4th Epping Forest South (Bancroft’s School) Sea Scout Group Privacy policy

Last updated: 4th July 2020

This Data Privacy Notice/Policy describes the categories of personal data that the 4th EFS (Bancroft’s) Sea Scouts process and for what purposes. 4th Epping Forest South (Bancroft’s School) Sea Scout Group (referred herein as 4th EFS Sea Scouts) is a registered charity (1037676) in the UK.

4th EFS Sea Scouts 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 4th EFS (Bancroft’s) Sea Scouts.

In addition to the specific detail in this policy, we conform to the UK scouting Privacy and Data Protection Policy. This and other policies which govern scouting in the UK can also be accessed via the Scouting Policy, Organisation and Rules page.

GDPR roles

The Data Controller for 4th EFS Sea Scouts is the group Executive Committee who are appointed at an Annual General Meeting and are charity trustees

The data we may process

We hold information about each of our youth members and their parents or guardians in order to help us to ensure the safety and well-being of all scouts, including leaders and helpers.

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, via our OSM system or via our online membership system Compass.  In the case of adult members and volunteers, data may also be provided by third parties, such as Criminal Record Disclosure Services.

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, are able to participate in certain third party provide activities 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, carry out driver training and insurance.
  • Training records – so that members can track their progression through the Scout programme or adult training scheme.
  • 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.
  • Media in the form of photos, video, audio – for the purposes outlined in detail below for publicising what we do to existing, past and potential members and as part of our activities.

Medical information

Medical information about scouts is held in our OSM account and is used in order to ensure the safety and well-being of scouts during regular meetings and at other scouting events. During offsite events, medical information for scouts attending the event may be reproduced in electronic or paper form and held by leaders on site at the event or acting as home contact points. External copies are destroyed securely after the event completion.

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 and other media of our members via our membership forms. 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. More detail on our use of such media is provided below.

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
  • 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 4th EFS Sea Scouts
  • 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
  • to allow you to connect to our systems and to ensure that you have a legitimate right to do so.

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 4th EFS (Bancroft’s) Sea Scouts
  • to respect a person’s religious beliefs with regards to activities, food and holidays

Data Retention

Youth personal and medical information is held for a period of twelve months after a young person leaves the group.

Photographs and video which may contain images of youth members are retained indefinitely for the uses described below and as a historical record of the group’s activities. The Scout Association’s Data Protection Policy can be found here and the Data Privacy Notice here.

Sharing your information

Young people and other data subjects

We will normally only share personal information with adult volunteers holding an appointment in the 4th EFS Sea Scouts. We will share the personal data of youth members and their parents/guardians with The Scout Association Headquarters for the purpose of managing safeguarding cases. The privacy and security notice for The Scout Association can be found here: https://www.scouts.org.uk/DPPolicy.

The sharing of this data will be via the Online Scout Manager platform which is used by 4th EFS Sea Scouts to manage youth membership. The privacy and security notice for OSM can be found here: https://www.onlinescoutmanager.co.uk/security.html

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 4th EFS Sea Scouts 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 outside of 4th EFS Sea Scouts 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.  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 an activity or event is part of a larger activity or using facilities provided by a third party and medical information is required by third party providers in order for a young person to participate we will either provide the medical information provided to us or issue a separate consent or medical form is required by the provider.

In the event that we are informed by a parent or guardian or by another scout group that the young person is moving to a new section, we will pass the full scouting record, including health and medical information to the new section either within the OSM system or by electronic or paper copy.

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

Attendance and Achievement Record

During their time in the group, attendance and achievement data will be generated for the youth member and stored in OSM. This data will be used internally to allow us to run the program and award Scout badges.

We will also share this information with our sponsors, Bancroft’s School, to allow them to monitor levels of participation in scouting as part of their co-curricular coordination, and to allow scouting achievements to be added to school records and reports.

Anonymised attendance and achievement data will be transferred to the Scout Association as part of an annual census.

Anonymised attendance and achievement data will be transferred to the Royal Navy during the Biennial Review process which is part of the Royal Navy Sea Scout Recognition Scheme.

Safeguarding and child protection

In the event that we believe that there is a potential or actual safety or safeguarding issue relating to an individual youth member, in addition to following the prescribed scout safeguarding procedures then in force, we will collaborate with the child safety procedures at Bancroft’s school regardless of the nature or location of the event triggering us to identify a relevant issue. Copies of the scout safeguarding procedures under which we operate are available on the scout website or upon request.

Photography and video

During our regular meetings, and at external activities, still or video images may be taken by leaders and stored securely within the group’s Google G Suite storage.
Images may be used for one or more of the following purposes

  • Use on the 4th EFS Sea Scouts public Facebook page
  • Use on the 4th EFS Sea Scouts public website
  • Use on the 4th EFS Sea Scouts public Youtube channel
  • Use during online sessions via Google Meet, Teams, Zoom or other video conferencing platform which may include other scout groups or scout members
  • Use by the GLNE County, EFS District and UK scout organizations to promote scouting
  • Articles in Bancroft’s School publications (including Old Bancroftian’s publications
  • Display on internal Bancroft’s School (permanent and/or temporary) display boards
  • Display during Bancroft’s events to parents & pupils (including prospective parents & pupils
  • Display use during Scouting events, including the 4th EFS Annual General Meeting

Some of our activities, particularly those conducted online,  involve our youth members taking their own photos and videos of themselves and submitting them to us for use as part of a digital activity. Such images and media may include members of their family, including siblings. This privacy policy applies to all individuals who appear in submitted media and we will take submission of any media as consent to use according to this policy.

Non-family individuals should not be included in such media if possible, however it is the responsibility of parents/guardians to ensure that any individuals appearing in image and video are aware of this policy and have provided consent, if necessary.

In keeping with Scout safeguarding principles, individual scouts are not identified in associated captions or text without the consent of parents / guardians.

How media is protected, processed and stored within the 4th EFS Sea Scouts systems is also described by a media processing policy which is available upon request.

How we store your personal data

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 membership system of Online Youth Manager, this system is used for the collection and storage of youth member personal data.
  • Google GSuite – is the online document storage, email and online services platform used by 4th EFS (Bancroft’s) Sea Scouts for storing digital media, planning documentation, risk assessments etc.
  • Social media sites – as identified in the media section of this policy
  • Paper copies – as described within this document
  • GoCardless – a third party online payments system used in conjunction with Online Scout Manager to collect payments for events, camps and subscriptions.

In addition adult volunteers will hold some personal data and media on local storage for the purposes of processing, planning and executing some activities.

Printed records and data held while attending events – paper is sometimes used to capture and retain some data as outlined in this policy

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.

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.

Responsible use of our systems and cyber-bullying

Our youth members are provided with access to some of our tools, primarily but not limited to our Gsuite system. We also facilitate communication via email and social media. All cubs and scouts have an account on our Gsuite system, although this does not enable them to send or receive external emails and communications.

Some of the online collaboration tools that we use allow individuals within the 4thefsscouts.org.uk internet domain to communicate in with each other and should be used in a responsible and acceptable way.

We have a zero tolerance policy towards online bullying and any young person found using the tools inappropriately will be removed from the system immediately.

How we provide this privacy notice

A link to this website page is provided to those whose data is being processed by us.  A printed version is also available on request.

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 is 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
  • 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.

Website Cookies

This site is administered through our google system which may use cookies to remember preferences, remember you and to provide the functionality of the site.  This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience.

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 Stephen Young, our Group Scout Leader or our executive committee directly, contact details for which can be found in the leaders section of our website.