Standards for public agencies

2020 Edition

Group Living Services (PA-GLS) 15: Privacy Provisions

The agency provides for resident comfort, dignity, privacy, and safety.
2020 Edition




Group Living Services allow individuals who need additional support to regain, maintain, and improve life skills and functioning in a safe, stable, community-based living arrangement.
Full Implementation, Outstanding Performance
A rating of (1) indicates that the agency's practices fully meet the standard and reflect a high level of capacity.  
  • All elements or requirements outlined in the standard are evident in practice, with rare or no exceptions: exceptions do not impact service quality or agency performance. 
Substantial Implementation, Good Performance
A rating of (2) indicates that an agency's infrastructure and practices are basically sound but there is room for improvement.
  • The majority of the standards requirements have been met and the basic framework required by the standard has been implemented. 
  • Minor inconsistencies and not yet fully developed practices are noted; however, these do not significantly impact service quality or agency performance.

Partial Implementation, Concerning Performance
A rating of (3) indicates that the agency's observed infrastructure and/or practices require significant improvement.  

  • The agency has not implemented the basic framework of the standard but instead has in place only part of this framework.  
  • Omissions or exceptions to the practices outlined in the standard occur regularly, or practices are implemented in a cursory or haphazard manner.  
  • Service quality or agency functioning may be compromised.  
  • Capacity is at a basic level.
Unsatisfactory Implementation or Performance
A rating of (4) indicates that implementation of the standard is minimal or there is no evidence of implementation at all.  
  • The agency’s observed service delivery infrastructure and practices are weak or non-existent; or show signs of neglect, stagnation, or deterioration.
Self-Study EvidenceOn-Site EvidenceOn-Site Activities
  • Privacy policy
  • Privacy procedures
  • Judicial order, law, or contract, as applicable
  • Interviews may include:
    1. Program director
    2. Relevant personnel
    3. Residents
  • Review case records
  • Observe facility

Fundamental Practice

PA-GLS 15.01

The agency ensures residents’ comfort, dignity, privacy, and safety by:
  1. prohibiting the use of surveillance cameras or listening devices in bedrooms;
  2. maintaining doors on sleeping areas and bathroom enclosures;
  3. providing one- or two-person rooms to residents who need extra sleep, protection from sleep disturbance, or extra privacy for clinical reasons; and
  4. requiring employees to knock before entering a resident’s room unless there is an immediate health or safety concern.


When agencies are required to employ alternate practices, documentation must be provided to justify the practice. Documentation may include a judicial order, law, contract, copy of the state's safety plan for a resident, or clear, clinical written justification for a resident.

Sensitivity should always be taken to ensure that all service recipients, especially abuse or trauma survivors and the LGBTQ population, feel safe and not violated.
Note: Please see the Facility Observation Checklist for additional guidance on this standard.

Fundamental Practice

PA-GLS 15.02

Searches of residents or their property are conducted in a trauma-informed manner that respects client rights, dignity, and self-determination and include, as appropriate to the frequency and invasiveness of searches:
  1. communicating to service recipients policies for searches of individuals or their property;
  2. timely notification of a parent and/or legal guardian;
  3. definition and documentation of reasonable cause and assessed risk of harm to self or others;
  4. trained, qualified staff; and
  5. an administrative review process including documentation, notification, and the timetable for review.


Search procedures should correspond directly to the invasiveness of the search to be conducted. For example, more invasive searches should be reserved for higher risk situations with reasonable cause, should only be conducted by highly qualified personnel, and always require an administrative review.

Fundamental Practice

PA-GLS 15.03

The agency communicates policies that respect residents’ privacy for reviewing mail and only does so when a previous incident involving the resident indicates that:
  1. the mail is suspected of containing unauthorized, dangerous, or illegal material or substances, in which case it may be opened by the resident in the presence of designated personnel; or
  2. receipt or sending of unopened mail is contraindicated.


Programs serving individuals with substance use conditions may require personnel to review mail without incident due to the reason for which residents are seeking treatment. If an agency employs this approach, it must provide justification for taking such measures, which may include health, safety, and other security concerns.
Examples: Examples of mail include letters, packages, emails, and other forms of correspondence via social media and electronic communication.

Fundamental Practice

PA-GLS 15.04

All residents can have private telephone conversations, and any restriction is:
  1. based on contraindications and/or a court order;
  2. approved in advance by the program director or an appropriate designee;
  3. documented in the case record; and
  4. reauthorized weekly by the immediate supervisor of the direct service provider.