Other Guild Policies
- Data Privacy Notice
- GDPR Lawful Basis
- Consent Privacy Notice
- Short Form Privacy Notice
- Safeguarding Outline
- Bell Restoration Fund Guidelines
DATA PRIVACY NOTICE
We are providing this notice as required by the General Data Protection Act 2018. (“we/us/our” and “the Guild” are used interchangeably)
- 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 the data controller’s possession or likely to come into such possession. From the 25th May 2018 processing of personal data is governed by the General Data Protection Regulation (“GDPR”).
- Who are we?
The Truro Diocesan Guild of Ringers (‘TDGR) is a charitable & voluntary organisation working to the benefit of the bellringing community in the geographical area of the Truro Diocese. For the purposes of data protection we are a data controller (contact details below). This means we decide how your personal data is processed and for what purposes.
TDGR represents and supports ringers. For the avoidance of doubt bands are separate and distinct entities from the TDGR and any data processing activities they undertake are subject to the data privacy policies of their parochial church council.
- What personal data do we hold and how do we process it?
We aim only to collect and hold the information about you which is necessary for the purpose of running the Guild. This will include your, name, home address, phone number and email address together with the tower you ring at. This information is collected directly from you when you complete your yearly return to our membership secretary
We can use your personal data for the following purposes:
- To administer membership records and maintain our own accounts, records and gift aid claims.
- To publish a directory of officers of the guild.
- To provide to anyone who visits the website, an anonymous means of emailing tower contacts
- To provide a directory of names of ringers at each tower, details of the tower captain and secretary for members of the Guild.
- To promote good fellowship amongst ringers of all traditions including via An Clogh and The Westerner magazines available to members of the Guild.
- To organise and conduct training events.
- To promote the installation, augmentation, care and restoration of rings of bells and their fittings.
- To analyse visitors to our website. (IP address, which we cannot link back to the individual concerned)
- To administer the TDGR email list. (See below in Sharing your personal data.)
The TDGR complies with its obligations under 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.
- What is the legal basis for processing your personal data?
We have a legitimate interest in holding and processing information about you in order to conduct the necessary activities of a territorial bell ringing guild. You can see our Legitimate Interest Assessment on a separate tab on https://tdgr.org.uk/guild/policies/
Where we collect data that is outside of this legitimate interest, we will always request an additional optional consent. Circumstances where we do this include:
- We require an explicit consent of the data subject for ringers between age 13 and 18 and their parents for members under the age of 13 for the inclusion of their names on the website, and also to include any of their personal data in our magazines An Clogh and The Westerner.
- Where you have requested that your personal data be included in the publicly available areas of the website for contact purposes. (eg some tower captains have requested their telephone number be available publicly).
- Photographs to be posted in the publicly available areas of the website.
- Sharing your personal data
With the exception of HMRC with respect to claiming Gift Aid, TDGR does not share the personal information of individual members with third parties.
- How long do we keep your personal data?
We only keep data for as long as it is necessary for the purpose it was collected. We will only keep membership details for currently subscribed members. Unless you tell us specifically that you no longer wish to be a member your membership will lapse at the end of the first year in which you no longer pay your subscription fee (as defined by our constitution). This means it can take up to 12 months for data on lapsed members to be removed from our records
- Your rights and your personal data
You have the following rights with respect to your personal data:
- The right to request a copy of your personal data which the TDGR holds about you;
- The right to request that the TDGR corrects any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary for the TDGR to retain such data;
- The right to withdraw your consent to data processing at any time;
- The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data to request a restriction is placed on further processing;
- The right to object to the processing of personal data by the TDGR;
- The right to lodge a complaint with the Information Commissioners Office.
- Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy 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.
- Contact Details
To exercise all relevant rights, queries or complaints please in the first instance contact the Guild Secretary of the TDGR (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.
When someone visits our website we use a third party service to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow third parties to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Third party links
You might find links to third party websites on our websites. These websites should have their own privacy policies which we recommend you familiarise yourself with. We do not accept any responsibility or liability for these policies whatsoever as we have no control over them.
MCS & JW
General Data Protection Regulations
These regulations abbreviated to GDPR are in force now and have to be applied from 28.5.2018 when the 2 year implementation period ends. They will replace all previous data protection law. Their introduction was heavily championed in Europe by one of our MEPs. Very simply, they are designed to protect the individual’s interests in the legitimate use of any information collected by an organisation which is likely to identify that individual. Images are data.
At the “lowest” level of collection ie. data processing, are organisations such as TDGR because what we collect is extremely limited and it is shared in few and limited ways and in ways which I believe our members expect. An example of a more significant level are insurance companies who collect sensitive information and want to share it with those companies with whom they have commercial interests. We are all aware of the significant data breaches which have taken place in the recent past eg. Yahoo mail, Nat West bank
Without discussing the criteria, paragraph 14 of the ICO’s guidance on fines is clear that fines may be imposed on any data controller for any “serious contravention”. In this instance the trustees of the Guild are the data controllers and the web master and/or report editor are the processors assisted by district and tower secretaries. Needless to say, the controllers are responsible for the processors. Whether the Guild should underwrite incompetence and ignorance by its trustees is not a debate that should ever happen.
THE LEGAL BASIS FOR PROCESSING DATA
Article 6 GDPR provides 6 bases of equal value. A6(1)(a) and A6(1)(f) may be applied to TDGR viz. consent to data collection the uses of which must be clearly and individually consented to and “legitimate interest”. I have read A6 and many of the others; the ICO’s guidance on A6(1)(f) and A29 Data Protection Working Party Opinion 06/2014 on the notion of the legitimate interests of the data controller under Article 7 of Directive 95/46EC (adopted 9.4.2014).
I am of the opinion that TDGR may properly use A6(1)(f) as its lawful basis for collecting data. As required, and prior to drafting the “privacy notice” I will set out the process which led me to this opinion. If accepted by my fellow trustees (and perhaps adopted by standing committee – a matter for discussion by the trustees as data controllers) it demonstrates our accountability for our decision under the GDPR.
The Process – The Legitimate Interest Assessment (LIA)
A6(1)(f) “processing is necessary for the purposes of the legitimate interests pursued by the controller or third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where that subject is a child.”
Are we pursuing a legitimate interest, is the processing necessary for that purpose and do the individual’s interests override the legitimate interest?
TDGR is a church bell ringing guild composed of individuals members organised by tower allegiance. They ring church tower bells as a hobby and one which goes back some 400 years. There are no membership qualifications under the rules of the Guild however, in practice, members will be bell ringers who usually ring at the church under which they are listed as members.
TDGR is “managed” by various officers with areas of individual responsibility or expertise, who are usually also trustees, and a standing committee.
Each year TDGR collects the names, addresses, telephone numbers and email addresses of those persons listed above together with the officers of each of the 4 districts and the email address of every tower contact for any tower with members in the Guild. Those who provide their contact details do so knowing that they will be available to any who access the TDGR website. For tower contacts, your email address may be stored in the background of the Contact Form to enable contact to be made anonymously by anyone who visits the website. Your data will not be disclosed in this event.
The names and email addresses of every member are also collected. They are made available to all members who log in to the website, listed against the tower where they usually ring.
All details above have until recently been reproduced yearly in a paper Report and Year Book. In future they may be reproduced, with consent obtained in the annual return, in a Guild Directory, both in paper form and on the Guild Website.
The treasurer holds banking details of those who pay by standing order/direct debits or who gift aid their subscription.
Legitimate Interest – this must mean not so much the specific purpose for which we collect data but more, what benefit does TDGR gain or more widely, society.
The benefit(s) to the Guild as a whole and to the individual is that each knows how many ringers there are; what their names are; where they are based ie. the tower at which they ring; where officers are based; where ringers are “thin on the ground”; where young people are likely to be found and therefore welcome other young ringers; what ringing compositions they have been involved in and where; what towers are most used or active and many other very ringing specific information.
The Guild gains subscriptions which it uses to further the collective interest and to manage membership.
The wider public as well as the individual Guild member benefits because they can contact each other primarily to facilitate ringing or ringing interests. The wider public here are other ringers from all over the world but also the wider public who might search for any number of reasons. A lack of collection would result in ringers communicating the same information in an uncontrolled and haphazard way to the detriment of ringing and ringers.
Were this data not collected the benefits would be lost to the membership and the wider world of ringing which is a niche hobby of decreasing interest to the extent that the government has chosen to support it over recent years. That indicates a level of importance assigned by government in recognising the value ringing offers to the country as a whole.
As regards the additional data processed by the treasurer, gift aid is a national benefit which is designed to help charities and the electronic payments by some provide for certainty of payment and receipt not only for TDGR but are utilised by everyone with a bank account.
As described above, data use is neither unethical nor unlawful.
The necessity test – as described above, the collection or processing makes only the very minimum of personal information available and that of all the information collected only a few supply more than their name. As ringers enjoy and gain experience from ringing bells other than those upon which they have learnt to ring their interest amounts primarily to ease of communication with other ringers, towers and Guild officers. In my opinion there is no other way to go about it and only the barest detail is readily available to the wider ringing community which makes it unobtrusive. Additionally, this data is not actively shared other than by existing on the web site. It is certainly not shared for any marketing or commercial interest. Banking details are not shared and no one other than the treasurer has access to them.
The balancing test – At the risk of repetition, TDGR is a group of individuals, living in the same geographical area, sharing the same ancient hobby and interest in furthering their experience. The data collected is minimal and the individual knows what is collected and the use to which it is put and is available. To my knowledge, no one has ever objected. The reason why data processing is not based on “consent” is because of the logistics of gaining written consent from each ringer. Not every ringer rings each week, it cannot be acquired over the telephone or realistically by email and knowing our ringers, there are ` number of them who will object to signing consent whereas they have happily given it verbally every year often for many years. In this instance individuals would be alienated from a group which may have been an important part of their life for years. The adverse impact is not in my opinion in the collection but in not collecting and processing the minimal data.
Data available to the wider world including ringers could be further restricted in the event that all tower members are listed behind a member only tab on the web site which would be password protected.
We do process children’s data but only their names and age bracket to determine whether their consent or parent/guardian consent is required. They are only identifiable as children once posted on the website, if one knows that only their forenames are posted. Posting forenames only, serves to protect their identities further.
We do not require data about vulnerable adults so we cannot look at impact. The same opt out as now will continue hereafter viz. an individual can tell the person doing the initial processing that their name should not be included.
The ICO requires this LIA to be done; kept as part of our data controller responsibilities, to be reviewed and to form part of our privacy notice.
Annie Holland, TDGR President
December 20th. 2017 reviewed 8th June 2019
Revised 3rd December 2021 MCS Opinions expressed remain as written by Annie Holland.
THE TRURO DIOCESAN GUILD OF RINGERS
Consent Privacy Notice
The TDGR is a data controller. Its role is administered by the TDGR Trustees. Contact is via the Guild Secretary who can be contacted via email@example.com
Personal data collected where consent is the lawful basis;
For those whose data may be published in the public facing pages of the website.
Where there is not legitimate interest in your details being shared – e.g. you are not a Guild Officer, then for your name, age, address, telephone number, email address or image to appear on the website, we will apply ‘consent’ as the legal basis. Consent forms are available on the website, and from the secretary (firstname.lastname@example.org) or webmaster (email@example.com).
For those appearing in our Magazines, either An Clogh or The Westerner:
For children and young people under 18 years, your name, tower and occasionally contact details, and your image, and personal details depending on the article, may be published as part of the magazine. Specific consent forms will be available from the editors. For adults, inclusion of personal data in the magazine is considered to be covered by ‘legitimate interest’, as it encourages fellowship between ringers, one of the main objectives of the Guild.
(Your data included in the magazines for journalistic purposes may not be able to be removed at a later date.)
For those attending Guild Webinars:
Where you have been recorded on one of the Sunday evening or other webinar style events.. To join these events, using Zoom Video conferencing, you will have had the option to join the meeting with or without video. In recognition of the fact this is often an automatic action, at the start of the recording the GDPR slide pointing out the video etiquette and the fact a recording is being made will be shown and an explanation will be given, along with instructions and an offer of help, to switch off your video and mute your microphone if you have inadvertently clicked to join with video and sound. The recordings of these events are hosted on YouTube but they are not available via YouTube but only via the TDGR website. If you have not switched off your video or muted your microphone, a small image of you or recording of your voice may be displayed on the video that is available via the website.
Your data may be available to any who cares to access the web site however, beyond this TDGR does not share your information with any other person or party.
The legal basis for doing this rests upon you consenting to this.
You have the right to withdraw your consent at any time. Please advise the Guild Secretary. (firstname.lastname@example.org)
Your statutory rights are not affected by this notice namely
Your right to find out the data we hold about you
Your right to correct inaccuracies
Your right to have your data deleted
Your right to be forgotten
(Except occasionally with respect to the magazines)
You are not under any obligation to provide the data therefore there are no consequences should you choose not to do so.
Updated 3/12/21 MCS (webmaster)
TDGR – DATA PROTECTION
For members of the Guild
Short Form Privacy Notice – copy of full document has been sent to your tower secretary/contact.
The law requires us to provide this information and we want you to know that we consider that we have a “legitimate interest” in collecting the very small amount of data that we do.
We will not share your data outside of this Guild. It will be available to members who log into the website.
We use your data to manage the membership and to promote the objects of the Guild.
We will only contact you about Guild matters.
updated 18/8/21 MCS
What are cookies ?
As most of the online services, our website uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data.
The third-party cookies used on our website are mainly for understanding how the website performs, how you interact with our website, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.
What types of cookies do we use ?
Essential: Some cookies are essential for you to be able to experience the full functionality of our site. They allow us to maintain user sessions and prevent any security threats. They do not collect or store any personal information. For example, these cookies allow you to log-in to your account and add products to your basket, and checkout securely.
Statistics: These cookies store information like the number of visitors to the website, the number of unique visitors, which pages of the website have been visited, the source of the visit, etc. These data help us understand and analyze how well the website performs and where it needs improvement.
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Annual Subscription: Adult £5.00
Annual Subscription: Minor FREE
Non Resident Life Member £5.00
Lapel Badges (see “Available from Guild Secretary”) £2.00
Guild Report (free to resident members) £2.00 When available
In 2016 there were significant changes in respect of Child Protection and Vulnerable Adults. Some towers may still not be compliant. It is the responsibility of the Incumbent and the PCC to ensure safeguarding in their church activities. Ringers will obviously wish to be helpful in this regard, if only for their own protection.
Tower Captains will need to familiarise themselves with the Guidance & Procedures of both the Church and the Central Council (2019) (select the ‘Tower Operation’ tab) . Please note, these procedures are a requirement of the Church, supported by both the Diocese and Central Council so they must be followed
Perhaps the most significant change was that anyone involved in directly caring for and/or teaching a child (a child is anyone under the age of 18) will be required to be DBS checked, whether they are supervised or not. This applies also for transporting children as part of a formal arrangement, irrespective of frequency. The same rules apply with vulnerable adults. Visiting tutors are required to show their DBS but visiting groups are responsible for their own checks. Although it is nowhere clearly stated, the implication of this is that other than in a one-off situation the presence of a parent is not sufficient and all tutors (but not helpers) need to be DBS checked. This procedure is now supposed to be fairly quick online and is free for volunteers.
It is a requirement of the Church that responsible posts, such as Tower Captain, have a proper job description, are recruited via a Confidential Declaration of suitability, that references and DBS checks are requested as appropriate and that Safeguarding training (only half a day) be undertaken and updated every 3 years. A suggested job description is available on this site. “Role Descriptions.”
Safeguarding Guidance should be available in all towers (ie printed off and on the notice board or similar) and, where children are expected, a signed attendance register kept.
This may all sound rather onerous but I don’t think it needs to be. The most important issue that needs addressing now is for anyone involved (or potentially involved) in the direct teaching or care of young people should be DBS checked and undergo some basic training. Even where there are no young ringers at present it is still recommended that TCs and their Deputies be DBS checked now in order to cover any eventuality, including the fact that adult vulnerability is not always obvious.
For local arrangements and the training program go to: Diocesan Safeguarding Information
Link to Church of England Parish Safeguarding Handbook
Over the last year, online ringing has become far more popular as a result of the Covid-19 Lockdowns. It is believed by CCCBR that it will continue to be more popular than it was prior to Covid-19 and they have produced some Safeguarding advice for the online environment. Along with this is a Summary of Best Practice
Print off the Guidance from the CCCBR website and display it in the tower. Ask your Parish Safeguarding Officer to arrange any outstanding DBS checks, given the changes outlined above.
Where there are young ringers (or the potential for young ringers) the TC should book themselves in for Foundation & Leadership Training (now called CO (online) C1 and C2) if required.
Any ringer doing hands on teaching needs to be DBS checked, C0 and C1 trained and supervised by the Tower Captain.
Initiate a signed register (this may need a tactful introduction).
Liaise with PCC over job description and recruitment procedures.
Ensure Risk Assessment is displayed in tower and reviewed annually.
Any queries to Safeguarding Officer via safeguarding page contact form
TDGR Bell Restoration Fund Guidelines
Grants are awarded for work to bells, frames and fittings. Work to towers (except when linked to a bell project) is excluded.
Applications may be made for restoration work costing up to £75,000. Projects costing in excess of that figure may be considered on their merits. (added 12/18)
Applications for work costing in excess of £25,000, net of recoverable VAT must be accompanied by at least two quotations from bell hangers (added 3/21).
There is an expectation that projects costing less than £25,000 net will be accompanied by two quotations from bell hangers unless the value of the project is under £10,000 in which case one quotation is sufficient. Applicants unable to secure a second quote should contact the Guild Bell Restoration Officer before submitting the application.
The cost of professional fees (eg architect) is not grant eligible.
Other major grants, legacies and donations will be taken into account.
The Guild Bell Restoration Officer must be satisfied that the proposed work is necessary and will be the best solution.
The proposed work must be supported by the PCC. A Church Warden or Chairman of the PCC must sign the application form.
A Faculty or Rule B permissions, if necessary for the proposed work should have been, or will be, obtained.
Where the applicant proposes that their restoration project is carried out by a person(s) or firm of engineers or builders (the contractor(s)) who are not bell hangers and that project does not require either a Faculty or Rule B permissions, the grant form must be accompanied by a letter from the Incumbent or Chair of the PCC stating that the PCC is satisfied that the proposed contractor(s) is/are competent to carry out the work which is the subject of the grant application. For the avoidance of doubt, neither the BRO nor TDGR accept any responsibility for work which is not carried out by a recognised bell hanger and the latter are responsible for their work. (added 4.3.19)
Grants may be released upon written confirmation to the BRO that the work has been completed to the satisfaction of the Incumbent and PCC.
Provision should be made for future regular maintenance.
Grant awards remain valid for two years and are subject to a satisfactory final inspection. There is an expectation that on completion of the work the bells will be made available to occasional visiting ringers.
Initial enquiries should be made to the Bell Restoration Officer.
Initial enquiries should be made to the Bell Restoration Officer. Applications are considered by the Standing Committee which usually meets in January, June and November. Grants are paid directly to the PCC on satisfactory completion of the project.