Privacy & Cookies Policy

Last updated – 23rd April 2019

240Project would like all of our visitors and supports to feel confident, protected and comfortable with how their personal information will be treated or used. The following Privacy & Cookies Policy outlines how we collect, use and store your personal information.

Personal information as referred to in this Policy means any personal data or information relating to you that identifies or could identify you personally as described below.

1. Who we are

2. How we collect information about you

3. What we collect, why we collect it and how we store it

4. Legal basis for using your information

5. Email updates

6. Sharing your information

7. Keeping your information safe

8. How long we hold your information for

9. Your rights

10. Cookies

1. Who we are

240Project are committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner in accordance with applicable laws governing protection and privacy of personal data (“Data Protection Law”).

For further information about our privacy practices, please contact us by:

Writing to 240Project, Latymer Christian Centre, 116 Bramley Rd, London W10 6SU
Calling us on 0207 2217530
Emailing info@240project.org.uk

References to “we”, “us”, or “our” in this Privacy Policy are references to 240Project, a charity registered in England and Wales, registered charity number: 1180267.

2. How we collect information about you

240Project values protecting the privacy of all that come into contact with the organisation.

We may collect minimal information from:

Users seeking our services (“Members”):
When you interact with us directly: When Members visit 240Project’s space at Latymer Christian Centre in person. When Members visit 240Project’s space at Latymer Christian Centre, only first names and signatures are collected manually on a paper sign-in sheet. This data is stored only on original paper copies.

Staff, session workers and volunteers:
When you interact with us directly: When applying for positions and progressing through reference checks and interview stages.

Donors:
When you interact with us through third parties: When you provide a donation through a third party supplier (ie. PayPal, Just Giving, etc.) that we work with and provide your explicit consent for your personal information to be shared with us.

Website visitors:
When you visit our website: We gather general information through cookies, clicks and pages visited.

3. What we collect, why we collect it and how we store it

Members:
When Members visit 240Project’s space at Latymer Christian Centre, only first names and signatures are collected manually on a paper sign-in sheet. This data is stored only on original paper copies. Only the Project Manager and Director of the charity have access to these paper records.

Staff, session workers and volunteers:
Upon direct consent, we gather personal data limited to full name, contact information (email and mobile phone number), relevant qualifications, DBS and reference checks. The limited data collected by 240Project is stored in a spreadsheet saved locally on a password protected laptop. The spreadsheet is password protected and maintained by the Project Manager. Only the Project Manager and the Director of the charity have access to this spreadsheet. Once an applicant is approved, all data except for full name and contact information is deleted.

Donors:
When you provide a donation through a third party supplier (ie. PayPal, Just Giving, etc.) that we work with and provide your explicit consent for your personal information to be shared with us, we receive the name, email address, and monetary value listed in the form you submit. The limited data collected by 240Project is stored in a general contacts spreadsheet saved locally on a password protected laptop. The spreadsheet is password protected and maintained by the Project Manager. Only the Project Manager and the Director of the charity have access to this spreadsheet.

Website visitors:
We use this information to make improvements to our website and to ensure we provide the best service and experience for you. This website is hosted by Squarespace. Squarespace collects personal data when you visit this website, including:

Information about your browser, network and device
Web pages you visited prior to coming to this website
Your IP address

This information may also include details about your use of this website, including:

Clicks
Internal links
Pages visited
Scrolling
Searches
Timestamps

Squarespace needs the data to run this website, and to protect and improve its platform and services. Squarespace analyses the data in a de-personalised form.

This website uses font files from Google Fonts and Adobe Fonts. To properly display this site to you, servers where the font files are stored may receive personal information about you, including:

Information about your browser, network, or device
Your IP address

Wherever possible we use anonymous information which does not identify individual visitors to our website. We may also track which pages of the 240Project website (www.240project.org.uk) you visit when clicking on links in emails from us. This website also uses cookies. For further information, see “Cookies” below.

Sensitive Personal Information
Data Protection Law recognises that some categories of personal information are more sensitive than others (this is called ‘special category’ or ‘sensitive’ personal data). An example of this is information about ethnic origin. 240Project does not collect Sensitive Personal Information.

4. Legal basis for using your information

We will only use your personal information where we have one or more of the following legal basis for doing so:

Where we have your freely given, specific, informed and unambiguous consent to use this information for a particular purpose;
Because we need to use it in order to enter into or fulfil a contract with you (for example, if you apply for a staff or volunteer position);
To protect yours or someone else’s vital interests (e.g. a medical emergency);

For us to comply with a legal obligation; and/or

Where use of that information is necessary in 240Project’ ‘legitimate interests’ to help us to administer and achieve our work as a charity. Whenever we process your personal information under the ‘legitimate interest’ lawful basis, we make sure that we balance our interests against your legal rights and interests as an individual. In particular, we will not process your personal information in a manner that is privacy intrusive.

5. Email updates

For donors, we may contact you periodically about our work and how you can support 240Project. We will only send direct communications by email if you have explicitly given consent. You can stop us sending you these communications at any time by contacting info@240project.org.uk or clicking the unsubscribe link at the bottom of the relevant email communication.

6. Sharing your information

All data is contained to the Project Manager and Director of the charity. The complete data set is not and will not be shared with any third party unless legally obliged to do so.

7. Keeping your information safe

We take looking after your information very seriously. We’ve implemented appropriate and proportionate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.

Our website may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. Please be aware that advertisers or websites that have links on our website may collect personally identifiable information about you. This privacy statement does not cover the information practices of those other websites or advertisers.

Any debit or credit card details which we receive on our website are collected securely by PayPal our payment processing partner, according to the Payment Card Industry Data Security Standards. We never store any payment card information ourselves.

None of the 240Project Trustees are data protection professionals. Given the scale and nature of the personal data held, it would be a disproportionate use of charitable funds to employ a data protection professional.

The Trustees will seek appropriate professional advice commensurate with its data protection requirement whenever:

they are planning to make significant changes to the ways in which they process personal data;
there is any national publicity about new risks (e.g.: cyber-attacks) which might adversely compromise the Charity’s legitimate processing of personal data covered by the GDPR.

8. How long we hold your information for

We only keep your personal information only for as long as is reasonable and necessary for the relevant activity we collected it for.

240Project has a data retention policy that sets out the different periods we retain personal information for in accordance with our duties under Data Protection Law. The criteria we use for determining relevant data retention periods are based on:

various legislative requirements (for example, duties to hold transaction details for tax/accounting purposes);
the purpose for which we collected that personal information and where we have identified a continued legitimate need to hold that information to serve such purpose (For example: in the case of data subjects who held a role, such as a volunteer, with the charity, the retention period is that for which the Charity reasonably has a legitimate interest in being able to identify that individual’s role in the event of any retrospective query about it.); and
guidance issued by relevant regulatory authorities including, but not limited to, the UK Information Commissioner’s Office (ICO).

240Project will regularly – not less than every 12 months – review the personal data that we hold and and remove any data where retention is no longer justified. Such removal shall be made as soon as is reasonably practical. Personal information that we no longer need to hold is securely disposed of and/or anonymised so you can no longer be identified from it.

9. Your rights

You have various rights in respect of the personal information we hold about you – these are set out in more detail below. If you wish to exercise any of these rights or make a complaint, you can do so by contacting info@240project.org.uk or calling 0207 2217530. If you are not satisfied with our response, you can also make a complaint to the UK data protection supervisory authority, the Information Commissioner’s Office (ICO), see – https://ico.org.uk/:

Access to your personal information: You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge, unless a request is manifestly unfounded or unreasonable. Please make all requests for access in writing to info@240project.org.uk, and provide us with evidence of your identity.
Right to object: You can object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct communication purposes. Please contact us as noted above, providing details of your objection.
Consent: If you have given us your consent to use personal information (for example, for email communication), you can withdraw your consent at any time.
Rectification & Erasure: You can ask us to correct or complete any inaccurate or incomplete personal information held about you. You can also ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.

Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request due to legal exemptions. We may also need you to verify your identity before we can fully comply with a request.

10. Cookies

What is a cookie?
‘Cookie’ is a name for a small file, usually of letters and numbers, which is downloaded onto the browser (e.g. Internet Explorer, Safari or Google Chrome) of your device, like your computer, mobile phone or tablet when you visit a website. A cookie, by itself, cannot be used to identify you.

Why do we use cookies?
We use cookies to distinguish you from other users of our website. This helps us to improve the user experience. For further information about viewing the cookies dropped on your device, visit About the cookies Squarespace uses.

These functional and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you.

These analytics and performance cookies are used on this site, as described below, only when you acknowledge our cookie banner. We use analytics cookies to view site traffic, activity, and other data.

No cookies, please
You can opt out of all our cookies (except the strictly necessary ones) in your browser settings. But, if you choose to refuse all cookies, our website may not function for you as we would like it to.

Policy for Safeguarding Vulnerable Adults

Introduction

This policy and the accompanying guidelines detail 240Project’s approach to Safeguarding Vulnerable Adults aged 18 and over. 240Project does not serve under 18 year olds. This policy follows guidelines set out in the London Multi-Agency Adult Safeguarding Policy and Procedures (updated August 2016) and The Care Act 2014. This policy supersedes all other policies and statements with respect to Safeguarding and should be read in conjunction with 240Project’s other policies including the Staff and Volunteer Induction Handbook and the Complaints Policy and Procedures.

Safeguarding Standards Statement

The aim at 240Project is to provide a place where all members have the right to enjoy and participate in the activities offered at the project in a safe, positive and secure environment. 240Project recognises:

● It is the human right of all adults to live a life that is free from abuse and neglect;

● Adults can be at risk from various forms of abuse;

● Abuse may be committed by anyone, including those who are in a trusting relationship with an adult at risk;

● We have a duty to do everything possible to prevent, report and confront abuse wherever it is found.

In order to ensure these obligations are fulfilled 240Project will: ● Ensure that staff and volunteers are aware of this policy and the accompanying guidelines;

● Ensure that staff and volunteers are trained in recognising abuse and know how to report it;

● Ensure that Managers take seriously any allegations of abuse and report them to the relevant agency;

● Implement procedures for the recruitment and selection of trustees, staff and volunteers that comply with current legal requirements and good practice; ● Ensure that everyone who comes to 240Project knows that they can report concerns of abuse; ● Take seriously any allegation that a member of staff or volunteer has committed abuse;

● Nominate a Lead Safeguarding Officer, who will be Edward Farrelly.

Agreed and signed on behalf of the Management Committee

By Geoffrey Murray, Chair

Date:

Version 2/November 2020 240Project CIO 1180267

240Project Safeguarding Policy Guidelines

Aims

240Project is an Arts and Wellbeing Activity Centre for adults who may have been affected by homelessness, social exclusion and isolation. Many of our members are vulnerable adults with a history of mental health issues, drug or alcohol abuse.

The project aims to ensure that all current and potential members are welcomed in a safe, caring environment with a happy and friendly atmosphere. In doing so the charity takes seriously the welfare of all vulnerable adults who come onto its premises or who are involved in its activities. 240Project will not tolerate the abuse of adults in any of its forms and is committed to safeguarding adults with care and support needs from harm.

This policy outlines the steps 240Project will make to safeguard an adult with care and support needs if they are deemed to be at risk. It sets out the roles and responsibilities of the project in working together with other professionals and agencies in promoting the adults welfare and safeguarding them from abuse and neglect.

This policy is intended to support staff and volunteers to understand their role and responsibilities in safeguarding adults. All staff and volunteers are expected to follow this policy.

The key objectives of this policy are for all staff and volunteers of 240Project to:

● have an overview of adult safeguarding

● be clear about their responsibility to safeguard adults

● ensure the necessary actions are taken where an adult with care and support needs is deemed to be at risk

This policy is based on:

- The Care Act 2014 and the Care and Support statutory guidance;

- London Multi-Agency Adult Safeguarding Policy and Procedures.

Under the Human Rights Act 1998, everyone has the right to live free from abuse and neglect: https://www.equalityhumanrights.com/en/human-rights/human-rights-act

What is safeguarding adults?

‘Safeguarding means protecting an adult’s right to live in safety, free from abuse and neglect. It is about people and organisations working together to prevent and stop both the risks and experience of abuse or neglect, while at the same time making sure that the adult’s wellbeing is promoted including, where appropriate, having regard to their views, wishes, feelings and beliefs in deciding on any action. This must recognise that adults sometimes have complex interpersonal relationships and may be ambivalent, unclear or unrealistic about their personal circumstances.’

Care and Support Statutory Guidance, Department of Health, updated February 2017

Version 2/ November 2020 240Project CIO 1180267

All adults should be able to live free from fear and harm. But some may find it hard to get the help and support they need to stop abuse. An adult may be unable to protect themselves from harm or exploitation due to many reasons, including their mental or physical incapacity, sensory loss or physical or learning disabilities. This could be an adult who is usually able to protect themselves from harm but maybe unable to do so because of an accident, disability, frailty, addiction or illness.

240Project adheres to following the six key principles that underpin safeguarding work (See Appendix 1)

● Empowerment

● Prevention

● Proportionality

● Protection

● Partnership

● Accountability

240Project will not tolerate the abuse of adults, staff and volunteers should ensure that their work reflects the principles above and ensure the adult with care and support needs is involved in their decisions and informed consent is obtained. The project’s Safeguarding Officer should ensure that the safeguarding action agreed is the least intrusive response to the risk. Partners from the community should be involved in any safeguarding work in preventing, detecting and reporting neglect and abuse. We should be transparent and accountable in delivering safeguarding actions.

Safeguarding Procedures at 240Project

The Lead Safeguarding Officer at 240Project is:

Edward Farrelly (efarrelly@240project.org.uk)

The Safeguarding Duty Officer is:

Richard Todd Email: richard.paul.todd@hotmail.co.uk)

All staff and volunteers should contact the Safeguarding Duty Officer for any concerns/queries they have in regards to safeguarding adults. If this person is seen as inappropriate then the member of staff or volunteer should contact the Lead Safeguarding Officer. A log of the concern must be kept.

The Safeguarding Duty Officer is responsible to make decisions about notifying adult social services if required and consider alternative actions, where necessary.

The Lead Safeguarding Officer will ensure that the safeguarding policies and procedures are in place and up to date. They will ensure a safe environment is promoted for staff and volunteers and adults accessing the service. The lead Safeguarding Officer will also ensure they are up to date with their safeguarding adults training.

Version 2/November 2022 240Project CIO 1180267

What should I do if I am concerned?

(Please note, if someone is at immediate risk of harm/in need of urgent medical attention, take emergency action. Dial 999 for emergency services).

An adult safeguarding concern is any worry about an adult who has, or appears to have, care and support needs and may be at risk of abuse and neglect and may be unable to protect themselves against this (See Appendix 2). A concern may be raised by anyone, and can be:

● An active disclosure of abuse by the adult, where the adult tells a member of staff that they are experiencing abuse and/or neglect;

● A passive disclosure of abuse where someone has noticed signs of abuse or neglect, for example unexplained injuries;

● An allegation of abuse by a third party, for example a family/friend or neighbour who have observed abuse or neglect or have been told of it by the adult;

● A concern raised by staff or volunteers, others using the service, a carer or a member of the public;

● An observation of the behaviour of the adult at risk.

The following steps should be followed in raising a safeguarding concern:

1. Respond

Get brief details about what has happened and what the adult would like done about it, but do not probe or conduct a mini-investigation

Seek consent from the adult to take action and to report the concern. Consider whether the adult may lack capacity to make decisions about their own and other people’s safety and wellbeing. If you decide to act against their wishes or without their consent, you must record your decision and the reasons for this.

2. Report

Report the incident to the Safeguarding Duty Officer (Richard Todd). Has a crime been committed? If so, does it need to be reported (dial 101 unless there is an immediate risk, in which case dial 999).

3. Record

The concern must be recorded by completing a Safeguarding Report Form (see Appendix 3) which is kept by the Safeguarding Duty Officer. A safeguarding concern should not be reported in the Incident Book which is not locked away and therefore not confidential.

4. Refer

In making a decision whether to refer or not, the Safeguarding Duty Officer should take into account:

● the adult’s wishes and preferred outcome;

Version 2 /November 2022 240Project

● whether the adult has mental capacity to make an informed decision about their own and others’ safety;

● whether there is a person in a position of trust involved;

● whether a crime has been committed.

This should inform the decision whether to notify the concern to the following people:

● the police if a crime has been committed and/or;

● Kensington and Chelsea’s Duty Officer (part of adult social services) for possible safeguarding enquiry. The local number (office hours) is: 020 7361 3013. The out of hour’s emergency number is 020 7373 2227.

● Family/relatives as appropriate (seek advice from adult social services).

The designated safeguarding lead should keep a record of the reasons for referring the concern or reasons for not referring.

Confidentiality and information sharing

240Project expects all staff, volunteers and management committee members to maintain confidentiality at all times. In line with Data Protection law 240Project does not share information if not required.

It should be noted however that information should be shared with authorities if an adult is deemed to be at risk of immediate harm.

Recruitment and training

240Project is committed to safe recruitment practices including Disclosure and barring checks for key workers and interview and references requests for volunteers as outlines in 240 Projects’ Recruitment Policy.

240Project also ensures that all staff and volunteers receive basic awareness training on safeguarding vulnerable adults.

Complaints Procedure

The procedures as set out in 240Project’s Complaints Policy and Procedure is for the use of members, visitors, volunteers and donors. 240Project promotes transparency and honesty when things go wrong and should an individual wish to complain about safeguarding at 240Project then they should refer to the Complaints Policy.

Version 2/November 2022 240Project

Registered Charity No. 1180267

Appendix 1

Six Principles of Adult Safeguarding

The Care Act sets out the following principles that should underpin the safeguarding of adults:

1. Empowerment

People are supported and encouraged to make their own decisions and informed consent. “I am asked what I want as the outcomes from the safeguarding process and this directly inform what happens.”

2. Prevention

It is better to take action before harm occurs.

“I receive clear and simple information about what abuse is. I know how to recognise the signs, and I know what I can do to seek help.”

3. Proportionality

The least intrusive response appropriate to the risk presented.

“I am sure that the professionals will work in my interest and they will only get involved as much as is necessary.”

4. Protection

Support and representation for those in greatest need.

“I get help and support to report abuse and neglect. I get help so that I am able to take part in the safeguarding process to the extent to which I want.”

5. Partnership

Services offer local solutions through working closely with their communities. Communities have a part to play in preventing, detecting and reporting neglect and abuse. “I know that staf treat any personal and sensitive information in confidence, only sharing what is helpful and necessary. I am confident that professionals will work together and with me to get the best result for me.”

6. Accountability

Accountability and transparency in delivering safeguarding.

“I understand the role of everyone involved in my life and so do they.”

Version 2/November 2022 240Project

Appendix 2

What are the types of abuse regarding adults?

The Care and Support statutory guidance sets out the 10 main types of abuse:

● Physical abuse

● Neglect

● Sexual abuse

● Psychological

● Financial abuse

● Discriminatory abuse

● Organisation abuse

● Domestic violence

● Modern slavery

● Self-neglect

However you should keep an open mind about what constitutes abuse or neglect as it can take many forms and the circumstances of the individual case should be considered.

What are the possible signs of abuse?

● Depression, self-harm or suicide attempts

● Difficulty making friends

● Fear or anxiety

● The person looks dirty or is not dressed properly

● The person never has money

● The person has an injury that is difficult to explain (such as bruises, finger marks) ● The person has signs of a pressure ulcer

● The person is experiencing insomnia

● The person seems frightened, or frightened of physical contact

● Inappropriate sexual awareness or sexually explicit behaviour

● The person is withdrawn, changes in behaviour

You should ask the person if you are unsure about their well-being as there may be other explanations to the above presentation.

Version 2/November 2022 240Project

Appendix 3

240Project Safeguarding Report Form

This form should be used to record safeguarding concerns relating to a vulnerable adult. All the information must be treated as confidential and reported to the Lead Safeguarding Of icer within one working day. The form should be completed at the time or immediately following disclosure, but after all necessary emergency actions have been taken. Please complete the form as fully as possible.

Your details (the person completing the form)

Name:

Position:

Date:

Details of person affected

Name:

Address:

Telephone:

Details of the incident (please describe in detail only using facts)

Other person present or potential witnesses

Name:

Address: