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