- Consent Privacy Notice
- Data Privacy Notice
- GDPR Lawful Basis
- Short Form Privacy Notice
- Safeguarding Outline
- Bell Restoration Fund Guidelines
THE TRURO DIOCESAN GUILD OF RINGERS
Consent Privacy Notice
The data controllers are the TDGR Trustees. Contact is via the Guild Secretary who can be contacted via email@example.com
Personal data collected:
For Tower Captains and Secretaries:
Your name, role in the Guild, address, email address and telephone number is collected to display them on the Guild web site in order to enable contact to be made by Guild members who will have logged in to see your data.
Your email address may be stored in the background of the Contact Form to enable contact to be made anonymously. Your data will not be disclosed in this event.
For Guild Officers and people with a significant role within the Guild:
Your name, role in the Guild, email address and telephone number may be published on a publicly available page.
For those attending Guild Webinars:
Where you have been recorded on one of the Sunday evening or other webinar type events.. To join these events, using Zoom Videoconferencing, 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 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.
For those appearing in our Magazines, either An Clogh or The Westerner:
Where your name, age, tower and occasionally contact details, and your image, and personal details depending on the article, will be published as part of the magazine.
(Your data included in the magazines for journalistic purposes may not be able to be removed at a later date.)
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.
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 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 18/8/21 MCS
DATA PRIVACY NOTICE
DATA PRIVACY NOTICE 2020
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 – this is information which you give us which identifies you.
- The Data Controllers are – the trustees of the Guild who identify and require personal data to be provided to them. They may be contacted through the Guild Secretary, Hayley Young firstname.lastname@example.org
- The data processors are – the Guild Secretary who holds the paper returns, the district secretaries who help collect information and update the web site and your tower secretary who completes the return and updates the website. The moderators of the TDGR List which is our mail email facility is Jonatham Young and Martin Spittle. They have access to your names and email addresses. Martin Spittle (Guild webmaster), Bill Willis and Christiana Hancox (website admins), have access to all data provided by you to the Guild.
- What information do we collect? – We collect as little information as possible from you by way of the annual “tower returns” which your tower secretary completes. We collect your name under the tower(s) at which you ring. If you are a tower captain or tower contact/secretary we also collect your address and contact details. The same information is collected for those under 18. We ask for your email address and where given, add it to the TDGR-List as indicated on the “tower returns”. It is probable that tower returns will cease to be used in future and details will be recorded only on the website.
- What we do with your information (how we process it) – Although we collect very little of your personal information we comply with data protection regulations by keeping it up to date (annual basis as above), by restricting the number of persons who have access to it; by not sharing it with anyone except for the purposes for which it was provided and by protecting it from loss, misuse or accidental disclosure by using passwords and secure environments.
- What we use it for – we use it manage membership records, to maintain our accounts, banking, gift aid and to provide you with access to other members and tower/bell/ringing information.
- The TDGR-List – this is our mass email list to which you subscribe and may unsubscribe at will. It is not shared outside the Guild.
- The legal basis used to collect your data – the Guild relies on “legitimate interest”. A “legitimate interest assessment” has been completed.
- Sharing your data – we do not and will not share your data outside of the Guild.
- Your rights and your data – unless an exemption applies under the law you have the following rights with respect to your data:-
- you may request a copy of your personal data held by the Guild
- should you find your data to be inaccurate you may require us to amend it and/or not to use it until correction is agreed
- when the Guild has no need of your data it will be erased however, you may ask us to do this
- where you have provided your name and details as a tower contact/correspondent you may change your mind and ask us to withdraw this data
- you may object to the way we process your data
- you may complain to the office of the Information Commissioner (link on Guild website)
- to be told of any changes in the way we use your data before the change takes place
11. Point of Contact – in the first instance please contact the Guild Secretary – see above under para 2
8th June 2019 –
Reviewed 18/8/21 MCS
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 live nearest to the church under which they are listed as members.
TDGR is “managed” by 3 trustees, various officers with areas of individual responsibility or expertise 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 tower captain and secretary of every affiliated tower in the Guild. The names of every member, child and adults are also collected. It may be the intention to collect email addresses in future. The treasurer holds banking details of those who pay by standing order/direct debits or who gift aid their subscription.
Those who provide their contact details do so knowing that they will be available to any who access the TDGR website and will be reproduced each year until now in a paper Report and Year Book. All names are then listed in that paper report under the tower at which they ring and as far as I am aware, all names are given knowing that they will appear in the Report and Year book a copy of which is available to each tower. Names may be repeated in the report under different sections and that also applies to those who provide contact details.
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 else they may 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 the coming year. 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 or 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 childrens’ data but only their names. In future we can ensure that we record a parents’ permission although I would be surprised were verbal permission not secured now. They are only identifiable as children if one knows that the reason why their names have an asterisk. This will not happen in future and then they will not be identified anymore than any vulnerable adult. In the latter instance, as we do not require data about vulnerabilities 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
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
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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
One of the charitable aims of the Guild is promoting the installation, care, and restoration of rings of bells and their fittings. Since 1975 money has been raised to help any Parish within the Diocese with three or more bells hung for full circle ringing. The grant, along with practical support, aims to encourage Parishes with the restoration of bells so that they can be rung safely and easily. The trustees and members of the Standing Committee who administer the funds are aware that they are dealing with charitable money and have an obligation to see that it is spent wisely. They have therefore issued the following information:
GUIDELINES FOR APPLICANTS
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 £25,000 or less, net of recoverable VAT must be accompanied by a quotation from a bell hanger. Projects in excess of that sum must be accompanied by at least two quotations from bell hangers. (added 12/18)
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 faculty, 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. Grants may be released upon written confirmation to the BRO that the work has been completed to the satisfaction of the incumbent and PCC. 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)
Provision should be made for future regular maintenance.
Grant awards remain valid for two years and are subject to a satisfactory final inspection.
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.