The overarching purpose of a Postvention Community Working Group (PCWG) or equivalent is suicide prevention.

The sharing of personal information as part of PCWG activity is allowed under Rules 10 and 11 of the Health Information Privacy Code (2020; HIPC). These rules state that sensitive health information can be shared if:

“The disclosure of the information is one of the purposes
in connection with which the information was obtained.”
OR
“The disclosure of the information is necessary
to prevent or lessen a serious threat to public health or safety
or the life or health of an individual.”

A suicide cluster and signs of emerging suicide exposure effects (contagion) are both serious threats to public health and safety; individual wellbeing and lives may be at risk.

All members of a PCWG must be aware of their responsibilities under the Privacy Act (2020) and the HIPC (2020) with respect to personal information and any records kept as part of PCWG activities are deemed health records and must be treated in accordance with this legislation.

Such records might include:

• A Supported Persons Register /At Risk Register / Vulnerable Persons Register
• Minutes of meetings
• A record of those who have died by suspected suicide or made suicide attempts

The principals of the HIPC:

• Any information must be collected for a lawful purpose. In the case of postvention activities the overarching lawful purpose is suicide prevention, minimising the risk of further suicide exposure effects including suicide attempts and deaths by suicide.
• The information collected must be stored securely and safely.
• People can ask to see and correct (if inaccurate) information held about them and all reasonable steps must be taken to ensure information is accurate and up to date.
• All records must be kept for as long as a lawful purpose requires. Health regulations require health records to be retained for a minimum of ten years.
• Where possible, individuals concerned should authorise any sharing of their personal information. However, this is not necessary if the sharing of information is to prevent or lessen risk to public health or safety or the health or life of an individual, as is the case in suicide postvention.

Key guidelines for ensuring PCWG protection of Privacy

• All members of a PCWG must sign an agreement that they understand and agree to abide by the principals of the Privacy Act (2020), the Health Information Privacy Code (2020) and these Guidelines.
• It is recommended that a single lead agency is designated to hold all PCWG records. This agency should be equipped and experienced in securely managing such information (e.g. Oranga Tamariki, Te Whatu Ora, PHO, MoE).
• Only minimal necessary personal information about individuals (both the deceased and those identified as potentially vulnerable) sufficient to fulfil any legitimate postvention purpose is to be shared.
• Personal information should NOT be emailed between PCWG members or, if it is emailed, it should be done so securely; at a minimum using a password protected document attached to the email and not typed in the body of the email itself. The password should be sent separately (in a cell phone text for example) to the email
  with the password protected document attached.

When considering disclosing or sharing personal information the following questions must be taken into consideration:

• Does the situation meet the criteria for “serious threat” to “public health or safety” or the “life or health of an individual” in the context of suicide risk?
• Am I disclosing information only to those who can act to lessen or prevent the threat?
• Am I disclosing only as much information as is necessary to lessen or prevent the threat?