POLICIES



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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