GDPR Privacy Notice
General Data Protection Regulations (GDPR) Privacy Notice
MWSD-POL-12, November 2020
Mersey Weaver Scouts (MWS) collects and processes personal data relating to current and former Adult Volunteers, Helpers, Young Leaders and Youth Members ( Individuals). MWS is committed to being transparent about how it collects and processes the data and to meeting its data protection obligations. Mersey Weaver District Scout Council take the issue of privacy very seriously and we are committed to protecting and respecting our member’s privacy.
Who are we?
MWS, 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.)
Every year in June we hold an annual general meeting where members of the charity executive committee (our trustees), are elected, any parent of an Explorer Scout or member of the District Scout Council can nominate themselves to be elected at the AGM and every member of the District Scout Council has the right to attend the meeting.
Our offices are based at The Heath Technical & Business Park, Runcorn, Cheshire, WA7 4QX
Our Distirct 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, customers and funders.
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”).
How we gather personal information
The majority of the personal information we hold, is provided to us directly by yourself or by parents / legal guardian 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.
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 District itself may be running or attending.
- We use personal data for the following purposes:
- We collect personal and medical information for the protection of that person whilst in the care of the MWS
- To enable us 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 the Scout District
- 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.
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:
- We need to use the information to comply with our legal obligations
- We need to use the information to contact with you, regarding meetings, events, collection of membership fee’s etc, (i.e. for the day to day running of the district)
- 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.
- The processing is necessary for the persons legitimate interests or the legitimate interests of our Scout District unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
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 the online membership system of The Scout Association, this system is used for the collection and storage of Adult personal data.
Online Scout Manager 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 District.
Office 365 this system is used for the storage and collection of other data used by volunteers e.g. meeting minutes, Nights away notifications etc
Red Cloud Donation Manager a system used to process donations and Gift Aid.
Virtual Private Server on Microsoft Azure we maintain our own private web server in the UK with Microsoft Azure to host all of our websites. Data collected through our websites such as membership enquiries, bookings, purchases from our shop are stored securely on encrypted cloud storage.
Printed records and Event data
Paper is still sometimes used within the sections to capture and retain some data for example the following:
- New joiners form.
- Gift Aid Collection forms.
- Events coordination with event organisers.
In the case of Joining forms & Event forms this information is securely held by the leader and transferred to our secure digital systems as soon as possible before the paper form is destroyed.
Gift Aid collection forms if not collected digitally. will be securely held by the District Treasurer to aid in the collection of Gift Aid for monthly membership fee’s, we have a legal obligation to retain this information for 7 years after our last claim.
As a member of MWS 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. Where possible we will collect this data digitally using encrypted forms but when paper is required, we will ensure:
- Transfer of paper is secure, such as physical hand to hand transfer or registered post.
- Paper forms are securely destroyed after use.
- Secure destruction will be through a shredding machine or securely burned.
- Always keeping the paper records secure, especially when in transit, by using:
- A lockable brief case, lock box or secured dry bag in a zipped pocket on your person.
- A lockable filing cabinet if long term stored.
- If transferred to somebody, we will audit that they return them when the event is complete
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 or digitally online.
We use captured CCTV footage and images at our activity centres so that we can perform our duty protecting both our vistitor’s and our property. We may use the footage to support third-party organisations such as The Police, Solicitors and Insurance companies who may request data in support of Criminal or Civil action. All footage is either stored on a password protected recorder in a locked cabinet or on our secure cloud storage on Office365.
Information we hold about you
During recruitment and during the time you are member of scouting in the District, we will process personal information, some of which may be sensitive personal information about you. The types of information that we process may include:
- Name, address, date of birth, gender and contact details, including email address and telephone number;
- Details of your qualifications, skills, experience and membership history including start and end dates in Scouting within MWS and also previous roles in Scouting in other Districts;
- Information relating to Disclosure Barring Vetting (DBS)
- Details of your bank account and national insurance number;
- Information about your marital status, next of kin, dependants and emergency contacts;
- Information regarding your nationality;
- Information regarding any criminal record;
- Details of disciplinaries or complaints in which you may have been involved, including warnings issued to you and related correspondence;
- Assessments of your performance, including role reviews, improvement plans and related correspondence;
- Information regarding medical or health conditions, including whether or not you have a disability for which MWS needs to make reasonable adjustments; and
- Equal opportunities monitoring information, including information about your ethnic origin, health and religion or belief
MWS collects this information in a variety of ways, for example data collected through the adult or young persons information form, information gathered during the interview and selection process; identity documents such as your passport, birth certificate, and driving licence; forms completed by you during your training and development, or through performance reviews, meetings or other assessments.
MWS may also collect personal data about you from third parties, such as references supplied by former Scout Groups/Districts/Counties, employers, referees, individuals etc.
We also monitor communications via Email, Messaging Platforms, Intranet and CCTV in line and accordance with MWS ICT policy available in the MWS Sharepoint System.
Using your information
We use your information to manage all aspects of your role in Scouting in the District and to meet MWS’s obligations, including, but not limited to, recruitment, obtaining the required level of clearance, travel and other reimbursable expenses, development, performance appraisal, health support, disciplinary and complaint processes and other administrative, management and people related processes. The information we collect is essential to administer your Scouting relationship with the District.
Any personal information you provide to us including, and similar to, your name, address, telephone number and e-mail address will not be released, sold, or rented to any entities or individuals outside of The Scout Association (UK)
In some cases, MWS needs to process data to ensure that it is complying with its legal and/or obligations under POR. For example, it is required to check an Individuals entitlement to lead an activity (e.g. Nights Away) and to comply with health and safety law.
In other cases, MWS has a legitimate interest in processing personal data before, during and after the end of the Scouting relationship. Processing Individuals data allows the organisation to:
- Manage recruitment and development processes;
- Manage and maintain appropriate Vetting information;
- Maintain accurate and up to date records and contact details, including details of who to contact in the event of an emergency.
- Provision you with access to appropriate MWS systems and the creation of an MWS email address.
- Operate and keep a record of disciplinary and complaints processes, to ensure acceptable conduct within MWS;
- Operate and keep a record of performance and related processes, to plan for leadership development, succession planning and resource management purposes;
- Ensure effective general administration within the District;
- Manage effective travel arrrangements and the reimbursement of expenses
- Provide references on request for current or former Individuals;
- Respond to and defend against legal claims;
- Maintain and promote equality in MWS.
Some special categories of personal data, such as information about health or medical conditions is processed to carry out legal obligations, such as those relating to Indvidual’s with disabilities.
With regard to making appointment decisions MWS does not rely on automated decision-making processes.
Your information may be shared, as is necessary, internally, within the District with your line manager, Senior Managers, the Technology Support Unit, District Executive members and other appropriate persons for the purposes set out above.
MWS shares your data with third parties in order to obtain pre-appointment references from others. It also shares your data with third parties that process data on its behalf in connection with Scouting nationally (e.g The Scout Association (UK), it’s insurance subsidiary “Unity”, Cheshire Scouts, Online Scout Manager)
MWS may also make information available to other key stakeholders e.g. regulatory authorities, governmental organisations and third parties if required by any regulatory or legal authority. We have the right to disclose any information we have concerning you if we are compelled to do so by a court of law or requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property.
If you move from MWS to another Scout District 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.
Transfers outside the UK
MWS will not transfer your personal information outside of the UK, with the exception 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.
Third Party Data Processors
MWS 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
- Microsoft Office355 Enterprise used for secure transfer & storage of personal information for events and administration.
- Microsoft Azure we maintain a virtual private server from which we process and store data related to our events, shop, bookings systems and membership enquiries.
We are committed to keeping your personal information secure and have physical, electronic and operational procedures in place to safeguard and secure the information we collect. All MWS members have a legal duty to respect the confidentiality of information, and access to confidential information is restricted to those who have a legitimate need to access it.
Where MWS engages third parties to process personal data on its behalf, they do so on the basis of written instructions confirming they are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data and comply with GDPR. MWS limits the transfer of data ensuring this is only carried out where there is a clear justification.
Retention of data
We will keep your information for as long as necessary to fulfil our legal obligations and in accordance with statutory retention periods.
We will retain your personal information, throughout the time you/your child(ren) are a member of MWS and its subsidaries.
We will retain your full personal information for a period of one year after you have left MWS and in a much more limited form (just name, badge and attendance records) for a period of upto 15 years (or until the age 21) to fulfil our legal obligations for insurance and legal claims.
We will also keep any Gift Aid Claim information for the statutory 7 years as required by HMRC (which may be beyond age 21)
In relation to CCTV footage, Your captured personal footage/image will be retained for a maximum of 31 days and deleted after 32 days unless archived in relation to a request by a third party. If a request for footage/image is made, this footage/image will be stored on a secure drive on our Office 365 platform for a minimum of 3 months then deleted if not used as evidence in support of Criminal or Civil action.
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 MWS.
- The right to access your personal data – you can ask us to share with you the data MWS holds 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 systems Online Scout Manager and Compass.
- 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 to 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.
What if you do not provide personal data?
Under your role in MWS you have certain obligations to provide MWS with data. In particular, you may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide MWS with data in order to meet other regulatory or POR requirements (e.g. reporting driving offences if certified to drive a minibus). Failing to provide the data may mean that you are in breach of Scouting’s POR or MWS local policies.
Certain information, such as contact detail, information to support DBS clearance, have to be provided to enable the MWS to appoint you as an Individual in the District. If you do not provide information, this will hinder MWS’s ability to appoint you, maintain your appointment or support you in your role in an efficient manner. In the extreme, the failure to provide certain information may prevent MWS from appointing you or maintaining your appointment with Scouting in the District.
To exercise all relevant rights, queries of complaints please in the first instance contact our District Chair, Mersey Weaver Scouts, The Heath Technical & Business Park, Runcorn, WA7 4QX or firstname.lastname@example.org
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.
Mersey Weaver District Scout Council is registered with the ICO