GDPR Privacy Notice

GDPR Privacy Notice

2nd Clevedon Scout Group

Our Privacy and Fair Processing Notice describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the General Data Protection Regulations (GDPR).

  1. Who are we?

2nd Clevedon Scout Group is a youth charity. Our mission is to actively engage and support young people in their personal development, empowering them to make a positive contribution to society. We are incorporated by royal charter and are regulated as a member of the UK The Scout Association, (see www.scouts.org.uk for more information.) As part of The Scout Association we are not required to be individually registered with the UK Charity Commission.

Every year in May we hold an annual general meeting where members of the charity executive committee (our trustees), are elected, any parent of a youth members can decide to be in the executive at the AGM and every parent has the right to attend the Annual General Meeting.

We are based at 2nd Clevedon Scout HQ, Coleridge Vale Road North, Clevedon, North Somerset, BS21 6NL.

Our Group Executive Committee is the data controller for the information we collect from you. Any personal data that we collect will only be in relation to the work we do with our members and through our relationship with supporters, donors and funders.

  1. Your personal data – what is it?

Personal data relates to a living individual who can be identified from that data.  Identification can be by the information alone or in conjunction with any other information in our Scout Group’s (the data controller’s), possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).

  1. How we gather personal information

Most of the personal information we hold is provided to us directly by parents/legal guardians in either paper form or via our online membership systems, in the case of an adult member, data may also be provided by third party reference agencies, such as the Disclosure and Barring Service (DBS). Where a member is under the age of 18, this information will only be obtained from a parent/guardian and cannot be provided by the young person. Image data in the form of photographs and/or video taken during our meetings and events by adult volunteers, parents, or young people may be passed to us for publication or sharing within the constraints described within this notice. Passport-style images of young people are taken for identification purposes (see below). Images which are not used for either of these purposes are not retained.

  1. How do we process your personal data?

We comply with our obligations under the “GDPR” by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

We process the data to have the ability to contact the member, parents and guardians, to inform them of meetings, events that the group itself may be running or attending.

We use personal data for the following purposes: –

  • For the protection of that person whilst in the care of the Scout Group (medical information)
  • To respect a person’s beliefs with regards to activities, food and holidays (religious data)
  • To share images taken during meetings and events with parents (photographic and video data)
  • To enable us to provide a voluntary service for the benefit of the public in a geographical area as specified in our constitution
  • To administer membership records, including photographic identification
  • To publicize young people’s activities and achievements in the media (photographic data)
  • To fundraise and promote the interests of the Scout Group
  • To manage our volunteers
  • To maintain our own accounts and records (including the processing of gift aid applications);
  • To inform you of news, events, activities and services running at 2nd Clevedon Scout Group.

 

  1. What is the legal basis for processing your/your child(ren)’s personal data?

We only use your personal information where that is permitted by the laws that protect your privacy rights. We only use personal information where:

  1. We need to use the information to comply with our legal obligations.
  2. We need to use the information to contact with you, regarding meetings, events, collection of membership fees etc, (i.e. for the day to day running of the group)
  3. it is fair to use the personal information in your interests, where there is no disadvantage to you – this can include where it is in our interests to contact you about products or services within scouting.
  4. The processing is necessary for the persons legitimate interests or the legitimate interests of our Scout Group unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
  5. You have provided explicit consent for sharing (photographic and video data).

 

  1. How we store personal data

We are committed to the protection of your personal information.

We generally store personal information in one of two secure digital online database systems, where access to that data is restricted and controlled.

Compass: – is the online membership system of The Scout Association, this system is used for the collection and storage of Adult personal data.

Online Scout Manager (OSM) is an online membership system run by Online Youth Manager Ltd. This is a secure membership database where we store the personal information of Adults and Youth members for the day to day running of the group. Parents can access the system directly, for their own children only, via the MyScout portal.

Printed records and Event data

Where use of MyScout is not possible, paper is still used within the sections to capture and retain some data for example the following: –

  • New joiners form.
  • New joiners waiting lists.
  • Health and contact records update forms.
  • Gift Aid Collection forms.
  • Events consent from parents.
  • Events coordination with event organisers.
  • Award notifications/nominations

In the case of Joining forms, Health and contact update forms, this information is securely held by the leader or waiting list manager and transferred to our secure digital systems as soon as possible before the paper form is destroyed.

We store image data in two ways. Passport-type identification images are stored alongside membership data in OSM. Images from meetings and events are stored only as backup for images shared with parents using social media or on the group’s website or submitted for publication in the media. This data is held in a password-protected account on a laptop or desktop computer by the group’s webmaster.

Gift Aid collection forms will be securely held by the Group’s Treasurer to aid in the collection of Gift Aid for monthly membership fees, we have a legal obligation to retain this information for 7 years after our last claim.

Events

As a member of 2nd Clevedon Scout Group it is hoped you will take up the opportunity to attend events and camps, where is necessary to fulfil our legal obligations we will be required to potentially have a less secure means to access personal information, such as printouts of personal contacts and medical information, (including specific event contact forms), rather than relying on secure digital systems, as often the events are held where internet and digital access will not be available. We will minimise the use of paper to only what is required for the event/camp.

We will ensure:

  1. Transfer of paper is secure, such as physical hand to hand transfer or registered post.
  2. Paper forms are securely destroyed two months (see below) after use.
  3. Secure destruction will be through a shredding machine or securely burned.
  4. Always keeping the paper records secure, especially when in transit, by using:
    1. A lockable brief case.
    2. A lockable filing cabinet if long term stored.
  5. If transferred to somebody, we will audit that they return them when the event is complete.

Awards

Sometimes we may nominate a member for national award, (such as Queens Scout or Duke of Edinburgh award), such nominations would require we provide contact details to the awarding organisation, this is most often done on paper via registered post.

  1. Sharing and transferring personal Information

We will only normally share personal information within our Scout Group leaders and executive members, and image data only among parents of young people in the same section.

We will however share your personal information with others outside our Scout Group where we need meet or enforce a legal obligation. This may include Gordano Scout District, Avon Scout County, The Scout Association and its insurance subsidiary “Unity”, local authority services and law enforcement. We will only share your personal information to the extent needed for those purposes.

We may share image data through publication on the group’s website, or by submitting it for publication in the media, in order to publicise the group’s activities, or celebrate young people’s achievements. Where this is done, due consideration will be given to any possible impact of the identifiability of young persons included in these images.

If you move from 2nd Clevedon Scout Group to another Scout Group or Explorer Scout Unit, we will transfer your personal information to them.

We will never sell your personal information to any third party for the purposes of marketing.

Sometimes we may nominate a member for national award, (such as Scouting or Duke of Edinburgh award). Such nominations would require we provide contact details to that organisation.

Your personal data will be treated as strictly confidential.  We will only share your data with third parties outside of the organisation where there is a legitimate reason to do so. We will take steps to anonymise the data we provide (i.e. collective reporting on gender, ethnicity, age, etc.).  If identifiable data is to be shared, we will seek your consent.

Third Party Data Processors

2nd Clevedon Scout Group employs the services of the following third-party data processors: –

  • The Scout Association via its adult membership system “Compass” which is used to record the personal information of leaders, adults and parents who have undergone a Disclosure and Barring Service (DBS) check.
  • Online Youth Manager Ltd (Online Scout Manager) which is used to record the personal information, badge records, event and attendance records etc. We have a data processing agreement in place with online youth manager. More information is available at https://www.onlinescoutmanager.co.uk/security.php
  • Dropbox inc occasionally used for secure transfer of limited personal information for membership records and/or events.
  • Google inc used for backup storage of limited personal information submitted for joiners.
  • Atlantic Systems used for storage and retrieval of DBS (child safety) check information about adult volunteers.
  • Facebook inc used for sharing image data of group activities among parents, using closed groups in accordance with The Scout Association’s Policy, Organisation and Rules documentation.
  • Fasthosts Internet Ltd hosts the group’s website. Personal data is not usually published on the website, but images may be, so this provider has been included for completeness.

Automated decision making

2nd Clevedon Scout Group does not have any automated decision-making systems.

Transfers outside the UK

2nd Clevedon Scout Group will not transfer your personal information outside of the UK, with two exceptions:

  • Where an Event is taking place outside of the UK and it is necessary to provide personal information to comply with our legal obligations, although generally such an event will have its own data collection form which will be securely held and disposed of after the event.
  • Where a third-party online storage provider uses servers based outside the UK. Where this happens, only GDPR-compliant providers will be used.

 

8. How do we protect personal data?

We take appropriate measures to ensure that the information disclosed to us is kept secure, accurate and up to date and kept only for as long as necessary for the purpose for which it is used.

9. How long do we keep your personal data?

We will retain your personal information, throughout the time you/your child(ren) are a member of 2nd Clevedon Scout Group.

We will retain your full personal information, including identification photographs, for a period of one year after you have left 2nd Clevedon Scout Group and in a much more limited form (just name, badge and attendance records) for a period of up to 15 years (or until the age 21) to fulfil our legal obligations for insurance and legal claims.

Image data will be removed from social media a maximum of two years after first being added. Images published on the group’s website may remain there for as long as they serve the required illustrative purpose but will be deleted once they are removed. In both cases, locally stored backup copies will be deleted at the same time.

The Scout Association requires that we retain personal data, including hard copies, specific to events/camps for two months after the event/camp. We will delete electronic data of this type, and securely destroy hard copies of same, once that period has elapsed, in accordance with the disposal procedures described above.

We will also keep any Gift Aid Claim information for the statutory 7 years as required by HMRC (which may be beyond age 21)

  1. Your rights and your personal data

You have the right to object to how we process your personal information. You also have the right to access, correct, sometimes delete and restrict the personal information we use. In addition, you have a right to complain to us and to the data protection regulator.

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: –

  • The right to be informed – you have a right to know how your data will be used by our Scout Group.
  • The right to access your personal data – you can ask us to share with you the data they have about you!
  • The right to rectification – this just means you can update your data if it’s inaccurate or if something is missing. You can view and edit your personal information directly on our online membership system Online Scout Manager, using the MyScout portal.
  • The right to erasure – this means that you have the right to request that we delete any personal data they have about you. There are some exceptions, for example, some information can be held for legal reasons.
  • The right to restrict processing – if you think there’s something wrong with the data being held about you, or you aren’t sure if we are complying with rules, you can restrict any further use of your data until the problem is resolved.
  • The right to data portability – this means that if you ask us, we will have to share your data with you in a way that can be read digitally – such as a pdf. This makes it easier to share information with others.
  • The right to object – you can object to the ways your data is being used. This should make it easier to avoid unwanted marketing communications and spam from third parties.
  • Rights in relation to automated decision making and profiling – this protects you in cases where decision are being made about you based entirely on automated processes rather than a human input.

Please contact your child(ren)’s leader, our Group Scout Leader or our Data Protection Lead for more information, in the first instance.

Whether or not you exercise your new rights is up to you – the main thing to remember is that they’re there if you need them.

  1. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

  1. Contact Details

To exercise all relevant rights, queries of complaints please in the first instance contact our Data Protection Lead at 2nd Clevedon Scout Group, 6 Halswell Road, Clevedon, North Somerset, BS21 6DL, or submit a query using the contact form available on the group’s website. Need to put a link in here.

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

 

Reviewed: 13/03/2019