Privacy

 

Who are we and what is this privacy notice?

“We” are 29th Purley & District Scout Group, also known as 29th Purley. We are an independent charity, established under Royal Charter and excepted from registering with the Charities Commission.

 

This Data Privacy Notice describes the categories of personal data that we process, and for what purposes and applies to members, parents/guardians of youth members, volunteers and supporters, as well as donors and members of the public who contact us.

 

We are committed to collecting and using data fairly and in accordance with the General Data Protection Regulations (GDPR) and the Data Protection Act 2018 (DPA)

 

Our data controller is the group Executive Committee who are appointed at each Annual General Meeting and includes our charity trustees. The Chair of our Executive Committee is Kevin Hardcastle.

 

Being a small charity, we are not required to appoint a Data Protection Officer, however data protection requests and queries may be sent to our Group Scout Leader, Anthony Eeles. You can contact us using our online form at https://29thpurley.org/join-the-adventure/

The data we may process.

The majority of the personal information we hold, is provided to us directly by you or by the parents or legal guardians of youth members verbally or in paper form, digital form or via our online membership systems Online Scout Manager and Compass.  In the case of adult members and volunteers, data may also be provided by third parties, such as the Disclosure and Barring Service.

 

Where a member is under the age of 18, this information is usually obtained from a parent or guardian and rarely provided by the young person.

 

We may collect the following personal information:

·       Personal contact details such as name, title, address, telephone numbers and personal email address – so that we can contact you.

·       Date of birth – so that we can ensure young people are allocated to the appropriate Section for their age and that adults are old enough to take on an appointment with Scouting.

·       Gender – so that we can address individuals correctly and accommodate for any specific needs.

·       Emergency contact information – so that we are able to contact someone in the event of an emergency.

·       Government identification numbers e.g. national insurance, driving licence, passport – to be able to process volunteer criminal record checks.

·       Bank account details, payroll information and tax status information – so that we are able to pay any staff that might be employed by us and collect gift aid from HMRC where donations are made.8

·       Training records – so that members can track their progression through the Scout programme or adult training scheme.

·       Race or ethnic origin – so that we can make suitable arrangements based on members cultural needs.

·       Health records – so that we can make suitable arrangements based on members medical needs.

·       Criminal records checks – to ensure Scouting is a safe space for young people and adults.

·       Attendance at sessions – for our records, that members can track their progression through the scout programme or adult training scheme

 

COVID 19:

 

·       We will conduct screening information regarding to risk factors related to Covid-19. This will include Special Category data relating to Health and Race/Ethnicity.

·       We will share our register of attending members with any PHE or NHS track and trace service or similar, or with the local scout district where they are asked to do so by the same.

The Lawful Basis by which we process your data.

In most cases the lawful basis for processing data will be:

–       Legitimate Interests for data relating to our youth members and their parents/guardians/emergency contacts

–       The performance of a contract for personal data for our adult volunteers

 

Special Category data such as health or religious beliefs or ethnic background processed under our legitimate interests as a not-for-profit organisation

 

We use legitimate interests to process photographs and make this clear on our membership form for youth members and their parents / guardians. It is possible to opt out of some processing of photographs by speaking to a leader or our data protection contact.

 

COVID 19:

Where we process data specifically relating to our Covid-19 procedures, we are processing data as follows:

 

To protect your vital interests by ensuring we plan sessions and activities in full awareness of any risk factors relating to Covid-19

 

In our legitimate interests and to protect your vital interests where we share your information with a public health body like the NHS or PHE or our local district to assist in Covid-19 contact tracing.

The purposes for which we process your data.

We use personal data for the following purposes:

·       to provide information about Scout meetings, activities, training courses and events to our members and other volunteers, and other local activities which may be of benefit

·       to provide a voluntary service for the benefit of the public in our local community

·       to administer membership records

·       to fundraise and promote the interests of Scouting

·       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 being run or attended by us, our local district, county, and national scouting

·       to ensure and evidence your suitability if volunteering for a role in Scouting

·       to contact your next of kin or other appointed emergency contact in the event of an emergency

·       to ensure you have and maintain the correct qualifications and skills.

 

We use personal sensitive (special) data for the following purposes:

·       for the protection of a person’s health and safety whilst in our care

·       to respect a person’s religious beliefs with regards to activities, food and holidays

·       for equal opportunity monitoring and reporting at a local and national level.

 

In the event we wish to use your personal data for a new purpose not covered by this notice we will provide you with a new notice prior to commencing the processing and setting out new information. If necessary, we will request your consent to the new processing.

How long we retain your information for.

We will usually retain your information until the end of the term after which you leave membership of our group, by leaving, moving to a different group or unit or we lose contact with you.

 

However, in the event of an incident where we need to process your data for additional purposes (for example an accident or emergency, a safeguarding concern or a complaint by you), we may retain your information for as long as is necessary under data protection legislation.

 

COVID-19:

We will retain and update the risk screening information you provide us for the duration of the Covid-19 pandemic, or for as long as the Scout Association / National Youth Agency recommend additional measures are taken.

 

We will retain the register of attendees for each event for at least 21 days after the event – in practice this is retained for the duration of a child or leader’s involvement in scouting for other purposes described above.

 

Sharing your information.

Young people and other data subjects

 

We will normally only share personal information with:

–       Adult volunteers within 29th Purley

–       Adult volunteers within Purley Cross Explorer unit where it is expected that a youth member will be transferring to that unit at the end of their time in our group. Likewise if a youth member is transferring to a different group or district we will transfer youth membership records to that group

–       Adult volunteers within the wider Scout Association for example in Croydon or Greater London South West specifically when taking part in joint activities or events.

–       Volunteers and Staff of Purley Baptist Church where joint events are planned, and you indicate a youth member is attending.

 

The Scout Association’s policies are found here

Purley Baptist Church’s policies are found here

 

Adult volunteers

We will normally only share personal information with adult volunteers holding appropriate appointments within the line management structure of The Scout Association (that is Croydon District and Greater London South West county), as well as with The Scout Association Headquarters as data controllers in common.

 

All data subjects

We will however share your personal information with others where we need meet a legal obligation. This may include The Scout Association and its insurance subsidiary (Unity Insurance Services), local authority services, HMRC (for gift aid purposes) and law enforcement. We will only share your personal information to the extent needed for those purposes.

 

We will only share your data with third parties outside of the organisation where there is a legitimate reason to do so.

 

We will never sell your personal information to any third party.

 

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

 

Where personal data is shared with third parties we will seek assurances that your personal data will be kept confidential and that the third party fully complies with the GDPR and DPA 2018.

 

COVID-19:

 

Unless you opt out by contacting your section leader or our Group Scout Leader, we will share records of attendees at affected sessions with NHS/PHE Test and Trace or similar public health services for the duration of the Covid-19 Pandemic.

How we store your information

We generally store personal information in the following ways:

 

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

 

Online Scout Manager – is the online system used by 29th Purley, Purley Cross Explorer Scout Unit and many other scout sections for the collection and storage of youth member personal data.

 

In addition adult volunteers will hold some personal data on local spreadsheets/databases.

 

We make limited use of printed records and data held while attending events – paper is sometimes used to capture and retain some data for example:

·       Gift Aid administration

·       Event registration

·       Health and contact records forms (for events)

·       Events coordination with event organisers

 

Paper records for events are used 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.

Your rights

As a Data Subject, 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 Information Commissioner’s Office (www.ico.org.uk).

 

Unless subject to an exemption under the GDPR and DPA 2018, 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 us.

·       The right to access your personal data – you can ask us to share with you the data we have about you. This is a Data Subject Access Request or “SAR”.

·       The right to rectification – this just means you can update your data if it’s inaccurate or if something is missing.  Adult members will be able to edit and update some information directly on The Scout Association’s Compass membership system.

·       The right to erasure – this means that you have the right to request that we delete any personal data we have about you. There are some exceptions, for example, some information will be held by The Scout Association for legal reasons.

·       The right to restrict processing – if you think that we are not processing your data in line with this privacy notice then you have the right to restrict any further use of that data until the issue 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.

·       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, it’s highly unlikely that this will be used by us.

 

COVID-19:

You may opt out of having your information shared with any Test and Trace services by contacting your section leader or our Group Scout Leader.

Who to contact If you have any queries relating to this Privacy Notice or our use of your personal data, please contact our Group Scout Leader via our online form at https://29thpurley.org/join-the-adventure/