Can collaborative agencies with an MOU containing confidentiality language share victim information for funder reporting reasons without getting a release?
Regardless of the language within a MOU, releases are always necessary to share personally identifying individual client information. However, you can share aggregate information for reporting to funders. Aggregate information means totals, so it’s acceptable to report that your program referred 7 people in a particular month but not to provide any identifying details.
It is important to remember that what is identifying varies from community to community. It is always inappropriate to share names, dates of birth, and U.S. social security numbers. For some communities it may also be identifying to report, for example, that you served a 42 year-old white women with 4 children, ages 11, 9, 8, and 6 or a 32 year-old Asian woman with a 2 year-old. Communities and agencies should consider what information is identifiable for individuals receiving services and should always provide the least amount of information possible.
The three major U.S. federal funding sources (Office for Victims of Crime, Office on Violence Against Women, and Department of Health and Human Services) do not require you to unduplicate victims between agencies, so there is no need to share personally identifying individual client information to meet federal reporting requirements.