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.
240Project Safeguarding Policy
Version: 4
Date: 10 Jan 2024
Named Safeguarding Lead
Edward Farrelly
Next Review Date
10 Jan 2025
File Location
Cloud/Local Mac
Signed
Edward Farrelly
1. Introduction
This policy and the associated guidance delineate 240 Project's commitment to safeguarding vulnerable adults aged 18 and over. This policy adheres to the London Multi-Agency Adult Safeguarding Policy and Procedures (updated August 2016) and The Care Act 2014.
It supersedes all previous safeguarding policies and should be read alongside other 240Project policies, such as our Staff and Volunteer Induction Handbook, and the Complaints Policy and Procedures.
2. Safeguarding Standards Statement
240Project strives to foster an environment where all participants can safely and positively engage in the activities offered. In fulfilling this commitment,
240Project will:
Ensure staff and volunteers are trained in recognising abuse and know how to report it
Implement robust procedures for the recruitment and selection of trustees, staff, and volunteers that adhere to legal requirements and good practice
Nominate a Lead Safeguarding Officer, currently Edward Farrelly
Treat allegations of abuse seriously and report them to relevant authorities
3. Safeguarding Policy Guidelines
The policy aims to ensure a safe, caring environment for all participants, particularly vulnerable adults. Staff and volunteers are expected to adhere to the policy. The policy is informed by The Care Act 2014, London Multi-Agency Adult Safeguarding Policy and Procedures, and the Human Rights Act 1998.
4. Safeguarding Procedures
The Lead Safeguarding Officer is Edward Farrelly. All staff and volunteers should contact the Safeguarding Duty Officer for any concerns/queries they have regarding safeguarding adults. A log of the concern must be kept.
5. Confidentiality and Information Sharing
While 240Project emphasises confidentiality, it is crucial to share information with relevant authorities if an adult is deemed to be at immediate risk of harm.
6. Recruitment and Training
240Project is committed to safe recruitment practices, including Disclosure and Barring checks for key workers, and interview and reference requests for volunteers. All staff and volunteers receive basic awareness training on safeguarding vulnerable adults.
7. Complaints Procedure
Refer to 240 Projects Complaints Policy and Procedure for information on how to lodge a complaint about safeguarding at 240Project.
It is essential to note that incidents occurring outside of the charity's premises and operational hours, excluding organised trips, fall outside the purview of this policy. In these situations, individuals should follow relevant local or national legislation or policies applicable to the situation or environment.
8. Scope of Safeguarding Policy
The protections and guidelines outlined in this Safeguarding Policy apply to all activities occurring within the premises of the charity and during its operating hours. They are designed to ensure the safety and well-being of all individuals engaged in our programs or services while they are within our care at the charity's facilities.
However, the scope of this policy extends beyond our physical premises and regular hours in certain circumstances. Specifically, these protections and guidelines also apply to any off-site trips, events, or activities organised, sponsored, or supervised by the charity, regardless of their location or timing.
In such instances, all individuals involved, including staff, volunteers, and participants, are required to adhere to the principles and procedures outlined in this Safeguarding Policy, ensuring the continuation of our commitment to safety, respect, and dignity for all.
Appendices
Six Principles of Adult Safeguarding
Types of Abuse
Indications of Abuse
Signed on behalf of the Trustees
Geoffrey Murray, Chair
Date:
Charity Registration Number: 1180267
240Project Safeguarding Policy Guidelines
1. Purpose and Scope:
This Safeguarding Policy is designed to ensure the safety and wellbeing of all individuals who interact with 240Project. This includes our staff, volunteers, and the people we serve. This policy applies to all forms of harm, including physical, emotional, sexual, and financial abuse or harm.
2. Definitions:
"Safeguarding" refers to the range of measures we take to protect individuals in our care from harm.
"Abuse" refers to any action that harms another person physically, emotionally, sexually, or financially. It can also include neglect.
3. Roles and Responsibilities:
Everyone at 240Project has a responsibility to ensure the safety and wellbeing of others. However, our Safeguarding Lead, currently Edward Farrelly, holds ultimate responsibility for this policy's implementation.
4. Reporting Concerns:
Any concerns about abuse or harm should be reported immediately to the Safeguarding Lead. If a person feels uncomfortable doing so, they can report to an alternate, Geoffrey Murray, our Chair.
5. Procedure for Managing Allegations:
Allegations of abuse or harm will be taken seriously and treated in accordance with our Complaints Policy and Procedure. They will be investigated promptly and thoroughly, with the support of external authorities as needed.
6. Training and Support:
All staff and volunteers will receive training on this Safeguarding Policy. We will also provide ongoing support to help everyone understand their roles and responsibilities around safeguarding.
7. Record Keeping and Data Management:
We will maintain clear and detailed records of all safeguarding concerns and allegations, and their outcomes. This will be done in accordance with our data protection policy and legal requirements.
8. Review:
This Safeguarding Policy will be reviewed every two years or following any significant incidents to ensure it remains effective and fit for purpose.
Appendix One : Six Principles of Adult Safeguarding
1. Empowerment:
Adults are encouraged to make their own decisions and informed consent is sought. We always presume an individual's capacity to make a decision, unless there is a clear and legal reason to believe otherwise. "I am asked what I want as the outcomes from the safeguarding process and these directly inform what happens."
2. Prevention:
We aim to prevent harm and reduce the risk of abuse or neglect to adults with care and support needs. Prevention of harm and abuse is a primary objective and responsibility of all, and every effort should be made to promote wellbeing and prevent harm and abuse from occurring. "I receive clear and simple information about what abuse is. I know how to recognise the signs and what I can do to seek help."
3. Proportionality:
The least intrusive response appropriate to the risk presented will be provided. Responses should be proportionate to the risks and desired outcomes of the individual involved. "I am sure that the professionals will work in my interest, as I see them and they will only get involved as much as needed."
4. Protection:
Support and representation for those in greatest need will be available. If someone is at risk, action will be taken to protect them from harm. "I get help and support to report abuse and neglect. I get help to take part in the safeguarding process to the extent to which I want."
5. Partnership:
Local solutions through services working with their communities will be sought. Communities have a part to play in preventing, detecting, and reporting neglect and abuse. "I know that staff 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 will be ensured. Everyone involved in safeguarding adults will be clear about their roles and responsibilities. "I understand the role of everyone involved in my life and so do they."
Appendix Two: Types of Abuse
1. Physical Abuse:
Includes hitting, slapping, pushing, kicking, misuse of medication, restraint, or inappropriate sanctions.
2. Sexual Abuse:
Includes rape, indecent exposure, sexual harassment, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, subjection to pornography or witnessing sexual acts, indecent exposure and sexual assault or sexual acts to which the adult has not consented or was pressured into consenting.
3. Psychological Abuse:
Includes emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, cyberbullying, isolation, or unreasonable and unjustified withdrawal of services or supportive networks.
4. Financial or Material Abuse:
Includes theft, fraud, internet scamming, coercion in relation to an adult’s financial affairs or arrangements, including in connection with wills, property, inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits.
5. Neglect and Acts of Omission:
Includes ignoring medical, emotional or physical care needs, failure to provide access to appropriate health, care and support or educational services, the withholding of the necessities of life, such as medication, adequate nutrition, and heating.
6. Discriminatory Abuse:
Includes forms of harassment, slurs or similar treatment; because of race, gender and gender identity, age, disability, sexual orientation, or religion.
7. Organisational Abuse:
Includes neglect and poor care practice within an institution or specific care setting such as a hospital or care home, for example, or in relation to care provided in one’s own home. This may range from one-off incidents to ongoing ill-treatment. It can be through neglect or poor professional practice as a result of the structure, policies, processes, and practices within an organisation.
8. Self-neglect
This covers a wide range of behaviour neglecting to care for one’s personal hygiene, health, or surroundings and includes behaviour such as hoarding. In some cases, adults may make a conscious choice to neglect themselves, and the right to do so can be a self-determination issue.
9. Domestic Violence:
This includes an incident or a pattern of incidents of controlling, coercive, threatening, degrading, and violent behavior, including sexual violence, by a partner or family member.
10. Modern Slavery:
Covers slavery, human trafficking, forced labour, and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude, and inhumane treatment.
Remember, any or several types of abuse can be perpetrated at the same time. Abuse can happen anywhere: for example, in someone's own home, in a public place, in hospital, in a care home or in college. It can be caused by anyone, for example, a partner, relative, friend, carer, neighbour, an associate, a colleague, a professional or health worker, a volunteer or a stranger.
Appendix Three: Indications of Abuse
1. Physical Abuse:
Signs may include unexplained bruises, burns or cuts; frequent injuries; unexplained pain; reluctance to be touched; flinching at sudden movements; fear of physical contact.
2. Sexual Abuse:
Signs may include unexplained difficulty walking or sitting; sudden changes in behaviour or school performance; pregnancy, especially in young girls; evidence of sexual activities; knowledge of sexual behaviour beyond what is expected for the person's age.
3. Psychological Abuse:
Signs may include excessive fear or anxiety; withdrawal from normal activities or relationships; sudden changes in mood or behaviour; unexplained changes in eating or sleeping patterns; frequent nightmares or disturbed sleep.
4. Financial or Material Abuse:
Signs may include unexplained or sudden inability to pay bills; unexplained or sudden withdrawal of money from accounts; personal belongings missing; signature on checks or documents that do not resemble the person's signature.
5. Neglect and Acts of Omission:
Signs may include weight loss; dehydration; untreated physical problems; dirty or unsanitary living conditions; lack of necessary aids such as glasses, hearing aids, or medications.
6. Discriminatory Abuse:
Signs may include persistent failure to meet the person's basic physical, emotional, health, or educational needs; isolation or exclusion from activities or services; repeated instances of disrespectful or inappropriate language or behaviour.
7. Organisational Abuse:
Signs may include lack of flexibility or choice for the person; inadequate staffing levels; lack of respect for privacy or dignity; inappropriate or harsh responses to behaviour.
8. Self-neglect:
Signs may include poor personal hygiene; unsanitary or unsafe living conditions; lack of necessary medical or physical care; malnutrition or dehydration; refusal of assistance with daily activities.
9. Domestic Violence:
Signs may include frequent or unexplained injuries; fear of a specific individual; changes in behaviour, mood, or appearance; isolation from friends, family, or outside activities.
10. Modern Slavery:
Signs may include lack of personal belongings, identification or travel documents; restricted freedom of movement; unusual fear or anxiety; signs of physical or emotional abuse; evidence of control by another person, such as being accompanied at all times.
It is essential to remember that these are potential indicators of abuse. Noticing one or more of these signs does not guarantee that abuse is occurring. It should, however, trigger an investigation to determine whether abuse is happening and what steps should be taken.
Addendum: National Lottery Community Fund Safeguarding Policy
The safeguarding policy of the National Lottery Community Fund as found in this link is hereby incorporated into this policy. Where there are contradictions in practice, any issues will be resolved between the trustees of the charity in consultation with RBKC safeguarding team and the National Lottery Community Fund.