Voluntary Action Leicestershire VAL Employment Data Sharing Policy, June 2013 Name of Policy Introduction Voluntary Action LeicesterShire (VAL) takes its commitment to protecting all of the data that we hold on individuals and organisations very seriously. VAL needs to keep certain information on all persons and groups involved with VAL in order to carry out its day-to-day operations, meet its objectives and comply with legal obligations. VAL is committed to ensuring any personal data will be dealt with in accordance with the terms of the Data Protection Act 1988. To comply with the law, personal information will be collected and used fairly, stored safely and not disclosed to any other person unlawfully. This document covers all of the projects and services provided by VAL including: Infrastructure support (support provided to the VCS around influencing decisions, developing their groups and volunteering); The VALUES project; Healthwatch; the Parent Partnership Service; the Choice Advice Service; and the Children’s Workforce Development Project. (NB. This list reflects VAL’s projects and services as delivered in April 2013. This list is subject to change) Guiding principles VAL will fully uphold the Data Protection Act 1998 when dealing with personal information, including respecting the right of data subjects under this Act. VAL will not hold information about individuals or groups without their knowledge and consent. VAL will only hold information for specific purposes. It will inform data subjects what these purposes are, and inform them if those purposes change. VAL will only obtain data that is adequate, relevant and not excessive in relation to the purpose, or purposes, for which it is collected. 1 VAL will make every effort to ensure that the data held is accurate and kept up-to-date, and will respond to any request from an individual or group to check the accuracy of the data that is held about them. VAL will not keep data processed for any purpose for longer than is necessary for that purpose. VAL will maintain secure data storage systems and policies ensuring that personal and organisational data is protected against unauthorised or unlawful processing. VAL will maintain procedures for staff in the event of a data breach. Where possible, VAL will protect the anonymity and confidentiality of individuals and groups it supports when sharing information externally. What information do we collect? VAL holds information on both organisations and individuals. This policy covers only the organisational data that VAL holds1. NB. Please refer to VAL’s separate Data Protection Policy for information about data relating to personal information. VAL holds a range of information about the groups/organisations we engage with. This may include information such as: oThe organisation/group’s services and beneficiaries oThe organisation/group’s current and past support needs oThe organisation/group’s annual income oThe organisation/group’s staffing and volunteering arrangements (e.g. numbers of full and part time staff; numbers of volunteers) PLEASE NOTE: Records may include names and addresses of individuals in their role as part of an organisation or group. For the purpose of data sharing, this information is treated as ‘organisational’ data2. Please refer to VAL’s Data Protection Policy for information about data relating to personal information 2 Val can offer an alternative postage address if required. 1 2 How we may use your organisation/group’s information? VAL collects organisational data to ensure that we can: 1. Offer appropriate support to the VCS. 2. Influence policy and decision-making relating to the VCS. 3. Recruit and support volunteers. 4. Inform you of appropriate, relevant and timely information. In particular, we may use the organisational information we collect to: Plan our services according to need; Inform general research about the VCS; Send mailings to inform organisations/groups of news and events that may be of interest to them (NB. Groups can limit the type of news and events they receive by changing their mailing preferences); Include groups/organisations on VAL’s Online Directory (only done with the group’s/orgainsation’s permission); Provide performance reports to our funders (this includes the provision of named case studies). How do we use organisational information to communicate with you? Groups/organisations are able to specify their mailing preferences (post/ email/ both/ neither) to ensure they receive appropriate mailings from VAL. In addition, groups/organisations are able to opt-in to receiving tailored information, which overrides the general mailing preferences set. In cases where VAL is engaging with multiple contacts from the same group/organisation, contacts can specify their own mailing preferences. 3 How do we use organisational information in our performance reports? VAL’s performance reports are publicly available on VAL’s website. Named case studies are provided to demonstrate how VAL’s work benefits the local community. However, we would not name a group, nor include any other identifying information, when a group/organisation has accessed any of the following support from VAL: Support relating to allegations of criminal activities; Support relating to HR issues that involve a grievance or disciplinary action against any individual in the group/organisation (staff member, volunteer or trustee); Support relating to poor contractual performance; Support relating to financial crisis; Support relating to TUPE and redundancy issues. VAL is also required to provide a list of groups/organisations that we have worked with each quarter to funders, but this list will not contain information about the type of support that the groups/organisations received from VAL. Why, when and how do we share information with third parties? VAL receive a number of requests from funders and commissioners for information about VCS provision in a locality. We believe this is important to provide because: 1. It helps promote VCS services in the area. 2. It supports the visibility of VCS provision in the area. 3. It helps funders retain accurate and appropriate contact with VCS groups. 4. It helps to identify opportunities and gaps for partnership and crosssector working for the benefit of communities. VAL adopts the position that we will supply lists of groups/organisations operating in an area to statutory partners as long as there is a clear rationale, and clear purpose, for the use of that information. For example, we may provide a list of VCS provision in an area in order that a funder is able to undertake an effective and worthwhile consultation exercise. We will not however supply individual names or contact details unless this information is 4 contained with the group’s/organisation’s Online Directory entry (i.e this contains publicly available information). In no circumstance will VAL share information about a group’s/organisation’s financial or human resources, and the content of any support provided by VAL will not be shared in this way; this information (content of provided by VAL) will only ever be available in the form of structured case studies, as mentioned in the section above. In cases where a request for information comes from other sources (e.g. private companies), VAL will only ever refer them to VAL’s Online Directory and/or offer to disseminate information to groups/organisations via its database on behalf of the third party, respecting groups/organisations’ mailing preferences in the process. In addition, there may be times when VAL has to share information with regulatory bodies if we have serious concerns relating to the legal operation of a group/organisation. For example, if VAL receives information or evidence that leads VAL to believe or suspect that there is serious malpractice taking place – i.e. putting service users at significant risk - VAL is required to inform the Charity Commission. How can you change your organisational information? You can contact VAL at any time to review/change/amend your information by contacting the VAL helpline (0116 257 5050; [email protected]). VAL also undertake bi-annual audits to review the accuracy of its data and you can request an amendment to your Online Directory entry via the website (http://www.valonline.org.uk/directory). Further information If you would like further information about VAL’s Data Sharing Policy, please contact the VAL Helpline (0116 257 5050; [email protected]). 5
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