Privacy Policy
Principles of the General Data Protection Regulation Act 2016
21 Together needs to collect, maintain and use certain personal data about current, past and prospective members of the organisation, and other companies or individuals it has dealings with. 21 Together is dedicated to handling, processing, and storing this personal data in accordance with the General Data Protection Regulation Act 2016 (the Act).
21 Together has a responsibility to protect any personal data it collects from you. 21 Together is committed to meeting its obligations under the Act. These principles require that personal data must:
be fairly and lawfully processed and not processed unless specific conditions are met;
be obtained for one or more specified, lawful purposes and not processed in any manner incompatible with those purposes;
be adequate, relevant and not excessive for those purposes;
be accurate and, where necessary, kept up to date;
not be kept for longer than is necessary;
be processed in accordance with the data subject’s rights under the Act;
be kept secure from unauthorised or unlawful processing and protected against accidental loss, destruction or damage;
not be transferred to countries outside the European Economic Area (EEA) unless the country or territory ensures adequate protection for the rights and freedoms of the data subjects.
We are also committed to GDPR compliancy
We believe that the responsible use of personal information collected on our web site is critical. We have therefore adopted this Privacy Statement. The extent and type of information we receive from you on our external web sites depends on the information you provide to us through our contact mailboxes and/or via any of the contact forms within this website and/or through any registration processes on this website and/or via making a purchase on this websites.
We only use your personally identifiable information to respond to your requests and to provide you with information about 21 Together, such as news, details of events and courses that we feel may be of interest to you. You may opt out of receiving this information at any time (please see details below).
Cookies
21 Together uses Google Analytics to monitor traffic to and on the websites but does not collect any personal data from visitors to its web site that is not voluntarily provided.
What we collect:
21 Together collects personal data that data subjects (you) provide, which is information that can be used to identify someone as an individual. 21 Together will only do this when you (as the data subject) have consented to 21 Together’s request for that personal data. Personal data is provided by you and collected by 21 Together in a variety of ways including, without limitation, when applying for membership, courses, and any other activity run by 21 Together. This personal data may include your:
Name;
Address;
Telephone number;
Email;
When applying for a child or young person to access any of our activities or interventions we may ask for personal information in respect of the child or young person. This information is only used by staff and therapists to ascertain the most appropriate interventions or courses of action dependent on the needs of the individual.
How 21 Together will use a data subject’s personal data.
By providing personal data, you agree that 21 Together may use your personal data to:
Respond to your requests;
Provide you with tips, helpful information, news and updates of the organisation, or similar and relevant organisations;
Notify you of new services;
Seek your views on new services;
21 Together will act as a data controller of such personal data.
21 Together will only collect personal data to serve a specific purpose and only gather the minimum amount needed.
21 Together will obtain a data subject’s informed consent to process his or her personal data in cases where it is necessary and appropriate to do so.
21 Together will not use personal data collected for one purpose for a different purpose without getting the data subject’s consent.
21 Together will correct any personal data where it is notified that such personal data is incorrect, and delete all copies of personal data on the request of the data subject.
Only authorised trustees, staff and volunteers of 21 Together can carry out processing of personal data.
How 21 Together protects your personal data
21 Together will take appropriate measures to protect personal data consistent with applicable privacy and data security laws.
When 21 Together uses a third-party service provider, (eg, email providers, online banking, social media platforms) that provider will be required to use appropriate measures to protect the confidentiality and security of personal data.
Unfortunately, no data transmission over the internet is 100 per cent secure. As a result, while we try to protect your personal information, 21 Together cannot guarantee the security of any information you transmit to us and you do so at your own risk.
Sharing personal data with third parties
21 Together may share the personal data of a data subject in compliance with applicable law.
In certain special cases where permitted by applicable law, 21 Together may disclose your personal data:
when 21 Together has reason to believe that disclosure of this information is necessary to identify, contact or bring legal action against someone who may be causing injury to you or otherwise injuring or interfering with 21 Together’s rights, property or operations, other users of this website or anyone else who could be harmed by such activities;
when 21 Together believes that applicable law requires it, or in response to any demand by law enforcement authorities.
Unless otherwise specified in the website or by directly asking your permission, 21 Together will not pass your personal data to other third parties.
Sometimes 21 Together uses selected third parties to provide support services in the normal course of business (eg, Google for email, online banking portals etc). These parties may, from time to time, have access to your personal data to enable them to provide those services to 21 Together. 21 Together requires all third parties providing such support services to meet the same standards of the Act. Any third party will be prohibited from using your personal data for that third party’s own purposes. In particular, 21 Together will not allow service providers to use your personal data for the marketing activities of that service provider.
Links to other websites and Social Media
The 21 Together website may from time to time provide links to or embed third party websites. This 21 Together policy does not apply to those third party websites. If you choose to enter such a linked site, you agree that 21 Together is not responsible for the availability of such websites and 21 Together does not review or endorse and shall not be liable, directly or indirectly, for:
how these third party websites treat your personal data;
the content of such third party websites; or
the use that others make of these third party websites.
Please ensure you check the data protection policy posted on a third party website or mobile application you access before entering any personal data.
Access to information – Subject Access Request
21 Together will retain your information only for the period necessary to fulfil the purposes outlined in this 21 Together policy, unless a longer retention period is required or permitted by applicable law. Anyone who is the subject of personal data held by 21 Together has the right to make a subject access request to request the updating, correcting or removal of personal data that has been provided to us, at any time, using the contact information provided at the end of this 21 Together policy. Applicable laws may also give you the right to access information that you have provided to 21 Together.
21 Together will deal promptly with subject access requests and will do so with no charge.
Changes
21 Together will update this 21 Together policy to take account of changes in working practice or applicable law. If the changes that 21 Together makes are material, 21 Together may make you aware of these changes.
Contact 21 Together
Please address any questions, comments and requests regarding this 21 Together policy to 21 Together using the contact information below. If you contact 21 Together, please provide information as to how 21 Together may contact you.
To contact 21 Together regarding any aspect of 21 Together’s approach to data protection, or if you wish to opt out of receiving any of the information emails that we send out, please email us on info@21together.org.uk.
Safeguarding Children Policy
At 21 Together, the safety and well-being of children and young people are our top priorities. Our Safeguarding Children Policy outlines our commitment to providing a secure and enjoyable environment for all participants, especially children, during our events and activities.
Our Commitment:
We prioritize the welfare of children above all else.
We welcome children from diverse backgrounds and ensure they feel safe and valued.
We take all necessary steps to protect children from harm, discrimination, and mistreatment.
We treat any suspicions or allegations of poor practice or abuse with utmost seriousness.
We recruit and train our staff and volunteers to uphold good practice in child protection.
We believe in working closely with parents and children to ensure their safety and well-being.
Promoting Good Practice:
We encourage good practice by:
Ensuring all staff have completed the relevant level of Safeguarding training and DBS checks
Maintaining open and transparent environments.
Making our activities fun, fair, and free from bullying.
Treating all young people with respect and dignity.
Always putting the welfare of the child first.
Avoiding unnecessary physical contact and ensuring consent when required.
Involving parents when necessary and providing constructive feedback.
Reporting Concerns:
If you suspect any form of abuse or poor practice, we urge you to:
Report the incident to our designated safeguarding lead, any other member of staff, or the relevant authorities.
Confidentiality:
We understand the importance of confidentiality and handle information on a need-to-know basis, involving parents, authorities, and any alleged abusers as required, while adhering to data protection laws.
Recruiting and Selecting Personnel:
We take rigorous steps to prevent unsuitable individuals from working with children, including background checks, references, and thorough interviews.
Conclusion:
Our Safeguarding Children Policy reflects our unwavering commitment to ensuring the safety, protection, and well-being of all children participating in 21 Together activities. We adhere to relevant legislation and guidelines, and this policy underlines our dedication to safeguarding children.
For more information on our full Safeguarding Children Policy, please contact us. Your child's safety is our priority.
Safeguarding Lead: James Hanley – Education Lead
Whistleblowing Policy
It is important that any fraud, misconduct or wrongdoing by staff or others working on behalf of the charity is reported and properly dealt with. We therefore require all individuals to raise any concerns that they may have about the conduct of others in the charity or the way in which the organisation is run. This policy sets out the way in which individuals may raise any concerns that they have and how those concerns will be dealt with.
Background
The Public Interest Disclosure Act 1998 amended the Employment Rights Act 1996 to provide protection for workers who raise legitimate concerns about specified matters in the public interest. These are called "qualifying disclosures". A qualifying disclosure is one made by an employee who has a reasonable belief that:
· a criminal offence;
· a miscarriage of justice;
· an act creating risk to health and safety;
· an act causing damage to the environment;
· a breach of any other legal obligation; or
· concealment of any of the above;
is being, has been, or is likely to be, committed. It is not necessary for you to have proof that such an act is being, has been, or is likely to be, committed - a reasonable belief is sufficient. You have no responsibility for investigating the matter - it is the charity's responsibility to ensure that an investigation takes place.
If you make a protected disclosure you have the right not to be dismissed, subjected to any other detriment, or victimised, because you have made a disclosure. We encourage you to raise your concerns under this procedure in the first instance.
Principles
· Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. Staff and others working on behalf of the charity should be watchful for illegal or unethical conduct and report anything of that nature that they become aware of.
· Any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the person who raised the issue.
· No employee or other person working on behalf of the charity will be victimised for raising a matter under this procedure. This means that the continued employment and opportunities for future promotion or training of the worker will not be prejudiced because they have raised a legitimate concern.
· Victimisation of an individual for raising a qualified disclosure will be a disciplinary offence.
· If misconduct is discovered as a result of any investigation under this procedure our disciplinary procedure will be used, in addition to any appropriate external measures.
· Maliciously making a false allegation is a disciplinary offence.
· An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, you should not agree to remain silent. You should report the matter to the Charity Manager or the Chair of the Board of Trustees.
Procedure
This procedure is for disclosures about matters other than a breach of your own contract of employment, which should be raised via the Grievance Procedure.
Stage 1: In the first instance, any concerns should be raised with the Charity Manager, who will arrange an investigation of the matter. The investigation may involve you and other individuals involved giving a written statement. Any investigation will be carried out in accordance with the principles set out above. Your statement will be taken into account, and you will be asked to comment on any additional evidence obtained. The Charity Manager will take any necessary action, including reporting the matter to the Chair of the Board of Trustees and any appropriate government department or regulatory agency. The Charity Manager will also invoke any disciplinary action required. On conclusion of any investigation, you will be told the outcome and what the charity has done, or proposes to do, about it. If no action is to be taken, the reason for this will be explained.
Stage 2: If you are concerned that the Charity Manager is involved in the wrongdoing, has failed to make a proper investigation or has failed to report the outcome of the investigations to the relevant person, you should escalate the matter to the Chair of the Board of Trustees. The Chair will arrange for a review of the investigation to be carried out, make any necessary enquiries and make their own report to the Board.
Stage 3: If on conclusion of stages 1 and 2 you reasonably believe that the appropriate action has not been taken, you should report the matter to the relevant body. This includes:
· HM Revenue & Customs
· The Health and Safety Executive
· The Environment Agency
· The Serious Fraud Office
· The Charity Commission
· The Pensions Regulator
· The Information Commissioner
· The Financial Conduct Authority
· The Competition and Markets Authority
· The Independent Office for Police Conduct
You can find the full list in The Public Interest Disclosure (Prescribed Persons) Order 2014: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/496899/BIS-16-79-blowing-the-whistle-to-a-prescribed-person.pdf
Data protection
When an individual makes a disclosure, we will process any personal data collected in accordance with the data protection policy. Data collected from the point at which the individual makes the report is held securely and accessed by, and disclosed to, individuals only for the purposes of dealing with the disclosure.
Complaints Policy