ART is concerned to protect the
personal details of the teachers and ringers who use its services and
has put in place policies to ensure that this happens. We ask you to
read four key policy documents which cover data protection in your
teaching:
- Privacy Policy
- Data Protection Policy
- Data security procedures (part of the Data Protection Policy)
- Photography and Video Policy
What in practice does this mean for me as an ART Teacher?
General Principles
ART’s
Privacy Policy sets out how the Association, its officials and
volunteers, use personal information provided by ringers, teachers and
other users of its services. You could summarise this by saying “don’t
use someone’s details for any purpose they would not reasonably expect
you to use them for”. Particular care should be exercised in keeping and
using the contact details of children, i.e. those under 18. The sharing
of an ART user’s details outside your work in connection with ART’s
activities should normally only be done with the permission of the user.
Data Security and Safeguarding
“Permission
to ring” forms for children and vulnerable adults (VAs) should include
contact information for both the child or VA and their parent or carer.
It may also include medical information, and this is classed in D. P.
law as sensitive data requiring secure storage and careful use. The
issues of when, how and with whom information on the forms should be
shared are complex, particularly where forms contain medical
information. In special circumstances, such as acrimonious marital
break-up or domestic abuse, the address and tower location of a ringer
may be sensitive information. For teachers, ART suggests:
- As a minimum any key background information should be shared by
the teacher with one other responsible adult (normally a deputy) in the
tower to cover any possible absence of the teacher.
- Emergency contact telephone numbers for children and V.A.s should
be displayed in the home tower and carried by the teacher (in a
diary/notebook or on a mobile phone) for access in other towers, at
events or on outings.
- The teacher should consider sharing information with more adults
in the group if the child or vulnerable adult is attending an event
outside the home tower.
Secure storage and access to data
- Few towers have
secure facilities for storage. A church office may have the means to
store confidential information, but off-site secure storage of consent
forms at home by the tower captain or secretary may be necessary.
- Consent
forms should ideally be stored in a lockable filing cabinet, but should
as a minimum be kept in a file out of sight in a room to which access
is restricted and controlled.
- Access to electronic files should
similarly be controlled by good computer security measures such as not
sharing log in details, using strong passwords, not keeping sensitive
data on portable devices such as mobile phones or pen drives which can
easily be lost.
Communicating with children and young people under 18 and vulnerable adults
- •
The legal age of adulthood is 18, although the Data Protection Act 2018
(which incorporated the GDPR) gives rights to young people from the age
of 13. ART recommends that all communications to those under 18 are
copied in the first instance to their parent or guardian. However, ART
offers membership to teachers from the age of 16 and it may be
appropriate for parents to opt out of routine communications with young
ringers and teachers aged 16 and 17. Similarly, the carers of vulnerable
adults should be kept informed of any issues or activities affecting
the adults for whom they are responsible.
- A separate ART policy
covers the use of video recordings and photography. Permission should be
sought before videoing or photographing anyone taking part in
activities led by ART teachers. Photographs or videos made to assist the
teacher in their teaching, particularly where these involve children,
should be deleted as soon as the purpose for which they were made has
been met. This should normally be done at the end of the session in
which the photo or recording was made.
Other Issues
Teachers should also be aware that any issues connected with:
- Requests for access to a user’s own personal data
- Loss or corruption of data
- How long to retain records
are covered by guidelines within
ART’s Data Protection Policy and any queries should be referred to ART’s
Data Protection Adviser: dataprotection@ringingteachers.org.
Further Information
If you
would like to know more about the GDPR, a short video (7 minutes long)
gives an introduction to GDPR: “What is the GDPR? A summary of the EU
GDPR” by IT Governance Ltd.