Confidential Information Policy — version 2

This policy sets the rules for classifying, handling, releasing and protecting information across all of Synch: every department and team (including Community Relations, the Synch Academy and the Education & Training Board, Internal Affairs, the Transparency Department, Management, Leadership, the Office of the MD and the Executive), and every Synch Discord server, website, portal and bot. Following it is mandatory for everyone who volunteers for Synch, in every role, and it continues to apply after someone leaves.

It replaces the Internal Affairs Confidential Information Policy of the former Support Central Group. How we handle personal data is also explained in our Privacy Policy and GDPR Notice. How to ask us for information is explained in our Freedom of Information Request guidelines.

1. Our approach to disclosure

Synch is an unregistered, volunteer-run online community. At the time this policy was written, Synch is not legally required to disclose its decisions, deliberations or internal records to anyone. We choose to be as open as we reasonably can, in good faith:

• Anyone can contact us about anything by opening a ticket in our Discord server (discord.gg/NvbG77QZSP).
• Anyone can request information formally with a Freedom of Information Request (FOIR), submitted through an OMD/Executive Ticket. See our FOIR guidelines.

This doesn't limit your rights over your own personal data. If you're in the UK, the EU or Switzerland, you can ask for a copy of the personal data we hold about you at any time, as explained in our GDPR Notice. That's a separate right, handled separately, and it isn't subject to this policy's discretion.

2. Classification levels

Every piece of information Synch holds falls into one of four levels. If you're unsure which level something is, treat it as the higher one and ask Internal Affairs.

Information from a higher level stays at that level wherever it's copied, quoted or summarised. A screenshot of a Restricted channel is Restricted.

3. What counts as confidential

Anything at the Confidential or Restricted level. This includes, but isn't limited to, the following.

A. Information about people (confidential user information)

Also called privileged information: any information about a specific person that isn't publicly available through our public channels or public records.

• Identity and contact details: email addresses, time zones, regions, pronouns and birthdays given to us, alternate accounts, and linked accounts.
• Communication records: ticket transcripts, appeal transcripts, private messages between staff and members, and DMs sent through our bots.
• Moderation and disciplinary records: infraction history, warnings (including verbal warnings), mutes, bans, disciplinary action, fines, and staff notes about someone's conduct.
• Reports and reporters: the content of user reports and staff reports, and the identity of anyone who reported someone, raised a concern or asked an anonymous question. This is always Restricted.
• Staff records: applications and their answers, interview notes, background checks, onboarding records, staff files, quota and performance records, promotion and demotion discussions, leave of absence requests and the reasons given, and resignation details.
• Academy records: enrolments, exam answers and grades, certificate records, and anything a partner community can see about its own members.
• Economy and rewards records: individual balances, transactions, taxes, fines, bonds, payouts and prize claims.
• Technical data: IP log records, device or connection information, and any other personally identifiable information (PII) that Synch collects.

B. Internal records

• Messages in staff-only channels, and voice channel conversations or recordings.
• Meeting records: agendas, meeting minutes, notes and summaries of staff or leadership meetings.
• Governance records: motions, motion amendments, votes and their results, and how individuals voted (Restricted).
• Internal reports: weekly team and department reports, audits, reviews and statistics that haven't been published.
• Investigations and case files, including evidence and witness statements (Restricted).
• Plans and drafts: unannounced decisions, draft policies and announcements, budgets, Treasury and economy plans, event and giveaway plans before they're published.
• Partnership and third-party dealings: negotiations and agreements with partner communities, and anything shared with us in confidence by another community or by Discord.
• Any other information that Internal Affairs, Leadership or the Executive has classed as sensitive.

C. Security information (always Restricted)

• Bot tokens, API keys, webhook URLs, passwords and any other credentials.
• Server permission and role configurations, and how staff tools, portals and bots work behind the scenes.
• Moderation methods: automod rules, filter and blocklists, alt-account and raid detection, and anything that would help someone avoid moderation.
• Backups and exports of our databases, servers or channels.

4. How confidential information must be handled

Everyone on staff must:

• Keep it only where it already lives: our access-controlled staff channels, portals and bots.
• Not copy it out: no screenshots, exports, downloads or forwarding to DMs, other servers, personal notes, or public channels.
• Not paste it into outside tools or services, including AI tools, translators, paste sites or file-sharing sites.
• Not discuss it in public channels, or with anyone who doesn't have the matching access, including friends, family or members of other communities.
• Report accidental access straight away: if you see something you shouldn't have, stop, don't share it, and tell Internal Affairs.
• Hand everything back when leaving: when you leave a role or Synch, you lose access, you must delete any copies you hold, and your duty of confidentiality continues.

5. How confidential information may be accessed or released

Confidential information may be accessed or released only in these ways:

• Internal need: a member of staff needs it for an approved task, following the internal procedure in section 7.
• Consent: the person the information is about expressly agrees, or chooses to share it themselves. Consent covers only that person's own information, never anyone else's in the same record.
• A Freedom of Information Request (FOIR): someone inside or outside Synch submits a request through an OMD/Executive Ticket, following our FOIR guidelines. Every FOIR is reviewed, and must be approved, by the Appeals Committee. If a release would include information about another person, that person is told first, and given a reasonable time to object before anything is released.
• Your own personal data: a subject access request under our GDPR Notice.
• Safety and legal obligations: where we must report something to Discord's Trust & Safety team, or where disclosure is required by law or is needed to protect someone from serious harm. Only the minimum necessary is shared, and the Deputy Director of Transparency or higher approves it (or is told immediately afterwards, in an emergency).

6. Releasing information: full, partial and redacted

When information is released, through a FOIR or otherwise, the decision is one of the following. Parts of one request can have different outcomes.

Redaction

A redaction removes a specific part of a record before it's released, so the rest can be shared. We redact rather than refuse wherever we reasonably can.

• Redactions are made on a copy. The original record is never changed.
• Each redaction is replaced with a visible marker showing why it was removed, for example [REDACTED: R1]. We never hide the fact that something was redacted.
• Redactions are kept to the minimum needed: a name, not the whole message; a message, not the whole transcript.
• Every redaction is recorded in the release log (section 9), with the reason and who approved it.

Redaction reasons

Information about the requester themselves is never redacted under R1.

7. Internal access by staff

Staff access to confidential information must be documented, and must follow the principle of minimum necessary access: staff look only at what they need for a specific, approved task, and nothing more.

Chain of evidence. Staff who need to request or access confidential information outside their normal duties must get approval, and record it, through their chain of responsibility: their team's Head, then their department's Director, then Internal Affairs for anything that crosses departments or involves Restricted information. The record shows who accessed what, why, who approved it and when. This gives a clear chain of evidence and makes everyone accountable for the information they access.

8. Data protection principles

Everyone on staff must handle confidential information according to these principles, which follow the UK and EU General Data Protection Regulation (GDPR).

A. Data minimisation and purpose limitation

• Collect only what's needed. Staff collect, use or store only the confidential information that is strictly necessary for a specific, legitimate purpose, for example investigating a reported infraction or deciding an appeal.
• No secondary use. Information collected for one purpose must never be used for another, unrelated purpose (for example personal curiosity, harassment or any other misconduct), unless there is a documented justification approved by the Deputy Director of Transparency or higher.

B. Storage limitation and integrity

• Retention. Confidential user information is kept in a form that identifies the person only for as long as it's needed for the purpose it was collected for. Our retention schedules must be followed; for example, infraction history may be deleted after 36 months of inactivity. Inactivity means the person hasn't tried to appeal the infraction or used any Synch service in that time.
• Security. Staff must keep confidential information safe from unauthorised or unlawful use, accidental loss, destruction or damage, by following section 4 and keeping it in secured, staff-only channels and access-controlled systems.

C. Reclassification

Information can move to a lower level, for example when a decision is announced or an investigation closes. Only Internal Affairs, Leadership or the Executive can reclassify information, and a record is kept of each change. Until then, information keeps its level, even if some of it has become known another way.

9. Accountability and enforcement

Records. Internal Affairs, through the Transparency Department, keeps records of: access requests and approvals, the chain of evidence, retention logs, reclassifications, and every release, including each FOIR, its outcome and every redaction made.

Breaking this policy. Any unauthorised access, use, disclosure or leak of confidential information is a serious breach of this policy. It will lead to immediate disciplinary action, which may include:

• Removal of all administrative permissions and access.
• Immediate removal from all staff positions.
• A permanent ban from Synch's servers and services.

Members who aren't on staff and who share leaked Confidential or Restricted information may face moderation action.

Data breaches. If confidential information is lost, leaked or accessed without authorisation, the Deputy Director of Transparency or higher must be told immediately, so an internal investigation and any necessary outside action can begin.

10. Changes to this policy

This policy takes effect immediately. Synch's Leadership and the Executive may change it when needed. Every version is kept in this page's history.