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Data Protection Policy and Procedure: Volunteers

Introduction

Bethany Christian Trust respects your personal information and is committed to protecting your privacy. We comply with all applicable data protection legislation, including the General Data Protection Regulation (GDPR), to ensure your personal data is handled responsibly.

This page outlines our approach to handling your personal data in your role as a volunteer with us.

1. Information we collect

In the course of your volunteering with us, you may come into contact with, and have to use, confidential personal information about clients, employees, and other volunteers. This can include names and addresses, and even information about personal circumstances, families, health and other private matters.

Bethany Christian Trust also holds personal data about you. A privacy notice will be provided separately which tells you what information we hold, what we do with it, who we share it with and the lawful basis for the processing of your data. If your data changes you should let us know at the earliest opportunity so that our records can be updated.

Bethany Christian Trust considers that personal data includes:

  1. Personal details, including name, address, age, contact information
  2. References and CVs
  3. Emergency contact details
  4. Pertinent notes on discussions between management and the volunteer
  5. Appraisals and documents relating to problems or complaints
  6. Training records

2. Purpose of data collection

The personal data that has been collected about you will be kept for the following purposes:

  1. Recruitment, training and development
  2. Administration
  3. Performance review
  4. Recording of pertinent communication with volunteers
  5. Compliance with legislation

We will review the nature of the information being collected and held on an annual basis to ensure there is a sound business reason for requiring the information to be retained.

We may use personal information provided by you either with your consent or on the basis of the following:

  1. Contract: the processing is necessary for the volunteer agreement that we have with you
  2. Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations)
  3. Vital interests: the processing is necessary to protect someone’s life
  4. Public task: the processing is necessary for us to perform a task in the public interest or for official functions, and the task or function has a clear basis in law
  5. Legitimate interests: the processing is necessary for our or your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests

3. Your rights

To ensure compliance with the Regulations and in the interests of privacy, volunteer confidence and good volunteer relations, the disclosure and use of information held by Bethany Christian Trust is governed by the following conditions:

  1. Personal data must only be used for one or more of the purposes specified in this Policy
  2. Bethany Christian Trust documents may only be used in accordance with the statement within each document stating its intended use
  3. Provided that the identification of individual volunteer is not disclosed, aggregate or statistical information may be used to respond to any legitimate internal or external request for data (for example, surveys, staffing level figures)
  4. Personal data must not be disclosed, either within or outside Bethany Christian Trust to any unauthorised recipient. If you are in any doubt about what you may or may not do, seek advice from your supervisor, the Volunteer Coordinator or the People Team

In accordance with Bethany’s Data Protection Policy, you are entitled to request a copy of the information which Bethany holds about you.

If you become aware that the personal information Bethany holds about you is inaccurate, you may request that it be amended. Any requests in this respect or any other correspondence relating to this notice should be done in accordance with the Bethany’s data protection policy.

Where processing is based upon consent, you have the right to withdraw consent at any time, which will not affect the lawfulness of processing based on consent before its withdrawal.

Our Data Protection Officer is Ruth Longmuir who will monitor GDPR compliance within the organisation.

4. Data retention and data sharing

Click on the headings below to read more about the details of each type of information we hold on you and who we may share it with.

Recruitment process information

This includes:

  • Application Form: Personal details (name and address, email address, phone number, date of birth), all information gathered during the recruitment process
  • Reference details
  • Training records

Who it is shared with:

Internally shared with:

  • Volunteer Coordinator
  • Volunteer Supervisor
  • Senior Management
  • HR

Legal basis for processing this information:

Legitimate interest:

  • To ensure that all relevant contact details are known and up to date
  • To ensure that the volunteer is suitable for the volunteering role
  • To ensure that there is a log of training in relation to statutory requirements for any volunteering roles

Retention period for keeping this information:

Six years after the termination of volunteering

Bank details

Who it is shared with:

Internally shared with:

  • Volunteer Coordinator
  • Volunteer Supervisor
  • Finance

Legal basis for processing this information:

Legitimate interest:

  • To ensure payment are made to the volunteer for expenses etc. 

Retention period for keeping this information:

Six years

Health information (including medical information)

Who it is shared with:

Internally shared with:

  • Volunteer Coordinator
  • Volunteer Supervisor
  • Senior Management
  • HR

Externally shared with:

  • Occupational Health provider if appropriate
  • Counselling providers if appropriate

Legal basis for processing this information:

Legitimate interest:

  • Personal data and special category data may be collected to ensure we can meet our H&S obligations, to provide any adjustments and to monitor absence levels
  • Special category data

Retention period for keeping this information:

Six years after the termination of volunteering

Copies of passport/driving license/birth certificate and eligibility to volunteer documentation

Who it is shared with:

Internally with:

  • Volunteer Coordinator
  • Volunteer Supervisor
  • Senior Management
  • HR

Legal basis for processing this information:

Legal obligation:

  • To ensure we meet our legal obligations  

Retention period for keeping this information:

Two years after the termination of volunteering

Induction form

Next of kin details (name, address, phone number, relationship to you).

Who it is shared with:

Internally shared with:

  • Volunteer Coordinator
  • Volunteer Supervisor
  • Senior Management
  • HR

Legal basis for processing this information:

Legitimate interest:

  • To ensure that the correct people within the business can make contact with your next of kin in the case of an emergency

Retention period for keeping this information:

Six years after the termination of volunteering

Health and Safety information

Information (details of any aspect of health and safety including risk assessments, accident reports, health and safety manuals for which we require to take professional advice or report as required), including personal details where required.

Who it is shared with:

Internally shared with:

  • Health and Safety department
  • Volunteer Coordinator
  • Volunteer Supervisor
  • Senior Management
  • HR

Externally shared with:

  • Health and Safety Executive and any other governing or professional body

Legal basis for processing this information:

Legal obligation:

  • To ensure that we meet our obligations regarding health and safety

Please get in touch with our Volunteer Coordinator at volunteers@bethanychristiantrust.com to request the full list of record types that we hold in compliance with data protection regulations.

Sound and motion recordings by way of CCTV

Who it is shared with:

Internally with:

  • Volunteer Coordinator
  • Volunteer Supervisor
  • Senior Management
  • HR

Externally shared with:

  • Police Scotland

Legal basis for processing this information:

Legitimate interest:

  • To protect staff safety and security, and protect our company equipment  

Retention period for keeping this information:

Up to four weeks

Disclosure information

Information will only be gathered about criminal convictions where it is appropriate for the particular volunteering role and we are legally permitted to do so.

Who it is shared with:

Internally with:

  • Volunteer Coordinator
  • Volunteer Supervisor
  • Senior Management
  • HR

Externally shared with:

  • Disclosure Scotland
  • Volunteer Scotland

Legal basis for processing this information:

Legal obligation:

  • To ensure that volunteers are legally able to work with vulnerable adults in a regulated environment

Retention period for keeping this information:

On receipt of the PVG/Disclosure from Disclosure Scotland the volunteer’s disclosure number is recorded with their name and role title until the volunteer leaves their role.

Information will be retained in compliance with the Disclosure Scotland guidelines.

Our IT providers of support are: Tecnica, One Advanced, and Microsoft which includes cloud-based storage. Tayl, our online training provider, may have access to volunteer details. In the case that this should require a volunteer’s personal email address, explicit consent will be sought.

The supervisory authority is the Information Commissioner’s Office (ICO). Where you have a complaint regarding the handling of your data, which you do not think can be handled internally, then you have the right to make a complaint to the ICO.