Safeguarding

Here at Burgh Baptist Community Church we take safeguarding seriously. We want everyone who comes into our church to feel welcomed, safe and comfortable with what they see and hear. We follow the Baptist Union best practices and our safeguarding policy below, reflects their recomendations. Please contact a member of our safeguarding team if you have any concerns.

BURGH BAPTIST CHURCH
SAFEGUARDING
POLICY & PROCEDURES

  • SECTION 1 – SAFEGUARDING POLICY STATEMENT

SECTION 2 – SAFEGUARDING PROCEDURES

INTRODUCTION 

2.1 Procedure for Recognising and Reporting Abuse
2.1.1 What to do if Abuse is Suspected or Disclosed
2.1.2 Responding to Concerns
2.1.3 Responding to Concerns Raised about Adults at Risk
2.1.4 Allegations Against Workers
2.1.5 Abuse of Trust
2.1.6 Allegations Made Against Children and Adults at Risk
2.1.7 Pastoral Care
2.2 Safer Recruitment
2.3 Safer Behaviour

SECTION 3 – BEST PRACTICE GUIDELINES

3.1 – Working With Children
3.1.1 Ratios
3.1.2 Children with Special Needs
3.1.3 Visiting Children or Young People at Home
3.1.4 Children with no adult supervision
3.1.5 Mentoring
3.1.6 Peer Group Activities for Young People
3.1.7 Physical Contact
3.1.8 Electronic Communications – Cyber Safety
3.2 Working with Adults at Risk
3.2.1 Premises
3.2.2 Language
3.2.3 Worship
3.2.4 Insurance
3.2.5 Financial integrity
3.2.6 Photographs
3.2.7 Computers
3.2.8 Record keeping
3.2.9 Pastoral Relationships
3.3 Health And Safety – Safe Practice and Safe Premises
3.3.1 Consent forms
3.3.2 Health and Safety
3.3.3 Fire
3.3.4 First Aid
3.3.5 Supervision of Groups
3.3.6 Food Hygiene
3.3.7 Risk Assessment
3.3.8 Insurance
3.3.9 Transport
3.3.10 Outings and Overnight Events involving Children
3.3.11 Outings and Overnight Events involving Adults at Risk
3.3.12Hiring of Church Premises
3.4 Safer Community
3.4.1 Bullying
3.4.2 Working with Alleged or Known Offenders
3.4.3 Alleged or known offenders who are themselves adults at risk

SECTION 4 – USEFUL CONTACTS

APPENDIX 1 – DEFINITIONS OF ABUSE

APPENDIX 2 – DETAILED GUIDANCE ON REPORTING REQUIREMENTS

SECTION 1 – SAFEGUARDING POLICY STATEMENT

SAFEGUARDING POLICY STATEMENT FOR BURGH BAPTIST CHURCH

Our Vision:

The vision statement of Burgh Baptist Church is to be Christ centered, disciplemaking, risk taking, kingdom building, pilgrim people of God.

OUR AIM:

To promote and sustain the ongoing growth & development of Christian disciples of all ages, making them:
1) followers of Christ 2) fishers of men 3) leaders of ministry

To evangelise seekers and equip believers.

OUR TOOLS:

Primary: The Bible
“16 All Scripture is inspired by God and profitable for teaching, for reproof, for correction, for training in righteousness; 17 so that the man of God may be adequate, equipped for every good work.” (2 Tim 3:16-17, NASB)

Secondary: Other resources, as appropriate

OUR METHODS:

1) Teaching/exploring the Bible at all maturity levels
from spiritual milk to spiritual meat (in groups, one-to-one etc.).

2) Providing spiritual and practical development to equip for
whole life worship of Christ, and Christian work inside & outside of the church.

In fulfilling this vision, we:
• Welcome children and adults at risk into the life of our community
• Run activities for children and adults at risk
• Make our premises available to organisations working with children and adults at risk

Our Safeguarding Responsibilities
The church recognises its responsibilities in safeguarding all children, young people and adults at risk, regardless of gender, ethnicity or ability.
As members of this church, we commit ourselves to the nurturing, protection and safekeeping of all associated with the church and will pray for them regularly. In pursuit of this, we commit ourselves to this policy and to the development of sound procedures to ensure we implement our policy well.

• Prevention and Reporting of Abuse
It is the duty of each church member to help prevent the abuse of children and adults at risk, and the duty of each church member to respond to concerns about the well-being of children and adults at risk. Any abuse disclosed, discovered or suspected will be reported in accordance with our procedures. The church will fully co-operate with any statutory investigation into any suspected abuse linked with the church.

• Safer recruitment, support and supervision of workers
The church will exercise proper care in the selection and appointment of those working with children and adults at risk, whether paid or voluntary. All workers will be provided with appropriate training, support and supervision to promote the safekeeping of children and adults at risk.

• Respecting children and adults at risk
The church will adopt a code of behaviour for all who are appointed to work with children and adults at risk so that all children and adults are shown the respect that is due to them.

• Safer working practices
The church is committed to providing an environment that is as safe as possible for children and adults at risk and will adopt ways of working with them that promote their safety and well-being.

• A safer community
The church is committed to the prevention of bullying. The church will seek to ensure that the behaviour of any individuals who may pose a risk to children, young people and adults at risk in the community of the church is managed appropriately.

Safeguarding contact points within our church
The church has appointed the following individuals to form part of the church safeguarding team:

Rebecca Baggaley, Designated Person for Safeguarding (DPS)

She will advise the church on any matters related to the safeguarding of children and adults at risk and take the appropriate action when abuse is disclosed, discovered or suspected.

Phone number 07508413276

Email address [email protected]

Julia Page, Deputy Designated Person for Safeguarding (DDPS)

She will assist the Designated Person for Safeguarding (DPS) in helping the church on any matters related to the safeguarding of children and adults at risk and take the appropriate action when abuse is disclosed, discovered or suspected.

Phone number 07443455890

Email address [email protected]

Rebecca Baggaley, Safeguarding Trustee

She will raise the profile of safeguarding within the church and oversee and monitor the implementation of the safeguarding policy and procedures on behalf of the church trustees.

Phone number 07508413276

Email address [email protected]

Our church Minister is also an important part of the Church Safeguarding Team. Where possible, the Church Safeguarding Team will work together if and when issues arise. However, each person has a responsibility to report allegations of abuse as soon as they are raised.

Putting our Policy into Practice
• A copy of the safeguarding policy statement will be displayed permanently on the church noticeboard and in the church office and is available on our church website.
• Each worker with children and/or adults at risk will be given a full copy of the safeguarding policy and procedures and will be asked to sign to confirm that they will follow them.
• A full copy of the policy and procedures will be made available on request to any member of, or other person associated with the church.
• The policy and procedures will be monitored and reviewed annually, and any necessary revisions adopted into the policy and implemented through our procedures.
• The policy statement will be read annually at the church AGM, together with a report on the outcome of the annual safeguarding review.

SECTION 2 – SAFEGUARDING PROCEDURES

Introduction

Each trustee, church leader and worker (paid or voluntary) needs to be familiar with these procedures, and those in leadership roles will be expected to attend both Level 2 and Level 3 BUGB Excellence in Safeguarding training (delivered through your local Baptist association team) to ensure that they have the knowledge and confidence needed to deal with safeguarding issues as they arise.

Over the following pages, you will find clear, specific information on how to recognise and report abuse and how to respond to concerns raised within the church. It is vitally important that these procedures are well known and that all those working with children and/or adults at risk in the church have the information and training needed to work with these procedures.

All church workers (paid and voluntary) who work with children and/or adults at risk will be expected to attend the BUGB Level 2 Excellence in Safeguarding training before they are able to work without supervision.

2.1 PROCEDURE FOR RECOGNISING, RESPONDING TO AND REPORTING ABUSE

2.1.1 What to do if Abuse is Suspected or Disclosed
Abuse and neglect are forms of maltreatment of a child or adult at risk. Somebody may abuse or neglect a child or adult by inflicting harm, or by failing to act to prevent harm. Children and adults at risk may be abused in a range of settings, by those known to them or, more rarely, by a stranger. There are many ways in which people suffer abuse. For more information, please see Appendix 1.

Everyone has his or her part to play in helping to safeguard children and adults at risk within the life of the church:
• If the behaviour of a child or adult at risk gives any cause for concern
• If an allegation is made in any context about a child or adult at risk of being harmed
• If the behaviour of any individual towards children or adults at risk causes concern

  • WHAT TO DO WHAT NOT TO DO
    • Listen to and acknowledge what is being said.
    • Try to be reassuring & remain calm.
    • Explain clearly what you will do and what will happen next.
    • Try to give them a timescale for when and how you / the DPS will contact them again.
    • Take action – don’t ignore the situation.
    • Be supportive.
    • Tell them that:
    They were right to tell you;
    You are taking what they have said seriously;
    It was not their fault;
    That you would like to pass this information on to the appropriate people, with their permission;
    • Be open and honest.
    • Give contact details for them to report any further details or ask any questions that may arise.                                                                                                                           Do not promise confidentiality.
    • Do not show shock, alarm, disbelief or disapproval.
    • Do not minimise what is being said.
    • Do not ask probing or leading questions or push for more information.
    • Do not offer false reassurance.
    • Do not delay in contacting the DPS.
    • Do not contact the alleged abuser.
    • Do not investigate the incident any further.
    • Never leave a child or adult at risk waiting to hear from someone without any idea of when or where that may be.
    • Do not pass on information to those who don’t need to know; not even for prayer ministry

2.1.2 Responding to Concerns
When there are concerns that a child, young person or adult is being abused, the following process must be followed. More detailed information can be found in Appendix 2.

If the DPS is not available or is implicated in the situation, any reports or concerns should be passed to another member of the church Safeguarding Team.

If you think that anyone is in imminent danger of harm, a report should be made immediately to the police by calling 999.

2.1.3 Responding to Concerns Raised about Adults at Risk
When a concern is raised about an adult it should be treated in the same way as a concern about a child i.e., the church worker (paid or voluntary) should:

1) Recognise that abuse may be taking place
2) Respond to the concern
3) Record all the information they have received
4) Report the concern to the DPS who may, in turn, report it to the statutory authorities

It is not your role to decide whether someone has mental capacity and is, therefore, able to make decisions that impact on their safety and well-being. Decisions on mental capacity are best made by professionals with the relevant background information to hand. Always share your concerns with the DPS even if you do not have the consent of the adult to do so – in this instance, make sure the DPS knows that the person concerned has not given consent for the information to be passed on.

The Care Act 2014 provides helpful guidance on these situations:
“If the adult has the mental capacity to make informed decisions about their safety and
they do not want any action to be taken, this does not preclude the sharing of information with
relevant professional colleagues. This is to enable professionals to assess the risk of harm
and to be confident that the adult is not being unduly influenced, coerced or intimidated and
is aware of all the options. This will also enable professionals to check the safety and validity
of decisions made. It is good practice to inform the adult that this action is being taken
unless doing so would increase the risk of harm”.

The DPS will consider all the information to hand and decide whether it is appropriate for the information to be reported to the statutory authorities (see appendix 2 for further information). If there are any concerns about an adult’s mental capacity, the DPS will contact the Local Authority Adult Safeguarding Team for advice.

2.1.4 Allegations Against Workers
If you see another worker acting in ways which concern you or might be misconstrued, speak to the DPS about your concerns as soon as you can. This includes the actions or behaviours of those in leadership positions in the church.

Church workers should encourage an atmosphere of mutual accountability, holding each other to the highest standards of safeguarding practice. The following procedure should be followed:
1) When an allegation of abuse has been made do not approach the alleged perpetrator about it
2) Follow the usual safeguarding procedure: Recognise, Respond, Record, Report
3) Once the allegation has been reported to the DPS they can liaise with the relevant statutory authority
4) Whilst waiting for an outcome from the statutory authorities, the worker about whom concerns have been raised will be supervised as closely as possible, without raising suspicion
5) Once the statutory authorities are involved, the church will follow their advice with regard to the next steps to take (for example, suspension of worker, putting a contract in place)
6) A written record of all discussions with statutory authorities or other parties should be maintained by the DPS and stored securely and confidentially, where only those directly involved in safeguarding (DPS, Safeguarding Trustee, Minister) can access them.
7) No information about the allegation will be shared with people in the church other than those directly involved in safeguarding, not even for prayer purposes.

The suspension of a worker following an allegation is, by definition, a neutral act. Our priority as a church is to protect children and adults at risk from possible further abuse or from being influenced in any way by the alleged perpetrator.

It may be necessary, for the sake of the child/adult at risk or to satisfy the needs of an investigation, for the alleged perpetrator to worship elsewhere. In such cases, the new church DPS will be informed of the reasons for this happening.

When concerns are expressed about the Minister

Any safeguarding concerns involving a Minister should always be reported immediately to the local Baptist Association Safeguarding Contact in addition to following the church’s usual procedures. Do not tell the Minister that a concern has been raised about them.

When concerns are expressed about the church DPS / Safeguarding Trustee

Any safeguarding concerns involving the DPS or Safeguarding Trustee should be raised with the Minister. Do not tell the DPS / Safeguarding Trustee that a concern has been raised about them.

2.1.5 Abuse of Trust
Relationships between children and adults at risk and their church workers can be described as ‘relationships of trust’. The worker is someone in whom the child or adult at risk has placed a degree of trust. This may be because the worker has an educational role, is a provider of activities, or is even a significant adult friend. It is not acceptable for a church worker to form a romantic relationship with a child or adult at risk with whom they have a relationship of trust.

While by no means restricted to young leaders, those who are in their early adult years will need to be particularly aware of the need not to abuse their position of trust in their relationships with other young people who are not much younger than themselves.

2.1.6 Allegations Made Against Children and Adults at Risk

Children and young people are by nature curious about the opposite sex. However, where a child is in a position of power, has responsibility over another child (as in a babysitting arrangement) and abuses that trust through some sexual activity, then this is abusive. Where one child introduces another child to age-inappropriate sexual activity or forces themselves onto a child, this is abusive. Such situations will be taken as seriously as if an adult were involved because the effects on the child victim can be as great.

When such an instance occurs, they are investigated by the statutory authorities in the same way as if an adult were involved, though it is likely that the perpetrator would also be regarded as a victim in their own right, as they may have also been abused. It cannot be assumed that young people will grow out of this type of behaviour, as most adult sex offenders started abusing in their teens or even younger.

Allegations against adults at risk will be investigated by the statutory authorities. If the alleged perpetrator is unable to understand the significance of questions put to them or their replies, they can access support from an ‘appropriate’ adult whilst they are being questioned. This role can be filled by a range of people, such as a family member, carer, social worker, etc. In court, adults at risk may be allowed to be assisted by an intermediary or give evidence through a live link.

When an allegation is made against a child or adult at risk the following procedure should be followed:

1) Do not approach the person about whom the allegation has been made or their parents/carers
2) Follow the church’s safeguarding procedure: Recognise, Respond, Record, Report
3) Seek advice from the DPS, who will speak to the police or social services about when to inform a parent. The DPS will also seek advice about what steps need to be taken to ensure the needs of both the victim and alleged perpetrator are met; this may include placing the child or adult at risk on a Safeguarding Contract or equivalent (see section 3.4: Safer Community / Working with Alleged or Known Offenders)
4) Make sure there is pastoral support in place for the child or adult at risk throughout the process involved.

2.1.7 Pastoral Care
Following an allegation/suspicion

When an allegation/suspicion arises in the church, a period of investigation will follow, which will be stressful for all involved. The church will ensure that one person is responsible for dealing with the authorities, another offers support to the victim/s and their family, and another gives pastoral care to the alleged perpetrator, without compromising the alleged victims or their families. It may be necessary to appoint other people to support the families involved.

Where a statutory investigation is underway, this support will be provided with the knowledge of the statutory authority involved.

Where the perpetrator accepts some responsibility, they will be encouraged to seek specialised interventions/treatment to reduce the risk of re-offending. This may only be appropriate once the investigation and legal processes have been completed.

Supporting those who have experienced abuse

As a church, we are committed to caring for those who have experienced abuse and refer to the Baptist Union of Great Britain Supporting Those who have Experienced Abuse guide to ensure that we adhere to a model of best practice.

We recognise it is important that those who have experienced abuse:
• Are accepted for who they are, without being made to forgive or being put into a position of feeling guilty and responsible for what happened to them.
• Know that God loves them unconditionally and that nothing can or will change this truth.
• Can be confident that those in the church community who know about the abuse are with them on their journey – no matter how long or difficult that journey may be.

It may be necessary to signpost individuals to specialist support. The DPS has a list of relevant local information and contacts, ready for anyone who may need it.

2.2 SAFER RECRUITMENT

As a church, we are committed to safer recruitment practices. When recruiting both paid and volunteer church workers, the following process will be applied:
1) We will develop a clear role profile, person specification and application form.
2) When advertising a role which involves working with children or adults at risk, we will make it clear that any appointment is subject to a DBS check.
3) All applicants will be asked to complete an application form and include the names of two referees.
4) Shortlisting of applicants will be carried out by at least two people, including the line manager or group leader directly overseeing the role being recruited for.
5) Interviews will be carried out by at least two people, including the line manager or group leader.
6) References, a Self-Disclosure Form and an enhanced DBS check must be completed satisfactorily before the appointed person starts in their role.
Note: Under the Criminal Justice and Court Services Act 2000, it is an offence for anyone disqualified from working with children or adults at risk to knowingly apply, accept or offer to work with children or adults at risk. It is also a criminal offence to knowingly offer work with children or adults at risk to an individual who is so disqualified or to knowingly allow such an individual to continue to work with children or adults at risk.

Additional Checks for Paid Workers
In addition to the above checks which should be completed for both paid and volunteer church workers, an applicant’s UK residency status and/ or right to work in the UK will be checked when recruiting for a paid role.

References
Formal written references will be requested, ideally in the form of at least one professional and one personal reference

Appointment and Supervision
The church’s safeguarding policy and procedures will be discussed with the applicant and they will be required to sign their agreement to adhere to them. All workers will have a role description and clear lines of accountability to a leader and the leadership team.
Paid workers will also have an assigned supervisor whom they will meet with regularly to discuss work and address any issues or areas of concern. There will be a probationary period of six months in the role before any paid appointment is confirmed.
There will also be regular team meetings to review procedures, share concerns and identify other matters that may need clarification and guidance.

Training
It is important that all workers understand our church’s agreed safeguarding procedures and attend BUGB Excellence in Safeguarding training at least once every four years. Where a worker is successfully recruited but has not yet been able to attend the training, they should be given a copy of the Baptist Union of Great Britain’s Gateway to Level 2 Excellence in Safeguarding booklet and asked to complete the relevant sections. Additional specialist training will also be arranged where needed, for example, in First Aid.
Young leaders under 18 years of age
In law, young leaders under the age of 18 are children and cannot be treated as adult members of a team. Training and mentoring will be given to ensure that they are helped to develop and hone their skills, attitudes and experience. Young leaders must always be closely supervised by an adult leader and never given sole responsibility for a group of children. When considering ratios of staff to children, young leaders need to be counted as children, not leaders. The safeguarding procedures apply to a young leader just as they do to any other person. Parent/carer permission needs to be sought for young leaders just as you would for any other person under 18 years of age.

2.3 Safer Behaviour
The church has a code of behaviour for all those working with children and/or adults at risk so that everyone is shown the respect that is due to them:

• Treat everyone with dignity and respect.
• Use age and ability appropriate language and tone of voice. Be aware of your body language and the effect you are having on the child or adult at risk.
• Listen well to everyone. Be careful not to assume you know what a child or adult at risk is thinking or feeling. Listen to what is being spoken and how it is said. At the same time, observe the individual’s body language to better understand what is being said.
• Be aware of any physical contact you may have with a child or adult at risk and record it when necessary. For instance, if you need to stop a fight, administer First Aid, give a hug to someone in distress, or protect yourself or others from danger.
• Do not make sexually suggestive comments about or to a child or adult at risk, even in ‘fun’.
• Do not scapegoat, belittle, ridicule or reject a child or adult at risk.
• Keep a record of any significant incidents or concerns on a Safeguarding Incident Form (see Appendix 3). Enter the names of all those present and anything of note which you observe, e.g. details of any fights broken up by the workers, allegations made, etc. All workers who witnessed the incident, overheard it or responded in any way should record the details and sign and date the form.

Specific considerations when working with children:
• Do not invade the privacy of children when they are using the toilet or showering
• The level of assistance with personal care (eg. toileting) must be appropriate and related to the age of the child, whilst also accepting that some children have special needs.
• Avoid rough games involving physical contact between a worker and a child
• Avoid sexually provocative games
• When it is necessary to discipline children, this should be done without using physical punishment. There may, however, on the rare occasion be circumstances where a child needs to be restrained in order to protect them or a third person.
• Only invite children and young people to your home or on trips in groups and always make sure that another worker is present.
• Notify the DPS of any children’s trips which take place in the name of the church. Parental permission must always be sought.
• Do not give lifts to children or young people on your own. Ensure that if transporting children as part of your church role, you have the correct insurance cover in place as well as parental permission.
• No person under 18 years of age should be left in sole charge of any children of any age. Nor should children or young people attending a group be left alone at any time.
No one should normally be left working alone with children, young people or adults at risk, but should instead work as part of a team. If there are insufficient leaders for groups:
• Internal doors should be left open.
• At least two people should be present before external doors are opened for an event.
• Consider whether you could combine groups together or rearrange planned activities.
• Reconsider whether you can run the group safely, carrying out a Risk Assessment to record your findings.

If workers do find themselves on their own with children or adults at risk, they should:
• Assess the risk of sending the child or adult at risk home.
• Phone another team member and let them know the situation.
• Train additional leaders as soon as possible.
If a child or adult at risk wants to talk on a one-to-one basis you should make sure that:
• You try to hold the conversation in a corner of a room where other people are present.
• You leave the door open if you are in a room on your own.
• Another team member knows where you are.

Consideration should be given to how many workers should be involved with the group and whether they should be male or female workers or both. See section 3.11 for recommended ratios. The only adults allowed to participate in children’s and adult at risk activities are those safely appointed and appropriately trained. The leader of the activity should be aware of any other adults who are in the building whilst the activity is running.

SECTION 3 – BEST PRACTICE GUIDELINES

The church is in an amazing position in society, with the opportunity to minister to individuals from the whole community, from the very young to the very old. These best practice guidelines are in place to help those working on behalf of the church to do it well, prioritising the safety and well-being of those they are working with. Whilst this section is divided into adults and children, some aspects of good practice will overlap.

3.1 – WORKING WITH CHILDREN

3.1.1 Ratios
When working with children the following recommended minimum ratios of workers to children apply:
Age range
The recommended minimum ratio for INDOOR activities Recommended minimum ratio for OUTDOOR activities
0 – 2 years 1:3 (minimum 2) 1:3 (minimum 2)
3 years 1:4 (minimum 2) 1:4 (minimum 2)
4 – 7 years 1:8 (minimum 2) 1:6 (minimum 2)
8 – 12 years 2 adults for up to 20 children (preferably one of each gender) with an extra adult for every 10 additional children 2 adults for up to 15 children (preferably one of each gender) with an extra adult for every 8 additional children
13 years and over 2 adults for up to 20 children (preferably one of each gender) with an extra adult for every 10 additional children 2 adults for up to 20 children (preferably one of each gender) with an extra adult for every 10 additional children

This does not take into account special circumstances such as behavioural issues, developmental issues, disability and so on, which may mean an increase to the recommended ratios. In calculating the ratios of workers to children, young leaders who are under the age of 18 should be counted as one of the children, not one of the workers.

3.1.2 Children with Special Needs
Children and young people who have a disability can be at greater risk of abuse. They will often require more help with personal care, such as washing, dressing, toileting, feeding, mobility, etc. Some children may have limited understanding and behave in a non-age-appropriate way. It is good practice to speak with the parents/carers of children/young people with special needs and find out from them how best to assist the child or young person.

3.1.3 Visiting Children or Young People at Home
It is unlikely that workers will need to make pastoral visits to children and their families at home on behalf of the church. If a situation occurs where it is needed then it should be done in pairs, and with the prior agreement of the Minister.

3.1.4 Children with no adult supervision
When children turn up to and want to join in with church activities without the knowledge of their parents/carers, workers will:
• Welcome the child and try to establish their name, age, address and telephone number.
• Record their visit in a register.
• Ask the child if a parent/carer is aware of where they are. Where possible, phone and make contact.
• Without interrogating the child, find out as soon as possible whether they have any specific needs (eg. medication) so that you can respond appropriately in an emergency.
• Give the child a consent form and explain it needs to be filled in and brought back next time.

3.1.5 Mentoring
If a worker is working with a young person as part of the recognised church mentoring programme:
• The parents of all young people involved in mentoring are required to sign a letter to say they are aware that the mentoring is happening and who it is with.
• Mentoring meetings should only be held in agreed places and should be in view of other people.
• A mentoring meeting should have an agreed start and end time, and someone should be aware that a meeting is taking place and where it is being held.
• A basic record should be kept of dates of significant meetings and any text messages or emails.
• Appropriate boundaries should be put in place in regard to times and demand, i.e. not phoning or texting late at night, etc.
• A written record should be kept of issues/decisions discussed at meetings.

3.1.6 Peer Group Activities for Young People
All youth activities will be overseen by named adults who have been selected in accordance with safer recruitment procedures. It is accepted that groups aged 16+ may benefit from being led and run by peers. In this situation, adult leaders will contribute to programme planning and reviews and will always be present to oversee any peer-led activities taking place.

3.1.7 Physical Contact
• Keep everything public. A hug within a group context is very different from one behind closed doors.
• Touch should be related to the child’s needs, not the workers.
• Touch should be age-appropriate and generally initiated by the child rather than the worker.
• Workers should avoid any physical activity that is, or may be thought to be, sexually stimulating to the adult or the child.
• Children are entitled to privacy to ensure their personal dignity.
• Children have the right to decide how much physical contact they have with others, except in exceptional circumstances such as when they need medical attention.
• When giving first aid (or applying sun cream, etc), workers should encourage the child to do what they can manage themselves but consider the child’s best interests and give appropriate help where necessary.
• Team members should monitor one another in the area of physical contact. They should help each other by constructively challenging anything which could be misunderstood or misconstrued.

3.1.8 Electronic Communications – Cyber Safety
Modern Technologies and Safe Communication
A worker’s role description will include an acknowledgement and approval of technologies such as email, social networking and mobile phone communications as a legitimate means of communicating with young people. It should also include the expectations of the church in relation to their use. On the general consent form, parents/carers sign to agree that the young person can receive such communications.

Young people also need to be aware of the protocols that workers follow in relation to electronic communications. It is important to remember that as well as the parent/carer, young people have a right to decide whether they want a worker to have their contact details and should not be pressurised otherwise.

It is not appropriate to use these communication methods with children aged 11 years and younger. For more information on cyber safety, please refer to the Baptist Union of Great Britain Cyber Safety Guide, which can be found on their website.

Email
Email should be limited to sharing generic information, for example, to remind young people about meetings. If email is being used, workers will ensure that they are accountable by copying each message to a designated email address. It is important workers use clear and unambiguous language to reduce the risk of misinterpretation, for example, avoiding inappropriate terms such as ‘love’ when ending an email.

Communicating using Instant Messaging (eg. Snapchat, Whatsapp, Instagram)
Instant messaging should be kept to an absolute minimum. Workers should save significant conversations and keep a log stating with whom and when they communicated.

Mobile Phones
Workers need to take care in using mobile phones to communicate with young people:
• Mobile phone use should primarily be for the purposes of information sharing.
• Workers should keep a log of significant conversations/texts.
• Any texts or conversations that raise concerns should be passed on to the worker’s supervisor.
• Workers should use clear language and should not use abbreviations like ‘lol’ which could mean ‘laugh out loud’ or ‘lots of love’.
• Paid workers will be issued with a mobile phone under a contract that provides itemised billing.
• Workers should not take photos of children, young people or adults at risk unless permission is sought in advance and should not store such photos on personal phones.

Social Networking
• Workers should have a site that is used solely for children’s / youth work communications and is totally separate from their own personal site. This is to ensure that all communication with children and young people is kept within public domains.
• Workers should not send private messages to children on social networks. Workers should ensure that all communications are transparent and open to scrutiny.
• Workers should not accept ‘friend’ or ‘following’ requests from children on their personal site, nor seek to be ‘friends’ or a ‘follower’ of any child known to them in a church context.

Taking Videos and Photographs of Children
Since the introduction of the Data Protection Act in 1998, churches must be very careful if they use still or moving images of clearly identifiable people. There are several issues to be aware of:
• Permission must be obtained, via the consent form, of all children who will appear in a photograph or video before the photograph is taken or footage recorded.
• It must be made clear why that person’s image is being used, what you will be using it for, and who might want to look at the pictures.
• If images are being taken at an event attended by large crowds, such as a sports event, this is regarded as a public area and permission from a crowd is not necessary.
• Many uses of photographs are not covered by the Data Protection Act 1998, including all photographs and video recordings made for personal use, such as a parent/carer taking photographs at school sports days or videoing a church nativity play.
• Children and young people under the age of 18 should not be identified by surname or other personal details, including email, postal address or telephone number.
• When using photographs of children and young people, it is preferable to use group pictures.

3.2 WORKING WITH ADULTS AT RISK

3.2.1 Premises
The church building will be made as accessible as possible to all people. Any restrictions to access, visibility, audibility, toilet facilities, lighting or heating will be addressed wherever possible, and where necessary, aids and adaptations put in place.

3.2.2 Language
Every effort will be taken to use appropriate language and suitable vocabulary, enabling the greatest level of inclusivity and accessibility. We will be mindful of the language used within worship and the language used to describe people (such as derogatory words focusing on aspects of someone’s disability, race or sexuality rather than the person themselves).

3.2.3 Worship
In all worship services, we will consider the varied requirements of our congregation and try to be as inclusive as possible, by:
• Providing some copies of large print type for all printed materials
• Speakers always facing the congregation and not covering their mouths when talking, enabling those who rely on lip-reading
• Describing what is being presented on a screen for those who cannot see it clearly
• Using inclusive language
• Using a variety of liturgy and resources to cater for different levels of understanding
• Using a microphone during times of open prayer so that all can hear
• Considering holding a service that specifically caters for certain groups of adults at risk, such as those with learning disabilities, the deaf or the visually impaired.

3.2.4 Insurance
We will take reasonable steps to safeguard adults at risk and will follow any specific safeguarding requirements as laid out by our insurance company.

3.2.5 Financial integrity
Arrangements are in place for dealing with money, financial transactions and gifts, as outlined below:
• Those who work with adults at risk may become involved in some aspects of personal finance – collecting pensions or benefits, shopping or banking, etc. If handling money for someone else, always obtain receipts or other evidence of what has been done.
• Workers should not seek personal financial gain from their position beyond any salary or recognised allowances or expenses.
• Workers should not be influenced by offers of money.
• Any gifts received should be reported to the church trustees, who should decide whether or not the gift can be accepted.
• Any money received by the church should be handled by two unrelated church workers.
• Care should be taken not to canvass for church donations from those adults who may be at risk, such as the recently bereaved.
• Workers should ensure that church and personal finances are kept apart to avoid any conflict of interest.
• If someone alters their will in favour of an individual known to them because of their church work or pastoral relationship, it should be reported to the trustees. Workers should not act as Executors for someone they know through their work or pastoral role, as this may lead to a conflict of interests.
• Expert legal advice should be sought on matters such as Power of Attorney and Appointeeship to ensure that the situation is clearly understood and is the most appropriate course of action for the adult at risk.

3.2.6 Photographs
Workers should make sure that they have the person’s permission to take a picture, and that the subject is happy with the intended use of the pictures. When taking group pictures, workers should remember to get permission from everyone who will be photographed.

3.2.7 Computers
All church computers will have suitable parental controls and blocks put on. Although this is not failsafe, it will make using the computers for inappropriate behaviour more difficult, whilst also protecting any vulnerable users. We will create a policy specifically for church computer use, including terms and conditions for use as well as what will happen if someone breaches these conditions.

3.2.8 Recordkeeping
It is good practice to record pastoral visits or meetings, noting the date, time, location, subject and any actions which are to be taken. The record of these meetings should stick to facts and try to avoid opinion. Any records of safeguarding allegations, concerns or disclosures should be passed on to the DPS and stored in a safe and secure manner for at least 75 years.

3.2.9 Pastoral Relationships
All those involved in pastoral ministry should work in a way that follows clearly defined procedures, which set out the boundaries to protect those carrying out the pastoral ministry as well as those receiving it:
• Workers should be aware of the power imbalance within pastoral relationships and the potential for abuse of trust.
• Behaviour that suggests favouritism or gives the impression of a special relationship, should be avoided.
• Workers should be aware of the dangers of dependency within a pastoral relationship.
• Workers should never take advantage of their role and engage in sexual activity with someone with whom they have a pastoral relationship.
• All people receiving pastoral ministry should be treated with respect and should be encouraged to make their own decisions about any actions or outcomes.
• Workers should not pastorally minister to anyone whilst under the influence of alcohol or drugs.
• Workers need to recognise the limits of their own abilities and competencies and get further help when working with situations outside of their expertise or role.

3.3 Health  And Safety – Safe Practice and Safe Premises

3.3.1 Consent forms
It is essential that we have important information about all children and young people involved in any activities at the church, which is recorded on our consent forms. The first week someone attends workers must record their name, medical emergency information and a contact name and number. Then they must bring their completed form back with them. Similar details will be gathered for adults at risk.

3.3.2 Health and Safety
All activities for children, young people and adults at risk will comply with the church’s current health and safety policy and will be conducted in accordance with Guidelines for users of Burgh Baptist Church, with particular attention paid to the sections on Fire Action, First Aid, PAT testing, Health and Safety and Kitchen and Food Hygiene.
Whenever possible, at all events involving food preparation, at least one worker will hold a valid Basic Food Hygiene Certificate.
Buildings being used for children’s and adult at risk groups will be properly maintained. A representative from the teams involved will take part in an annual health and safety review in order to consider all aspects of safety for everyone involved in using the premises.

3.3.3 Fire
It is the responsibility of all group leaders/responsible persons within the building to ensure the safety of themselves and those who are in their care. In addition, it is a legal requirement that all group leaders/responsible persons are familiar with the emergency procedures in the event of a fire.

3.3.4 First Aid
Our church has a number of trained First Aiders and there is a list showing who they are on the noticeboard. All church groups will ensure that they have sufficient trained first aiders on their regular team so that there is always a first aider present at events and activities.
We have two first aid kits (one for adults and one for under 18s) as well as an incident reporting book, which must be completed in the event of any accidents, injuries or incidents. A first aid kit must also be available for external events. A nominated individual will ensure that the contents of the first aid kits are checked on a regular basis. Completed accident forms should be passed on to the nominated individual.
3.3.5 Supervision of Groups
The person responsible for a group/activity must sign in at the start and end of that activity so that it is apparent who the ‘responsible person’ for that activity is – even if you were already in the building or are staying on afterwards. You also need to make sure that you keep a register so that you know who is on the premises.

3.3.6 Food Hygiene
The Food Hygiene (England) Regulations 2013 state that anyone who handles food or whose actions could affect its safety must comply with the regulations. It therefore follows that those with responsibility for food will need to possess the Basic Food Hygiene Certificate and be aware of food safety (preparation, handling and storage, disposal of waste, etc).

3.3.7 Risk Assessment
Before undertaking any activity with children or adults at risk, the leader will ensure that a risk assessment is carried out. It is advisable to appoint someone specifically for this task.

3.3.8 Insurance
Residential activity organisers will check that there is adequate insurance cover for any activities planned. If the trip is at a centre it is also important to establish that there is appropriate public liability insurance in place.

3.3.9 Transport
These guidelines apply to all drivers involved in the transportation of children, young people and adults at risk on behalf of the church. They do not apply to private arrangements, for example, transport arrangements made between friends.
• Only those who have gone through the church safer recruitment procedures for workers will transport children and adults at risk (within the DBS eligibility criteria).
• All drivers will have read the church’s Safeguarding Policy and agree to abide by it.
• Drivers will be aged 21 or over and have held a full driving licence for at least two years.
• Drivers must ensure that they have adequate insurance cover and that the vehicle being used is road worthy.
• All hired minibuses will have a small bus permit, the necessary insurance and a driver with a valid driving licence that entitles them to drive a minibus.

Our practice specifically for transporting children is as follows:
• Parental consent will be given for all journeys.
• All children and young people should be returned to an agreed drop off point. At collection or drop off points, children should never be left on their own; make sure they are collected by an appropriate adult.
• At least two workers should be present when transporting children as part of a church role.

3.3.10 Outings and Overnight Events involving Children
There are some specific considerations that need to be made for outings and overnight events involving children:
• A risk assessment must be carried out beforehand.
• Parents will be informed in writing of all the arrangements.
• Consent forms will be obtained for the specific activities involved.
• There will be workers with first aid and food hygiene certificates with the group.

Sleeping Arrangements
Sleeping arrangements for overnight events will be carefully considered. It may be acceptable for workers to share sleeping accommodation with children/young people in a large dormitory or on an activity such as youth hostelling, where it is customary practice and there is more than one worker per room. Workers will not share sleeping accommodation with fewer than three children. Arrangements will be age-appropriate, provide security for the child/young person and be safe for everyone involved. The event leader will ensure that parents understand what the arrangements will be and are happy with them.

Adventurous Activities
No child will participate in adventurous activities without the written consent of the parent /carer. The activity leader will ensure that the staff engaged in such activities are properly trained and qualified and that the correct ratio of staff to children is met. At an activity centre or for an organisation whose own staff undertake such activities, if the activities come within the scope of the Adventure Activities Licensing Regulations 2004, the activity leader needs to ensure that the premises are licensed.

Fire Safety
The event leader will have a fire safety procedure in place, which will include the following:
• Everyone will be warned of the danger of fire. If the overnight event is in a building, then everyone must be made aware of the fire exits. A fire drill will be practised on the first day.
• When using a building as a residential facility, ensure that the fire alarm is audible throughout the accommodation and that all signs and exits are clearly visible. The building will also need to comply with fire regulations.
• In the case of an emergency, ensure measures are in place to alert children and young people with disabilities (e.g. a child who is hard of hearing).

Safety
It is the responsibility of the workers to always know the whereabouts of every child/young person participating in an overnight event, and this may include monitoring access on and off the site.
General safety rules will be applied as appropriate (e.g. no running around tents due to the risk of injury from tripping over guy lines).

Swimming Trips
There will be an increased adult to child ratio for swimming trips. Prior to the trip, workers will establish the swimming ability of the children attending and obtain specific consent. Workers should never change in front of the children.

3.3.11 Outings and Overnight Events involving Adults at Risk
As with outings and events for children, there are additional considerations for a group taking adults with additional needs, such as learning difficulties or mental health needs, on outings or overnight events:

• A risk assessment must be carried out beforehand
• Planning for the trip should take into account specific medical, physical and support needs of each group member, bearing in mind that there may be people in the group who have individual care needs that will have to be met (including personal care)
• Adults at risk should be included in the planning of trips and events
• Consideration should be given to the suitability and accessibility of the venue and accommodation, travel time and mode of transport, and the affordability of the event
• Adults at risk should be given all the information about the trip beforehand so that they know where they are going, how long it will take to get there and what type of activities they will be taking part in.
• There should be a minimum of two leaders with each group; the individual needs of those attending may determine the additional number of people required.

Sleeping Arrangements
Consideration should be given to the individual needs of those staying overnight. If there is a need for personal care or additional support during the night, it would be better than the person’s usual caregiver who also attends the event and therefore shares a room with them.

Personal Care
It is not appropriate for church workers to perform personal care for adults at risk unless this is their usual task (ie if they have come along to help generally, but also have a caring role for a member of the group, they can provide personal care for that person).

Activities
Leaders should consider the mobility needs of the group when deciding on activities or events. For example, if members of the group have difficulty walking, then including a walking tour around a town may be inaccessible to some who are attending. If you have members of the group who use wheelchairs then consideration needs to be given as to whether you have sufficient workers to support those who may need pushing.

Safety
It is the responsibility of the workers to always know the whereabouts of every person in the group; this may include monitoring access on and off the site.
General safety rules will be applied as appropriate and advice sought from the event organiser/venue about the fire evacuation procedures. A copy of the event/venue risk assessment should be included with the group leader’s risk assessment.

Consent and Medical Information
It is important to recognise that adults at risk are mostly able to give consent for their own involvement in activities, inclusion in photographs and medical treatment. However, in some situations, the question of capacity may arise. The guidelines clearly state that an adult at risk should have a say in their care and any arrangements made for them, however, there may be occasions when you need to involve others in decision making. In these situations, seek advice from the DPS with regard to who should be involved.
A medical consent form should be completed by each member of the group and held by the leader. This will include any health concerns, emergency contact information and contact details for their GP. This will allow emergency medical personnel to have access to information should the need arise.

Holding and Dispensing of Medication
Church workers should never agree to hold or dispense medication for those on an event. If someone is unable to manage their own medication, then consideration should be given as to whether their usual carer could attend with them or whether they will not be able to attend the event.

3.3.12 Hiring of Church Premises
The responsible adult for an activity held at Burgh Baptist Church must attend a training session based on the Baptist Union of Great Britain Guidance Leaflet PC10: Hiring of Church Premises.

3.4 SAFER COMMUNITY

3.4.1 Bullying
Bullying is another form of abuse, and it can be verbal or physical. Bullying doesn’t just happen to children, often adults can be victims too. There is no legal definition of bullying, but it is usually defined as a repeated pattern of behaviour intended to cause emotional or physical harm to another person or exert power over them. The effect of bullying on the victim can be profound, both emotionally and physically, regardless of their age, ability or status.
It is important to recognise that bullying happens within churches, and it is not isolated to the children and young people. Anyone in the church can be a victim of bullying, just as anyone in the church can be the bully, including those in leadership.
Some examples of bullying that could arise in the church context are:
• Being verbally or physically abusive towards another person
• Isolating or deliberately ignoring someone, or excluding them from group activities
• Spreading rumours and malicious untruths about another person in the church
• Use of email, phone or social media to publicly challenge or undermine someone
• Name calling and personal insults
• Making false accusations
• Sending abusive messages or degrading images via phone, email or social media
Bullying will always cause a great deal of pain and harm for those on the receiving end. Many people affected by bullying, both children and adults, believe they have nowhere to turn. They are scared to speak out and often blame themselves. They can become fearful and reclusive. It is important that churches are able to recognise when bullying is occurring and are prepared to take action to resolve the situation.
Some signs that can indicate a person is being bullied are as follows:
• Withdrawal from group or church activities; appearing anxious, tearful or more reticent than usual, particularly in a certain context; development of mental health difficulties, such as depression or anxiety disorders; drop in performance relating to any church roles; physical injuries.
In order to help prevent bullying, the following procedures will be adopted within the church:
• The children and young people will be involved in agreeing a code of behaviour for their groups, which makes it clear that bullying is unacceptable. This should then be displayed somewhere visible to the whole church.
• The church will display signs stating the importance of valuing and respecting each other even in disagreements and this will be practically embedded into the leadership approach to others.
• Everyone in the church, whether children or adults, should know how they can report any incidents of bullying.
• All allegations of bullying will be treated seriously, and details will be carefully checked before action is taken.
• The bullying behaviour will be investigated, and bullying will be stopped as quickly as possible.
• An attempt will be made to help bullies change their behaviour.
• All allegations and incidents of bullying will be recorded, together with the actions that are taken.
• Where an allegation of bullying is made against a church or group leader, advice will be sought from the local Baptist Association Safeguarding Contact as this should be addressed.
• Incidents of bullying may be reported to the statutory authorities in line with the church safeguarding procedures.

It is important to distinguish bullying from other behaviour, such as respectfully challenging or disagreeing with someone else’s beliefs or behaviours, setting reasonable expectations with regard to work deadlines and activities or taking legitimate disciplinary action.

3.4.2 Working with Alleged or Known Offenders
When someone attending the church is known to have abused children or adults at risk, or a serious allegation has been made, the church safeguarding team will supervise the individual concerned and offer pastoral care, but in its commitment to protecting vulnerable groups, will set boundaries for that person which they shall be expected to keep. These will be set out in what is known as a Safeguarding Contract.
When it is known that a person who has been convicted of abusing children, young people or adults is attending our church, it is important that their behaviour within the church community is properly managed and that a contract is put in place. There are also times when it will be appropriate to take such measures with a person who has faced allegations of abuse but hasn’t been convicted.

In determining the details of the contract:
• The DPS will inform and take advice from the local Baptist Association Safeguarding Contact.
• There will be a discussion about who should be informed about the nature of the offence and the details of the contract.
• The rights of the offender to re-build their life without people knowing the details of their past offence should be balanced against the need to protect children, young people and adults at risk.
• The members of the church Safeguarding Team will always be informed.
• The DPS should determine whether the person is subject to supervision or is on the Sex Offenders’ Register. If so, the DPS should make contact with the offender’s specialist probation officer (SPO) who will inform the church of any relevant information or restrictions that they should be aware of.

An open discussion will be held with the person concerned in which clear boundaries are established for their involvement in the life of the church. A written contract will be drawn up which identifies appropriate behaviour. The person will be required to sign the contract and it will be monitored and enforced. If the contract is broken certain sanctions will be discussed and considered with the local Baptist Association Safeguarding Contact.

3.4.3 Alleged or known offenders who are themselves, adults, at risk
A formal contract may be quite a daunting process for someone with learning difficulties or a young person yet having safeguards in place is still necessary. Therefore, an alternative may be to arrange a meeting with the individual in question where they can be taken though the main elements of a formal contract in a way that is non-threatening and easy to understand. Notes would be taken, and the individual would need to verbally agree to the requirements laid out in the meeting.

Rather than signing a formal ’contract’, the individual would instead sign to say that they agree with the minutes or meeting notes and that they will stick to what has been agreed during the meeting. This will result in the same outcome as a contract but is a more informal and appropriate approach for an adult at risk. The agreed requirements will need to be reviewed regularly to make sure that the individual is complying, exactly as a formal contract would be.

SECTION 4 – USEFUL CONTACTS

Local Authority Designated Officer (LADO)
Lynsey Norris 01522 730 325 email [email protected]

Police
Contact 101, or 999 in an emergency

Lincolnshire Adult Safeguarding Services
8.45am—5pm 01522 782 155
Out of hours 01522 782 333

Lincolnshire Children’s Safeguarding Services
8.45am—5pm 01522 782 111
Out of hours 01522 782 333

Local Baptist Association Safeguarding Contact
Based in Nottingham Alan Davies 07963675951 email [email protected]
Based in N Lincs Helen Parker 07726923565 email [email protected]

APPENDIX 1 – DEFINITIONS OF ABUSE

Understanding, Recognising and Responding to Abuse
Abuse and neglect are forms of maltreatment of a child or adult at risk. Somebody may abuse or neglect a child or adult by inflicting harm, or by failing to act to prevent harm. Children and adults at risk may be abused in a family, or in an institutional or community setting; by those known to them or, more rarely, by a stranger. They may be abused by an adult or adults or a child or children. There are many different ways in which people suffer abuse. The list below is, sadly, not exhaustive.

Type of abuse  Child/ Adult at risk
Physical Actual or likely physical injury to a child, or failure to prevent physical injury to a child. To inflict pain, physical injury or suffering to an adult at risk.
Emotional The persistent, emotional, ill treatment of a child that affects their emotional and behavioural development. It may involve conveying to the child that they are worthless and unloved, inadequate, or that they are given responsibilities beyond their years. The use of threats, fear or power gained by another adult’s position, to invalidate the person’s independent wishes. Such behaviour can create very real emotional and psychological distress. All forms of abuse have an emotional component.
Sexual involves forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening. This includes non-contact activities, such as involving children in looking at, or in the production of, pornographic material or watching sexual activities or encouraging children to behave in sexually inappropriate ways. Any non-consenting sexual act or behaviour.

No one should enter into a sexual relationship with someone for whom they have pastoral responsibility or hold a position of trust.

Neglect
Where adults fail to care for children and protect them from danger, seriously impairing health and development. A person’s wellbeing is impaired and their care needs are not met. Neglect can be deliberate or can occur as a result of not understanding what someone’s needs are.

Type of Abuse Additional Definitions
Financial The inappropriate use, misappropriation, embezzlement or theft of money, property or possessions.
Spiritual The inappropriate use of religious belief or practice; coercion and control of one individual by another in a spiritual context; the abuse of trust by someone in a position of spiritual authority (e.g. minister). The person experiences spiritual abuse as a deeply emotional personal attack.
Discrimination
The inappropriate treatment of a person because of their age, gender, race, religion, cultural background, sexuality or disability.
Institutional The mistreatment or abuse of a person by a regime or individuals within an institution. It can occur through repeated acts of poor or inadequate care and neglect, or poor professional practice or ill-treatment. The church as an institution is not exempt from perpetuating institutional abuse.
Domestic Abuse Domestic abuse is any threatening behaviour, violence or abuse between adults who are or have been in a relationship, or between family members. It can affect anybody regardless of their age, gender, sexuality or social status.
Domestic abuse can be physical, sexual or psychological, and whatever form it takes, it is rarely a one-off incident. Usually, there is a pattern of abusive and controlling behaviour where an abuser seeks to exert power over their family member or partner.
Cyber Abuse The use of information technology (email, mobile phones, websites, social media, instant messaging, chatrooms, etc.) to repeatedly harm or harass other people in a deliberate manner.
Self-harm is the intentional damage or injury to a person’s own body. It is used as a way of coping with or expressing overwhelming emotional distress. An individual may also be neglecting themselves, which can result in harm to themselves.
Mate crime ‘Mate crime’ is when people (particularly those with learning disabilities) are befriended by members of the community, who go on to exploit and take advantage of them.
Modern Slavery Modern slavery is the practice of treating people as property; it includes bonded labour, child labour, sex slavery and trafficking. It is illegal in every country of the world.
Human Trafficking Human trafficking is when people are bought and sold for financial gain and/or abuse. Men, women and children can be trafficked, both within their own countries and over international borders. The traffickers will trick, coerce, lure or force these vulnerable individuals into sexual exploitation, forced labour, street crime, domestic servitude or even the sale of organs and human sacrifice.
Radicalisation The radicalisation of individuals is the process by which people come to support any form of extremism and, in some cases, join terrorist groups. Some individuals are more vulnerable to the risk of being groomed into terrorism than others.
Honour / Forced Marriage An honour marriage / forced marriage is when one or both of the spouses do not, or cannot, consent to the marriage. There may be physical, psychological, financial, sexual and emotional pressure exerted in order to make the marriage go ahead. The motivation may include the desire to control unwanted behaviour or sexuality.

Female Genital Mutilation Female genital mutilation (FGM) comprises all procedures involving partial or total removal of the female external genitalia or other injury to the female genital organs for non-medical reasons as defined by the World Health Organisation (WHO). FGM is a cultural practice common around the world and is largely performed on girls aged between 10 and 18. Performing acts of FGM is illegal in the UK as is arranging for a child to travel abroad for FGM to be carried out.
Historic Abuse Historic abuse is the term used to describe disclosures of abuse that were perpetrated in the past. Many people who have experienced abuse don’t tell anyone what happened until years later, with around one-third of people abused in childhood waiting until adulthood before they share their experience.

Whilst it is not possible to be prescriptive about the signs and symptoms of abuse and neglect, the following list sets out some of the indicators which might be suggestive of abuse:
 unexplained injuries on areas of the body not usually prone to such injuries
 an injury that has not been treated/received medical attention
 an injury for which the explanation seems inconsistent
 a child or adult at risk discloses behaviour that is harmful to them
 unexplained changes in behaviour or mood (e.g. becoming very quiet, withdrawn or displaying sudden bursts of temper)
 inappropriate sexual awareness in children
 signs of neglect, such as undernourished, untreated illnesses, inadequate care.

It should be recognised that this list is not exhaustive and the presence of
one or more indicators is not in itself proof that abuse is actually taking place.
It is also important to remember that there might be other reasons why most of the above are occurring

APPENDIX 2 – DETAILED GUIDANCE ON REPORTING REQUIREMENTS

STAGE 1 – THE WORKER
The duty of the person who receives information or who has a concern about the welfare of a child, young person or adult at risk is to RECOGNISE the concerns, make a RECORD in writing and RESPOND by passing on their concerns to the DPS. If he/she is not contactable, or they are implicated in the situation, another member of the church Safeguarding Team should be contacted instead.
Concerns should be passed on to the DPS within 24 hours of the concern being raised. If anyone is considered to be in imminent danger of harm, a report should be made immediately to the police by calling 999. If such a report is made without reference to the DPS, they should be informed as soon as possible afterwards.
A written record using the standard incident report form should be made as soon as possible after a child or adult at risk tells you about harmful behaviour, or an incident takes place that gives cause for concern.
The record should:
• be hand-written as soon as possible after the event
• be legible and state the facts accurately (when hand-written notes are typed up later the original hand-written notes should be retained)
• include the child or adult at risk’s name, address, date of birth (or age if the date of birth is not known)
• include the nature of the concerns/allegation/disclosure
• include a description of any bruising or other injuries that you may have noticed
• include an exact record of what the child or adult at risk has said, using their own words where possible
• include what was said by the person to whom the concerns were reported
• include any action taken as a result of the concerns
• be signed and dated
• be kept secure and confidential and made available only to the church Safeguarding Team (including the church minister), representatives of any statutory authorities involved and the local Baptist association.

If concerns arise in the context of children’s or adult at risk work, the worker who has the concern may in the first instance wish to talk it through with their group leader, where appropriate. However, such conversations should not delay concerns being passed on to the DPS. It should be clear that the duty remains with the worker to record and pass on their concerns to the DPS.
If an issue concerns an adult at risk who does not give permission to pass on the information to anyone else, the worker should explain that they will need to speak with the DPS, who will have greater expertise in dealing with the issue at hand.
If a concern is brought to the attention of a group leader by one of the workers, the leader should remind the worker of their duty to record and report and will also themselves have a duty to pass on the concern to the DPS.

STAGE 2 – THE DESIGNATED PERSON FOR SAFEGUARDING (DPS)
The duty of the DPS on receiving a report is to REVIEW the concern that they have received and REPORT the concern on to the appropriate people, where necessary.

The duty to REVIEW
In reviewing the report that is received, the DPS:
• should take into account their level of experience and expertise in assessing risk to children or adults at risk.
• must take into account any other reports that have been received concerning the same individual or family.
• may speak with others in the church where appropriate (including the Minister and church Safeguarding Team, unless allegations involve them) who may have relevant information and knowledge that would impact on any decision being made. Such conversations should not lead to undue delay in taking any necessary action.
• may consult with other agencies to seek guidance and advice in knowing how to respond appropriately to the concerns that have been raised.

The duty to REPORT
The DPS will decide who the report should be referred on to, working in conjunction with the church Safeguarding Team where appropriate. They may:
• refer back to the worker who made the initial report if there is little evidence that a child or adult at risk is being harmed, asking for appropriate continued observation.
• refer the concern to others who work with the child or adult at risk in question, asking for continued observation where appropriate.
• Inform parents/carers under certain circumstances, where doing so would not present any further risk of harm.
• Make a formal referral to the police or local Social Services team. With adults at risk, confidentiality means that someone’s personal business is not discussed with others, except with their permission. This is not always possible when considering passing relevant information about abuse or concerns to the statutory authorities, however, it is possible to keep the information confidential to the relevant parties. This means not telling or hinting to others what has been disclosed, not even for prayer ministry purposes. For adults at risk, concerns will only be referred to the police or Social Services without consent where:
 the person lacks the mental capacity to make such a choice
 there is a risk of harm to others
 in order to prevent a crime
 If an allegation is made against someone who works with children* the allegation should be reported to the Local Authority Designated Officer (LADO) or equivalent. The LADO is located within Children’s Services and should be alerted to all cases in which it is alleged that a person who works with children has:
 behaved in a way that has harmed, or may have harmed, a child
 possibly committed a criminal offence against children or related to a child
 behaved towards a child or children in a way that indicates s/he is unsuitable to work with children.
• If an allegation is made against someone who works with adults at risk*, it should be reported to the police or Adult Social Services.
*If a worker has an allegation made against them, they should step down from all church duties until the incident has been investigated by the statutory authorities. It may also be appropriate to put a Safeguarding Contract in place; this should be discussed with the local Baptist Association Safeguarding Contact.
• Whenever a formal referral is made to the police, Social Services or LADO, the DPS should report the referral to:
 The Safeguarding Trustee
 The Minister
 The local Baptist Association Safeguarding Contact

A record should be kept of all safeguarding incidents and should be considered in the annual review of the church’s safeguarding policy. All original reports should be retained safely and securely by the DPS and a written record should be made of the actions taken.

STAGE 3 – THE NEXT STEPS

Responsibilities to REPORT and SUPPORT in stage 3 of the process are shared by the church Safeguarding Team and the Minister.

The duty to SUPPORT
Once concerns, suspicions and disclosures of abuse have been addressed, the church continues to have a responsibility to offer support to all those who have been affected, including:
Victims; Alleged perpetrators; Children; Adults at risk; Other family members; Church workers; Church Safeguarding Team; Minister; Leadership Team.

The duty to REPORT
If a church worker has been accused of causing harm to children, young people or adults at risk this would be classed as a serious incident that should be reported to the Charity Commission by those churches that are registered with the Charity Commission.
If a worker has been removed from their post or would have been removed from their post because of the risk of harm that they pose to children, young people or adults at risk, there is also a statutory duty to report the incident to the Disclosure and Barring Service (DBS).

For more information:

Please see www.baptist.org.uk for more information about safeguarding in Baptist churches, including a range of specialist guides and a library of free downloadable resources.

BUGB Excellence in Safeguarding training for your church:
Information and booking arrangements for the BUGB Levels 2 and Level 3 Excellence in Safeguarding training can be made through your local Baptist association team. Please see their website for details of nearby courses or the opportunity to host safeguarding training at your church.

In an emergency:
If you find yourself facing an emergency situation, where you believe that someone attending your church is being harmed or is at imminent risk of harm, please ring the police on 999 and ask to speak to an officer in the child or adult protection teams. Always keep records and let your DPS know that you have made this call.

Becky-001
DESIGNATED PERSON FOR SAFEGUARDING Rebecca Baggaley Phone 07508413276 Email: [email protected]
DEPUTY PERSON FOR SAFEGUARDING Julia Page Phone 07443455890 Email: [email protected]

Burgh Baptist Church Data Protection Policy

Burgh Baptist Church is committed to protecting all information that we handle about people we support and work with, and to respecting people’s rights around how their information is handled. This policy explains our responsibilities and how we will meet them.

Contents

Section A – What this policy is for ……………………………………………………………….4
1. Policy statement ………………………………………………………………………………………….4
2. Why this policy is important ………………………………………………………………………4
3. How this policy applies to you & what you need to know …………………….5
4. Training and guidance ………………………………………………………………………………….6
Section B – Our data protection responsibilities ……………………………………….6
5. What personal information do we process? ……………………………………………6
6. Making sure processing is fair and lawful ………………………………………………..7
7. When we need consent to process data …………………………………………………..9
8. Processing for specified purposes ……………………………………………………………..9
9. Data will be adequate, relevant and not excessive ………………………………….9
10. Accurate data ……………………………………………………………………………………………….9
11. Keeping data and destroying it …………………………………………………………………9
12. Security of personal data ………………………………………………………………………….10
13. Keeping records of our data processing …………………………………………………10
Section C – Working with people we process data about (data subjects) 10
14. Data subjects’ rights ……………………………………………………………………………………10
15. Direct marketing ………………………………………………………………………………………….11
Section D – working with other organisations & transferring data ………….11
16. Sharing information with other organisations ………………………………………11
17. Data processors …………………………………………………………………………………………..12
18. Transferring personal data outside the United Kingdom (UK) …………..12
Section E – Managing change & risks ……………………………………………………………..12
19. Data protection impact assessments ………………………………………………………12
20. Dealing with data protection breaches …………………………………………………..13
Schedule 1 – Definitions and useful terms ……………………………………………………14
Schedule 2 – ICO Registration ………………………………………………………………………..16
Schedule 3 – Appropriate Policy Document …………………………………………………17

 

 

Section A – What this policy is for

1.         Policy statement

1.1       Burgh Baptist Church is committed to protecting personal data and respecting the rights of our data subjects; the people whose personal data we collect and use. We value the personal information entrusted to us and we respect that trust, by complying with all relevant laws, and adopting good practice.

We process personal data to help us:

a)         maintain our list of church members and regular attenders;

b)         provide pastoral support for members and others connected with our church;

c)         provide services to the community including Parish Nursing;

d)         safeguard children, young people and adults at risk;

e)         recruit, support and manage staff and volunteers;

f)          maintain our accounts and records;

g)         promote our services;

h)         maintain the security of property and premises;

i)           respond effectively to enquirers and handle any complaints

1.2          This policy has been approved by the church’s charity trustees who are responsible for ensuring that we comply with all our legal obligations. It sets out the legal rules that apply whenever we obtain, store or use personal data.

2.         Why this policy is important

2.1          We are committed to protecting personal data from being misused, getting into the wrong hands as a result of poor security or being shared carelessly, or being inaccurate, as we are aware that people can be upset or harmed if any of these things happen.

2.2          This policy sets out the measures we are committed to taking as an organisation and, what each of us will do to ensure we comply with the relevant legislation.

2.3          In particular, we will make sure that all personal data is:

a)    processed lawfully, fairly and in a transparent manner;

b)    processed for specified, explicit and legitimate purposes and not in a manner that is incompatible with those purposes;

c)    adequate, relevant and limited to what is necessary for the purposes for which it is being processed;

d)    accurate and, where necessary, up to date;

e)    not kept longer than necessary for the purposes for which it is being processed;

f)     processed in a secure manner, by using appropriate technical and organisational means;

g)    processed in keeping with the rights of data subjects regarding their personal data.

3.         How this policy applies to you & what you need to know

3.1          As an employee, trustee or volunteer processing personal information on behalf of the church, you are required to comply with this policy. If you think that you have accidentally breached the policy, it is important that you contact our Data Protection Officer  immediately so that we can take swift action to try and limit the impact of the breach.

Anyone who breaches the Data Protection Policy may be subject to disciplinary action, and where that individual has breached the policy intentionally, recklessly, or for personal benefit they may also be liable to prosecution or to regulatory action.

3.2          As a leader/manager: You are required to make sure that any procedures that involve personal data, that you are responsible for in your area, follow the rules set out in this Data Protection Policy.

3.3          As a data subject of Burgh Baptist Church; We will handle your personal information in line with this policy.

3.4          Our Data Protection Officer is responsible for advising Burgh Baptist Church and its staff and members about their legal obligations under data protection law, monitoring compliance with data protection law, dealing with data security breaches and with the development of this policy. Any questions about this policy or any concerns that the policy has not been followed should be referred to them at [email protected]

3.5          Before you collect or handle any personal data as part of your work (paid or otherwise) for Burgh Baptist Church, it is important that you take the time to read this policy carefully and understand what is required of you, as well as the organisation’s responsibilities when we process data.

3.6          Our procedures will be in line with the requirements of this policy, but if you are unsure about whether anything you plan to do, or are currently doing, might breach this policy you must first speak to the Data Protection Officer.

4.         Training and guidance

4.1          We will provide general training at least annually for all staff to raise awareness of their obligations and our responsibilities, as well as to outline the law. 

4.2          We may also issue procedures, guidance or instructions from time to time. 

Section B – Our data protection responsibilities

5.         What personal information do we process?

5.1          In the course of our work, we may collect and process information (personal data) about many different people (data subjects). This includes data we receive straight from the person it is about, for example, where they complete forms or contact us. We may also receive information about data subjects from other sources including, for example, previous employers and referees.

5.2          We process personal data in both electronic and paper form and all this data is protected under data protection law. The personal data we process can include information such as names and contact details, education or employment details, references and visual images of people.

5.3          In some cases, we hold types of information that are called “special categories” of data in the UK GDPR.

 

‘Special categories’ of data (as referred to in the UK GDPR) includes information about a person’s: racial or ethnic origin; political opinions; religious or similar (e.g. philosophical) beliefs; trade union membership; health (including physical and mental health, and the provision of health care services); genetic data; biometric data; sexual life and sexual orientation.

Special category personal data does not include personal data about criminal allegations, proceedings or convictions, as separate rules apply. Other than in the circumstances described in paragraphs 5.4 to 5.8 below, information relating to criminal convictions and offences should not be processed unless the processing is authorised by law or is carried out under the control of official authority. Special category personal data can only be processed under strict conditions, including the data subject’s explicit consent (although other alternative conditions can apply in limited, very specific circumstances as described below).

We will not hold information relating to criminal proceedings or offences or allegations of offences unless there is a clear lawful basis to process this data.  

5.4          We may process information relating to criminal proceedings or offences or allegations of offences to safeguard against any risks posed to others under Article 6(1)(f) UK GDPR where the processing is necessary for the purposes of the legitimate interests of Burgh Baptist Church but not where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

5.5          We may also process special category or criminal convictions etc data (“criminal offence data”) where it fulfils one of the substantial public interest conditions under Schedule 1, Part 2 of the Data Protection Act 2018, in particular, Conditions 10, 11, 12, 18 and 19. 

5.6          We may also seek to obtain, use and retain criminal offence data in reliance upon Condition 31 relating to criminal convictions under Schedule 1, Part 3 of the Data Protection Act 2018.

5.7          For the purposes of Schedule 1, Part 4 of the Data Protection Act 2018, more information about Burgh Baptist Church processing of special category and criminal convictions data under Conditions 10, 11, 12, 18, 19 and 31 can be found in the “Appropriate Policy Document” in Schedule [3] of this policy.

5.8          The processing of special category and criminal convictions data described in paragraphs 5.4 to 5.8  will only ever be carried out on the advice of statutory authorities, the Ministries Team of the Baptist Union of Great Britain or our Regional Association Safeguarding contact person.

5.9          Other data may also be considered ‘sensitive’ such as bank details but will not be subject to the same legal protection as the types of data listed above.

6.         Making sure processing is fair and lawful

6.1          Processing of personal data will only be fair and lawful when the purpose for the processing meets a legal basis, as listed below, and when the processing is transparent. This means we will provide people with an explanation of how and why we process their personal data at the point we collect data from them, as well as when we collect data about them from other sources.

How can we legally use personal data?

6.2          Processing of personal data is only lawful if at least one of these legal conditions, as listed in Article 6 of the UK GDPR, is met:

a)         the processing is necessary for a contract with the data subject;

b)         the processing is necessary for us to comply with a legal obligation;

c)         the processing is necessary to protect someone’s life (this is called “vital interests”);

d)         the processing is necessary for us to perform a task in the public interest, and the task has a clear basis in law;

e)         the processing is necessary for legitimate interests pursued by Burgh Baptist Church or another organisation, unless these are overridden by the interests, rights and freedoms of the data subject.

f)          If none of the other legal conditions apply, the processing will only be lawful if the data subject has given their clear consent.

How can we legally use ‘special categories’ of data?

6.3          Processing of ‘special categories’ of personal data is only lawful when, in addition to the conditions above, one of the extra conditions, as listed in Article 9 of the UK GDPR, is met. These conditions include where:

a)         the processing is necessary for carrying out our obligations under employment and social security and social protection law;

b)         the processing is necessary for safeguarding the vital interests (in emergency, life or death situations) of an individual and the data subject is incapable of giving consent;

c)         the processing is carried out in the course of our legitimate activities and only relates to our members or persons we are in regular contact with in connection with our purposes;

d)         the processing is necessary for pursuing legal claims.

e)         If none of the other legal conditions apply, the processing will only be lawful if the data subject has given their explicit consent.

6.4          Before deciding which condition should be relied upon, we may refer to the original text of the UK GDPR as well as any relevant guidance, and seek legal advice as required.

What must we tell individuals before we use their data?

6.5          If personal data is collected directly from the individual, we will inform them about; our identity/contact details, the reasons for processing, and the legal bases, explaining our legitimate interests, and explaining, where relevant, the consequences of not providing data needed for a contract or statutory requirement; who we will share the data with; if we plan to send the data outside of the United Kingdom; how long the data will be stored and the data subjects’ rights.

This information is commonly referred to as a ‘Privacy Notice’.

This information will be given at the time when the personal data is collected.

6.6          If data is collected from another source, rather than directly from the data subject, we will provide the data subject with the information described in section 6.5 as well as: the categories of the data concerned; and the source of the data.

This information will be provided to the individual in writing and no later than within 1 month after we receive the data, unless a legal exemption under the UK GDPR applies. If we use the data to communicate with the data subject, we will at the latest give them this information at the time of the first communication.

If we plan to pass the data onto someone else outside of Burgh Baptist Church, we will give the data subject this information before we pass on the data.

7.         When we need consent to process data

7.1          Where none of the other legal conditions apply to the processing, and we are required to get consent from the data subject, we will clearly set out what we are asking consent for, including why we are collecting the data and how we plan to use it. Consent will be specific to each process we are requesting consent for and we will only ask for consent when the data subject has a real choice whether or not to provide us with their data.

7.2          Consent can however be withdrawn at any time and if withdrawn, the processing will stop. Data subjects will be informed of their right to withdraw consent and it will be as easy to withdraw consent as it is to give consent.

8.         Processing for specified purposes

8.1          We will only process personal data for the specific purposes explained in our privacy notices (as described above in section 6.5.) or for other purposes specifically permitted by law. We will explain those other purposes to data subjects in the way described in section 6, unless there are lawful reasons for not doing so.

9.         Data will be adequate, relevant and not excessive

9.1          We will only collect and use personal data that is needed for the specific purposes described above (which will normally be explained to the data subjects in privacy notices). We will not collect more than is needed to achieve those purposes. We will not collect any personal data “just in case” we want to process it later.

10.      Accurate data

10.1       We will make sure that personal data held is accurate and, where appropriate, kept up to date. The accuracy of personal data will be checked at the point of collection and at appropriate points later on.

11.      Keeping data and destroying it

11.1       We will not keep personal data longer than is necessary for the purposes that it was collected for. We will comply with official guidance issued to our sector about retention periods for specific records.

11.2       Information about how long we will keep records for can be found in our Data Retention Schedule.

12.      Security of personal data

12.1       We will use appropriate measures to keep personal data secure at all points of the processing. Keeping data secure includes protecting it from unauthorised or unlawful processing, or from accidental loss, destruction or damage.

12.2       We will implement security measures which provide a level of security which is appropriate to the risks involved in the processing.

Measures will include technical and organisational security measures. In assessing what measures are the most appropriate we will take into account the following, and anything else that is relevant:

a)         the quality of the security measure;

b)         the costs of implementation;

c)         the nature, scope, context and purpose of processing;

d)         the risk (of varying likelihood and severity) to the rights and freedoms of data subjects;

e)         the risk which could result from a data breach.

12.3       Measures may include:

a)         technical systems security;

b)         measures to restrict or minimise access to data;

c)         measures to ensure our systems and data remain available, or can be easily restored in the case of an incident;

d)         physical security of information and of our premises;

e)         organisational measures, including policies, procedures, training and audits;

f)          regular testing and evaluating of the effectiveness of security measures.

13.      Keeping records of our data processing

13.1       To show how we comply with the law we will keep clear records of our processing activities and of the decisions we make concerning personal data (setting out our reasons for those decisions).

Section C – Working with people we process data about (data subjects)

14.      Data subjects’ rights

14.1       We will process personal data in line with data subjects’ rights, including their right to:

a)         request access to any of their personal data held by us (known as a Subject Access Request);

b)         ask to have inaccurate personal data changed;

c)         restrict processing, in certain circumstances;

d)         object to processing, in certain circumstances, including preventing the use of their data for direct marketing;

e)         data portability, which means to receive their data, or some of their data, in a format that can be easily used by another person (including the data subject themselves) or organisation;

f)          not be subject to automated decisions, in certain circumstances; and

g)         withdraw consent when we are relying on consent to process their data.

14.2       If a colleague receives any request from a data subject that relates or could relate to their data protection rights, this will be forwarded to our Data Protection Officer immediately.

14.3       We will act on all valid requests as soon as possible, and at the latest within one calendar month from the date of receipt of the request, unless we have reason to, and can lawfully extend the timescale. This can be extended by up to two months in some circumstances.

14.4       All data subjects’ rights are provided free of charge.

14.5       Any information provided to data subjects will be concise and transparent, using clear and plain language.

15.          Direct marketing

15.1       We will comply with the rules set out in the UK GDPR, the Privacy and Electronic Communications Regulations (PECR) and any laws which may amend or replace the regulations around direct marketing. This includes, but is not limited to, when we make contact with data subjects by post, email, text message, social media messaging, telephone (both live and recorded calls) and fax.

Direct marketing means the communication (by any means) of any advertising or marketing material which is directed, or addressed, to individuals. “Marketing” does not need to be selling anything, or be advertising a commercial product. It includes contact made by organisations to individuals for the purposes of promoting the organisation’s aims.

15.2       Any direct marketing material that we send will identify Burgh Baptist Church as the sender and will describe how people can object to receiving similar communications in the future. If a data subject exercises their right to object to direct marketing we will stop the direct marketing as soon as possible.

Section D – working with other organisations & transferring data

16.      Sharing information with other organisations

16.1       We will only share personal data with other organisations or people when we have a legal basis to do so and if we have informed the data subject about the possibility of the data being shared (in a privacy notice), unless legal exemptions apply to informing data subjects about the sharing. Only authorised and properly instructed staff are allowed to share personal data.

16.2       We will keep records of information shared with a third party, which will include recording any exemptions which have been applied, and why they have been applied. We will follow the ICO’s statutory  Data Sharing Code of Practice (or any replacement code of practice) when sharing personal data with other data controllers. Legal advice will be sought as required.

17.      Data processors

         We will not engage any agencies to process personal data for us.

18.      Transferring personal data outside the United Kingdom (UK)

18.1       Personal data cannot be transferred (or stored) outside of the United Kingdom unless this is permitted by the UK GDPR. This includes storage on a “cloud” based service where the servers are located outside the UK.

18.2       We will only transfer data outside the UK where it is permitted by one of the conditions for non-UK transfers in the UK GDPR.

Section E – Managing change & risks

19.      Data protection impact assessments

19.1       When we are planning to carry out any data processing which is likely to result in a high risk we will carry out a Data Protection Impact Assessment (DPIA). These include situations when we process data relating to vulnerable people, trawling of data from public profiles, using new technology, and transferring data outside the UK. Any decision not to conduct a DPIA will be recorded.

19.2       We may also conduct a DPIA in other cases when we consider it appropriate to do so. If we are unable to mitigate the identified risks such that a high risk remains we will consult with the ICO.

19.3       DPIAs will be conducted in accordance with the ICO’s guidance on Data Protection Impact Assessments.

20.      Dealing with data protection breaches

20.1       Where staff or volunteers, think that this policy has not been followed, or data might have been breached or lost, this will be reported immediately to the Data Protection Officer.

20.2       We will keep records of personal data breaches, even if we do not report them to the ICO.

20.3       We will report all data breaches which are likely to result in a risk to any person, to the ICO. Reports will be made to the ICO within 72 hours from when someone in the church becomes aware of the breach.

20.4       In situations where a personal data breach causes a high risk to any person, we will (as well as reporting the breach to the ICO), inform data subjects whose information is affected, without undue delay.                     

This can include situations where, for example, bank account details are lost or an email containing sensitive information is sent to the wrong recipient. Informing data subjects can enable them to take steps to protect themselves and/or to exercise their rights.

 

 Schedule 1 – Definitions and useful terms

The following terms are used throughout this policy and have their legal meaning as set out within the UK General Data Protection Regulation (“UK GDPR”). The UK GDPR definitions are further explained below:

Data controller means any person, company, authority or other body who (or which) determines the means for processing personal data and the purposes for which it is processed. It does not matter if the decisions are made alone or jointly with others.

 The data controller is responsible for the personal data which is processed and the way in which it is processed. We are the data controller of data which we process.

Data processors include any individuals or organisations, which process personal data on our behalf and on our instructions e.g. an external organisation which provides secure waste disposal for us. This definition will include the data processors’ own staff (note that staff of data processors may also be data subjects).

Data subjects include all living individuals who we hold or otherwise process personal data about. A data subject does not need to be a UK national or resident. All data subjects have legal rights in relation to their personal information. Data subjects that we are likely to hold personal data about include:

a)         the people we care for and support;

b)         our employees (and former employees);

c)         consultants/individuals who are our contractors or employees working for them;

d)         volunteers;

e)         tenants;

f)          trustees;

g)         complainants;

h)         supporters;

i)           enquirers;

j)           friends and family;

k)         advisers and representatives of other organisations.

ICO means the Information Commissioners Office which is the UK’s regulatory body responsible for ensuring that we comply with our legal data protection duties. The ICO produces guidance on how to implement data protection law and can take regulatory action where a breach occurs.

Personal data means any information relating to a natural person (living person) who is either identified or is identifiable. A natural person must be an individual and cannot be a company or a public body. Representatives of companies or public bodies would, however, be natural persons.

Personal data is limited to information about living individuals and does not cover deceased people.

Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and behaviour.

Privacy notice means the information given to data subjects which explains how we process their data and for what purposes.

Processing is very widely defined and includes any activity that involves the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing can also include transferring personal data to third parties, listening to a recorded message (e.g. on voicemail) or viewing personal data on a screen or in a paper document which forms part of a structured filing system. Viewing of clear, moving or stills images of living individuals is also a processing activity.

Special categories of data (as identified in the UK GDPR) includes information about a person’s:

a)         Racial or ethnic origin;

b)         Political opinions;

c)         Religious or similar (e.g. philosophical) beliefs;

d)         Trade union membership;

e)         Health (including physical and mental health, and the provision of health care services);

f)          Genetic data;

g)         Biometric data;

h)         Sexual life and sexual orientation.

 

Schedule 2 – ICO Registration

Data Controller: Burgh Baptist Church

Registration Number: ZA326213

Date Registered: 12th March 2018 Registration Expires: Ongoing

 

Address:

Causeway

Burgh Le Marsh

PE24 5LT

 

Schedule 3 – Appropriate Policy Document

APPROPRIATE POLICY DOCUMENT – Burgh Baptist Church

Schedule 1, Part 4, Data Protection Act 2018: processing of special category and criminal offence data for the purposes of Parts 1, 2 or 3 of Schedule 1 of the Data Protection Act 2018.

Who we are

Burgh Baptist Church is a Christ centred, community serving Baptist church.

For further information on what we do, please visit our website:       

www.burghbaptistcommunitychurch.org.uk

What this policy does

This policy explains how and why Burgh Baptist Church collects, processes and shares special category personal data about you and data relating to criminal convictions etc in order to carry out our functions, in accordance with the data protection principles set out in the UK General Data Protection Regulation (UK GDPR.) Pursuant to Part 4 of Schedule 1 of the Data Protection Act 2018 (DPA 2018), special category data (Parts 1 and 2 of Schedule 1), and data relating to criminal convictions etc (Part 3 of Schedule 1), can only be processed lawfully if it is carried out in accordance with this policy. Burgh Baptist Church staff, trustees and volunteers must therefore have regard to this policy when carrying out sensitive processing on our behalf.

Our approach to data protection

  • Burgh Baptist Church is committed to ensuring that the collection and processing of personal data is carried out in accordance with the UK GDPR and the DPA 2018.
  • This is implemented through the provision of training for all staff, trustees and volunteers on data protection to ensure compliance with our policies and procedures.
  • Burgh Baptist Church values openness and transparency, and we have committed to and published a number of policies and processes to assist data subjects and to explain how we handle personal data. These include the Burgh Baptist Church data protection policy, our data retention schedule and the privacy notices on our website

            www.burghbaptistcommunitychurch.org.uk

which describe what information we hold, why we hold it, the legal basis for holding it, who we share it with, and the period we will hold it for.

  • Burgh Baptist Church has appointed a Data Protection Officer (DPO), who is Julia Page The DPO has the day to day responsibility for ensuring that the information Burgh Baptist Church collects is necessary for the purposes required and is not kept in a manner that can identify the individual any longer than necessary. Data protection training is provided for all new staff and volunteers and an annual update on data protection is provided to staff, trustees and volunteers, to ensure that everyone is familiar with Burgh Baptist Church’s data protection policies and procedures and in particular the processing of any special category and criminal offence data. The DPO will review any Data Protection Impact Assessments for Burgh Baptist Church.
  • Due to the nature of the activities performed by Burgh Baptist Church, the church may need to share information with other organisations e.g. the Baptist Union of Great Britain and East Midlands Baptist Association and third parties, including statutory bodies and professional advisers, details of which can be found in our privacy notice at

            www.burghbaptistcommunitychurch.org.uk

The data protection principles

In summary, Article 5 of the UK GDPR states that personal data shall be:

  • processed lawfully, fairly and transparently
  • collected for specific and legitimate purposes and processed in accordance with those purposes
  • adequate, relevant and limited to what is necessary for the stated purposes
  • accurate and, where necessary, kept up-to-date
  • retained for no longer than necessary, and
  • kept secure

Special category data and criminal convictions etc data

Special category data

Personal data refers to any information by which a living individual can be identified. Individual identification can be by information alone or in conjunction with other information. Certain categories of personal data have additional legal protections when being processed. These categories are referred to in the legislation as “special category data” and are data concerning:

  • health
  • racial or ethnic origin
  • political opinions
  • religious or philosophical beliefs
  • trade union membership
  • genetic data
  • biometric data
  • sex life or sexual orientation

Criminal convictions etc data

The processing of criminal convictions etc data also has additional legal safeguards. Criminal convictions etc data (“criminal offence data”) includes information about criminal allegations, criminal offences, criminal proceedings and criminal convictions.

Special category and criminal offence data we process about you

Burgh Baptist Church collects, processes and shares special category and criminal convictions data where it is necessary in order to carry out our functions. This processing is usually carried by the Designated Person for Safeguarding, the minister or certain charity trustees for the purpose of safeguarding against any risks posed to others in our church or attending our church activities by those who are involved in our church, to mitigate the risk of individuals committing criminal offences (including of a sexual nature) and to assess individuals’ suitability for ministry or other work at  Burgh Baptist Church, including by reference to risks they may pose to others. These functions and the requisite processing of personal data are matters of substantial public interest.

If we process personal information about you, you are a “data subject.” Below is a non-exhaustive list of categories of data subjects who we might process information about:

  • Employees, volunteers, workers or charity trustees of Burgh Baptist Church;
  • A child or individual in membership with or associated with Burgh Baptist Church

Burgh Baptist Church will share this data with third parties only where strictly necessary (please see the section “Who we share your personal data with” below).

Special category data and criminal offence data may be collected from the following non-exhaustive list of sources:

  • Data subjects
  • Church members or individuals in regular contact with the church – including the minister, church officers, workers or volunteers, and the church’s Designated Person for Safeguarding
  • The Baptist Union of Great Britain (BUGB) Specialist Teams, in particular the BUGB Ministries Team and National Safeguarding Team.
  • Our Regional Association East Midlands Baptist Association and, in particular, our East Midlands Baptist Association Safeguarding contact person.
  • Police, Social Services or the Local Authority Designated Officer for safeguarding.

Burgh Baptist Church may also obtain and process this data for other statutory and legal obligations for example, including, but not limited to:

  • responding to data subject access requests under data protection legislation
  • in connection with our duties under the Equality Act 2010.

The legal basis for processing your special category or criminal convictions data

Privacy Notices are available on the Burgh Baptist Church website at:

www.burghbaptistcommunitychurch.org.uk

The Privacy Notices set out the legal bases for our processing of your personal data. 

Where we process special category and criminal offence data it will be by reference to Article 6(1)(f) UK GDPR and Conditions 10, 11, 12, 18, 19 and 31 of Schedule 1 Data Protection Act 2018, which are described below:

Article 6(1)(f) UK GDPR, where the processing is necessary for the purposes of the legitimate interests of Burgh Baptist Church, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Special category or criminal offence data may also be processed by Burgh Baptist Church where it fulfils one of the substantial public interest conditions under Schedule 1, Part 2 of the Data Protection Act 2018:

  • Condition 10:

where the processing is necessary for the purposes of the prevention or detection of an unlawful act, it must be carried out without the consent of the data subject so as not to prejudice those purposes, and is necessary for reasons of substantial public interest.

In order to mitigate the risk of individuals committing criminal offences, including of a sexual nature, Burgh Baptist Church may undertake a risk assessment, receive, make a record of and share information about an individual who has been reported to us by another individual or a statutory authority, where there is a significant concern about their conduct and the risk they may pose to others.

  • Condition 11:

where the processing is necessary for the exercise of a protective function, it must be carried out without the consent of the data subject so as not to prejudice the exercise of that function and is necessary for reasons of substantial public interest. In this paragraph, “protective function” means a function which is intended to protect members of the public against – dishonesty, malpractice or other seriously improper conduct, unfitness or incompetence, mismanagement in the administration of a body or association, or failures in services provided by a body or association.

Burgh Baptist Church may exercise protective functions in partnership with BUGB’s Safeguarding and Ministries Teams or the Regional Association, which include assessing individuals’ suitability for ministry or other work within Burgh Baptist Church, including by reference to risks they may pose to others. These functions are discharged by custom, practice and with the consensus of the members of Burgh Baptist Church and the requisite processing of personal data is a matter of substantial public interest.

  • Condition 12:

where the processing is necessary for the purposes of complying with, or assisting other persons to comply with, a regulatory requirement which involves a person taking steps to establish whether another person has committed an unlawful act, or been involved in dishonesty, malpractice or other seriously improper conduct, and in the circumstances the controller cannot reasonably be expected to obtain the consent of the data subject to the processing, and the processing is necessary for reasons of substantial public interest.

Burgh Baptist Church may, in partnership with the Regional Association or BUGB, investigate and risk assess an individual’s suitability for ministry or other work within or connected with Burgh Baptist Church or the Baptist family, which is in the substantial public interest and forms an integral part of “generally accepted principles of good practice” as per the definition of “regulatory requirement” in Condition 12.

  • Condition 18:

where the processing is necessary for the purposes of protecting an individual from neglect or physical, mental or emotional harm, or protecting the physical, mental or emotional well-being of an individual, the individual is – aged under 18, or aged 18 and over and at risk, the processing is carried out without the consent of the data subject for one of the reasons listed in sub-paragraph (2), and (d) the processing is necessary for reasons of substantial public interest. (2) The reasons mentioned in sub-paragraph (1)(c) are – (a) in the circumstances, consent to the processing cannot be given by the data subject; (b) in the circumstances, the controller cannot reasonably be expected to obtain the consent of the data subject to the processing; (c) the processing must be carried out without the consent of the data subject because obtaining the consent of the data subject would prejudice the provision of the protection mentioned in sub-paragraph (1)(a).

Burgh Baptist Church may process criminal and special category data for the purposes of safeguarding minors and vulnerable persons or adults at risk.

  • Condition 19:

where the processing is necessary for the purposes of protecting the economic well-being of an individual at economic risk who is aged 18 and over and the processing is of data concerning health, is carried out without the consent of the data subject for one of the reasons listed in sub-paragraph (2) and is necessary for reasons of substantial public interest. An “individual at economic risk” means an individual who is less able to protect his or her economic well-being by reason of physical or mental injury, illness or disability. Burgh Baptist Church may seek to rely on this condition if it is required to investigate allegations of financial abuse by an individual in ministry or other work or who is involved in the life of Burgh Baptist Church, for the purpose of safeguarding vulnerable persons or adults at risk.

Burgh Baptist Church may also seek to obtain, use and retain criminal offence data in reliance upon the following additional condition relating to criminal convictions under Schedule 1, Part 3 of the Data Protection Act 2018:

  • Condition 31:

where the processing is carried out by a not-for-profit body with a religious aim in the course of its legitimate activities with appropriate safeguards where it relates solely to the members or former members of the body or to persons in regular contact with it in connection with its purposes, and the personal data is not disclosed outside that body without the consent of the data subjects.

Who we share your personal data with

We are required to share your data with third parties where we have a legal obligation to do so. We may also share information with our partner organisations with whom we have a Data Sharing Agreement, or as set out in our Privacy Notices available here:

www.burghbaptistcommunitychurch.org.uk

The persons/organisations we may share your special category and criminal offence data with are:

  • Our charity trustees, employees, contractors and volunteers on a need-to-know basis;
  • The BUGB Specialist Teams;
  • East Midlands Baptist Association;
  • Churches and other appointing or employing bodies as appropriate
  • Counsellors, professional supervisors and risk assessment consultants
  • The Police and Social Services, Local Authority Designated Officers and other statutory agencies
  • The Disclosure and Barring Service and our DBS Checking Company
  • Before sharing information with any of the above persons or organisations, careful consideration is given to the rights and freedoms of the data subject against what is needed to be shared to achieve our overarching goal of safeguarding children, young people and adults at risk from harm within Burgh Baptist Church and to support and promote exemplary ministry. Special category and criminal offence data is only disclosed where it is reasonably necessary to do so and a record and full details of any disclosure to third parties is kept in a locked filing cabinet.

Automated decision making

Currently Burgh Baptist Church undertakes no automated decision making in relation to your personal data.

How we keep your data secure and how long we keep it for

Burgh Baptist Church deploys a range of technical and organisational measures to protect the personal data it holds and processes. Controls include but are not limited to

  • Data is only collected when needed for a specific purpose or as a legal obligation.
  • Personal data is stored on password protected devices or in locked filing cabinets with access limited to those who need to process it.
  • Personal data is destroyed when requested by the Data Subject where legally permitted, or when it is no longer needed for the purpose it was given.
  • Examples include:
  • ‘Computer Security in the Workplace’ training for all staff and part of the induction for new staff
  • Acceptable use of IT equipment and systems defined in the IT General Policy provided to all users of Burgh Baptist Church systems
  • Strong defences of the Burgh Baptist Church core IT system (e.g. Firewalls, Malware Detection & Defence)
  • Encryption of data both at rest and in transit across Burgh Baptist Church networks where appropriate and the use of password protected documents when sharing data.
  • Where needed, appropriate redaction takes place before witness statements, case notes or investigation reports are shared.
  • Deployment of Information Security Tools (e.g. Data Loss Prevention, Mobile Device Management, Secure External Email)
  • Robust procedures for the reporting of any data or potential data breaches

These measures are under constant review by Burgh Baptist Church

Burgh Baptist Church has a Data Retention Schedule which lists the data we hold and how long we hold it for. To find out how long we keep your data for please see our Data Retention Schedule.

Your rights in relation to the data we hold

Data protection legislation provides you with a number of rights relating to your personal data, including your special category and criminal conviction etc data. These rights are subject to some specific exemptions. Your rights may include:

  • the right to access your data
  • the right to have your data corrected if it is wrong or incomplete
  • the right to request restrictions to the processing of your data
  • the right to object to your data being processed
  • the right to have your data erased
  • the right to be informed about how your data is processed
  • rights relating to automated decision making and data portability

You should keep us informed of any changes to your information so that we can be confident that the data we hold about you is accurate. To understand more about these rights and how to exercise them please see our Privacy Notice

www.burghbaptistcommunitychurch.org.uk

and the Information Commissioner’s Office website: https://ico.org.uk/.

Data Protection Officer/Contact

Julia Page is our Data Protection Officer and is the person responsible for matters relating to the protection of personal data. She can be contacted at the address below or by email [email protected]  or phone 07443455890.

Your right to complain to the Information Commissioner

If you are unhappy with any aspect of the way in which we have processed your personal data, you have the right to make a complaint to the Information Commissioner’s Office:

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

www.ico.org.uk

Tel: 0303 123 1113

[email protected]

Feedback or complaints about Burgh Baptist Church, staff or volunteers

If you want to give us feedback or make a complaint about Burgh Baptist Church, its staff or volunteers in relation to the handling of your personal data, please contact

Julia Page

Burgh Baptist Church

Causeway

Burgh Le Marsh

PE24 5LT

Tel: 07443455890

Email: [email protected]

Review of this policy

This policy will be regularly reviewed and may be subject to revision. Please visit our website to check for any updates.