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MP Academy Data Protection Policy

 

Overview

The Academy is committed to respecting the privacy rights of individuals and complying with data protection law.  This Policy sets out our approach to data protection law and the principles that we will apply to our processing of personal data.

This Policy is written as though General Data Protection Regulation (GDPR), effective from 25thMay 2018, and the current Data Protection Act 1998 (“DPA”) are both in force.

The Data Protection Laws all require that the personal data is processed in accordance with the Data Protection Principles (see below) and gives individuals rights to access, correct and control how we use their personal data (see Data Subject Rights below)

Data will relate to an individual and therefore be their personal data because it identifies the individual – e.g. persons names, addresses, telephone numbers and email addresses.

 

Lawful processing of data

Processing of data includes collection, modification, transfer, viewing, deleting, holding, backing up, archiving, retention, disclosure or destruction.  Even storage of personal data is a form of processing. We might process personal data using computers or manually by keeping paper records. 

In order for personal data to be processed lawfully, the Academy will process it on the following legal basis described in the Data Protection Laws:

o   the processing is necessary for the legitimate interest / reasons of the Academy staff or volunteers (e.g. keeping in touch with members, players about upcoming fixtures or access to club facilities).

We will only process personal data for certain purposes and in accordance with the 6 principles of ‘good information handling’ (including keeping personal data secure and processing it fairly and in a transparent manner)

We will respect the rights of those individuals about whom we process personal data (including providing them with access to the personal data we hold on them)

We will keep adequate records of how data is processed and, where necessary, notify the Information Commissioner’s Office (ICO) and possibly data subjects where there has been a data breach.

 

Data protection principles

The Data Protection Laws set out 6 principles for maintaining and protecting personal data, which form the basis of the legislation. All personal data must be:

1.           processed lawfully, fairly and in a transparent manner and only if certain specified conditions are met;

2.           collected for specific, explicit and legitimate purposes, and not processed in any way incompatible with those purposes (“purpose limitation”);

3.           adequate and relevant, and limited to what is necessary to the purposes for which it is processed (“data minimisation”);

4.           accurate and where necessary kept up to date;

5.           kept for no longer than is necessary for the purpose (“storage limitation”);

6.           processed in a manner that ensures appropriate security of the personal data using appropriate technical and organisational measures (“integrity and security”).

 

Data subject rights

Under Data Protection Laws individuals have certain rights in relation to their own personal data.  In summary these are:

1.           The rights to access their personal data, usually referred to as a subject access request

2.           The right to have their personal data rectified;

3.           The right to have their personal data erased, usually referred to as the right to be forgotten;

4.           The right to restrict processing of their personal data;

5.           The right to object to receiving direct marketing materials;

6.           The right to portability of their personal data;

7.           The right to object to processing of their personal data; and

8.           The right to not be subject to a decision made solely by automated data processing.

The Academy will respond to any request or exercise of these rights by any data subject without undue delay.

 

 

Code of conduct for members and guests 

All Members and Guests* of this Cricket Academy will:

1. Respect the rights, dignity and worth of every person.

 

2. Treat everyone equally and not discriminate anyone based on age, gender, disability, race, ethnic origin, nationality, colour, parental or marital status, religious belief, class or social background, sexual preference or political belief

 

3. Not to condone, or allow to go unchallenged, any form of discrimination if witnessed

 

4. Display high standards of discipline

 

5. Promote the positive aspects of cricket, for example fair play, teamwork, sportsman spirit etc.

 

6. Encourage all participants to learn the Laws and rules and play within them, always respecting the decisions of match officials

 

7. Actively discourage unfair play, rule violations and arguing with match officials

 

8. Recognise good performance of players rather than match results
 

9. Place the well-being and safety of children above the development of performance

 

10. Ensure activities are appropriate for the age, maturity, experience and ability of the individual(s)

 

11. Respect children’s opinions when making decisions about their participation in cricket

 

12. Not smoke, drink or use banned substances while working with children in the ground

 

13. Not provide children with alcohol when they are under the care of the club or at the ground

 

14. Follow ECB guidelines set out in the “Safe Hands – Cricket’s Policy for Safeguarding Children” and any other relevant guidelines issued 

 

15. Report any concerns in relation to a child to the child welfare officer, and by following the reporting procedures laid down by the ECB

* Members and guests include all members and officers of the cricket club and all guests of those members and officers, as well as all individuals who watch/attend/participate / officiate in matches hosted by the club in whatever capacity.

In addition to the above, all Academy officers and appointed volunteers will:

1. Have been appropriately vetted, if required

 

2. Hold relevant qualifications and be covered by appropriate insurance

 

3. Always work in an open environment (i.e. avoid private, or unobserved, situations and encourage an open environment).  NB This includes the online world – club officers and volunteers are actively discouraged from online or other electronic communication with children – any such communication should be via parents

 

4. Inform players and parents of the requirements of cricket

 

5. Know and understand the ECB’s “Safe Hands – Cricket’s Policy for Safeguarding Children”

 

6. Develop an appropriate working relationship with young players, based on mutual trust and respect

 

7. Ensure physical contact is appropriate and necessary and is carried out within recommended guidelines with the young player’s full consent and approval

 

8. Not engage in any form of sexually related contact with a young player. This is strictly forbidden, as is sexual innuendo, flirting or inappropriate gestures and terms. The ECB adopts the Home Office guidelines. These recommend “people in positions of trust and authority do not have sexual relationships with 16-17 year olds in their care”

 

9. Attend appropriate training to keep up to date with their role, especially with respect to the safeguarding of children


Photography and filming policy 

1. The Academy wishes to ensure photography and video footage taken is done so appropriately.  Parents and carers should not be prevented from taking pictures of, or filming their children.

 

2. These are normal family practices and help mark milestones in a child’s life. The introduction of proportionate controls on the use of photographic equipment (cameras, and videos, including mobile phones) is part of general safeguarding good practice.

 

3. The Academy is keen to promote positive images of children playing cricket and is not preventing the use of photographic or videoing equipment.

 

4. Photographs are considered ‘personal data’ in terms of the Data Protection Act. Depending on the circumstance, consent from either the child, adult, or both should be sought before capturing, sharing or publishing images where a child can be identified, including posting on the club’s website etc. In addition, as with all personal data, it should be processed in accordance with the principles laid out in the Data Protection Act, and other relevant legislation and guidance.

 

5. Any concerns during about photography or filming at an Academy event should be reported to a club official or event organiser. 

 

6. In printed media and social media, a child’s picture and name should not appear  together.

 

7. Parents / carers will be offered the opportunity to withhold consent for photographs / filming of their child without question

 

8. Photographs / images are not to be taken at matches or training without the prior permission of the parents / carers of the child.

 

9. If no consent has been given for a child, then it is to be made known to the relevant person of the other team (e.g. coach / team manager) so the appropriate person/s taking photographs for the other team is / are aware and can avoid taking photographs of that particular child

 

10. Children should be informed a person will be taking photographs

 

11. Children should be informed that if they have concerns they can report these to the coach or team manager

 

12. Any concerns regarding inappropriate, or intrusive, photography should be reported to the Club Welfare Officer and recorded in the same manner as any other child protection or safeguarding concern

 

13. The Academy will only use images of children in appropriate kit (training or competition), to reduce the risk of inappropriate use, and to provide positive images of the children

  

14. The parents / carers and children will be asked to provide written consent for the use of photography and video analysis


Safeguarding Policy Statement 

The MP Cricket Academy is committed to ensuring all Children (i.e. all persons under the age of 18) participating in cricket have a safe and positive experience.

We will do this by:

1. Recognising all children participating in cricket (regardless of age, gender, race, religion, sexual orientation, ability or disability) have the right to have fun and be protected from harm in a safe environment.

2. Ensuring individuals working within cricket at the Academy provide a welcoming, safe, and fun experience for children.

3. Adopting and implementing the England and Wales Cricket Board (ECB) “Safe Hands – Cricket’s Policy for Safeguarding Children”.

4. Appointing a Club Welfare Officer and ensuring they attend all current and future training modules required by the ECB.

5. Ensuring all people who work in cricket at the Academy (such as staff, officials, volunteers, team managers, coaches and so on) have a responsibility for safeguarding children, and understand how the “Safe Hands Policy” applies to them.

6. Ensuring all individuals working within cricket at, or for, the club are recruited and appointed in accordance with ECB guidelines and relevant legislation.

7. Ensuring all individuals working within cricket at the Academy are provided with support, through education and training, so they are aware of, and can adhere to, good practice and Code of Conduct guidelines defined by the ECB and the Academy.

     8. Ensuring the name and contact details of the Club Welfare Officer is available:

      i. As the first point of contact for parents, children and volunteers/staff within the club

      ii. As a local source of procedural advice for the club, its committee and members.

 iii. As the main point of contact within the club for the ECB County Welfare Officer and the ECB Safeguarding Team. 

      iv. As the main point of contact within the club for relevant external agencies in connection with child safeguarding. 

     9. Ensuring correct and comprehensive reporting procedures exist for raising and managing child safeguarding concerns.

    10. Providing an environment where the views of children, parents and volunteers are sought and welcomed on a range of issues. This will help us create an environment where people have the opportunity to voice any concerns (about possible suspected child abuse/neglect, and/or about poor practice) to the Club Welfare Officer *

*Details of the County Welfare Officer will be made available on the website, in case the Club Welfare officer is unavailable, or the concern relates to the Club Welfare officer.

     11. Ensuring all suspicions concerns and allegations are taken seriously and dealt with swiftly and appropriately

 

     12. Ensuring access to confidential information relating to child safeguarding matters is restricted to those who need to know in order to safeguard children – including the Club Welfare Officer and the appropriate external authorities, such as the Local Authority Designated Officer (LADO), as specified within ECB child safeguarding procedures 

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