opened and allocated.
2. When a beneficiary makes direct contact with the branch / division there are two possible courses of action:
a) The preferred option: the branch / division provide the client with the Regional Ofice contact details so that client triage and verbal consent can be obtained. A case will then be opened and allocated.
b) If option a) is not possible: the caseworker must use the ‘Client Referral Form into SSAFA’ to collect the clients details.
The form is sent by SSAFA email to the Regional Office no later than two working days after the contact. The Regional Office then contacts the client for triage and verbal consent prior to opening and allocating a case.
Hardcopy and digital versions of the form on a personal device must be destroyed / deleted as soon as they have been sent to the Regional Office.
Beneficiary triage via email by the Regional Office
The Regional Office should make every effort to speak directly to the beneficiary, although it is recognised that for some they will not wish to, or perhaps be unable to.
Should this happen then the case will need to be worked via the hardcopy Form A route.
Consent to store personal data should be clearly confirmed with the beneficiary and this email turned into a PDF and attached via the paperclip to the COBSEO contact in order for the case to proceed.
Can verbal consent be gained retrospectively?
Cases created on Mosaic prior to 20 November 2023:
No, verbal consent cannot be applied retrospectively as this section will not appear in the COBSEO contact, and the ‘verbal consent’ option will not exist on Section two ‘Declaration’ - therefore a hardcopy Form A is required.
Consent and opening of cases for Overseas Branches?
Please contact the Overseas Regional Operations Manager
Can Prison in Reach workers use verbal consent, and how do they open a case?
Verbal consent: can only be used directly between the Regional Office and beneficiary, so unless the beneficiary has the ability to contact the Regional Office it will not be possible to use this form of Consent and the usual hardcopy Form A should be utilised for caseworking.
Opening a case: this needs to be actioned by the Regional Office. Therefore, the PIR Caseworker should contact the Regional Office providing the beneficiaries details and signed consent as soon as possible, and no later than two working days after the meeting so that a case can be opened and allocated. A full hardcopy Form A will need to be upload to the case once it is fully completed.