Volunteer Policies

Introduction

Southampton Business Improvement District LTD trading as GO! Southampton (“the Company”) holds Personal Data about job applicants, employees, clients, suppliers and other individuals for a variety of Business Purposes.

This policy sets out how the Company seeks to protect Personal Data and ensure employees and associated persons understand the rules governing their use of Personal Data to which they have access in the course of their work.

In particular, this policy requires employees and associated persons to ensure that the Executive Director should be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.

The Executive Director is responsible for the monitoring and implementation of this policy. If you have any questions about the content of this policy or other comments you should contact the Executive Director.

Scope

This policy applies to all employees and associated persons. ‘Associated Persons’, for these purposes includes but not limited to, directors (board members), agency workers, casual workers, freelancers, consultants, seconded staff, agents, suppliers, volunteers and sponsors.

All employees and associated persons are expected to adhere to the principles set out in this policy.

The Company may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.

 Definitions

In this policy:

“Business Purposes” means the purposes for which Personal Data may be used by the Company, e.g. personnel, administrative, financial, regulatory, payroll and business development purposes;

“Personal Data” has the same meaning as set out in the General Data Protection Regulation (“GDPR”);

“Processing Data” means obtaining, recording, holding or doing anything with data, such as organising, using, altering, retrieving, disclosing or deleting it.

General principles

The Company’s policy is to process Personal Data in accordance with the applicable data protection laws and rights of individuals as set out below. All employees and associated persons have personal responsibility for the practical application of the Company’s data protection policy.

The Company will observe the following principles in respect of the processing of Personal Data:

• to process Personal Data fairly and lawfully in line with individuals’ rights;
• to make sure that any Personal Data processed for a specific purpose are adequate, relevant and not excessive for that purpose;
• to keep Personal Data accurate and up to date;
• to keep Personal Data for no longer than is necessary;
• to keep Personal Data secure against loss or misuse;
• not to transfer Personal Data outside the EEA without adequate protection.

Fair and lawful processing

Employees and associated persons should generally not process Personal Data unless:

• the individual whose details are being processed has consented to this;
• the processing is necessary to perform the Company’s legal obligations or exercise legal rights;
• the processing is necessary for a contract the Company has with the individual, or because they have asked you to take specific steps before entering into a contract;
• the processing is necessary to protect someone’s life;
• the processing is necessary for you to perform a task in the public interest;
• the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

When gathering Personal Data or establishing new data protection activities, employees and associated persons should ensure that individuals whose data is being processed receive appropriate data protection notices to inform them how the data will be used. In any case of uncertainty as to whether a notification should be given, employees and associated persons should contact the Executive Director.

It will normally be necessary to have an individual’s explicit consent to process Personal Data. The consent should be informed, which means it needs to identify the relevant data, why it is being processed and to whom it will be disclosed. Employees and associated persons should contact the Executive Director for more information on obtaining consent to process Personal Data.

 Accuracy, adequacy, relevance and proportionality

Employees and associated persons should make sure data processed by them is accurate, adequate, relevant and proportionate for the purpose for which it was obtained. Personal Data obtained for one purpose should generally not be used for unconnected purposes unless the individual has agreed to this.

Individuals have the right to ask the Company to correct Personal Data relating to them which they consider to be inaccurate. If a member of staff receives such a request and does not agree that the Personal Data held is inaccurate, they should nevertheless record the fact that it is disputed and inform the Executive Director.

Employees and associated persons must ensure that Personal Data held by the Company relating to them is accurate and updated as required. If personal details or circumstances change, employees and associated persons should inform the company, so that the Company’s records can be updated.

Security

Employees and associated persons must keep Personal Data secure against loss or misuse in accordance with the Company’s policies. Where the Company uses external organisations to process Personal Data on its behalf additional security arrangements need to be implemented in contracts with those organisations to safeguard the security of Personal Data. Employees and associated persons should consult the Executive Director to discuss the necessary steps to ensure compliance when setting up any new agreement or altering any existing agreement.

Data retention

Personal Data should not be retained for any longer than necessary. The length of time over which data should be retained will depend upon the circumstances including the reasons why the Personal Data was obtained.

International transfer

Employees and associated persons should not transfer Personal Data outside the EEA without first consulting the Executive Director. There are restrictions on international transfers of Personal Data from EEA to other countries because of the need to ensure adequate safeguards are in place to protect the Personal Data. Employees and associated persons unsure of what arrangements have been or need to be put in place to address this requirement should contact the Executive Director.

Rights of individuals

Individuals have the right to be informed about how, why and on what basis the Personal Data is processed. Any questions relating to this should be referred immediately to the Executive Director.

Individuals are entitled to request access to information held about them. All such requests should be referred immediately to the Executive Director. This is particularly important because the Company must respond to a valid request within the legally prescribed time limits.

Individuals are also entitled to request to have their Personal Data deleted from the Company’s records in certain instances. All such requests should be referred immediately to the Executive Director. This is particularly important because the Company must respond to a valid request within the legally prescribed time limits.

Individuals also have the right to restrict the processing of their Personal Data in certain circumstances. All such requests should be referred immediately to the Executive Director.

Employees and associated persons should not send direct marketing material to someone electronically (by email for example) unless that individual has explicitly consented to receiving marketing material. Employees and associated persons should abide by any request from an individual not to use their Personal Data for direct marketing purposes and should notify the Executive Director about any such request.

Employees and associated persons should contact the Executive Director for advice on direct marketing before starting any new direct marketing activity.

Any employee and associated persons who would like to correct or request information that the Company holds relating to them should contact the Executive Director.

Reporting breaches

Employees and associated persons have an obligation to report actual or potential data protection compliance failures to the Executive Director immediately upon becoming aware of such failure/potential failure. This allows the Company to:

• investigate the failure and take remedial steps if necessary; and
• make any applicable notifications.

Consequences of failing to comply

The Company takes compliance with this policy very seriously. Failure to comply puts both employees and associated persons and the Company at risk.

For employees, the importance of this policy means that failure to comply with any requirement will be dealt with in accordance with the Company’s disciplinary procedure. As far as associated persons are concerned, breach of this policy could lead to the suspension or termination of any relevant contract, sub-contract or other agreement with the associated person.

Employees and associated persons with any questions or concerns about anything in this policy should not hesitate to discuss these with the Executive Director.

Whistleblowing Procedure

Key points

The Whistleblowing Procedure sets out the framework for dealing with allegations of illegal and improper conduct. Southampton Business Improvement District LTD trading as GO! Southampton (“the Company”) is committed to the highest standards of transparency, probity, integrity and accountability.

This procedure is intended to provide a means of making serious allegations about standards, conduct, financial irregularity or possible unlawful action in a way that will ensure confidentiality and protect those making such allegations in the reasonable belief that it is in the public interest to do so from being victimised, discriminated against or disadvantaged.

This procedure does not replace other policies and procedures such as the complaints procedure, the Grievance and Harassment and Bullying Policies and other specifically laid down statutory reporting procedures. This procedure is intended to ensure that the Company complies with its duty under the Public Interest Disclosure Act 1998.   

Scope

To be a whistleblower, you must be a worker of the Company, including employees, trainees and agency workers. However, in the interest of transparency the Company will welcome the same procedure to be followed by directors, volunteers, partners and anyone working with or on behalf of the Company. The Company will not discriminate any person following this process.

This procedure applies to, but is not limited to, allegations about any of the following:

• That a criminal offence has been committed, is being committed or is likely to be committed.
• That a person has failed, is failing or is likely to fail to comply with any legal obligation to which the person is subject.
• That a miscarriage of justice that has occurred, is occurring, or is likely to occur.
• That the health or safety of any individual has been, is being, or is likely to be, endangered.
• That the environment, has been, is being, or is likely to be, damaged.
• That information tending to show any of the above, is being, or is likely to be, deliberately concealed.
• That the business or any associated person has been, is being, or is likely to be receiving or offering bribes.
• That any foreign official has been, is being, or is likely to be bribed or offered facilitation payment by the company or any associated person.

Those who become aware of information within their role, which they reasonably believe tends to the above allegations, must use the Company’s the Disclosure Procedure as set out below.

Disclosure Procedure

• Information which reasonably tends to show one or more of the above should promptly be disclosed to the Company Executive Director so that any appropriate action can be taken.
• If it is inappropriate to make such a disclosure to the Company Executive Director, the report should be sent to Company Board Director Chair whose details can be found on gosouthampton.co.uk or through the Charity Commission’s whistle blowing policy whistleblowing@charitycommission.gsi.gov.uk.
• The whistleblower will suffer no detriment of any sort for making such a disclosure in accordance with this procedure.
• However, failure to follow this procedure may result in the disclosure of information losing its ‘protected status’.
• For further guidance in relation to this matter or concerning the use of the disclosure procedure generally, contact the Company Executive Director, the Company Board Director Chair whose details can be found on www.gosouthampton.co.uk or the Charity Commission’s whistle blowing policy whistleblowing@charitycommission.gsi.gov.uk.

Confidentiality

All allegations will be treated in confidence and every effort will be made not to reveal a whistleblower’s identity unless the whistleblower otherwise requests or the matter is subsequently dealt with through other Company procedures such as the Disciplinary Procedure. Similarly, if the allegation results in court proceedings, then the whistleblower may have to give evidence in open court if the case is to be successful.

Anonymous Allegations

This procedure encourages whistleblowers to put their name to an allegation wherever possible as anonymous allegations may often be difficult to substantiate/prove.  Allegations made anonymously are much less powerful but anonymous allegations will be considered at the discretion of the Company Executive Director/Board of Directors Chair.

In exercising discretion to accept an anonymous allegation the factors to be taken into account:

• The seriousness of the issue raised,
• The credibility of the allegation; and
• Whether the allegation can realistically be investigated from factors or sources other than the complainant

Untrue Allegations

No disciplinary or other action will be taken against a whistleblower who makes an allegation in the reasonable belief that it is in the public interest to do so even if the allegation is not substantiated by an investigation.  However, disciplinary action may be taken against a whistleblower who makes an allegation without reasonable belief that it is in the public interest to do so, for example making an allegation frivolously, maliciously or for personal gain where there is no element of public interest.

Allegation

Whether a written or oral report is made it is important that relevant information is provided, including:

• The name of the person making the allegation and a contact point.
• The background and history of the allegation including relevant dates, and names and positions of those who may be in a position to have contributed to the allegation; and
• The specific reason for the allegation. Although someone making an allegation will not be expected to prove the truth of any allegations, they will need to provide information to the person they have reported to, to establish that that there are reasonable grounds for the allegation.

Someone making an allegation may be accompanied by another person of their choosing during any meetings or interviews in connection with the allegation. However, if the matter is subsequently dealt with through another procedure the right to be accompanied will at that stage be in accordance with the relevant procedure.

Action on receipt of an Allegation

The person who has received the allocation, as per the Disclosure Procedure, will record the details of the allegation, gathering as much information as possible. This will be completed within 5 working days of receipt of the allegation and will include:

• The record of the allegation,
• The acknowledgement of the allegation,
• Any documents supplied by the whistleblower.

The investigator will ask the whistleblower for their preferred means of communication and contact details. These will be used for all communications with the whistleblower in order to preserve confidentiality.

If the allegation concerns suspected harm to children or vulnerable adults the appropriate authorities will be informed immediately.

An acknowledge of the allegation will be sent in writing with:

• An indication of how the Company propose to deal with the matter,
• An estimate of how long it will take to provide a final response,
• An indication of whether any initial enquiries have been made,
• Information on whistleblower support mechanisms; and
• An indication whether further investigations will take place and if not, why not.

Where the allegation has been made internally and anonymously, the Company will be unable to communicate what action has been taken.

Support

The Company will take steps to minimise any difficulties which may be experienced as a result of making an allegation.  For instance, if a whistleblower is required to give evidence in criminal or disciplinary proceedings the Company will arrange for them to receive advice about the procedure and advise on the support mechanisms that are available.

Responsibility for the Procedure

The Company Executive Director and the Company Board Director Chair Trustees have overall responsibility for the operation of this Procedure and for determining the administrative processes to be followed and the format of the records to be kept.

Monitoring

A Register will record the following details:

• The name and status (e.g. employee) of the whistleblower.
• The date on which the allegation was received.
• The nature of the allegation.
• Details of the person who received the allegation.
• Whether the allegation is to be investigated and, if yes, by whom.
• The outcome of the investigation.
• Any other relevant details.

The Register will be confidential and only available for inspection by the Company Executive Director, and the Company Board Director Chair.

Safeguarding Statement

This Safeguarding Statement is to ensure protection for children, young people, and vulnerable adults from harm, abuse, and neglect. It is important to Southampton Business Improvement District Ltd trading as GO! Southampton (“the Company”) that full commitment is given to this, which includes being alert to signs of potential risk, understanding your expectations and reporting any concerns promptly.

This Statement applies to anyone working in a voluntary role for the Company, including, but not limited to the Welcome Volunteers and Board Directors. Throughout this Statement, this will be referred to as ‘Volunteers’. This Statement stands alongside all other policies and procedures, including the Whistleblowing Policy, GDPR Policy and the Volunteer Handbook.

Responsibilities and Expectations
The Executive Director at the Company is responsible for monitoring Safeguarding on behalf of the Company and ensuring that safeguarding is embedded in the Company. To help ensure a positive safeguarding culture, Volunteers are expected to comply with this statement, including the following expectations:

Volunteer Expectations

It is not anticipated, required or acceptable within the role of any Volunteer that they will be left alone with children, young people, and vulnerable adults. Should this situation occur, or should Volunteers anticipate this is likely to occur, Volunteers are to immediately alert the appropriate person listed in the ‘Reporting Concerns’ section below.

In the event of a Volunteer being at risk of being in soul company of a child, young person or vulnerable adult, the Company will require the Volunteer to carry out a Disclosure and Barring Service (DBS) check and comply with a Safeguarding Policy which is appropriate for their new responsibilities, including references and background checks. This is to take place, even if the incident is only anticipated once. Readers are reminded that it only takes one occasion for something tragic to happen, and this is not acceptable.

It is possible that Volunteers will be in public with children, young people, and vulnerable adults within the car of a parent, guardian or carer. For a positive safeguarding culture, the following is expected by all Volunteers:

• Prioritise safeguarding. It is expected that Volunteers will take their safety and the safety of others as priority within their role.
• Take time to understand who they must report safeguarding concerns on to.
• Report all safeguarding concerns immediately.
• Volunteers working within the public, or within spaces where public may attend, are expected to remain in pairs or more.
• Any potential for safeguarding issues, including neglect and abuse is to be reported to Executive Director via the details below under ‘Reporting Concerns’. Neglect includes any failure to meet a person’s basic needs, such as food, shelter, or medical care. Abuse includes any action that harms another person, including physical, emotional, sexual, financial, or discriminatory harm.
• Volunteers are to familiarise themselves with all Volunteer policies and procedures.
• Volunteers can access Safeguarding training, free of charge via the GO! Southampton ‘Business Training Hub’. Please contact info@gosouthampton.co.uk if you do not have access and would like to.

Report Concerns

If someone is in immediate danger, contact emergency services on 999.

All other concerns should be reported to your immediate contact, and/or the Executive Director of the Company. Their details are:

Stephen Manion, Executive Director

GO! Southampton

Stephen.manion@gosouthampton.co.uk

Network Eagle Lab

Portland Terrace

Southampton

SO14 7SJ

Reports should be made in writing and include as much factual information as possible.