Privacy Policy

Our privacy policy describes the categories of personal data that we process, and the purposes for which we process it.

9th Warwick Emscote Scout Group is committed to collecting and using personal data in accordance with all current and subsequent data protection legislation.

Who we are
1. We are 9th Warwick Emscote Scout Group, a youth charity. We may refer to ourselves as the Group throughout this document.
2. We are incorporated by royal charter and are regulated as a member of The Scout Association. As part of The Scout Association, we are not required to be individually registered with The Charity Commission for England and Wales.
3. We are based at All Saints CofE Junior School, Nelson Avenue, Warwick, CV34 5LY.
4. Our website address is https://www.emscotescouts.org.uk/.
5. Our Group Executive Committee is the data controller for the information we collect from you. Any personal data that we collect will only be in relation to the work we do with our members, and through our relationship with supporters, donors and other funders.
Your personal data
1. Personal data is any form of data that relates to a living individual who can be identified from that data. The identification could be obtained from the information alone, or in conjunction with any other information in the Group’s possession, or in conjunction with any other information which we are likely to come into such possession.
2. We process personal data in line with, and our processing of personal data is governed by, current UK data protection legislation and any subsequent legislation as appropriate.
How we gather personal data
1. For youth members, who are defined as any member under 18 years of age, the personal information we hold is provided directly by the parents or legal guardians of our youth members, in either paper form or via our online membership systems.
  1. We do not accept information from young people directly. We will only accept and obtain information on or deal with data requests relating to youth members directly from adults responsible for the young person.
2. For adult members, the personal information we hold is provided directly by the adult members and may also be provided by third party reference agencies, such as the Disclosure and Barring Service.
How we process personal data
1. We comply with our obligations under data protection legislation and ensure that:
  1. Your personal data is kept up to date.
  2. Your personal data is stored securely.
  3. We do not collect or retain excessive amounts of personal data.
  4. We protect your data from loss, misuse, unauthorised access and disclosure.
  5. We put adequate and appropriate measures in place to protect personal data.
2. We collect and use personal data for the following purposes:
  1. We collect email addresses so that we can invite parents and guardians to use our Online Scout Manager Parent Portal, which enables parents and guardians to maintain the data we collect
  2. We collect personal and medical information for the protection of the member whilst they are in the care of our group so that, for example, we can ensure that the member does not come into contact with any potential allergens, or we know what medications a member usually takes.
  3. We collect the postal address of members, parents and guardians to enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution.
  4. We collect religious data so that we can respect a member’s beliefs with regards to any activities, food or holidays, ensure that their parents are informed when it comes to the variations of The Promise that the member can make, and also to ensure that our programme supports our membership’s combined spirtitual development needs.
  5. We collect email addresses and telephone numbers so that we can contact members, parents and guardians to inform them about and invite them to meetings and events that take place as part of our programme.
  6. We collect email addresses so that we can contact parents and guardians to inform them about members’ progress through Scouting, and awards and badges that they may receive from time to time.
  7. We collect email addresses and telephone numbers so that we can contact parents and guardians to request their assistance from time to time to help run sessions and to assist at events.
  8. We collect postal addresses, email addresses and telephone numbers so that we can contact parents and guardians to request information as part of The Scout Association’s annual census.
  9. We collect personal data to help us manage our volunteers.
  10. We collect personal data maintain our own accounts and records, including the processing of gift aid applications.
  11. We collect email addresses to help us to inform you about news, events and activities running at the Group.
3. Whenever we process data for the purposes outlined in paragraph 4.2, we will ensure we always take account of your rights in relation to your personal data. You have the right to object to the processing of your data in this manner if you wish, but please bear in mind that it may affect our ability to carry out the tasks above for your benefit.
4. We also collect and process special category data for the following purposes:
  1. We collect information on the gender, ethnicity and additional needs of our members for statistical purposes as part of The Scout Association’s annual census, using the secure Online Scout Manager Parent Portal, operated by Online Youth Manager Limited. The information is anonymised, and there is no way for our volunteers or members to see any details beyond aggregated totals. Processing is carried out with appropriate safeguards, and no personal data is disclosed outside that body without the consent of the data subjects.
5. Whenever we process special category data, as outlined in paragraph 4.4, we will always:
  1. Ensure that we always ask for your consent to do so.
  2. Offer you an easy way to remove the data you have supplied, if you so desire.
  3. Give you the option, where possible, to opt-out of providing the special category data through the use of a “prefer not to say” option.
The legal basis for processing personal data
1. We only use personal information where:
  1. We need to use the information to comply with our legal obligations.
  2. We need to use the information to contact members in relation to meetings, events, collection of membership fees and for any purpose directly connected with the day-to-day running of the group.
  3. It is fair to use the personal information in your interests, where there is no disadvantage to you – for example, where we contact you about products or services offered within scouting.
  4. The processing is necessary to provide appropriate safeguarding for our youth members, for example, where we carry out enhanced background checks on adults who wish to volunteer with the group.
  5. The processing would be reasonably expected by you by the individual, and is necessary for the individual’s legitimate interests, or the legitimate interests of our group unless there is a good reason to protect the individual’s personal data which overrides those interests.
How we store personal data
1. We are committed to ensuring that your data is protected and stored securely at all times.
2. We generally store personal information on our members in one of two secure digital online database systems:
  1. For youth members, we use a system called Online Scout Manager, a secure online membership system run by Online Youth Manager Limited, where we store the personal information of adult and youth members for the general day-to-day running of the group.
  2. For adult members, we use a system called Compass, a secure online membership system run by The Scout Association, where we store the personal details of helpers, supporters and leaders of the Group.
  3. Access to all secure digital online database systems is restricted and controlled.
3. When a new youth member joins our Group, when a youth member wishes to join our Group via our website, or where have no space available in the appropriate section, we will collect data on the youth member through our New Members Waiting List on Online Scout Manager. We will usually advise the adult responsible for the prospective youth member within two weeks when we expect a space to become available.
  1. In cases where the individual no longer wishes to join the group, all personal details will be immediately erased from our secure online digital systems.
4. When a youth member attends an event, and where it is necessary for us to fulfil our legal obligations by having access to personal contacts and medical information, we will occasionally use paper copies of the data so that we have access to the information in locations where we would not otherwise have access to the internet and our secure digital online systems. The use of these forms and the data held on them will be minimised to ensure that we only use what is required for the event or camp. Additionally, we will ensure that:
  1. The transfer of such paper records will be handled personally in a secure hand-to-hand manner between the Group Secretary and the Leader-in-Charge.
  2. Paper records will be kept secure and on the person by the Leader-in-Charge throughout the course of the event.
  3. Should any such paper records be transferred to any other authorised person, such as members of the district, county, regional or HQ teams who are running an event, that we will audit the return of the paper records prior to the end of the event.
  4. All such paper records will be securely destroyed, by means of shredding or incineration, at the end of the event.
5. When we nominate a youth member for an award, such as a Chief Scout’s, Queen’s Scout or Duke of Edinburgh’s Award, such nominations will require us to provide contact details to the awarding body. In such cases where it is not possible for us to provide this information over a secure connection, we will ensure that the information is sent securely by registered post.
6. When consent is required from parents and guardians for youth members to take part in events, we will capture this consent online through the Online Scout Manager Parent Portal.
7. Gift Aid Declaration forms will be securely held by the Group Treasurer to aid in the reclamation of Gift Aid on membership subscription fees, in line with section 12.2.
8. When coordinating events with third party organisations, we will occasionally be asked to collect personal data on paper event forms for the purposes of coordinating with event organisers. Information stored on paper forms will be held until such time that it is no longer required, and then securely destroyed.
9. When a youth member is no longer attending, is joining another group, or is otherwise leaving the group, all of the following processes will be followed, where applicable:
  1. For all youth members, we will mark their personal record for deletion, and will retain the information in line with section 12 of this policy.
  2. In cases where there is an outstanding balance due to the group from the youth member, we will retain data for the responsible adult for as long as is necessary to ensure that monies due are paid to the group.
  3. In cases where the youth member is leaving and joining another group, we will mark the retain the information for as long as is necessary to transfer the personal details and records of the youth member. We will only transfer the data to the other group’s Online Scout Manager when a Data Transfer Form is completed and given to us, providing that:
    1. An adult responsible for the youth member, listed as a primary contact on the youth member’s record on Online Scout Manager, signs the form and consents to the transfer.
    2. The Group Scout Leader (GSL) or the Assistant or Deputy Group Scout Leader (AGSL or DGSL) for the destination group confirms the name of the section, as stored within Online Scout Manager, on the Data Transfer form.
    3. The GSL, AGSL or DGSL for the destination group signs the form and consents to the transfer.
Sharing and transferring personal data
1. Your personal data will be treated as strictly confidential at all times, and we will only share your data with third parties outside of the organisation where there is a legal and legitimate reason for us to do so.
2. We will only normally share personal information between our Section Leadership and Group Executive Committee teams.
3. We may also share your personal details with senior leadership teams outside our Scout Group where we need to meet or enforce a legal obligation. This may involve transferring your data to the District Commissioner of Warwick Scout District or their chosen representative, the County Commissioner of Warwickshire Scout County or their chosen representative, The Scout Association and its insurance subsidiary Unity, the local authority and law enforcement agencies, or the NHS or other public health agencies. We will only share your personal information to the extent needed for those purposes.
4. If your young person moves from 9th Warwick Emscote Scout Group to another Scout Group or Explorer Scout Unit, we will not transfer any personal details to that group without first obtaining consent as outlined in section 6.9.3.
5. If your young person volunteers as a Young Leader with another Scout Group, we will only transfer personal details to that group after we are provided with a Young Leader Placement Agreement that has been completed by the Young Leader, the receiving Section Leader, the District Explorer Scout Leader for Young Leaders or District Explorer Scout Commissioner, and the receiving Group Scout Leader.
6. We will never sell or otherwise share your personal information to or with any third party for the purposes of marketing.
7. We may, should we choose to nominate a member for an award, such as the Chief Scout’s, Queen’s Scout or Duke of Edinburgh’s Award, share your personal information with the awarding body for the purposes of providing contact details to them.
8. We will, on an annual basis, provide The Scout Association, with anonymised statistics for the purpose of providing collective reporting on gender, ethnicity, religion and age. We use the Online Scout Manager Census Aggregation tools to allow you to provide this information anonymously. If we are ever asked to provide identifiable data, we will seek your consent before we do so.
9. Anonymised real-time aggregate data will also be shared with The Scout Association for the purposes of improving support for local groups and increasing external funding of Scouting. No personally identifiable information will be shared for this purpose. If we are ever asked to provide identifiable data, we will seek your consent before we do so.
10. Your personal data may also be accessed by The Scout Association’s Safeguarding team on Online Scout Manager, through a data sharing arrangement between the Group, Online Youth Manager Limited and The Scout Association.
  1. Data will only be obtained through the arrangement as a last resort in cases where the information cannot be obtained through the usual channels or in the event of an emergency.
  2. The data shared via the arrangement will be used to protect children by helping The Scout Association’s Safeguarding team to access critical information quickly, in exceptional circumstances and as a last resort, where the information cannot be obtained through the usual channels or in the event of an emergency.
  3. The personally identifiable data shared will be limited to the personal details (the name, date of birth and contact details) of members and their parents or guardians in OSM. All access will be controlled, transparent and logged within OSM’s audit trail for Scout Groups to see.
  4. Any personal data taken out of OSM for these purposes will be managed via secure child protection systems at The Scout Association HQ, with details only kept as long as case records are required.
  5. https://www.scouts.org.uk/dppolicy, our data sharing arrangement, this privacy policy and all applicable data protection legislation.
  6. For data that The Scout Association may access via Online Scout Manager, The Scout Association will act as an independent data controller, and will determine any purpose for the onward processing of the data in accordance with its safeguarding policies and procedures, its own Data Protection Policy, as outlined in paragraph 7.10.5, and all applicable data protection legislation.
11. We may share your personal details with the Department of Health and Social Care or any applicable services operated by the government or NHS in the event that we are made aware that any member or volunteer or visitor to the group has been exposed to an infectious disease to assist with any test and trace programme operated by the aforementioned government departments or agencies or other public health agencies as may be applicable.
Third party data processors
1. The Group employs the services of the following third-party data processors:
  1. The Scout Association, via its adult membership system Compass, which is used to record the personal information of leaders, adults and parents who have undergone a Disclosure and Barring Service (DBS) check.
  2. Online Youth Manager Limited, which is used to record the personal information, badge records, event and attendance records of our youth members. We have a data processing agreement in place with Online Youth Manager Limited, and a page outlining their approach to data security can be found at https://www.onlinescoutmanager.co.uk/security.html.
  3. Microsoft Corporation, via its Microsoft 365 platform, which the Group uses for email, documentation and productivity purposes, occasionally used for the secure transfer of limited personal information for events.
  4. Dropbox, Inc., which the Group occasionally uses in conjunction with other Scoout Group, Disctrict and County event planning teams, for the secure transfer of limited personal information for events.
  5. Google LLC, and Google UK Limited, via its G Suite platform, which the Group has made use of in the past for purposes related to the day-to-day running and management of the Group, and which the Group occasionally uses in conjunction with other Scout Group, District and County event planning teams, for the secure transfer of limited personal information for events.
  6. Intuit Ltd., which the Group uses in connection with its financial and accounting systems and requirements.
2. In addition to the third party processors used by the Group, The Scout Association may be required to share personal data with other third parties including but not limited to the Police, local authorities, public health agencies and other statutory or regulatory bodies.
Automated decision making
The Group does not use or make use of any automated decision-making systems.
Transfers outside of the UK
The Group will not transfer your personal information outside of the UK, with the exception where an event is taking place outside of the UK and it is necessary to provide personal information to comply with our legal obligations, although, generally, such events will have their own data collection forms, which will be securely held and destroyed after the event.
How we protect personal data
1. We take appropriate measures to ensure that the information disclosed to us is kept secure, accurate and up to date, and is kept only for as long as necessary for the purpose for which it is used.
2. We ensure that all Group members with access to personal data have undergone The Scout Association’s data protection training, that they are aware of our Privacy Policy, and that they understand their obligations under this policy and current data protection legislation.
Retaining personal data
1. We will retain your full personal information for a period of one year after you have left the Group, and in a much more limited form (retaining just your name and your badge records) for a period of up to 15 years, or until the member reaches the age of 21, to fulfil our legal obligations for insurance and legal claims.
2. We have a legal obligation to retain all Gift Aid Declaration forms and the information held on them for the statutory 7 years, as required by HMRC, which may result in information being held on a member beyond them reaching 21 years of age.
Your rights and your personal data
1. You have the right to object to how we process your personal information.
2. You have the right to access, correct, and – in some cases – delete and restrict the personal information we use.
3. You have the right to complain to us and to the data protection regulator. If you have a complaint about data use, and you wish to contact the regulator, you can write to the Information Commissioner.
4. Unless subject to an exemption under data protection legislation, you have the following rights with respect to your personal data:
  1. You have the right to know how your data will be used by our Scout Group.
  2. You have the right to access your personal data, and can ask us to share the data we have about you with you.
  3. You have the right to update your personal data if it is inaccurate, or if something is missing.
    1. Parents or legal guardians of our youth members can update personal information using the Online Scout Manager Parent Portal.
    2. Adult members can update their personal information using Compass and Online Scout Manager, in cases where they have Leader access.
  4. You have the right to request that we delete any personal data we have about you. However, there are some exceptions, for example, where we can continue to retain data relating to you for legal reasons.
  5. You have the right to restrict any further use of your data if you think there’s something wrong with the data we hold about you, or you aren’t sure if we’re complying with data protection legislation, until the problem is resolved.
  6. You have the right to request a copy of your information in machine readable form, such as a PDF, so that you can share your information with others.
  7. You have the right to object to the way in which your data is being used, which makes it easier for you to avoid unwanted marketing communications and spam from third parties.
  8. You also have rights in relation to automated decision making and profiling, protecting you in cases where decisions are being made about you based entirely on automated processes rather than human input.
5. If you have any questions regarding your data, you should contact our Group Scout Leader or Data Protection Lead (if one is appointed) in the first instance for more information.
6. Whether or not you exercise your rights is up to you – but your rights are always there for you, if you need them.
Changing how we use your personal data
If we decide to change the way in which we use your personal data, or if we wish to use your personal data for a new purpose which is not covered by this privacy policy, we will provide you with a new notice explaining the new use, prior to commencing.
Contacting us regarding our privacy policy
1. If you wish to contact us regarding data, if you wish to exercise your rights, or if you have a complaint, you should contact our Group Scout Leader or Data Protection Lead (if one is appointed):
  1. By writing to us:
    9th Warwick Emscote Scout Group
    c/o 55 Greville Road
    Warwick
    CV34 5PB
  2. Or by emailing:
    privacy@emscotescouts.org.uk.
2. If you wish to complain to the data protection regulator, you can contact the Information Commissioner’s Office:
  1. By telephone on 0303 123 1113
  2. Through their website at https://ico.org.uk/global/contact-us/email/
  3. Or by writing to:
    Information Commissioner’s Office
    Wycliffe House
    Water Lane
    Wilmslow
    Cheshire
    SK9 5AF

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