This Impact Assessment follows the process set out in the Information Commissioner’s Office DPIA guidance, and should be read alongside that guidance and the criteria for an acceptable DPIA set out in European guidelines on DPIAs.
It has been prepared as part of a major project to update and replace ART’s SmART Ringer online system which records the personal details and achievements of ringers and ringing teachers and supports their continuing development. In due course it will be revised and extended to cover all of ART’s information systems and services.
ART offers a Training Scheme (ATS) for teachers of bell ringing, a learning programme (Learning the Ropes [LtR]) for new ringers and other training events and programmes. SmART Ringer (SR) is an online platform which supports the development of trainee teachers, accredited members of ART and ringers. It also records their achievements and, for accredited members, the history of their membership.
The project, Son of SmART Ringer (Son of SR), aims to replace the existing platform with a new and updated system with better functionality, greater resilience and in-built compliance with data protection legislation and guidance. It will also support a growing range of programmes offered by ART.
The Son of SR project team identified a need for a Data Protection Impact Assessment (DPIA) for the following reasons:
Flow diagrams depicting the various processes being planned in Son of SR are attached to this assessment as Annex 1.
Teachers can register themselves for ATS courses via the ART Events website. Their personal details will be transferred to Son of SR following their attendance at a course. Ringers will either be able to register themselves or be registered by their teacher on the LtR or other programmes for ringers. This information will be updated with details of any achievements made, any other programmes joined and, in the case of teachers, their steps to gaining membership. All users will continue to have access to their own personal data and to information and resources which support their role while they remain in membership or active users.
A user’s personal data will be available to share with officers and appropriate volunteers of ART and other users who are linked to the individual, such as in the ringer-teacher, teacher-mentor, or teacher-tutor relationships.
As noted above, the data of children will be stored and used in connection with their progress on programmes and safeguarding policies are in place to regulate how communication is made with those under 18 or identified as vulnerable adults. The new Son of SR system will take cognisance of the “Age-appropriate design code of practice” in handling this data and it is not envisaged that this will include profiling, automated decision-making or geolocation elements. The age of those under 18 will be verified by a parent or guardian.
The Son of SR system will not directly process data likely to be regarded as high risk.The base-line data held by the system about an individual will comprise their full name, contact details (address, telephone numbers, email address), age band or date of birth, their tower location and unique record number. To this may be added:
Data relating to criminal convictions may be disclosed to ART by the DBS, but will be stored separately and securely from Son of SR.
The system will store details of a data subject’s attendance, achievements and membership for the lifetime of the individual unless a request is received to delete it. Deletion requests will be met by pseudonymising and archiving the record. Records may also be marked as inactive and archived where an individual’s account has not been used for a significant period
The current system has approximately 9,500 users and it is anticipated that Son of SR may need a capacity of up to 25,000 users, although its theoretical capacity will be much greater. Users will continue to be drawn from across the UK, but a small number will also be based in other jurisdictions, notably Australia, New Zealand, Canada, the United States and European Union countries.
The prime purpose of the Son of SR system will be to record the events attended and achievements made by individual users; users may be any age from 8 years or above, but a majority will be adults (18+). The initiative for taking actions to join programmes, achieve programme targets and gain recognition in the form of accreditation or certification will rest initially with the user, but may also lie with their teacher or coach. The system may occasionally generate reminders or explanatory communications to advise users of next steps available.
For ringers on some programmes, it will be the teacher who records the ringer’s achievements and for teachers it will be their mentor who records their progress and an assessor who submits the outcome of an assessed lesson. Accreditation as an ART Teacher is normally made following the completion of all the required steps. On other programmes the data subject will be able to record their own progress subject to some achievements being a matter of public record on other databases such as Bellboard.
The services of SmART Ringer will be available to children as noted above, but will not be designed specifically for children, although safeguards will be incorporated to protect them when using the system. Research suggests that currently young ringers make little or no use of the current system. Cognisance is taken of safeguarding guidance from bodies such as the Central Council of Church Bell Ringers and the Church of England and a consultation meeting was held with a group of young ringers and their parents. Leaders of youth ringing groups were also consulted about the current and potential use of SmART Ringer by young people. This led to a decision that, provided simple and clear language is used throughout, an alternative version of the system for young users or vulnerable adults is not warranted.
A record of the consultation meetings held is attached to this assessment as Annex 2.
The overall aim of ART and its programmes is to raise the standard of ringing teaching and to improve the learning experience of ringers. In supporting those aims, Son of SR will:
ART is a membership organisation dedicated to the ongoing support of its teachers to maintain standards of teaching. Access to some facilities is dependent on users maintaining their current membership.
It also provides LtR and other programmes to help ringers develop their skills. The LtR scheme is a nationally recognised standard for new ringers, giving them transferable skills. This helps to maintain the heritage of full-circle tower bell ringing in the UK and other English-speaking countries. Evidence suggests that ringers who learn at an early age, normally as upper primary and secondary school children, are able to make much better progress in their ringing careers. SmART Ringer aims to provide good support in their earlier ringing development.
A focus group of parents and young ringers was held at the Troyte Ringing Centre in Devon to discuss how ART and its teachers should communicate with youngsters, particularly those in the 16- and 17-year-old age group.
Leaders of other young ringer groups were consulted about how their youngsters currently use or do not use the SmART Ringer platform. As a result of this research, it was decided that, provided simple and clear language is used throughout, an alternative version of the system for young users or vulnerable adults is not warranted.
Consultation was carried out with volunteer and staff users and potential users such as tutors, assessors and administrators about how the new system will work for them.
No further consultations are planned but full cognisance is being taken of ICO guidance. A record of the consultation meetings and email research conducted is attached as Annex 2.
ART describes its use of data and the lawful bases for that use in its Privacy Policy. The lawful bases are:
Data subjects will be told how to access data in response to any Subject Access Request. They will be able to review the data held about themselves using a secure personal login to Son of SR and will be able to correct some data fields themselves or request changes to other data by contacting ART administrative support.
There are no plans currently to use Artificial Intelligence to process data or to make international transfers and none are envisaged.
The rights of data subjects are set out in ART’s Privacy Policy and staff and key volunteers are given training in data protection and working with the GDPR. A description of the training given to staff and volunteers is given in Annex 3.
1. Best interests of the child: Parents are included in all communications with children under 16. 16 and 17 year olds and their parents are involved in a discussion about their communication preferences.
2. Any potential high-risk processing: DPIA is being completed because services are available to children. Son of SR will not directly process high-risk data.
3. Age-appropriate application: All email communication to under-16s will be to the parent or guardian’s mailbox. Communication to 16- and 17-year-olds will be agreed with both the child and their parents. Parents will give their written agreement to their youngster’s participation before registration and will provide ART with an appropriate email address for communications. ART Teachers confirm the age of ringers they are registering and parents of these will be contacted for consent. Teachers will be asked to provide a date of birth for themselves on registering for teacher training courses and other events.
4. Transparency: ART’s Privacy Policy will be reviewed for child-friendly language and simple, clear language will be used throughout the system. All users will be required to tick a check box to confirm having read it.
5. Detrimental use of data: Users are made aware of need to protect data through advice to teachers ( https://ringingteachers.org/about/policies/data-protection-guidance-art-teachers) and training given to staff and volunteers in key roles (see notes on training – Annex 3).
6. Policies and community standards: Members are made aware of guidance from relevant bodies (CofE, Charity Commission, CCCBR).
7. Default settings: There are no plans to provide personalisation as such, but what an individual has access to will be determined by the programme for which they are registered. Privacy will be protected by access to an individual’s data being restricted to those with a business need.
8. Data Minimalisation: We are clear on the purpose and use of the data we collect. Users have some choice as to which elements of the services ART offers they use.
9. Data sharing: Data is not shared with other organisations without the user’s consent. Children’s data would not be shared with other bodies without parental consent. A data sharing agreement would be put in place before any exchange of data with other organisations.
10. Geolocation: There are no plans to use geolocation other than recording home tower.
11. Parental controls: There are no plans to use direct parental controls. ART’s data is low risk and therefore controls are not thought to be relevant. Parents or guardians give written consent for children to register with ART as outlined above.
12. Profiling: Is not used in Son of SR.
13. Nudge techniques: Will only be used to promote good privacy and health and well-being choices. ART may use information to promote other appropriate ART services and products without nudge techniques.
14. Connected toys and devices: Not used.
15. Online tools to help children exercise their rights: Age-appropriate messaging is not thought to be required.
|
Risk |
Likelihood |
Impact |
Risk Rating |
|
Unauthorised persons gain access to users’ data. |
Possible |
Minimal |
Low |
|
Users’ data is misused in connection with abusive behaviour. |
Possible |
Significant |
Medium |
|
Publication of users’ location may be lead to threat of abuse e.g. in case of marital breakup |
Remote |
Significant |
Medium |
|
Loss or corruption of data results in records of achievements or membership being lost |
Remote |
Significant |
Low |
Risk | Options to reduce or eliminate risk | Effect on risk | Residual risk |
Unauthorised access
| Logins and access permissions restrict availability of data to a user | Reduced | Low
|
Unauthorised access | Virus protection and firewalls used to prevent uncontrolled access | Reduced | Low |
Data misuse | D.P. training given to staff & volunteers. Guidance to other users such as teachers. Members required to evidence DBS clearance | Reduced | Medium |
Location data misused | Users can opt-out of publication of home tower | Reduced | Low |
Loss of data | Data frequently backed-up | Reduced | Low |
Last Modified: July 2022
If you have any questions about this policy or data protection you are invited to contact the Association at: