Policies.

General Data Protection Regulations 

Overview

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?

The data

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 secretary@tdgr.org.uk

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 (secretary@tdgr.org.uk) or webmaster (admin@tdgr.org.uk).

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. (secretary@tdgr.org.uk)

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

About this cookie policy

What are cookies ?

How do we use cookies ?

What types of cookies do we use ?

How can I control the cookie preferences ?

Checked as all still correct March 2024. MS

Safeguarding Outline

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

Online Ringing

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

Summary

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

Truro Diocesan Guild of Ringers Membership Code of Conduct

Code of Conduct TDGR 2023 pdf

1. Purpose

1.1 A document to be used to formalise the processes the Guild can use to resolve issues, conflicts or breaches rules to enable it, and it’s membership to carry out the ‘Object’ and ‘Powers’ of the Guild

• Encouraging members to ring for services and on other appropriate occasions;
• Promoting good fellowship amongst ringers of all traditions;
• Supporting bands in the recruitment, retention and training of ringers;
• Helping members to achieve a high standard of ringing;
• Promoting the installation, augmentation, care and restoration of rings of bells and their fittings; and
• Furthering an appreciation of bells and bell ringing amongst the general public.

2. Application

2.1 This code will apply to all members of the Guild and relates to their conduct and behaviour whilst acting in a Guild member capacity.

2.2 The Code does not relate to standards of ringing other than with respect to members’ safety.

2.3 The Code will act as a reference in circumstances where the conduct of a member raises concerns and the potential application of some kind of response from the Guild; for instance informal or formal encouragement for improvement or temporary or permanent exclusion from membership or removal from office.

2.4 Any issue associated with safeguarding must be undertaken in accordance with relevant safeguarding procedures of the Church of England. Issues referred to the Guild will be taken up with the Diocesan Safeguarding Officer.

2.5 Members are obliged to follow Canon Law when entering a church and as such the ultimate jurisdiction is that of the incumbent and churchwardens.

3. Principles

3.1 Members are expected to support the object of the Guild and its powers and not actively undermine or subvert any of those values. Nevertheless, it is recognised that Guild values should be subject to scrutiny in a manner consistent with Guild rules and this Code of Conduct.

3.2 The Guild considers that good relations between members will assist the Guild to meet its aspirations.

3.3 The Guild recognises that disagreements will occur from time to time and that such dissonance can often be positive, aid communication and help the Guild make progress toward fulfilling its objectives. However, the Guild expects its members to manage such disagreement in a respectful manner for instance through the criticism of ideas rather than individuals.

3.4 The Guild is particularly concerned to ensure that high standards of conduct, as set out in this code, are maintained by members in all environments including social media.

4. Expected standard of conduct and behaviour

4.1 The Guild expects its members to maintain the following standards:

• To act lawfully at all times when undertaking activities as Guild members.
• To support the objectives and rules of the Truro Diocesan Guild of Ringers (TDGR) or, if a member feels they can be improved upon, constructively suggest changes to them in accordance with Guild rules.
• To ring in a safe and responsible manner, following both Guild and Church Health and Safety requirements.
• To be hospitable and welcoming to others at any event associated with Guild ringing.
• To promote good fellowship amongst bell-ringers and those with whom they interact, for instance church incumbents and officials and residents who hear bells being rung.
• Not to bully, intimidate or harass others and to report or condemn such behaviour if ever witnessed.
• To abide by, and uphold, legislation and formal guidance provided by, or adopted by, the Guild. In particular that relating to;
  • Safeguarding
  • Health and Safety
  • Data Protection
  • Discrimination
  • Social media use

5. Misconduct, Process and Application of Sanctions

5.1 The aim of the Code of Conduct is to foster good conduct and therefore sanctions applied should serve to encourage and support in the first instance rather than condemn.

5.2 Misconduct is defined as a breach of any of the ‘Expected standard of conduct and behaviour’ outlined in Section 4 above or breach of Guild rules.  Gross misconduct is defined as misconduct so serious as to fundamentally break the relationship between member and Guild. Examples include; perpetrating a criminal offence associated with Guild activities, serious and clear disregard for Guild rules on safeguarding and health and safety, clearly and unambiguously acting in such a way as to directly and seriously damage the Guild’s reputation or assets.

5.3  The following sanctions may be applied according to the severity and frequency of misconduct;

• A written warning for first misconduct or series of minor misconducts that work against the Guild objectives and/or doing damage to the reputation or assets of the Guild. To stay in effect for 1 year.
• Permanent withdrawal of membership and/or Office for continued behaviour that is clearly contrary to the interests of the Guild. The original decision for the permanent withdrawal of membership will be subject to a three year review by the Guild.  In cases where ‘withdrawal’ is lifted, re-election to membership is required.
• Any other sanction deemed fair and proportionate by the Standing Committee.

5.4 The following sanction may be applied in cases of gross misconduct:

• Permanent withdrawal of membership and/or Office for gross misconduct (including a first instance). Any permanent withdrawal of membership will be subject to a three year review by the Guild.  In cases where ‘withdrawal’ is lifted, re-election to membership is required.

5.5 The following processes will be followed in the event of a reported breach of this code;

• The President, Secretary or Safeguarding Officer must receive a letter of complaint or allegation in writing.
• Three members of the TDGR to be appointed by the President (but not including the President) to consider allegations of misconduct. The President should appoint persons that are independent of the situation and person concerned.  Normally one member of this inquiry group should be from the same district of the Guild as that of the member under scrutiny. One of the three to be appointed Chair.
• Both the group and respondent can seek legal advice.
• The group may seek the involvement of others such as the Diocese or Police.
• For matters that are unlikely to lead to a permanent withdrawal of membership:
  • The inquiry group is free to adopt whatever approach it thinks fit within the Guild rules, this Code of Conduct and the rules of natural justice.  For instance to avoid the unnecessary embarrassment of the person under scrutiny it may be deemed better that one member of the group be assigned to collect evidence and in particular to speak with the member. The subject will have the right to speak to the three members together if he/she so wishes but normally the process, unless serious, should be conducted in as informal and friendly way as possible.
  • At all times the member will be accorded the right to be accompanied by another member.
  • If, after consideration by the group, the sanction is to be a written warning the decision may be given directly, a letter drafted by the inquiry group and passed to the member within 7 days and the matter closed.  The Standing Committee will be advised of the outcome.
• If it becomes apparent to the group (at any stage) that the allegations could lead to a permanent withdrawal of membership then the inquiry group will adopt a more formal approach:
  • The group will hear evidence from:
    • The claimant and circumstances of the complaint.
    • Any other members or in some cases non-members.
  • Written statements and evidence will be collected and a copy provided to the respondent subject to the claim.  The group will invite the respondent to make his or her representations at a hearing.  At least 2 weeks-notice of the hearing will be given.
  • The respondent may only be accompanied at the hearing by another member.
  • In the respondent’s absence the hearing may still proceed.
• If, after consideration by the inquiry group, the recommended sanction is more severe than a written warning, the Standing Committee will be advised and a two-thirds majority of the Standing Committee will be required for any imposition of the recommended sanction.   They may also substitute a different sanction (or no sanction) from that recommended by the inquiry group.
• The complainant and respondent subject to the complaint will be informed of the outcome in writing.
• In all cases where a sanction is applied, the member in question shall have the right of appeal. Appeals must be lodged with the President within fourteen days of receipt of the sanction applied.
• Appeals will be heard by an Appeals Panel normally with two months of receipt of an appeal. The President will chair such an appeal with two further trustees of the Guild not previously involved in the case appointed by the President. Appeals panel members will not be members of the same district as the member in question.
• The outcome of the appeal will be communicated to the member in question as soon as is reasonably possible. No further appeal will be allowed.
• In the event that the President is the subject of misconduct all appointments, notifications and decisions made by the President will be delegated to the Guild Secretary.

6. Acknowledgement

6.1 The Guild acknowledges reference to the ANZAB Tower Stewardship Handbook 2007 (compiled by Christopher O’ Mahony) and the Lincolnshire Diocesan Guild Code of Conduct (authored by Chris Sharp).

Equality, Diversity & Dignity Policy

This policy applies to all members of The Truro Diocesan Guild of Ringers (TDGR) and covers all aspects of Guild activities, including meetings, events, communications, and interactions with fellow members and the wider community. The TDGR Standing Committee and officers have overall responsibility for implementing and monitoring this policy. All members have a responsibility to respect and comply with the policy, promoting equality and diversity in their actions and behaviour.

Equality

The TDGRis committed to the principles of equal opportunity, fairness and dignity to its membership and believes that every member, volunteer and visitors has the right to equal opportunities. Direct or indirect discrimination against any person on the grounds of the following protected characteristics, as defined in the Equality Act 2010, will not be tolerated:

�  Age

�  Disability

�  Gender Reassignment

�  Marriage/Civil Partnership

�  Pregnancy/Maternity

�  Race

�  Religion/Belief

�  Sex

�  Sexual Orientation

It is the responsibility of all members in their daily actions, decisions and behaviour to endeavour to promote these concepts, to comply with all relevant legislation and to ensure that they do not discriminate against members, volunteers or visitors.

Diversity

The TDGRis committed to valuing diversity and seeks to provide all members with the opportunity of personal development in towers on the basis of ability, experience and suitability, in additional to their potential for future development in their ringing.

Dignity

The TDGR aims to create a ringing environment in which members, associates and visitors are treated with respect, in a manner that allows them to maintain their dignity at all times and where there is zero tolerance of harassment and bullying.

Bullying and harassment includes any unwanted conduct related to protected characteristics, such as offensive comments, gestures, or jokes, which creates an intimidating, hostile, or degrading environment.

The TDGRoperates a zero tolerance to bullying and/or harassment and therefore any behaviour that falls into these categories will be investigated and could result in action being taken in accordance with our Code of Conduct.

The TDGR will provide training and guidance to members to promote equality and diversity awareness. Training can also be provided to raise awareness of unconscious bias and to develop skills in promoting inclusive practices.

Any incidents of discrimination or harassment should be reported to the TDGR Committee or

designated person. All complaints will be taken seriously and treated in confidence. The TDGR will investigate complaints promptly, impartially, and in accordance with its procedures.

Review

This policy will be reviewed regularly to ensure its ongoing suitability and effectiveness. Any necessary changes will be made, and all members will be informed of the updated policy.

Revision 1 – 03/07/2023

Jo Tolinson – Guild Public Relations Officer

Owen Borlase – Guild President

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.

FEES AND SUBSCRIPTIONS    

Annual Subscription: Adult                                                   £5.00

Annual Subscription: Associate                                           £5.00

Annual Subscription: Minor                                                  FREE

Non Resident Life Member                                                   £5.00

Lapel Badges (see “Available from Guild Secretary”)        £2.00