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HUG's Policies

HUG's Privacy Policy

How we respect your privacy. How HUG deals with information, collected by our organisation.

  

This Privacy Policy applies to information we at HUG, collect about individuals who interact with our organisation. It explains what personal information we collect and how we use it. 

If you have any comments or questions about this notice, feel free to contact us at bexhillandrotherhug@gmail.com,  bexhillhug@gmail.com or connect@bexhillhug.org.uk 


1. Personal data that we process

The following table explains the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed. 

  

Purpose

Data (key elements)

Basis

 

Enquiring about our organisation and its work


Name, email, message


Legitimate   interests - it is necessary for us to read and store your message so that we can respond in the way that you would expect.

 

Subscribing to email updates about our work


Name, email


Consent -   you have given your active consent. 

 

Making a donation


Name, email, address, payment information


Legitimate   interests - this information is necessary for us to fulfil your intention of   donating money and your expectation of receiving a confirmation message.

 

Signing up as a member


Name,   email

 

Website functionality


Website activity collected through cookies


Legitimate Interests

- it is  necessary for us to store a small amount of information, usually through cookies, to deliver the functionality that you would expect, such as remembering the contents of any request or order before you have fully completed the process. 


2. How we use your data

We will only use your data in a manner that is appropriate, considering the basis on which that data was collected, as set out in the table at the top of this policy. 

For example, we may use your personal information to:

● reply to enquiries you send to us;

● handle donations or other transactions that you initiate; 

● where you have specifically agreed to this, send you marketing communications by email relating to our work which we think may be of interest to you.


3. When we share your data

We will only pass your data to third parties in the following circumstances:

● you have provided your explicit consent for us to pass data to a named third party; 

● we are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party that fulfils our legal obligations in relation to the use of third-party data processors; or

● we are required by law to share your data. 

In addition, we will only pass data to third parties outside of the EU where appropriate safeguards are in place as defined by Article 46 of the General Data Protection Regulation. 


4. How long we keep your data

We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required. 

Where data is collected on the basis of consent, we will seek renewal of consent at least every three years. 

5. Rights you have over your data

You have a range of rights over your data, which include the following:

● Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of all our marketing emails). 

● You have the right to ask for rectification and/or deletion of your information. 

● You have the right of access to your information. 

● You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed. 

A full summary of your legal rights over your data can be found on the Information Commissioner’s website here: https://ico.org.uk/

If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us. 


Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible. 


6. Cookies & usage tracking

A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, e.g. remembering  your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.

Where cookies are used to collect personal data, we list these purposes in section 1 above, along with other personal data that we collect. However, we also use some cookies that do not collect personal information but that do help us collect anonymous information about how people use our website. We use Google Analytics for this purpose. Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users' computers. The information collected by Google Analytics about usage of our website is not personally identifiable. The data is collected anonymously, stored by Google and used by us to create reports about website usage. Google's privacy policy is available at http://www.google.com/privacypolicy.html.


7. Modifications

We may modify this Privacy Policy from time to time and will publish the most current version on our website. If a modification meaningfully reduces your rights, we'll notify people whose personal data we hold and is affected.

Data Protection Policy

  

1. Data protection principles

HUG is committed to processing data in accordance with its responsibilities under the GDPR. (General Data Protection Regulation).


Article 5 of the GDPR requires that personal data shall be:


  1. processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”


2. General provisions

  1. This policy applies to all personal data processed by the Charity. 
  2. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy. 
  3. This policy shall be reviewed at least annually. 
  4. The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data. 


3. Lawful, fair and transparent processing 

  1. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems. 
  2. The Register of Systems shall be reviewed at least annually. 
  3. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner. 



4. Lawful purposes

  1. All data processed by the charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information). 
  2. The Charity shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data. 
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be  in place to ensure such revocation is reflected accurately in the  Charity’s systems. 



5. Data minimisation

  1. The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. 


6. Accuracy

  1. The Charity shall take reasonable steps to ensure personal data is accurate. 
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date. 



7. Archiving / removal

  1. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process annually.      
  2. The archiving policy shall consider what data should/must be retained, for how long, and why. 


8. Security

  1. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date. 
  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information. 
  3. When personal data is deleted this should be done safely  such that the data is irrecoverable. 
  4. Appropriate back-up and disaster recovery solutions shall be in place. 


9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website). 

HUG's Equal Opportunities Policy Statement

HUG's Vulnerable Adult and Child Protection Policy

 

Definitions – for this document 

Vulnerable adult: Is a person who is or may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation (see Note 1 below). Vulnerable adults are entitled to: privacy; be treated with dignity; lead an independent life and to be enabled to do so; be able to choose how they lead their lives; the protection of the law; have their rights upheld regardless of ethical origin, gender, sexuality, impairment or disability, age, religion, or cultural background. Child: Describes a child aged 0-17 years. 


POLICY STATEMENT 

As Bexhill Homeless Unity Group, we want to restore dignity and revive hope to people from all walks of life. We are concerned with the individuals and their circumstances and actively encourage an inclusive environment throughout all our activities and projects. We seek to ensure that all our staff and volunteers are aware of what is required of them under the vulnerable adult and child protection policy and make sure that it is practised at all times. It is the responsibility of each one of us to prevent the physical, sexual, or emotional abuse and neglect of vulnerable adults and children. We commit ourselves to co-operate fully with the appropriate statutory authorities when they are conducting official investigation into physical, sexual, or emotional abuse and Note 1 March 2000. ‘No secrets: guidance on developing and implementing multi-agency policies and procedures to protect vulnerable adults from abuse’, Department of Health. (The broad definition of a ‘vulnerable adult’ referred to in the 1997 Consultation Paper Who decides? issued by the Lord Chancellor’s Department.) neglect of vulnerable adults and children or young people (by an adult or young person). This statement is to be brought to the attention of all staff and volunteers when they join, as part of their induction programme. Any amendments will be brought to the attention of all HUG workers.

Implementation 

BEXHILL HOMELESS UNITY GROUP SHALL: Plan its work so as to minimise situations where abuse of vulnerable adults and children might occur. Although the number of people who actively seek to abuse vulnerable adults and children is very small, Bexhill Homeless Unity Group Project can reduce opportunities for abuse in various ways. WE will, for instance: • Ensure that there is adequate supervision for all vulnerable adults and children. • Ensure that any vulnerable adult or child working with the project is aware who they can talk to if they have concerns. • Ensure that all staff and volunteers know where the nearest telephone is in case of emergencies and that phones are clearly labelled with directions for making external calls. • Arrange that, as far as possible, an adult is not left alone with a child where there is little or no opportunity of the activity being observed by others. This good practice can be of as much benefit to the adult as to the child. • Make sure the designated person has correct and up to date training. • Ensure staff and volunteers supervising vulnerable adults or children are suitably trained.

Designated Person and their role 

Bexhill Homeless Unity Group has a designated person who is responsible for dealing with any concerns about the protection of vulnerable adults or children. The designated person is......(insert Name). The designated person will be available for vulnerable adults and children to speak with should they feel the need to talk with someone about an incident which has happened working for or receiving assistance from Bexhill Homeless Unity Group, particularly if they feel they have been physically, sexually, or emotionally abused or neglected by an adult or young person.
RECORDING The designated person will make notes and keep confidential records of any disclosure or concerns they or another staff member/volunteer has and seek advice from the Social Services Department or the Police. Staff and volunteers must ensure that their recording of facts, incidents, assessments, referrals, case discussion, are all sufficient, accurate, concise, factual, up-to-date, legible and dated. Opinions should be kept to a minimum and backed up with factual evidence. Any supporting evidence should be preserved and clearly labelled. These records must be stored in an individual file and stored securely in a manner that safeguards the individual’s right to privacy and security. These records are available to individuals on request (not third party information) and may be used in disciplinary proceedings or in civil or criminal prosecutions. 


WHISTLE-BLOWING

Staff and volunteers are encouraged to take action when suspicious that abuse is occurring at work – no matter what the setting, who the suspected perpetrator is, or who the victim is. Bexhill Homeless Unity Group will respect and not penalise those who stand up for anyone who is suspected of being abused. Staff and volunteers have a responsibility to report any occurrences or suspicions of adult abuse. Those who report abuse are protected by the Public Interest Disclosure Act 1998. REMEMBER It is important that everyone in Bexhill Homeless Unity Group is aware that the person who first encounters a case of alleged or suspected abuse is not responsible for deciding whether or not abuse has occurred. That is a task for the professional vulnerable adult and child protection agencies once a concern about someone has been referred to them. 


Additional points Displaying Information 

Display the name of the designated person. Ensure all workers in Bexhill Homeless Unity Group know the name of the designated person and how they might be contacted. 


Applying agreed procedures for protecting vulnerable adults and children to all staff and volunteers 

It is possible to be lulled into a false sense of security, believing that those who work alongside vulnerable adults and children in Bexhill Homeless Unity Group will never be guilty of abuse because they are part of a Christian organisation. It is not safe to assume that all others are automatically safe to be with vulnerable adults or children. For this reason all procedures set in place to protect vulnerable adults and children should apply to all those in contact with them. This is not the same as treating each person who relates to vulnerable adults and children as being under suspicion, but a matter of taking sensible measures to protect vulnerable adults and children, which are then observed by everyone. This will involve thought and planning within each group to minimise the risk. If any member of staff or volunteer has concerns they should be raised with the designated person. If concerns are brought to the attention of the designated person and not adequately dealt with the next step is to talk to the Chairman for advice, or to contact Social Services/the Police as a private citizen to discuss your concerns 


Disclosure of Information 

There is a difference between confidentiality and secrecy. All personal and delicate information disclosed to us is confidential, but may not always be secret. Personal and delicate information staff and volunteers will be: • Confidential to Bexhill Homeless Unity Group and can be shared with staff/volunteers on a ‘need to know’ basis and • Can be shared with another agency when; - Permission is given by the person about whom the information is held. - There is an overriding justification to share information without the person’s consent. - The law requires it. 


Give staff and volunteers clear roles 

Abuse of vulnerable adults and children is most easily concealed where there is confusion among adults about roles and responsibilities. Included therefore in all job descriptions, both for employees and supervising volunteers, will be a clear description of roles and responsibilities. Also, the Volunteer’s Induction Pack will include a ‘Code of Conduct’ setting out the behaviour and values expected from all who serve in Bexhill Homeless Unity Group. Over and above the written word, expected behaviour towards vulnerable adults and children when working with Bexhill Homeless Unity Group will be explained to new workers as part of their induction. It is Bexhill Homeless Unity Group’s policy not to engage in regulated activities (close or personal tasks such as washing, dressing, massaging, or accompanying to the toilet) with vulnerable adults: members of staff and volunteers are therefore ineligible for DBS checks.
Supervision as a means of protection Regular staff meetings should be held where team leaders meet together to raise issues about their areas of work and discuss them. When receiving feedback about the work, particular attention should be paid to any situation or suggestion that a vulnerable adult or child is being either highly favoured or harshly treated as these are signs of abuse. Within Bexhill Homeless Unity Group our main area of concern about protecting people lies with the welfare of any vulnerable adult supported volunteers. Where possible, line managers should take opportunities to observe those vulnerable adults and children for whom they are responsible. In all recruitment decisions concerning volunteers: a) A detailed application form should be completed b) 2 references should be taken about the suitability of the application for the post being considered c) An informal interview will provide an extended conversation to allow an opportunity to explore in more detail the applicant’s experience and motivation for volunteering. 


Criminal convictions 

All volunteers must complete a volunteer application form before commencing work at Bexhill Homeless Unity Group. Details of criminal convictions (except those ‘spent’ under the Rehabilitation of Offenders Act 1974) must be provided so an adequate risk assessment can be undertaken. (Bexhill Homeless Unity Group reserves the right to dismiss a volunteer and/or ban them from the premises should they feel it is necessary). 


Training 

Training in the prevention of abuse, and the action to be taken if abuse occurs should be included as part of the training programme for Bexhill Homeless Unity Group and can normally be accessed free of charge via the local authority. Further guidelines concerning the safeguarding policies of your local council can also be obtained free of charge and a copy should be kept available as a reference. It should be noted that it is insufficient to give workers guidelines without equipping them with the skills and knowledge to carry them out. 


General 

All workers driving any vehicle which transports vulnerable adults and/or children must hold a valid road fund licence, be appropriately insured for business use, have a valid MOT certificate and comply with all appropriate legislation and regulations. Seat sharing is not permitted and seat belts must be worn. 


Review 

This policy and its implementation will be reviewed at least annually and whenever there are any legislative changes or amendments to guidance issued by relevant statutory bodies. Bexhill Homeless Unity Group Policy adopted October 2018 for immediate implementation and periodic review.


HUG's Health and Safety Policy

  Health and Safety Policy for Bexhill Homelessness Unity Group (HUG)


 

1. The Charity Trustees are ultimately responsible for the Health and Safety Policy. The Policy will be reviewed annually.

 

2. The HUG Project Manager is responsible to the Board of Trustees for ensuring that this Health and Safety Policy is implemented within St Barnabas Café.

 

3. Trustees’ Responsibilities 

The Trustees recognise their duty to staff, volunteers and all users of St Barnabas Café, and others who may be affected by the HUG’s activities, and aims to protect them from risks to their health and safety as far as is reasonably practicable. 


The above will be achieved by ensuring that the Projects Manager: 

a) identifies and assesses risks to which staff, volunteers, guests and visitors are likely to be exposed.


b) introduces specific measures as appropriate to minimise these risks 


c) adopts safe working practices 


d) maintains systems to effectively implement, monitor, review and improve health and safety on an on-going basis

 

e) receives appropriate instruction and training to help ensure that work and activity in and around the Hall are carried out safely and effectively

 

f) ensures that appropriate Employers’ and Public Liability insurance cover is in place 



4. Staff and Volunteers’ Responsibilities 

Everyone working in the Cafe has a responsibility to take reasonable care for the health and safety of him/herself and any other person who may be affected by his/her acts or HUGs at work. Staff and volunteers working in and around the Cafe should co-operate with the Trustees in efforts to comply with statutory requirements in the field of health and safety. In particular, all staff and volunteers should: 


a) work safely and efficiently 


b) use any equipment provided according to instructions 


c) report and record all incidents on the premises that have or may lead to injury or damage 


d) make suggestions to improve health and safety in and around the Cafe

 

e) ensure agreed measures are introduced to reduce or manage identified health and safety risks.

 



5. General Arrangements

 

a. Accidents 

The first aid box is located in the St Barnabas Café Kitchen. 

The person with responsibility for maintaining the first aid boxes is the Projects Manager. 


The person responsible for reporting incidents is the Projects Manager. An accident/incident record book is located in the Kitchen. 


b. Fire Safety 


The Projects Manager is responsible for ensuring the installation and maintenance of fire extinguishers and the clear marking of escape routes. Fire extinguishers will be maintained once a year. All staff and volunteers will be shown how to use the fire extinguishers and when to use them. 

Staff and volunteers should ensure as far as possible that a record of who is in the building at any given time is known. All staff and volunteers should be made familiar with fire exits and fire extinguishers. 


The fire routine is as follows: 


• on discovery of a fire the person concerned must raise the alarm and ensure that everyone evacuates the premises 


There is a no smoking policy for all rooms on the premises. 


c. Staff, Volunteers, Guests and Visitors 


The Trustees will ensure that, so far as is reasonably practicable, people who enter the premises will not be exposed to any health or safety hazard. Staff and volunteers will be instructed on the procedure for locking the premises and ensuring all appliances etc. are switched off. They will be informed of the No Smoking Policy. This is the responsibility of the Project Manager. 



6. Hazards  

A risk assessment form should be completed for all potential hazards and reviewed annually. a. Electrical Appliances 


A reporting schedule for maintenance of portable electrical appliances will be undertaken by the delegated member. 


This will meet the requirements as recommended in H&SE publication, “maintaining portable electrical equipment in offices and other low-risk environments”. 


If an appliance is found to be faulty, the appliance should be labelled immediately, taken out of use and the fault reported to the Projects Manager. 

b. House-keeping and premises

 

Risk assessments will be carried out in and around the premises and will include potential hazards such as trailing cables, loose carpeting, lighting, use of equipment and hand-tools, gardening tools and equipment, storage, waste disposal etc. 




THE RISK ASSESSMENT PROCESS 


The Trustees promote the use of the following 5-step approach: 

Step 1 Look for the hazards: eg slipping/tripping hazards, fire, chemicals, moving parts of machinery, electricity, dust, fumes, manual handling, noise, poor lighting, low temperature, trailing wires, overloaded shelves etc. 


Step 2 Decide who might be harmed and how: e.g. staff, volunteers, guests, visitors, or others. 


Step 3 List Existing Controls, Evaluate risks and decide whether existing precautions are adequate or whether more should be done. Consider whether existing controls reduce risk as far as is reasonably practicable. 


Step 4 Record Your Findings 


SEVERITY SCALE 

1. SLIGHT -  all injuries not defined as Major or Serious 

2. SERIOUS -  injuries that are not major but are likely to prevent someone working normally for more than 3 days 

3. MAJOR  - death or major injury e.g fracture of a bone, amputation, serious damage to eye etc. 


LIKELIHOOD SCALE 

1 LOW unlikely to happen 

2 MEDIUM could well happen 

3 HIGH certain or near certain to happen 

The risk rating is then calculated by multiplying the severity and likelihood figures. Risk ratings of 4 or more are significant and will demand action. 

Step 5 Review the Assessment and Revise it as necessary. Determine control measures. Consider the effectiveness of control measures. 

1. Remove the risk completely     

2. Try a less risky option 

3. Prevent access to the hazard 

4. Organise work to reduce exposure to the hazard 

5. Issue personal protective equipment 


HUG

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