1. What is this privacy notice/policy?
This Data Privacy Notice/Policy describes the categories of personal data 3rd Banstead Scout Group (hereafter referred to as 3rd Banstead) process and for what purposes. 3rd Banstead are committed to collecting and using such data fairly and in accordance with the requirements of the General Data Protection Regulations (GDPR), the regulations set by the European Union, and Data Protection Act 2018 (DPA 2018), the UK law that encompasses the GDPR.
This Privacy Notice/Policy applies to members, parents/guardians of youth members, volunteers, employees, contractors, suppliers, supporters, donors and members of the public who will make contact with 3rd Banstead.
2. Who we are
3rd Banstead are a registered charity with the Charity Commission for England & Wales; charity number 305687. The Data Controller for 3rd Banstead is the 3rd Banstead Board of Trustees who are appointed at an Annual General Meeting and are Charity Trustees. The Chair of the Charity Trustees is Richard Aram (email@example.com).
From this point on 3rd Banstead Scout Group will be referred to as “we”.
Being a small charity, we are not required to appoint a Data Protection Officer.
3. 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 England & Wales – Disclosure and Barring Service (DBS).
Where a member is under the age of 18, this information will only be obtained from a parent or guardian and cannot be 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.
- Tax status information – so that we are able to collect gift aid from HMRC where donations are made.
- 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.
4. The lawful basis we process your data by
We comply with our obligations under the GDPR and DPA 2018 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.
In most cases the lawful basis for processing will be through the performance of a contract for personal data of our adult volunteers and legitimate interest for personal data of our youth members. Sensitive (special category) data for both adult volunteers and our youth members will mostly align to the lawful basis of legitimate activities of an association. Explicit consent is requested from parents/guardians to take photographs of our members. On occasion we may use legitimate interest to process photographs where it is not practical to gather and maintain consent such as large-scale events. On such occasions we will make it clear that this activity will take place and give individuals the opportunity to exercise their data subject rights.
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 in 3rd Banstead
- to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution
- 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 3rd Banstead
- to ensure and evidence your suitability if volunteering for a role in Scouting
- to contact your next of kin 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 the care of 3rd Banstead to respect a person’s religious beliefs with regards to activities, food and holidays
- for equal opportunity monitoring and reporting.
5. Our retention periods
We will keep certain types of information for different periods of time in line with our retention policy.
Youth membership information is kept until your child leaves 3rd Banstead. Personal information forms relating to specific camps or events, are kept for a period of 2 months after the event. Information relating to payments and Gift Aid are kept for a period of 7 years for audit purposes.
Adult membership information is retained in accordance with the Scout Association’s Data Protection Policy.
The Scout Association’s Data Protection Policy can be found here and the Data Privacy Notice here.
6. Sharing your information
6.1 Young people and other data subjects
We will normally only share personal information with adult volunteers holding an appointment in 3rd Banstead or Banstead District Scouts.
When your child reaches the age of 13.5 years, we will share their record with Banstead District Scouts, allowing your child to be offered a place in one of our District Explorer units. We will transfer your child’s record to another Scout Group if requested by you.
6.2 Adult volunteers
We will normally only share personal information with adult volunteers holding appropriate appointments within the line management structure of The Scout Association for the 3rd Banstead as well as with The Scout Association Headquarters as data controllers in common.
6.3 All data subjects
We will however share your personal information with others outside of 3rd Banstead where we need meet a legal obligation. This may include The Scout Association and its insurance subsidiary (Unity Insurance Services), local authority services and law enforcement. This includes sharing contact details with government COVID-19 test and trace, where a youth members or adult has attended a meeting where someone has subsequently been tested and confirmed to have COVID-19. 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, or you request us 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.
7. How we store your personal data
We generally store personal information in the following ways:
7.1 Compass – is the online membership system of The Scout Association, this system is used for the collection and storage of adult volunteer personal data.
7.2 Online Scout Manager (OSM) – is the online membership system that we use for the collection and storage of youth member personal data. You will be given access to this system (referred to as OSM MyScout) to review and update your child’s records.
7.3 GoCardless – is the online payment system that is used by Online Scout Manger to process our annual subscription payments, and payments for some events.
7.4 Bookingbug – is an online system we use to allow booking and administration of certain events.
In addition adult volunteers will hold some personal data on local spreadsheets/databases.
Printed records and data held while attending events – paper is sometimes used to capture and retain some data for example:
- 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.
8. 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.
9. How we provide this privacy notice
A link to this website page is provided to those whose data is being processed by us.
10. 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.
- 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.
11. Website Cookies
Cookies are small files saved to your computer that track, save and store information about your interaction with a website.
12. Who to contact
If you have any queries relating to this Privacy Notice or our use of your personal data, please contact us by emailing our Group Scout Leader, Adam Buckell using the following email address: firstname.lastname@example.org.
13. Version number and date of the last review