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GDPR & Data Protection Policy

Safeguarding Policy

Equality and Diversity Statement

Project Constitution 





GDPR & Data Protection Policy



Last updated June 2023





Charity Turn The Tide (Charity number 1148141)
GDPR General Data Protection Regulation
Responsible Person Hugh Tessier (Treasurer)



1. Data protection principles



The Charity is committed to processing data in accordance with its responsibilities under the GDPR.



Article 5 of the GDPR requires that personal data shall be:



  1. processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”



2. General provisions



  1. This policy applies to all personal data processed by the Charity.
  2. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.
  3. This policy shall be reviewed at least annually.
  4. The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data.



3. Lawful, fair and transparent processing



  1. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
  2. The Register of Systems shall be reviewed at least annually.
  3. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.



4. Lawful purposes



  1. All data processed by the charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
  2. The Charity shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Charity’s systems.



5. Data minimisation



  1. The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  2. [Add considerations relevant to the Charity’s particular systems]



6. Accuracy



  1. The Charity shall take reasonable steps to ensure personal data is accurate.
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
  3. [Add considerations relevant to the Charity’s particular systems]



7. Archiving / removal



  1. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.



8. Security



  1. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
  3. When personal data is deleted this should be done safely such that the data is irrecoverable.
  4. Appropriate back-up and disaster recovery solutions shall be in place.



9. Breach



In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).








Turn The Tide – Safeguarding Policy






The purpose of this policy is to protect people, particularly children, at risk adults and beneficiaries of assistance, from any harm that may be caused due to their coming into contact with TURN THE TIDE. This includes harm arising from:



  • The conduct of staff or personnel associated with TURN THE TIDE
  • The design and implementation of TURN THE TIDE programmes and activities



The policy lays out the commitments made by TURN THE TIDE, and informs staff and associated personnel of their responsibilities in relation to safeguarding.



This policy does not cover:



  • Safeguarding concerns in the wider community not perpetrated by TURN THE TIDE or associated personnel



What is safeguarding?



In the UK, safeguarding means protecting peoples’ health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect1



In our sector, we understand it to mean protecting people, including children and at risk adults, from harm that arises from coming into contact with our staff or program’s.






  • All staff contracted by TURN THE TIDE
  • Associated personnel whilst engaged with work or visits related to TURN THE TIDE, including but not limited to the following: consultants; volunteers; contractors; programme visitors including journalists, celebrities and politicians



Policy Statement



TURN THE TIDE believes that everyone we come into contact with, regardless of age, gender identity, disability, sexual orientation or ethnic origin has the right to be protected from all forms of harm, abuse, neglect and exploitation. TURN THE TIDE will not tolerate abuse and exploitation by staff or associated personnel.



This policy will address the following areas of safeguarding [as appropriate]: child safeguarding, adult safeguarding, and protection from sexual exploitation and abuse.



TURN THE TIDE commits to addressing safeguarding throughout its work, through the three pillars of prevention, reporting and response.






TURN THE TIDE responsibilities






  • Ensure all staff have access to, are familiar with, and know their responsibilities within this policy
  • Design and undertake all its programs and activities in a way that protects people from any risk of harm that may arise from their coming into contact with TURN THE TIDE. This includes the way in which information about individuals in our programmes is gathered and communicated
  • Implement stringent safeguarding procedures when recruiting, managing and deploying staff and associated personnel
  • Ensure staff receive training on safeguarding at a level commensurate with their role in the organisation
  • Follow up on reports of safeguarding concerns promptly and according to due process



Staff responsibilities



Child safeguarding



TURN THE TIDE staff and associated personnel must not:



  • Engage in sexual activity with anyone under the age of 18
  • Sexually abuse or exploit children
  • Subject a child to physical, emotional or psychological abuse, or neglect
  • Engage in any commercially exploitative activities with children including child labour or trafficking



Adult safeguarding



TURN THE TIDE staff and associated personnel must not:



  • Sexually abuse or exploit at risk adults
  • Subject an at risk adult to physical, emotional or psychological abuse, or neglect



Protection from sexual exploitation and abuse



TURN THE TIDE staff and associated personnel must not:



  • Exchange money, employment, goods or services for sexual activity. This includes any exchange of assistance that is due to beneficiaries of assistance
  • Engage in any sexual relationships with beneficiaries of assistance, since they are based on inherently unequal power dynamics



Additionally, TURN THE TIDE staff and associated personnel are obliged to:



  • Contribute to creating and maintaining an environment that prevents safeguarding violations and promotes the implementation of the Safeguarding Policy
  • Report any concerns or suspicions regarding safeguarding violations by an TURN THE TIDE staff member or associated personnel to the appropriate staff member



Enabling reports



TURN THE TIDE will ensure that safe, appropriate, accessible means of reporting safeguarding concerns are made available to staff and the communities we work with.



TURN THE TIDE will also accept complaints from external sources such as members of the public, partners and official bodies.



How to report a safeguarding concern



Staff members who have a complaint or concern relating to safeguarding should report it immediately to their Safeguarding Focal Point Amanda King. If the staff member does not feel comfortable reporting to their Safeguarding Focal (for example if they feel that the report will not be taken seriously, or if that person is implicated in the concern) they may report to any other appropriate staff member.



Amanda King. Turn The Tide, Unit 6, Exchange Road, Stevenage, Hertfordshire, England, SG1 1PZ






TURN THE TIDE will follow up safeguarding reports and concerns according to legal and statutory obligations.



TURN THE TIDE will apply appropriate disciplinary measures to staff found in breach of policy.






It is essential that confidentiality in maintained at all stages of the process when dealing with safeguarding concerns. Information relating to the concern and subsequent case management should be shared on a need to know basis only, and should be kept secure at all times.



Safeguarding means:



Taking all reasonable steps to prevent harm, particularly sexual exploitation, abuse and harassment from occurring; to protect people, especially vulnerable adults and children, from that harm and to respond appropriately when harm does occur.



This definition draws from our values and principles and shapes our culture. It pays specific attention to preventing and responding to harm from any potential, actual or attempted abuse of power, trust, or vulnerability, especially for sexual purposes.



Safeguarding applies consistently and without exception across our programmes, partners and staff. It requires proactively identifying, preventing and guarding against all risks of harm, exploitation and abuse and having mature, accountable and transparent systems for response, reporting and learning when risks materialise. Those systems must be survivor-centred and also protect those accused until proven guilty. Safeguarding puts beneficiaries and affected persons at the centre of all we do.



him or herself, or unable to protect him or herself against significant harm or exploitation.



Dealing with Safeguarding Reports



Purpose and scope



The purpose of this document is to provide procedures for dealing with reports of breach of TURN THE TIDE Safeguarding Policy, where the safeguarding violation is:



  • Against staff or members of the public,
  • Perpetrated by staff, partners or associated personnel.






1. Report is received



1.1 Reports can reach the organisation through various routes. This may be in a structured format such as a letter, e-mail, text or message on social media. It may also be in the form of informal discussion or rumour. If a staff member hears something in an informal discussion or chat that they think is a safeguarding concern, they should report this to the appropriate staff member in their organisation.



1.2 If a safeguarding concern is disclosed directly to a member of staff, the person receiving the report should bear the following in mind:



• Listen



• Empathise with the person



• Ask who, when, where, what but not why



• Repeat/ check your understanding of the situation



• Report to the appropriate staff member (see below)



1.3 The person receiving the report should then document the following information, using an Incident Report Form if there is one:



• Name of person making report



• Name(s) of alleged survivor(s) of safeguarding incident(s) if different from above



• Name(s) of alleged perpetrator(s)



• Description of incident(s)



• Dates(s), times(s) and location(s) of incident



1.4 The person receiving the report should then forward this information to the Safeguarding Focal Point or appropriate staff member within 24 hours.



1.5 Due to the sensitive nature of safeguarding concerns, confidentiality must be maintained during all stages of the reporting process, and information shared on a limited ‘need to know’ basis only. This includes senior management who might otherwise be apprised of a serious incident.



1.6 If the reporting staff member is not satisfied that the organisation is appropriately addressing the report, they have a right to escalate the report, either up the management line, to the Board (or other governance structure), or to an external statutory body. The staff member will be protected against any negative repercussions as a result of this report.



2. Assess how to proceed with the report



2.1 Appoint a Decision Maker for handling this report



2.2 Determine whether it is possible to take this report forward



  • Does the reported incident(s) represent a breach of safeguarding policy?
  • Is there sufficient information to follow up this report?



2.3 If the reported incident does not represent a breach of TURN THE TIDE Policy, but represents a safeguarding risk to others (such as a child safeguarding incident), the report should be referred through the appropriate channels (e.g. local authorities) if it is safe to do so.



2.4 If there is insufficient information to follow up the report, and no way to ascertain this information (for example if the person making the report did not leave contact details), the report should be filed in case it can be of use in the future, and look at any wider lesson learning we can take forward.



2.5 If the report raises any concerns relating to children under the age of 18, seek expert advice immediately. If at any point in the process of responding to the report (for example during an investigation) it becomes apparent that anyone involved is a child under the age of 18, the Decision Maker should be immediately informed and should seek expert advice before proceeding.



2.6 If the decision is made to take the report forward, ensure that you have the relevant expertise and capacity to manage a safeguarding case. If you do not have this expertise in-house, seek immediate assistance, through external capacity if necessary.



2.7 Clarify what, how and with whom information will be shared relating to this case. Confidentiality should be maintained at all times, and information shared on a need-to-know



basis only. Decide which information needs to be shared with which stakeholder – information needs may be different.



2.8 Check your obligations on informing relevant bodies when you receive a safeguarding report. These include (but are not limited to):



• Funding organisations



• Umbrella bodies/networks



• Statutory bodies (such as the Charity Commission in the UK)



Some of these may require you to inform them when you receive a report; others may require information on completion of the case, or annual top-line information on cases. When submitting information to any of these bodies, think through the confidentiality implications very carefully.



3. Appoint roles and responsibilities for case management



3.1 If not already done so (see above), appoint a Decision Maker for the case. The Decision Maker should be a senior staff member, not implicated or involved in the case in any way.



3.2 If the report alleges a serious safeguarding violation, you may wish to hold a case conference. This should include:



• Decision Maker



• Person who received the report (such as the focal point, or manager)



• Safeguarding adviser (or equivalent) if there is one



The case conference should decide the next steps to take, including any protection concerns and support needs for the survivor and other stakeholders (see below).



4. Provide support to survivor where needed/requested



4.1 Provide appropriate support to survivor(s) of safeguarding incidents. Nb. this should be provided as a duty of care even if the report has not yet been investigated. Support could include (but it’s not limited to)



• Psychosocial care or counselling



• Medical assistance



• Protection or security assistance (for example being moved to a safe location)



4.2 All decision making on support should be led by the survivor.



5. Assess any protection or security risks to stakeholders



5.1 For reports relating to serious incidents: undertake an immediate risk assessment to determine whether there are any current or potential risks to any stakeholders involved in the case, and develop a mitigation plan if required.



5.2 Continue to update the risk assessment and plan on a regular basis throughout and after the case as required.



6. Decide on next steps



6.1 The Decision Maker decides the next steps. These could be (but are not limited to)



• No further action (for example if there is insufficient information to follow up, or the report refers to incidents outside the organisation’s remit)



• Investigation is required to gather further information



• Immediate disciplinary action if no further information needed



• Referral to relevant authorities



6.2 If the report concerns associated personnel (for example contractors, consultants or suppliers), the decision making process will be different. Although associated personnel are not staff members, we have a duty of care to protect anyone who comes into contact with any aspect of our programme from harm. We cannot follow disciplinary processes with individuals outside our organisation; however decisions may be made for example to terminate a contract with a supplier based on the actions of their staff.



6.3 If an investigation is required and the organisation does not have internal capacity, identify resources to conduct the investigation. Determine which budget this will be covered by.



7. Make decision on outcome of investigation report



7.1 The Decision Maker makes a decision based on the information provided in the investigation report. Decisions relating to the Subject of Concern should be made in accordance with existing policies and procedures for staff misconduct.



7.2 If at this or any stage in the process criminal activity is suspected, the case should be referred to the relevant authorities unless this may pose a risk to anyone involved in the case. In this case, the Decision Maker together with other senior staff will need to decide to decide how to proceed. This decision should be made bearing in mind a risk assessment of potential protection risks to all concerned, including the survivor and the Subject of Concern.



8. Conclude the case



8.1 Document all decisions made resulting from the case clearly and confidentially.



8.2 Store all information relating to the case confidentially, and in accordance with GDPR and local data protection law.



9 Record anonymised data relating to the case to feed into organisational reporting requirements (e.g. serious incident reporting to Board, safeguarding reporting to donors), and to feed into learning for dealing with future cases.








This statement applies to all Trustees, staff, volunteers, management committee members, users and the general public. Turn The Tide recognises respects and values diversity in its Trustees, employees, volunteers and service users.






Equality and diversity are central to the work of Turn The Tide



Turn The Tide will treat all people with dignity and respect, valuing the diversity of all. It will promote equality of opportunity and diversity. It will eliminate all forms of discrimination on grounds of race, gender, marital status, caring responsibilities, disability, gender re-assignment, age, social class, sexual orientation, religion/ belief, or any other factor irrelevant to the purpose in view.






Turn The Tide aims to:



  • Provide services that are accessible according to need
  • Promote equality of opportunity
  • Not unlawfully discriminate because of the Equality Act 2010 protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex (gender) and sexual orientation
  • Create effective partnerships with all parts of our community






Turn The Tide objective is to realise its standards by:



  • Working together with the community to provide accessible and relevant service provision that responds to service users’ needs
  • Responding to volunteer’s & employees’ needs and encouraging their development to increase their contribution to effective service delivery
  • Recognising and valuing the differences and individual contribution that all people make to Turn The Tide
  • Challenging discrimination
  • Providing fair resource allocation
  • Being accountable





Turn The Tide Arts Project Constitution 



1. Name 



The name of the organisation shall be Turn the Tide Arts, hereinafter referred to as the Project, TTT, or 3T. 



2. The Area 



The geographical area that TTT covers will be primarily defined as Stevenage and its surrounding villages. 



3. Aims 



TTT shall undertake activities which are of benefit to young people and residents of the Borough and surrounding area. To do this, TTT will: a) Promote to people within the defined geographical area and online. b) Provide opportunities for recreation and enjoyment, and encourage a community spirit and responsibility. c) Promote equal opportunities, valuing diversity and work for good relations among all members of the community. d) Regularly update all participants through website, social media, and community outreach. e) Be non-party political. 



4. Membership 



a) A copy of the constitution will be given to all incoming members and made freely available upon request. b) Participation in the project shall be open to all, particularly residents within the aforementioned geographical area. c) The Committee shall monitor the work, finances, and membership of the Project d) Specific interest groups will be encouraged and supported by the Project. e) Voting membership will end when a member dies, resigns, or is suspended for breach of Constitution or code of conduct. f) In the event of breaches of the Constitution or Code of Conduct, membership/participation can be suspended or ended after two verbal warnings have been issued by a Committee member. A report of verbal warnings must be given to other Committee members at the time of the breach. 



5. Appeals a) Any member who has been suspended or had their membership terminated shall have the Right to Appeal; if a member wishes to appeal they have the right to ask the Secretary to arrange a special meeting to hear the appeal. b) Appeal requests must be made to the Secretary within 28 days of receipt of the letter suspending or ending membership; a special meeting must be held not less than 14 days and not more than 21 days following the Secretary’s receipt of the member’s request for appeal. c) The Special Meeting Committee dealing with the appeal shall consist of 3 persons (providing they are not related to the member) who are not members of the Project. d) Any member who has invoked clause 5(a) shall have the Right to bring a third party, and if they wish, to also be represented by a third party or an ordinary member of the Project. e) The decision of the Appeals panel shall be binding on both parties. 



6. Equal Opportunities 



a) The Project will seek to ensure equality of opportunity and treatment of all those it comes into contact with, in accord with the Project’s Equal Opportunities Policy. 



7. The Committee a) 



The Committee shall have a minimum of the following Officers: Chairperson, Secretary, and Treasurer. The Committee shall have the power to appoint a Vice-Chairperson, Vice-Secretary and a Vice-Treasurer; Committee members shall be elected at an Annual General Meeting (AGM). b) The size of the Committee should be no less than three and no more than sixteen members. c) Every third year, three quarters of the Committee will stand down, but can be re-elected. No Committee member shall serve for more than three years, unless no other participants stand for election. d) The Chair (or in their absence the Vice-chair or other Committee member) shall conduct the meetings of the Project. e) The Committee may appoint Sub-committees as required to carry out activities for the Project; any Sub-committees shall be directly accountable to the Project Committee. f) At least one Committee member shall sit on any Sub-committee of the Project. g) The Committee shall agree in advance the Terms of Reference for any Sub-committee, and apply any finance raised by itself (or on its behalf) only within those Terms. 



8. Meetings/Annual General Meetings 



a) The Project shall hold an AGM once each calendar year, and not more than fifteen months shall pass between the date of one AGM and the next. b) The AGM shall: ● Agree Minutes of the last Annual General Meeting ● Receive an Annual Report from the Committee ● Present a Statement of Accounts to its members ● Elect Committee members ● Vote on amendments to the Constitution ● Consider any resolution put forward by members c) Any volunteer over the age of 18 shall be entitled to stand for election to the Committee, except for the Youth Committee where members between the ages of 13 and 17 years may stand. d) Nominations for the Committee must be received by the Secretary in writing at least three days before the meeting. e) Nominees should be present at the AGM unless they are unable to attend due to illness, holiday, etc., and at the discretion of the Committee. The Secretary must be informed at least three days before the meeting to enable them to pass on relevant apologies. f) An independent observer shall be invited to attend each AGM and confirm that the meeting was arranged and conducted in accordance with the Projects Constitution. g) All members must receive in writing no less than twenty-eight days notice of the AGM. Notice of the AGM shall be displayed on public notice boards in the Project area and on the Project website. 



9. Special General Meetings 



a) A Special General Meeting may be called by the Committee or if requested by at least eleven members of the Project. Requests should be made in writing to the Secretary at least twenty-one days before the requested meeting date. 



10. General Meetings 



a) Meetings will be chaired by the Chairperson but in the event of their absence the meeting will be chaired by the Vice-chair or, an elected Committee member. There shall be at least two General Meetings of the Project in any one calendar year. b) Decisions of the General Meeting shall be binding on the Committee. c) At least seven days notice shall be given for a General Meeting. If a member believes an item to be of a confidential nature this must be made known to the Committee before commencement of business. The Committee must decide if the item is to be discussed in a closed session at the end of the General Meeting. 



11. Committee Meetings 



a) The Committee shall meet at least four times a year. b) Committee meetings may be called by the Chair, and Secretary, or at the request of one third of the Committee members. At least seven days notice must be given to other Committee members. c) Meetings will be chaired by the Chairperson, or in the event of their absence, the Vice-chair or another Committee member will chair the meeting. 



12. Voting 



a) Decisions at Annual General Meetings shall be taken by a simple majority of those voting. b) In the event of a tie of the vote, the Chair of the meeting shall have the casting vote. The Chair of the meeting shall not otherwise vote on any resolution. c) If a counted vote is needed the numbers shall be counted, and duly recorded in the Minutes. d) Alterations to the Constitution require a two-thirds majority of those present and voting at an Annual General Meeting. Full details of proposed changes must be circulated twenty-eight days prior to the Meeting. e) Conflicts of Interest must at all times be declared. Members with a conflict of interest should then withdraw from the discussion and from voting on the issue in question. 



13. Minutes 



a) All formal meetings must be Minuted and the Minutes formally approved by the next meeting (Committee or General). 



14. Finance 



a) A simple record of income and expenditure must be produced each year at the AGM and be made available to all members on request. b) Accounts should be open to inspection by members on request. All monies raised by or on behalf of the Project shall be applied to further the aims of the Project, and for no other purpose. 



15. Dissolution 



a) The project can only be dissolved by a Special General Meeting called specifically to consider a motion to dissolve the Project. b) All members will be given 14 days written notice of such a meeting. Notices will be placed on public notice boards and the Project website. c) The Project can only dissolve if a majority of the members voting agree. d) The meeting shall decide on the disposal of any assets remaining after the satisfaction of debt and any other liabilities. These assets must be applied to charitable purposes agreed with the members of the Project. e) If a General Meeting does not take place to dissolve the Project, the Committee should either consult with members on what charitable cause to donate the project assets to, or retain them securely for a period of three years (after which they will be given to a charitable cause). f) Any sponsor assets the Project has been permitted to use (but which have not been transferred into ownership of the Project by way of outright donation or gift) must be returned to the sponsor if the sponsor so wishes. 



16. Code of Conduct for Committee and Project Members 



● All Committee and Project members must comply with the Constitution and Code of Conduct at times. ● A serious breach of any of the Projects Constitution or Code of Conduct may result in a Committee Member, following a majority vote of the Committee, being asked to resign. ● Members shall conduct themselves in a manner that will not cause offence to others. Racist, sexist or inflammatory remarks, or abusive behaviour, will not be tolerated. The Chair or Committee member/s has the right to warn the member/s of their behaviour. If they persist they will be suspended until further notice. ● The Project will provide each new Committee member with appropriate support and make them feel welcome at all times. Committee meetings will be held at times which are convenient to the majority of Committee Members. ● Committee Members must never personalise issues and should be willing to recognise that everybody is entitled to express their point of view without unduly preventing progress of discussion. ● Voters should always be prepared to accept the majority decision and not take such a decision as any form of personal slight or criticism.



17. Personal Interest of Committee Members



Committee Members must never use their position to seek preferential treatment for themselves, their family, or relatives. Nor should they be treated more or less favourably when requesting services from sponsors or other organisations. 



The Constitution and Code of Conduct was Adopted at a public meeting of the Project. 



Held on 02/06/2023