Summary:
The 5th New Forest North (Testwood) Scout group is committed to compliance with UK Data Protection Act 2018 and best practice in how it meets its duties. All personnel are required to adhere to the full policy (see below) and to sign a declaration of compliance.
The 5th New Forest North (Testwood) Scout group is the data controller and works with the Scout Association and others to process data.
The 5th New Forest North (Testwood) Scout group is an educational children’s charity (number 302291) that runs a programme of activities for the development of young people. Personal information of young people, adults, helpers and donors is processed.
The legal basis of this processing is for our legitimate interests, including administration of the Scout programme, governance, safety and safeguarding, employment reasons, fundraising and public relations. We process data for legal reasons including maintaining safety and safeguarding records in compliance with the Scout Association’s Policy Organisation and Rules, employment purposes, and maintaining accounting records as required by authorities. We process data by reason of data subjects’ consent including providing direct electronic communications, fundraising and statistical reporting about inclusion relating to ethnicity and disability.
Personal information is only used and shared internally and externally as required for the purposes of Scouting or as required by law.
Personal data is retained as required for the good administration of the 5th New Forest North (Testwood) Scout group and as required by law. Members’ data may not be completely erased from the Scout Association database for reasons of legitimate interest, including safeguarding.
Data subjects may make a subject access request by contacting the Data Protection Officer at the 5th New Forest North (Testwood) Scout group: Debbie St. John (Chairperson). Data Subjects have rights in accordance with the Data Protection Act 2018.
The full Data Protection, Confidentiality and Privacy Policy is available from the 5th New Forest North (Testwood) Scout group HQ (Garland Lodge) and on our website (see below).
Our Data Protection, Confidentiality and Privacy Policy
Who is this for and what does it apply to?
The UK’s Data Protection regulations were last updated in May 2018 to be consistent with European legislation known as the General Data Protection Regulations (GDPR). Data Protection regulations apply to all organisations that hold any information that identifies living people.
In Scouts, Data Protection applies to the lists of young people, adults and any other people recorded in a structured way for future contact. It applies to the use of the Compass membership system, from recruitment onwards, and Online Scout Manager (OSM). It applies to information gathered from our website, to activity information forms and fundraising list information.
It does not apply to incidental naming of people in, for example, minutes of meetings or action lists.
Our commitment:
The 5th New Forest North (Testwood) Scout group is committed to fully complying with the Data Protection rules. This means that every person (leaders, administrators, honorary officers and executive committee members) involved in the group will observe this policy.
Formal contact:
The 5th New Forest North (Testwood) Scout group is the data controller. The group’s Data Protection Officer is the Executive Committee Chairman, Debbie St. John. The contact address is Debbie St. John, 7 Charnwood Close, Totton, Southampton, SO40 2QB or by email: [email protected].
Not registered with the ICO.
As a charity, the 5th New Forest North (Testwood) Scout group, handles personal data only for the purposes of maintenance of its membership and donors and is not required to register with the Information Commissioners Office (ICO) or to pay the Data Protection fee.
How we use data.
The 5th New Forest North (Testwood) Scout group processes personal data using paper and electronic systems. It works with partner data processors including the Scout Association, Google, Microsoft, Online Scout Manager (OSM) and Dropbox for the group’s administration. Paypal and Eventbrite are also partners for fundraising activities. The 5th New Forest North (Testwood) Scout group has determined that our partner organisation’s processing of data on our behalf is compliant with GDPR and Data Protection regulations as far as we can assess.
The Legal Basis of our Data Processing
The 5th New Forest North (Testwood) Scout group is an educational children’s charity, number 302291. The young people it serves are members. Adults in leader, trustee and supporter roles are either members, associate members or non-members.
The 5th New Forest North (Testwood) Scout group also processes data of helpers and benefactors.
To achieve our charitable purposes, we process data for our legitimate interests. This includes processing for the purposes of
- Administration of the Scout programme and activities
- Governance
- Safety and safeguarding
- Fundraising and Public /Community relations
This includes processing by holding paper and electronic records, processing with the facilities of our data processing partners and sending communications by paper and electronic means.
We process data for legal reasons. This includes for the purposes of
- maintaining safety and safeguarding records in compliance with the Scout Association’s Policy Organisation and Rules (POR) and other statutory requirements e.g RIDDOR.
- maintaining accounting records as required by HMRC and the Charity Commission.
We process data by reason of data subjects’ consent. This includes for the purposes of
- Statistical reporting about inclusion, including ethnicity and disability;
- Fundraising by direct mail or electronic communications.
Special Categories of Personal Data
Data will be processed about members’ and adult helpers’ Ethnicity, Health, Disability and Religious Belief to enable inclusion. Information about criminal records will be processed to inform recruitment decisions but will not be kept. (Disclosure of all criminal convictions and cautions and the provision of an enhanced certificate from the Disclosure and Barring Service is required for all adults in relevant roles, this being in compliance with the relevant legislation about filtering and rehabilitation of offenders.)
The personal data of members and adult helpers we process will include full name and contact details, date of birth and age, records of service and training. Records of service will include roles and activities undertaken and role reviews. Relevant records will be kept for the management of safety, safeguarding and personnel.
Website information will be kept for the effective management of the website and statistical purposes.
Financial information about bank accounts, payment of membership and activity fees, donations, the processing of gift aid and the maintenance of records will be kept as required by regulations.
Sharing of your Personal Data
Subject to Data Protection regulations the 5th New Forest North (Testwood) Scout group will share your data as relevant with the Scout Association, the local Scout District (New Forest North Scouts) and Scout County (Hampshire Scouts) and Scout groups to enable the provision of Scout programme and activities, training opportunities, administration and promotion.
Data would be shared to comply with legal requirements when necessary or others when we have your consent.
Data would be shared with medical services to protect your vital interests
Data would be shared when relevant for the good administration of the charity and security of our processes.
Data will be processed by partner data processors including cloud-based services for the good administration of the 5th New Forest North (Testwood) Scout group and achievement of its charitable purposes.
Personal data may be transferred outside the UK and European Economic Area (EEA) through the use of cloud computing systems.
Sharing of your Personal Data through the Scouts and Online Scout Manager partnership
The 5th New Forest North (Testwood) Scout Group have opted in to a partnership between The Scout Association (TSA) and Online Scout Manager (OSM). In certain circumstances, personal data may be shared as below:
- TSA may transfer a person’s name to OSM on an ad hoc basis to inform OSM if someone is suspended from the Scouts. This is so OSM can remove their access to youth records.
- TSA may access personal data stored on OSM if it is required to respond to safeguarding cases in a timely manner. This is restricted to the Safeguarding team, to staff members that require it as a last resort to protect children. The access is logged within OSM’s audit trail and will only be attempted if the Safeguarding team are not able to contact volunteers at the 5th New Forest North (Testwood) Scout Group.
- Authorised staff at TSA will be able to see anonymous data in OSM to gain real time insights into Scouting nationally to provide better support for Scout groups and to increase external funding opportunities. This membership data helps feed into anonymous national information about membership numbers, age spread, gender balance, where groups are located and spread across postcodes.
Additional details of the partnership can be found at the Scouts’ website: scouts.org.uk/digital-transformation/online-scout-manager/
Confidentiality
The 5th New Forest North (Testwood) Scout group is an organisation with approximately 30 volunteer leaders with various levels of access to groups of Young Person’s and Adult’s information. All persons with access to personal data are required to maintain that personal data in confidence and not to share it outside a “need to know” basis as outlined above. All persons with access to personal data are required to complete appropriate training on the handling of data and agree to a Confidentiality and Data Protection statement.
Anyone accessing personal information is required to only use devices that are secure by being in their own homes or scouting premises else be protected by password and encrypted, and with system security and data back-up.
Safeguarding Partnership
The 5th New Forest North (Testwood) Scout group is a member of the Scout Association and complies with its Policy, Organisation and Rules (POR). POR details our safeguarding processes, involving recruitment and safeguarding investigations. Personal information will be passed to the Scout Association for their processes in safer recruitment and safeguarding. Information will be passed to the Police when there is a relevant concern.
Your Rights under Data Protection Regulations
Your rights are as follows:
- To be informed about how we process your personal data: this Data Protection and Privacy Policy seeks to provide that information.
- To have any erroneous personal data corrected: the 5th New Forest North (Testwood) Scout group requests all members to notify any changes and will update information without delay.
- To object to processing: the 5th New Forest North (Testwood) Scout group will comply with your request as far as possible. Some records are maintained for the formal administration of the charity, for safety and for safeguarding purposes when retention of records will be required.
- To restrict processing: the 5th New Forest North (Testwood) Scout group will comply with your request as far as possible,
- To have your personal data erased: the 5th New Forest North (Testwood) Scout group will comply with your request as far as possible.
- To request access: the 5th New Forest North (Testwood) Scout group will comply with current regulations.
- To move, copy or transfer your personal data: the 5th New Forest North (Testwood) Scout group will comply with your request as far as possible acknowledging that adult member records are included in the Scout membership system, Compass. The transfer of young persons data in OSM may be possible.
Subject Access
Any person who is the subject of personal data held by the group may make a subject access request by contacting the Data Protection Officer (Group Chairperson): Debbie St. John. The request will be processed in accordance with current regulation.
Adults may access their personal data by logging into the Scout membership system, Compass. Adults are encouraged to keep this up-to-date themselves.
Parents and Young People can log into Online Scout Manager (OSM) to access and edit their data.
Questions about Data Protection or the use of Personal Data
Any questions or comments about data protection or this policy, notwithstanding your rights above, should be addressed to the 5th New Forest North (Testwood) Scout group Data Protection Officer as above.
Adult Member’s Personal records
The personal membership profile of each adult member is kept on the Scout membership system, Compass. It is the responsibility of each member to ensure that they keep their own record up to date. If anyone has difficulty in accessing their membership record then they should ask their line manager for assistance. The Scout Information Centre (0345 300 1818; [email protected]) may also be able to help.
Internal and Other Directories
The compilation of any directory must have the approval of the executive committee. Directories must only contain the information that is specifically consented to include. The request for consent must include information about access to or distribution of the directory. The directory must be kept-up to date by a named person.
Programme, Activity and Training Registration
Adult volunteers will use appropriate and secure methods to gather information for registration. Only information that is necessary for the purpose will be requested.
Information may be gathered by paper or online forms. A data protection statement will be included in the form stating the whole use of the data and specifically identifying any sharing or not.
Activity registration data will often form part of relevant training and safeguarding information and so will be kept for the relevant time scale.
Retention of records
Records will be retained for the good administration of the 5th New Forest North (Testwood) Scout group. Records kept and timescales are below:
- For governance matters – indefinitely.
- Attendance records for safeguarding purposes – indefinitely.
- Adult membership, involvement and training records will be kept on Compass and not in other forms of record, therefore kept in compliance with the person’s membership and Scout Association policy.
- Notes and records from Safeguarding investigations will be sent to the Scout Association for retention and not kept locally.
- For accounting purposes – for 6 years after the end of the relevant year.
Consent for children
Consent for children (under 18’s) to participate in activities and to receive communications will require parental / guardian consent.
Consent to electronic mailings – unsubscribe
Mailings may be sent for notification of events, administration and governance. Anyone who wishes not to receive such mailings, providing it is not a duty, will be unsubscribed. All mailings will have an Unsubscribe facility.
Communication and Review of this Policy
This policy is available from the 5th New Forest North (Testwood) Scout group HQ (Garland Lodge) and on our website at www.5thtestwoodscouts.co.uk/privacy-policy
This Policy will be reviewed periodically as any changes in regulations or best practice occur; this will be at least every 3 years.
This Policy was agreed by the 5th New Forest North (Testwood) Scout group executive committee on 10th February 2021.
This policy has three appendices. They can be viewed at this page.
- Appendix 1 – Administrative procedures in the 5th New Forest North (Testwood) Scout group .
- Appendix 2 – Data Protection and Confidentiality agreement
- Appendix 3 – Summary Data Protection and Privacy Statement.