1.1 We take your privacy seriously.

1.2 Silver Cord is committed to respecting the privacy of all those for whom we hold personal information/data at any time.
This Privacy Notice sets out specifically the data protection and data privacy policies that fall within the oversight of Silver Cord as a `Data Controller’, and it explains how your personal data is processed by us and for what purposes.

The Silver Cord is committed to processing personal information we hold in accordance with current and developing national data legislation. This includes the General Data Protection Regulation (the “GDPR”) which governs the processing of personal data; and the Data Protection Act 1998 and the Privacy and Electronic Communications Regulations 2003.

2. The legal Basis for processing your data

Silver Cord will keep personal information up to date; store and destroy information securely; not collect or retain excessive amounts of data; protect personal data from loss, misuse, unauthorised access and disclosure and ensure that appropriate technical measures are in place to protect personal data.

The specific legal bases against which Silver Cord will process information are

• Legitimate Interest
• Compliance with a legal obligation
• To fulfil contractual obligations
• Consent
• Vital interest
• Public task

3. Personal Information

As a charity, we need to handle ‘personal information’ to do our work. All we mean by ‘personal information’ is a way of speaking about any information about you, that is either linked to you or could be used to identity you.

We may hold some personal information about you, if:

• You have asked us to keep in touch with you and tell you about our work;
• You have applied for our services;
• You have offered your services;
• You visit our website.

What do we use this information for?

•  To fulfil our duties
• For the purposes of sending you/keeping you informed of news/information which you have requested and that may be of interest to you

What personal information do we use?

• Name and contact details: For most purposes, we need people’s name and contact details. These contact details usually include a postal address and / or email address and sometimes a phone number.

How we collect personal information

The data we process is likely to constitute sensitive personal data because as a Christian charity the fact that we process your data at all may be suggestive of your religious beliefs. Where you provide this information, we may also process other categories of sensitive personal data: racial or ethnic origin. And, where this is relevant, mental and physical health, details of injuries, medication/treatment received, and criminal records, fines and other similar judicial records.

We collect and record personal information (i.e. information about you and your relationship with us) in various ways, including:

From you:

• You may give us information directly – for example, if you write, call or email us or complete an online application form.

From observing your interactions and relationship with us:

• We may keep a note of our actions;
• We may keep a note of your actions – for example if you apply for a grant;
• We may also collect some information electronically – for example via email.

Sharing Personal Data

We don’t sell or rent your personal information to anyone else. Personal data will be treated as strictly confidential and will only be shared for lawful purposes and connected to the following circumstances:

•  Third Party Services – We use a website company as a Data Processor. Their use of your personal information is governed by our agreement with them and their own Privacy Policy.
• Legal or regulatory obligations – In some circumstances, we may share personal information if we need to comply with legal or regulatory obligations.

We will only keep personal data for as long as is necessary.

How we keep your personal information safe

We take steps to secure your personal information, and regularly review our approach with proper controls for paper and electronic records.

Individual rights and personal data

Under data protection legislation, you have various rights, including the right to see what personal information we hold about you.

You have a number of rights including:

• to be informed about how we use your personal information;
• to see what personal information we hold about you and know how it is used;
• to correct inaccurate or incomplete information that we hold;
• to ask us not to use your personal information in certain ways.
• to ask us to delete your personal information if we have it;
• where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• at any time to withdraw your consent to our processing of your personal data.

You also have other rights, including the right to complain.

There are some circumstances in which these rights don’t apply.

If you wish to exercise any of these rights, please contact us in writing. We usually need to comply with your request within one month of receiving it. We may need some information from you to ensure that we can identify you.

How do we keep you informed about your privacy?

We regularly review our approach to privacy and the use of personal information and will keep this page on our website up to date.

3. About cookies

3.1 Our website uses cookies. Insofar as those cookies are not strictly necessary for the provision of [our website and services], we will ask you to consent to our use of cookies when you first visit our website.

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

3.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

3.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

4. Cookies that we use

4.1 Like other websites, when you visit our website, we collect some information about your visit. To do this we use cookies.

We use cookies for the following purposes:

• Authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website.
• Analysis - we use cookies to help us to analyse the use and performance of our website and services.
• Cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

5. Cookies used by our service providers

5.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

5.2 We use Church Pages for hosting services. You can view the privacy policy of this service provider at https://www.churchpages.co.uk/124/Privacy-Policy

6. Managing cookies

6.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

• https://support.google.com/chrome/answer/95647 (Chrome);
• https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
• https://help.opera.com/en/latest/security-and-privacy/ (Opera);
• https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac  (Safari); and
• https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

6.2 Blocking all cookies will have a negative impact upon the usability of many websites.

6.3 If you block cookies, you will not be able to use all the features on our website.

7. Our details

7.1 This website is owned and operated by Silver Cord.

7.3 You can contact us by email, using the email address published on our website.

Our charitable activities include working with vulnerable people. The purpose of this policy is to protect children and vulnerable adults and provide stakeholders and the public with the overarching principles that guide our approach in doing so.

Safeguarding Principles

We believe that:

• Nobody who is involved in our work should ever experience abuse, harm, neglect or exploitation.
• We all have a responsibility to promote the welfare of all of our beneficiaries, staff and volunteers, to keep them safe and to work in a way that protects them.
• We all have a collective responsibility for creating a culture in which our people not only feel safe, but also able to speak up, if they have any concerns.

Safeguarding Policy Applicability

This safeguarding policy applies to anyone working on our behalf, including our charity trustees and other volunteers.

Our partner organisations will be required to have their own safeguarding procedures that must, as a minimum, meet the standards outlined below, and include any additional legal or regulatory requirements specific to their work. These may, but are not limited to:

• Other UK regulators, if applicable, such as Ofsted or CQC.
• Other authorities, such as the DfES or NHS.
  


There may be other requirements or frameworks for those working overseas.

• Charity Commission guidance - working overseas.
• The International Child Safeguarding Standards.
• Keeping children safe online assessment tool.
• Safeguarding should be appropriately reflected in other relevant policies and procedures.

Types of Abuse

Abuse can take many forms, such as physical, psychological or emotional, financial, sexual or institutional abuse, including neglect and exploitation. Signs that may indicate the different types of abuse are at Appendix 1.

Reporting Safeguarding Concerns

If a crime is in progress, or an individual in immediate danger, call the police, as you would in any other circumstances.

If you are a beneficiary, or member of the public, make your concerns known to a member of our team, who will alert a senior member of the charity.

For members of the charity, make your concerns known to your supervisor. If you feel unable to do so, speak to a trustee.

The trustees are mindful of their reporting obligations to the Charity Commission in respect of Serious Incident Reporting and, if applicable, other regulator. They are aware of the Government guidance on handling safeguarding allegations.

Trustee Safeguarding Responsibilities

Responsibilities should be made clear and individuals provided with any necessary training and resources to enable them to carry out their role. It should be reflected in Committee Terms of Reference, job descriptions, annual plan and appraisal objectives, reporting to the trustee Board and other procedures, as necessary.

Trustees. This safeguarding policy will be reviewed and approved by the Board annually.

Trustees are aware of and will comply with the Charity Commission guidance on safeguarding and protecting people and also the 10 actions trustee boards need to take to ensure good safeguarding governance.

A lead trustee/committee with be given responsibility for the oversight of all aspects of safety, including whistleblowing and H&SW. This will include:

• Creating a culture of respect, in which everyone feel safe and able to speak up.
• An annual review of safety, with recommendations to the Board.
• Receiving regular reports, to ensure this and related policies are being applied consistently.
• Providing oversight of any lapses in safeguarding.
• And ensuring that any issues are properly investigated and dealt with quickly, fairly and sensitively, and any reporting to the Police/statutory authorities is carried out.
• Leading the organisation in way that makes everyone feels safe and able to speak up.
• Ensuring safeguarding risk assessments are carried out and appropriate action taken to minimise these risks, as part of our risk management processes.
• Ensuring that all relevant checks are carried out in recruiting staff and volunteers.
• Planning programmes/activities to take into account potential safeguarding risks, to ensure these are adequately mitigated.
• Ensuring that all appointments that require DBS clearance and safeguarding training are identified, including the level of DBS and any training required.
• Ensuring that a central register is maintained and subject to regular monitoring to ensure that DBS clearances and training are kept up-to-date.
• Ensuring that safeguarding requirements (eg DBS) and responsibilities are reflected in job descriptions, appraisal objectives and personal development plans, as appropriate.
• Listening and engaging, beneficiaries, staff, volunteers and others and involving them as appropriate.
• Responding to any concerns sensitively and acting quickly to address these.
• Ensuring that personal data is stored and managed in a safe way that is compliant with data protection regulations, including valid consent to use any imagery or video.
• Making staff, volunteers and others aware of:
  a) Our safeguarding procedures and their specific safeguarding responsibilities on induction, with regular updates/reminders, as necessary.
  b) The signs of potential abuse and how to report these.

Everyone. To be aware of our procedures, undertake any necessary training, be aware of the risks and signs of potential abuse and, if you have concerns, to report these immediately (see above).


Safeguarding And Fundraising

We will ensure that:

• We comply with the Code of Fundraising Practice, including fundraising that involves children.
• Staff and volunteers are made aware of the Institute of Fundraising guidance on keeping fundraising safe and the NCVO Guidance on vulnerable people and fundraising.
• Our fundraising material is accessible, clear and ethical, including not placing any undue pressure on individuals to donate.
• We do not either solicit nor accept donations from anyone whom we know or think may not be competent to make their own decisions.
• We are sensitive to any particular need that a donor may have.

Online Safeguarding

We will identify and manage online risks by ensuring:

• Volunteers, staff and trustees understand how to keep themselves safe online. You could use high privacy settings and password access to meetings to support this.
• The online services you provide are suitable for your users. For example, use age restrictions and offer password protection to help keep people safe
• The services we use and/or provide are safe and in line with our code of conduct.
• Protect people’s personal data and follow GDPR legislation.
• We have permission to display any images on our website or social media accounts, including consent from an individual, parent, etc.
• We clearly explain how users can report online concerns. Concerns may be reported using this policy, or direct to a social media provider using their reporting process. If you are unsure, you can contact one of these organisations, who will help you.
  


Approval and Review

Approved by Debs Fidler  on 8 August 2022.

Appendix 1 – Signs of Abuse

Physical Abuse.

• bruises, black eyes, welts, lacerations, and rope marks.
• broken bones.
• open wounds, cuts, punctures, untreated injuries in various stages of healing.
• broken eyeglasses/frames, or any physical signs of being punished or restrained.
• laboratory findings of either an overdose or under dose medications.
• individual's report being hit, slapped, kicked, or mistreated.
• vulnerable adult's sudden change in behaviour.
• the caregiver's refusal to allow visitors to see a vulnerable adult alone.
  


Sexual Abuse.

• bruises around the breasts or genital area.
• unexplained venereal disease or genital infections.
• unexplained vaginal or anal bleeding.
• torn, stained, or bloody underclothing.
• an individual's report of being sexually assaulted or raped.


Mental Mistreatment/Emotional Abuse.

• being emotionally upset or agitated.
• being extremely withdrawn and non-communicative or non-responsive.
• nervousness around certain people.
• an individual's report of being verbally or mentally mistreated.

Neglect.

• dehydration, malnutrition, untreated bed sores and poor personal hygiene.
• unattended or untreated health problems.
• hazardous or unsafe living condition (e.g., improper wiring, no heat or running water).
• unsanitary and unclean living conditions (e.g., dirt, fleas, lice on person, soiled bedding, faecal/urine smell, inadequate clothing).
• an individual's report of being mistreated.

Self-Neglect.

• dehydration, malnutrition, untreated or improperly attended medical conditions, and poor personal hygiene.
• hazardous or unsafe living conditions.
• unsanitary or unclean living quarters (e.g., animal/insect infestation, no functioning toilet, faecal or urine smell).
• inappropriate and/or inadequate clothing, lack of the necessary medical aids.
• grossly inadequate housing or homelessness.
• inadequate medical care, not taking prescribed medications properly.

Exploitation.

• sudden changes in bank account or banking practice, including an unexplained withdrawal of large sums of money.
• adding additional names on bank signature cards.
• unauthorized withdrawal of funds using an ATM card.
• abrupt changes in a will or other financial documents.
• unexplained disappearance of funds or valuable possessions.
• bills unpaid despite the money being available to pay them.
• forging a signature on financial transactions or for the titles of possessions.
• sudden appearance of previously uninvolved relatives claiming rights to a vulnerable adult’s possessions.
• unexplained sudden transfer of assets to a family member or someone outside the family.
• providing services that are not necessary.
• individual's report of exploitation.