Glos Folk Policies: Scroll down for Data Protection, Equal Opportunities, and Child Protection Policies.
Glos Folk Privacy Statement:
Glos Folk (Gloucestershire Folk Association) collects data from members, subscribers, supporters, and performers. The legal basis for this is consent.
The data collected is the minimum necessary for Glos Folk to perform our constitutional objectives, and normally is restricted to names, addresses, telephone numbers, and e-mail addresses. No sensitive data is collected. (except for dates of birth of members under 18). The data collected for the Glos Folk Diary of Events is all in the public domain.
Data is only held when necessary, and deleted when no longer relevant, ie when members leave the organisation.
All members, subscribers, supporters, and performers are entitled to see the information held by us, and to amend when necessary.
Glos Folk does not normally share data with other agencies. An exception might be when booking agencies ask for contact details of performers.
Glos Folk will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. Any security breach will be reported promptly to those affected.
Other websites. Our web site contains links to other websites. Glos Folk is not responsible for the privacy policies or practices of any third party.
We use a third party provider, Mail Chimp, to deliver our weekly mailing to subscribers. We gather statistics around email opening and clicks using industry standard technologies.
Glos Folk Data Protection Policy
Glos Folk (Gloucestershire Folk Association) needs to collect and use certain types of information about the Individuals or Service Users who come into contact with Glos Folk in order to carry on our work. This personal information must be collected and dealt with appropriately whether it is collected on paper, stored in a computer database, or recorded on other material and there are safeguards to ensure this under the Data Protection Act 1998, and as amended by future legislation and regulations..
2. Data Controller
Glos Folk is the Data Controller under the Act, which means that it determines for what purposes personal information held will be used. It is also responsible for notifying if necessary the Information Commissioner of the data it holds or is likely to hold, and the general purposes that this data will be used for.
Glos Folk does not normally share data with other agencies. An exception might be when booking agencies ask for contact details of performers.
The Individual/Service User will be made aware in most circumstances how and with whom their information will be shared. There are circumstances where the law allows Glos Folk to disclose data (including sensitive data) without the data subject’s consent.
a) Carrying out a legal duty or as authorised by the Secretary of State
b) Protecting the vital interests of an Individual/Service User or other person
c) The Individual/Service User has already made the information public
d) Conducting any legal proceedings, obtaining legal advice or defending any legal rights
e) Monitoring for equal opportunities purposes – i.e. race, disability or religion
f) Providing a confidential service where the Individual/Service User’s consent cannot be obtained or where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill Individuals/Service Users to provide consent signatures.
Glos Folk regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal.
Glos Folk intends to ensure that personal information is treated lawfully and correctly.
To this end, Glos Folk will adhere to the Principles of Data Protection, as detailed in the Data Protection Act 1998, and as amended by future legislation and regulations.
Specifically, the Principles require that personal information:
a) Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met,
b) Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,
c) Shall be adequate, relevant and not excessive in relation to those purpose(s)
d) Shall be accurate and, where necessary, kept up to date,
e) Shall not be kept for longer than is necessary
f) Shall be processed in accordance with the rights of data subjects under the Act,
g) Shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information,
h) Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of Individuals/Service Users in relation to the processing of personal information.
Glos Folk will, through appropriate management and strict application of criteria and controls:
• Observe fully conditions regarding the fair collection and use of information
• Meet its legal obligations to specify the purposes for which information is used
• Collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to comply with any legal requirements
• Ensure the quality of information used
• Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include:
o The right to be informed that processing is being undertaken,
o The right of access to one’s personal information
o The right to prevent processing in certain circumstances and
o The right to correct, rectify, block or erase information which is regarded as wrong information
• Take appropriate technical and organisational security measures to safeguard personal information
• Ensure that personal information is not transferred abroad without suitable safeguards
• Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information
• Set out clear procedures for responding to requests for information
4. Data collection
Informed consent is when
• An Individual/Service User clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data
• And then gives their consent.
Glos Folk will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form.
When collecting data, Glos Folk will ensure that the Individual/Service User:
a) Clearly understands why the information is needed
b) Understands what it will be used for and what the consequences are should the Individual/Service User decide not to give consent to processing
c) As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed
d) Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress
e) Has received sufficient information on why their data is needed and how it will be used
5. Data Storage
Information and records relating to service users will be stored securely and will only be accessible to authorised persons.
Information will be stored for only as long as it is needed or required by statute and will be disposed of appropriately.
It is Glos Folk’s responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.
6. Data access and accuracy
All Individuals/Service Users have the right to access the information Glos Folk holds about them. Glos Folk will also take reasonable steps ensure that this information is kept up to date by asking data subjects whether there have been any changes.
In addition, Glos Folk will ensure that:
• It has a Data Protection Officer (appointed at the Annual General Meeting) with specific responsibility for ensuring compliance with Data Protection
• Everyone processing personal information understands that they are contractually responsible for following good data protection practice
• Everyone processing personal information is appropriately trained to do so
• Everyone processing personal information is appropriately supervised
• Anybody wanting to make enquiries about handling personal information knows what to do
• It deals promptly and courteously with any enquiries about handling personal information
• It describes clearly how it handles personal information
• It will regularly review and audit the ways it holds, manages and uses personal information
• It regularly assesses and evaluates its methods and performance in relation to handling personal information
• All officers and members are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them
This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998. This review will take place at the Annual General Meeting.
In case of any queries or questions in relation to this policy please contact the Glos Folk Data Protection Officer:
Peter Cripps (firstname.lastname@example.org) Tel: 01452780401
Equal Opportunities & Diversity Policy
1.1 For the purposes of this document, we use the following definitions:
- Prejudice - a belief, opinion or assumption formed beforehand without sufficient information or from misinformation, resulting in an unfavourable view about a person or group of people;
- Discrimination – Prejudice plus an action (or omission to act). Direct discrimination is where a person is treated less favourably than another in similar circumstances; indirect discrimination is where an unjustifiable provision, criterion or practice applies equally but where such application disadvantages a particular group;
- Oppression – Discrimination plus power;
- Positive Action – Taking steps to allow an under represented group, or group which has historically had less access to particular employment/services, to operate on a more level playing field. Positive Action is legal in this country.
- Positive Discrimination – Employing an individual purely on grounds of their membership of a particular group. This is generally unlawful in this country, but note that where a Genuine Occupational Qualification (GOP) applies, this is not unlawful;
- Victimisation – Where a person is treated less favourably as a result of their making a complaint or supporting someone who has made or intends to or is suspected of making a complaint of discrimination;
- Harassment – is a form of discrimination and involves unwanted or unwelcome physical or verbal attention of a sexual/racist/homophobic or other discriminatory nature, which is found to be offensive or objectionable to the recipient, and which creates a hostile or intimidating environment.
2 Why this policy is needed
2.1 Glos Folk recognises that in this society, groups and individuals have been and continue to be oppressed and discriminated against on the grounds of their identity and/or membership of particular groups. Such inequality includes discrimination on grounds of race, nationality, physical or mental impairment, age, class, ethnic or cultural origins, HIV status, gender, sexual orientation, religious beliefs (or absence thereof), responsibility for dependents, learning difficulty, etc. This is not an exhaustive list. We also recognise that people often face simultaneous or multiple oppression.
2.2 Glos Folk acknowledges that discrimination operates through a number of commonly held assumptions and prejudices, and customs, which can result in institutional discrimination in addition to personal prejudice.
2.3 This policy underpins all other policies of Glos Folk. Where another policy is in conflict with the Equal Opportunities & Diversity Policy, the Equal Opportunities Policy shall prevail.
The Legal Framework
3.1 Glos Folk strives to ensure that it complies with its legal obligations under The Equal Pay Act 1970, Sex Discrimination Act 1975, Race Relations Act 1976, Disability Discrimination Act 1995, Human Rights Act 1998, Employment Equality (Sexual Orientation) Regulations 2003, Race Relations (Amendment) Act 2000, Parental Leave Directive, Equal Treatment Directive 2000, Employment Equality (Religion or Belief) Regulations 2003, Employment Rights Act 1996, Gender Recognition Act 2005, and Protection from Harassment Act 1997.
3.2 Glos Folk recognises that legislation is constantly being updated and amended and is therefore not static. We are committed to keeping up to date and complying with the same.
3.3 Glos Folk further recognises that existing law does not offer protection to all groups who may experience discrimination. This policy is intended to offer that additional protection in as far as is possible.
3.4 Vicarious Liability – Glos Folk understands that it is held responsible for the acts of its members except where it has taken active steps to prevent this.
4 Employment and Training
4.1 Glos Folk will not discriminate in its recruitment, training, promotion and other employment practices and will take positive action where necessary, including in the recruitment and retention of committee members, members, and volunteers.
Service Delivery and Implementation
5.1 Glos Folk recognises that the basic argument for an equal opportunities policy is one of access to services and contribution to their development and change. Each individual should have the opportunity to use Glos Folk’s services in relation to their need, provided that this use does not impinge unduly upon other users or local residents, does not unduly exclude people on any of the grounds listed in this policy; and that such use does not sanction discrimination on any of these aforementioned grounds.
6. Marketing, Publicity And Public Liaison
5.1 All external communications, including advertising, will reflect a commitment to equal opportunities and will promote equality of access to Glos Folk’s services,
7. Glos Folk Environment
7.1 Glos Folk aims to ensure that all people will receive a positive welcome from their first point of contact with the organisation and to create and sustain an environment in which people using our services and paid workers and volunteers feel comfortable, free from oppressive attitudes and surroundings, and not exposed to racial or sexual harassment; or to stereotyped attitudes and beliefs.
7.2 Glos Folk aims to create a climate of communication which reflects the aspirations of different linguistic and cultural groups and to facilitate communication between them by the provision of aids to communication and appropriate resources and equipment.
8 Responsibility for Implementation
8.1 Overall monitoring responsibility for this policy rests with the Committee, members will take day to day responsibility for its implementation.
8.2 Glos Folk believes that passive policies are inadequate and ineffective in combating discrimination and will positively seek to ensure that groups and individuals referred to in this policy are not disadvantaged in the composition of the management committee, in the provision of services, or in recruitment practices.
9. Monitoring And Evaluation
9.1 Glos Folk will keep statistical and other information on employment and service use to ensure that our services are anti-discriminatory and are made as accessible as possible to under-represented groups. Such information will be used to inform and develop future planning.
9.2 Glos Folk will review this policy annually and make amendments and set targets as a result. This will be an item on the Agenda at each AGM.
Date revised: 29.10.2008
Prepared by: Peter Cripps
Issue Number: 01
Appendix 1: Glos Folk Equal Opportunities Procedures
- Employment and Training
1.1 This section should be read in conjunction with Glos Folk’s other policies..
1.2 In advertising for vacancies, Glos Folk will ensure as far as is possible that all posts will be advertised in accordance with good equal opportunities practice, including advertising in a variety of press. Advertisements will include a summary of the person specification, details of hours and pay, whether training shall be given, and whether any positive action has been identified.
1.3 All jobs shall be open to job share or considered for flexible working hours where appropriate.
1.4 Training and development will be available to all members to ensure equal participation in the organisation’s service delivery.
Service Delivery and Implementation
- 1 All Adult members and members of Glos Folk Committee must be aware of the organisation’s commitment to equal opportunities and should be familiar with the contents of this policy document.
- 2 In order to ensure that its services are accessible to all, a service guide will be made available
2.3 Glos Folk will aim to use buildings accessible to people with disabilities..
2.4 Glos Folk aims to make provision for a broad and balanced range of integrated services which take into account the varying needs of different individuals and user groups. This will be reflected in the planning, provision, development and evaluation of services.
2.5 All members will take appropriate steps to identify the unmet needs of groups of people who are under-represented in Glos Folk, and will strive to plan services to meet those needs in ways that are sensitive to all sections of the community.
2.6 In order to promote equality of access, committee members will ensure that the organisation’s services are well publicised. Publicity will include statements about the Glos Folk Equal Opportunities & Diversity Policy and complaints procedures, and descriptions of provision for different needs;
2.7 Publicity will be targeted and terms of content, language and distribution as appropriate;
2.8 Adult members and the Glos Folk Committee will expected to deal sensitively and effectively with the tension that may arise from the integration of different groups of people using Glos Folk services;
2.9 Adult Members and Officers will record, and report to the Committee when appropriate, on the uptake of Glos Folk services by specific groups of people in order to monitor trends of usage and to inform the service planning process.
3. Marketing, Publicity And Public Liaison
3.1 Glos Folk will ensure that no information or resource materials distributed contain images, language or attitudes which are offensive or challenging to disabled people, or are racist, ageist, homophobic, or sexist.
4 Use of Contractors and Outside Experts
4.1 All contractors and outside experts must sign up to, and adhere to, this policy.
5. Grievances And Breaches Of Equal Opportunities
5.1 Any Adult Member, or member of the Committee or service user who feels that they have been discriminated against should raise the matter under the grievance procedure or complaints procedure.
5.2 Where an individual or user group behaves in such a manner as to be in contravention of the spirit of this policy, Glos Folk will exclude such individual(s)/group from using its services and ask them to leave the premises immediately.
Equal Opportunities Code Of Conduct
For Members, Paid Staff, Volunteers And Building Users
Everyone using Glos Folk services will be treated with dignity and respect and will be expected to reciprocate.
- Everyone’s feelings will be valued. Offensive behaviour, language or humour will not be tolerated.
- The Committee, and Adult Members of Glos Folk are committed to ensuring that the Equal Opportunities Policy is effective and is implemented through a plan of action, including monitoring procedures. This policy will be brought to the attention of all our members.
Glos Folk Child & Vulnerable Adult Protection Policy
Glos Folk believes that the safety of children, young people, and vulnerable adults is paramount on all occasions. Glos Folk will take all reasonable steps to ensure the safety of all children,young people, and vulnerable adults involved in the activities of Glos Folk.
Glos Folk is committed to protecting children, young people, and vulnerable adults from the following:
- Emotional distress
Exposure to inappropriate
Glos Folk is committed to ensuring all possible situations in which children, young people, and vulnerable adults are involved with them are risk assessed to ascertain the level of risk involved. Glos Folk will endeavour to establish suitable control measures to reduce risks to acceptable levels. All members of Glos Folk have a responsibility to be aware of this policy, any risk assessments and control measures in place in any situation in which children, young people, and vulnerable adults are involved.
This child protection policy will be available for all participants and interested parties for inspection.
Protecting children from harm and abuse.
Venues will have
- Adequate heating, lighting and ventilation
- Access to toilets and running water
- Clearly labelled exits and fire exits
- A No Smoking policy during all Glos Folk events that involve children, young people, and vulnerable adults
- Appropriate safety glass, handrails and non-slip floors
- Suitable levels of adult supervision at all times
- Suitable furniture for the age of the young people present.
- Clear arrangements around young people leaving the building
Age guidelines will be defined for all activities
- Each activity will have an agreed maximum number of children
- Glos Folk seeks to encourage children, young people, and vulnerable adults of all levels of ability to join in their activities in a safe manner
People working with children, young people, and vulnerable adults will not be under the influence of alcohol or drugs
- Glos Folk will ensure that arrangements for dealing with minor first aid needs and more major injuries are clear to all members of Glos Folk
- No single adult will be left in charge of children
- No child under 8 will be left alone at any time; children under the age of 10 should not be left alone except in using the toilet.
- Child will not be allowed to leave the event without the express permission of a parent.
- All members of Glos Folk will be aware that unnecessary touching of young people is inappropriate.
- All those working with children, young people, and vulnerable adults will be briefed on the child & vulnerable adult protection policy
Behaviour management of children
Corporal sanctions (smacking, slapping, shaking) are not acceptable in any circumstances
- Sanctions that threaten, frighten or humiliate children, young people, and vulnerable adults are not acceptable
- Bullying or threatening behaviour between children will not be tolerated
- Glos Folk will not accept disruptive or unruly behaviour from any child, which spoils the enjoyment of others.
- Decisions regarding the behaviour management of children regularly involved in Glos Folk activities will be discussed at ‘notices’ and a consensus reached.
Protection from sexual abuse
Glos Folk is totally committed to protecting young people of all ages from sexual abuse by any adult.
- No single adult will be left in charge of children.
- If any person reports any incident of inappropriate or unacceptable behaviour towards any child Glos Folk is committed to taking immediate and appropriate action to ensure the safety of any children present and, if the behaviour warrants it, to report the matter to the authorities.
- Glos Folk will try to be aware of the members who have had a CRB clearance in the preceding three years. Glos Folk will endeavour to ensure that one CRB cleared member is present at all activities when children, young people, and vulnerable adults are involved.
Protection from inappropriate behaviour, language and materials
- All members of Glos Folk will refrain from the use of swear words, lewd actions or making inappropriate references to sexual or illegal activities.
- All members will avoid racist and sexist attitudes and comments.
- When children, young people, and vulnerable adults are involved in any Glos Folk activity the use of sarcasm or overt criticism directed at children will be avoided.
Review and monitoring of this policy
An item ‘Child & Vulnerable Adult Protection policy’ will be added to the agenda of the Glos Folk AGM each year, to allow a review and discussion of the working of this policy if needed and for changes to be made to it.
An officer of Glos Folk will be appointed as ‘Child & Vulnerable Adult Protection Officer’ by the Committee each year with the responsibility of reviewing the policy and recommending changes in the light of legislation, developing good practice, and experience.
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