Last Updated 10/08/2019
This document describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the General Data Protection Regulation (GDPR).
Personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in our Scout Group’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (“the GDPR”).
How we gather personal information?
The majority of the personal information we hold on our members is provided to us directly by yourself as parents / legal guardian, mostly via our online membership systems or occasionally paper forms. In the case of an adult member or helper, data may also be provided by third party reference agencies, such as the Disclosure Scotland.
Where a member is under the age of 13, this information will only be obtained from a parent / guardian and cannot be provided by the young person. However we will accept and potentially record any personal information, such as about any ongoing medical treatment from any member no matter their age.
How we process personal data?
We comply with our obligations under GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We process the data to have the ability to contact the member, parents and guardians, to inform them of meetings and events that the group itself may be running or attending.
- we collect personal, medical and dietary information for the protection of that person whilst in the care of the 28th Ayrshire (Troon) Scout Group.
- to administer membership records
- to fundraise and promote the interests of the 28th Ayrshire (Troon) Scout Group.
- to manage our volunteers
- to maintain our own accounts and records (including the processing of Gift Aid applications)
- to inform you of news and activities relevant to 28th Ayrshire (Troon) Scout Group.
The legal basis for using your personal information?
We only use your personal information where that is permitted by the laws that protect your privacy rights
We only use personal information where:
- We need to use the information to comply with our legal obligations
- We need to use the information to contact with you, regarding meetings, events, collection of membership fees etc, (i.e. for the day to day running of the group)
- It is fair to use the personal information in your interests, where there is no disadvantage to you – this can include where it is in our interests to contact you about products or services within Scouting.
- The processing is necessary for the persons legitimate interests or the legitimate interests of the 28th Ayrshire (Troon) Scout Group, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
How we store personal data?
28th Ayrshire (Troon) Scout Group is committed to the protection of your personal information.
We generally store personal information in one of two secure digital online database systems, where access to that data is restricted and controlled.
Compass is the online membership system of The Scout Association, this system is used for the collection and storage of Adult personal data.
Online Scout Manager (including the Parent Portal) is an online membership system run by Online Youth Manager Ltd, this is a secure membership database where we store the personal information of Adults and Youth members for the day to day running of the group.
Our leadership team use their own (and potentially their employers’) computers, tablets and mobile phones to access Online Scout Manager.
When attending a large-scale Scouting event we are sometimes required to share personal information to event organisers via their own online systems. Examples include Norjam, KISC or other National Camps like Blair Atholl.
Printed records and Event data
Paper is occasionally still used within 28th Ayrshire (Troon) Scout Group to capture and retain some data, for example, the following: –
- Name lists for when we run section meetings and / or events.
- In-Touch details – only if the nominated person doesn’t have access to Online Scout Manager. Once the event is over, the paper records are destroyed.
As a member of 28th Ayrshire (Troon) Scout Group it is hoped you will take up the opportunity to attend events and camps, where is necessary to fulfil our legal obligations we will be required to potentially have a less secure means to access personal information, such as printouts of personal contacts and medical information, (including specific event contact forms), rather than relying on secure digital systems, as often the events are held where internet and digital access will not be available. We will minimise the use of paper to only what is required for the event/camp.
We will ensure
- Transfer of paper is secure, such as physical hand to hand transfer or registered post.
- Paper forms are securely destroyed after use.
- Secure destruction will be through a shredding machine or securely burned.
- Always keeping the paper records secure, especially when in transit, by using; A lockable briefcase or a lockable filing cabinet if long-term stored.
- If transferred to somebody, we will audit that they return them when the event is complete.
- Allergy information and medication will not be locked away as a leader may need fast access but will not be generally on show during an event.
Sometimes we may nominate a member for an award. Such nominations would require we provide contact details to the awarding organisation.
Sharing and transferring Personal Information
We will only normally share personal information with our scout group leaders and limited information to executive members.
Information may also be shared between the Tiger Explorer Scout Unit (“Explorers”) and the 28th Ayrshire (Troon) Scout Group. This may be because of a joint event that one of us is running (e.g. KISC, Norjam, Giant Sleepover etc). It could be that the organisation of an event requires either party to contact members which are not currently in their Group or Unit (for example; Explorers organising an event to which eligible members are not yet in the Unit), then either party will seek permission from the Section/Unit leader before communicating with members. Communications sent “on behalf” of another party will be stated (either visually or written) to avoid any confusion.
We will however share personal information where we need to meet or enforce a legal obligation. This may include Kyle & Carrick District Scouts, South West Scotland Region Scouts, Scouts Scotland, The Scout Association, local authority services and law enforcement agencies. We will only share your personal information to the extent needed for those purposes.
If a youth member or adult volunteer moves from 28th Ayrshire (Troon) Scout Group to another Scout Group or Explorer Scout Unit we may transfer personal information to them.
We will never sell your personal information to any third party for the purposes of marketing.
Your personal data will be treated as strictly confidential. We will only share your data with third parties outside of the organisation where there is a legitimate reason to do so. We will take steps to anonymise the data we provide (i.e. collective reporting on gender, ethnicity, age, etc.). If identifiable data is to be shared we will seek your consent.
Third Party Data Processors
28th Ayrshire (Troon) Scout Group employs the services of the following third-party data processors: –
- The Scout Association via its 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.
- Online Youth Manager Ltd (Online Scout Manager / Parent Portal) which is used to record the personal information, badge records, event and attendance records etc, we have a data processing agreement in place with online youth manager, more information is available at https://www.onlinescoutmanager.co.uk/security.php
- Dropbox inc occasionally used for secure transfer of limited personal information.
- Google used for secure transfer of limited personal information for events and also storage of images, video and audio. G Suite is also the email system we use for our sectional email addresses along with a number of other roles within the group.
- GoCardless is used to process Direct Debit payments. 28th Ayrshire (Troon) Scout Group does not have access to individuals’ bank account details via this service.
- Facebook, Twitter & Instagram are used to share posts, pictures, video & audio about what we get up to here at the 28th Ayrshire (Troon) Scout Group.
Transfers outside the UK
When the 28th Ayrshire (Troon) Scout Group members participate in international Scouting events (such as the KISC or a World Scout Jamboree), data may be transferred outside the UK.
Protection of personal data
We take appropriate measures to ensure that the information disclosed to us is kept secure, accurate and up to date and kept only for as long as necessary for the purpose for which it is obtained.
Retention of personal data
We will retain your personal information throughout the time you/your child(ren) are a member of the 28th Ayrshire (Troon) Scout Group.
We will retain your full personal information for a period of one year after you have left 28th Ayrshire (Troon) Scout Group and in a much more limited form (just name, badge and attendance records) for a period of up to 15 years (or until the age 21) to fulfil our legal obligations for insurance and legal claims.
We will also keep any Gift Aid claim information for seven years as required by HMRC.
Your rights and your personal data
You have the right to object to how we process your personal information. You also have the right to access, correct, sometimes delete and restrict the personal information we use. In addition, you have a right to complain to us and to the data protection regulator.
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: –
- The right to be informed – you have a right to know how your data will be used by our Scout Group.
- The right to access your personal data – you can ask us to share with you the data they have about you.
- The right to rectification – this means you can update your data if it’s inaccurate or if something is missing. Parents can view and edit personal information on the Parent Portal (part of Online Scout Manager) and adult volunteers can update their own details on Compass.
- The right to erasure – this means that you have the right to request that we delete any personal data they have about you. There are some exceptions. For example, some information can be held for legal reasons.
- The right to restrict processing – if you think there’s something wrong with the data being held about you, or you aren’t sure if we are complying to rules, you can restrict any further use of your data until the problem is resolved.
- The right to data portability – this means that if you ask us we will have to share your data with you in a way that can be read digitally – such as a pdf. This makes it easier to share information with others.
- The right to object – you can object to the ways your data is being used. This should make it easier to avoid unwanted marketing communications and spam from third parties.
- Rights in relation to automated decision making and profiling – this protects you in cases where decision are being made about you based entirely on automated processes rather than a human input.
Please contact your child(ren)’s leader or our Group Scout Leader for more information in the first instance.
Automated decision making
28th Ayrshire (Troon) Scout Group does not have any automated decision-making systems.
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
The law on image use and GDPR needs further clarification, the position 28th Ayrshire (Troon) Scout Group is as follows: –
Photographs (this includes images, video and audio) which can be classed as personal information of yourself or your child may be taken during activities and be used within a Scouting context and in particular publicity material, for example, Scouting publications and the media. This may be published to official Scout websites and scouting affiliated social media and our public display boards in both the Scout Hall & Centre.
We do ask for explicit consent “Yes/No” (via Online Scout Manager), as consent and this presumes that it can be revoked.
If we publish a photograph or image in any public forum such as in a newspaper, we no longer have control over that photograph, as it can be downloaded, screenshot, re-photographed and shared by others, stored in systems not related or controlled by 28th Ayrshire (Troon) Scout Group.
Under GDPR consent is invalid if people cannot easily withdraw consent, which would be the case with publishing to any publicly accessible system, therefore if you do not wish your child to appear in these then please confirm, in writing, to the Group Scout Leader, and we will not publish anything including your child on a public forum such as social media from that point forward, we will be unable to confirm full removal of images and photographs from the historical record online or otherwise stored.
Please note that the group cannot control or stop images being taken by other individuals, parents or organisations not connected with the 28th Ayrshire (Troon) Scout Group leadership team.
28th Ayrshire (Troon) Scout Group will store an image of you or your child on the Online Scout Manager (OSM) membership database for the purposes of identification, alongside and linked to the personal information, access to this image is limited to the leaders and authorised users of OSM as is the rest of the personal information.
To exercise all relevant rights, to raise queries or make a complaint, please in the first instance contact your section leader. You can also email them via this form.