Shared Earth
Learning Co-op
Data Protection Policy
SELco needs to process relevant personal data regarding members of
staff, volunteers, job applicants and young people as part of its operation and
shall take all reasonable steps to do so in accordance with this Policy.
SELco
has an appointed Data Protection Controller (DPC) who will ensure that all
personal data is processed in compliance with this Policy and the UK Data
Protection Act 2018 and associated regulations
The Principles
SELco
shall, so far as is reasonably possibly, comply with the Data Protection
Principles contained in the Data Protection Act to ensure all data is:-
· Fairly
and lawfully processed
·
Processed
for a lawful purpose
·
Adequate,
relevant and not excessive
·
Accurate
and up to date
·
Not
kept for longer than necessary
·
Processed
in accordance with the data subject's rights
·
Secure
We
will record how this data is kept and used.
Definitions
·
Parental
consent, includes the consent of a guardian.
·
Data
Subject, an individual who is the subject of the personal data.
Personal
Data
· Personal
data covers both facts and opinions about an individual where that data
identifies an individual. Processing of Personal Data Personal data may
also include sensitive personal data as defined in the Act
· Any
information which falls under the definition of personal data will remain
confidential and will only be disclosed to third parties with appropriate
consent, with certain exemptions – please see ‘Exemptions’ below.
Sensitive
Personal Data
· SELco
may, from time to time, be required to process sensitive personal data.
Sensitive personal data includes data relating to medical information, gender,
religion, race, sexual orientation, trade union membership and criminal records
and proceedings.
Rights
of Access to Information
· Data
subjects have the right of access to information held by SELco), subject to the
provisions of the UK Data Protection Act 2018 and the Freedom of Information
Act 2000.
· Any data
subject wanting to see their personal data should put their request in writing
to the DPC.
· SELco will
respond to written requests as soon as is reasonably possible and in any event,
within 40 days for access to records and 21 days to provide a reply to an
access to
information request. The information will be given to the data subject as soon
as is reasonably possible after it has come to attention of SELco and in compliance with the relevant Acts.
Exemptions
Certain data processing because of
issues related to:
·
National
security and the prevention or detection of crime
·
Where
the processing is necessary to exercise a right or obligation conferred or
imposed by law upon SELco including Safeguarding and prevention
of terrorism and radicalisation
The above are examples of exemptions
under the Act. Further information on exemptions should be sought from the DPC.
Accuracy
SELco will ensure that personal data
held in relation to all data subjects is accurate. Data subjects must notify
the data processor of any changes to information held about them.
Enforcement
If an individual believes that SELco has
not complied with this Policy or acted otherwise than in accordance with the UK
Data Protection Act 2018, the individual should notify the DPC or the
Information Commissioners Office.
Data
Security
· SELco
will take appropriate steps to ensure the security of personal data.
· All
staff will be made aware of this policy and their duties under the Act.
· All staff and young people are required to respect the personal
data and privacy of others. They must ensure that appropriate protection and
security measures are taken against unlawful or unauthorised processing of
personal data, and against the accidental loss of, or damage to personal data.
· An
appropriate level of data security must be used for the type of data and the
data processing being performed. In most cases, personal data must be stored in
secure systems and be secured when
transported offsite.
· All data
breaches will be reported without undue delay – and within 72 hours – to the
Information Commissioner’s Office (https://ico.org.uk). SELco
will inform any individuals affected without undue delay, where the
breach could result in ID theft or fraud; physical harm; significant
humiliation and/or damage to reputation.
External
Processors
SELco will ensure that where data
processed by external processors, for example, service providers, Cloud
services including storage, web sites etc. the processing is compliant with
this policy and the relevant legislation.
Secure
Destruction
When data held in accordance with this
policy is destroyed, it will be destroyed securely in accordance with best
practice at the time of destruction.
Retention
of Data
· SELco
may retain data for differing periods of time for different purposes as
required by statute or best practices
· SELco
may store some data such as registers, photographs, achievements, indefinitely
in its archive.
Right
to erasure
· Data
subjects have the right to ask for their information to be erased from our
current data. This request will be granted, providing that it doesn’t conflict
with legal proceedings and will not include information archived for legal
reasons.
Review
This policy will be reviewed annually. SELco’s
Data Protection Controller is Alex Hart.
Name printed: Alex Hart
Date: 15th
May 2018
Safeguarding
policy
Purpose and aim of the policy: to make clear what
our co-operative does to keep children safe.
(N.B. We have a separate policy for safe-guarding vulnerable adults, which is available on request.)
SELco's
objectives are to:
Enhance local people’s relationship with the
natural world, simultaneously developing their personal and social skills and
awareness of the importance of environmental sustainability; to offer a range
of challenges, activities games and tasks to build self-esteem, emotional
literacy and social skills outdoors; to nurture a love of the natural
environment in people, encouraging them to respect and protect the natural
spaces within our local community; to make our services accessible and
affordable; to improve community cohesion by working across generations and
integrating people from different backgrounds in our programmes.
Fundamental to this is our commitment to keeping children
safe.
This
policy applies to anyone who, through SELco, has direct contact with children
and young/vulnerable people.
Legal framework
This
policy has been written upon the basis of law and guidance that seeks to
protect children, namely:
·
Children Act 1989
·
United convention of the Rights of The Child 1991
·
Data protection Act 1998
·
Sexual offences Act 2003
·
Children Act 2004
·
Protection of freedoms Act 2012
·
Relevant government guidance on safeguarding
children
We seek
to keep children safe by valuing them, listening to them and respecting them and
ensuring that:
· All
staff and volunteers have an up-to-date DBS certificate and have completed basic safe-guarding
training.
· All
volunteers work under supervision of a member of staff.
· Everyone
is advised to avoid situations where they are alone with a child or out of view
of the group or other adults
· A
register is taken before each session begins and there is a regular head count.
· All
practitioners have an up-to-date understanding of safeguarding children issues
and are able to respond appropriately to any: Significant changes in a child’s
behaviour, deterioration in their general well-being, unexplained bruising or
signs of possible abuse, signs of neglect or comments children make which give
cause for concern
· Only
children five years and up may take part in a SELco activity where the parent
or guardian is not present and they must be able to go to the toilet unaided.
· SELco
has adopted the NSPCC
recommended ratio of adults to children as follows: Aged 5 - 8 years: 1:6; Aged
9 - 12 years: 1:8 Aged 13 – (up to) 18
years: 1:10.
· No
photographs may be taken of unaccompanied children without written consent from
parents/guardians/carers.
· There will be a qualified First Aider on site
at all times during the activity.
· All
accidents will be recorded for the accident record file.
· For activities where
children and/or vulnerable adults are unaccompanied by their carers, a consent
form must be completed . It is a requirement that carers on this form notify
any serious medical complaints, allergies and, where relevant, food
intolerances of said child/adult.
· All
SELco sessions will be risk assessed
relevant to the group activity. A copy of the RA will be available for
anyone to read. It will be periodically reviewed and updated.
Reporting
concerns
Any
concerns relating to abuse of children or vulnerable adults must be reported
immediately to the Safeguarding Representative, Alex Hart (Tel: 07547708288) but DO NOT HESITATE TO
CALL Somerset Children’s Services or 101 if you wish to discuss matters with
the police or a social worker. This will give you an opportunity to discuss
what has happened, get it formally recorded and for the correct level of
support to be offered. If accusations are made against an adult 101 should be
called at once but the Safeguarding Representative should also be notified and
informed of a report having been made.
Sometimes workers have concerns about the safeguarding
and wellbeing of a child or young person, without a clear disclosure of harm
from the child. These concerns can be vital for the early identification of
safeguarding and community groups are in a particularly strong position to
support children. In these instances, the protocol is:
· Discuss
with SELco’s designated Safeguarding Officer, Alex Hart
· Record
all details of concerns and actions immediately - stick to facts rather than
opinions - ideally with the knowledge of the child or young person and their
parent or carer (see below);
· If
no perceived adverse risk in doing so, the Safeguarding Officer should seek to
discuss concerns with parent or carer of child or young person; then,
· Report
concerns to Somerset Children’s Services via the telephone referral service via
0300 123 2224 (ask to speak to a qualified social worker).
· Be
prepared to have further involvement in a multi- agency discussion to make
plans for safeguarding and supporting the child or young person.
Equality statement
SELco is
committed to making sure that all children and young people have the same
protection regardless of age, disability, gender, racial heritage, religious
belief, sexual orientation or identity. We maintain an anti-discriminatory
practice and explicitly recognise the additional needs of children from
minority ethnic groups and disabled children and the barriers they may
face, especially around communication.
We are committed to reviewing our policy and good
practice annually
This policy was last
reviewed on 2nd February 2018
Signed:
Alex Hart
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