Data Protection Policy

Data Protection Act Disclosure
Cuckfield Dramatic Society (The Society) makes the following disclosures under the Data Protection Act 1998.
The society has an exemption from registration as its personal data processing is solely for the
purposes of
 Establishing and maintaining membership
 Supporting a not-for-profit body or association.
 Providing or administering activities for either the members or those who have regular
contact with it.
 Recording the purchase and use of tickets to the Society’s events
It is a condition of ticket purchase, membership and/or subscription to the mailing list (in any
capacity) that the Society may act as a Data Controller in respect of the associated personal data.
On occasion some images of persons in the audience may incidentally be recorded in the course of
still photography or video recording of the event for publicity or other purposes. However
individuals are not identified or catalogued in these images or recordings.

Categories of Personal Data Recorded
The society keeps the following categories of personal data either explicitly or incidentally.
a. Name and email address(es)
b. Postal address and phone number(s)
c. Details of tickets sold, events attended and associated textual notes
d. Interest and/or technical skill areas, playing age range, previous stage or other experience
e. Membership type and status, last payment date, last payment method
f. Notes relating to the administration of the society, and its productions
g. Video, audio or photographic images from productions or other events
The greatest potential scope of data kept is as follows:
Members (and former members who remain on the mailing list1): a, b, d, e, f, g
Mailing List Subscribers aka “Friends”: a, b, d, g
Audience Only Mailing List Subscribers: a
Ticket Purchasers: a, b, c
Audience Attendees: g
Data Accuracy and Access
 Any individual on the mailing list may adjust their details via the link in each message sent.
 Individuals may request a copy of data held by contacting the membership secretary.
 Updates or corrections may be sent in the same manner.
 A person may also apply to the membership secretary to ask that all administrative data be
deleted.
1 These former members may request data relating to their previous membership may be deleted – see below

Purpose and Uses of Personal Data
 Physical or electronic mailing lists for distributing, or recording the distribution of,
publications, newsletters, articles, text messages or other information to members or
subscribers or audience members.
 Maintenance of membership lists, ticket sales and associated financial records.
 Video, audio or photographic images for publicity, training and where appropriate as an
archive (typically these are of performers, but may include people in other roles, or,
incidentally some images of members of the audience).

Disclosure of Data
Data will only be disclosed when required, (and only under the authority of a Society committee
member) for the following purposes:
 Disclosures of personal contact details to other members (or those working with them) as part
of the Society’s productions or other activities (for example between members of cast or crew
for a particular production).
 Disclosures to persons acting as ticket agents when required for sales support.
 Disclosures to computer operator(s) and/or service(s) when required to repair/maintain
equipment and/or programmes.
 Issuing, or posting on the internet of images, videos or audio, and/or acting or crew roles for
publicity and review purposes.
 The Society does not sell or provide its membership list for use by any other organisation.

Data Retention
 Data is retained while a person remains a subscriber on the Society’s mailing list(s) or has
purchased tickets for a production within the last three years.
 If the owner of the email address selects to “unsubscribe” from the mailing list their records
will be marked as inactive and no automated email will be sent.
 Membership information of former members who remain on the mailing list as a friend (or
other non-paying mailing list subscriber) will be retained unless the former member explicitly
requests that the now surplus to needs data be deleted or unsubscribes from the mailing list.

Data Processing Services
Any data processing services used by the society will be subject to UK and EU data protection
rules.
The Society currently uses data processing services provided by TicketSource and MailChimp.
 TicketSource is based in the UK. For more information see their Privacy Policy.
 MailChimp is part of the US 'Safe Harbor Scheme'. This scheme, which is run by the US
government, ensures that data is protected to the same level as it would be in the UK. For
more information visit the MailChimp Privacy Policy.
Please note that when tickets are purchased through TicketSource there is a marketing option for
TicketSource to send details of other similar events unless the purchaser opts out.

Child Protection Policy

Cuckfield Dramatic Society (CDS) recognises its duty of care under the Children and Young Persons Act 1963, the Child (Performances) Regulations 1968, the Protection of Children Act 1999 and the Criminal Justice and Court Services Act 2000.

The society recognises that abuse can take many forms, whether it is physical abuse, emotional abuse, sexual abuse or neglect. We are committed to practice which protects children from harm. All members of CDS accept and recognize their responsibilities to develop awareness of the issues which cause children harm.

The society believes that:

The welfare of the child is paramount.
All children, whatever their age, culture, disability, gender, language, racial origin, religious beliefs and/or sexual identity have the right to protection from abuse.
All suspicions and allegations of abuse should be taken seriously and responded to swiftly and appropriately.
All members and volunteers of the society should be clear on how to respond appropriately.

The society will ensure that:

All children will be treated equally and with respect and dignity.
The duty of care to children will always be put first.
A balanced relationship based on mutual trust will be built which empowers the children to share in the decision making process.
Enthusiastic and constructive feedback will be given rather than negative criticism.
Bullying will not be accepted or condoned.
All adult members of the society provide a positive role model for dealing with other people.
Action will be taken to stop any inappropriate verbal or physical behaviour.
It will keep up-to-date with health & safety legislation.
It will keep informed of changes in legislation and policies for the protection of children.
It will undertake relevant development and training.
It will hold a register of every child involved with the society and will retain a contact name and number close at hand in case of emergencies.

The society follows National Child Protection guidelines, Equal Opportunities and Health and Safety guidelines.

The society has a dedicated Child Protection Office, who is in charge of ensuring that the child protection policy and procedures are adhered to.

That person’s name is Emma Gosling and she can be contacted on 01444 213227
This policy will be regularly monitored by the CDS Committee and is subject to annual reviews.
This policy used the NODA Model Child Protection Policy, v3.5 dated June 2016 as a basis.
This policy was created and adopted in July 2016, and was last reviewed and updated in January 2019.

Child Protection Procedures

Responsibilities of the Society

At the outset of any production involving children the Society will:

Undertake a risk assessment and monitor risk throughout the production process as per the CDS Health and Safety Policy.
Identify at the outset the person with designated responsibility for child protection.
Identify at the outset the person(s) with designated responsibility as chaperone(s) for each child separate from the person with designated responsibility for child protection.
Engage in effective recruitment of chaperones and other individuals with responsibility for children, including appropriate vetting (if necessary in consultation with the local education authority).
Ensure that children are supervised at all times.
Know how to get in touch with the local authority social services, in case it needs to report a concern.

Parents

The society believes it to be important that there is a partnership between parents and the company. Parents are encouraged to be involved in the activities of the company and to share responsibility for the care of children. All parents will be given a copy of the CDS Child Protection Policy.
All parents have the responsibility to collect (or arrange collection of) their children after rehearsals or performances. It is NOT the responsibility of the society to take children home.

Unsupervised Contact

The society will attempt to ensure that no adult has unsupervised contact with children.
If possible there will always be two adults in the room when working with children.
If unsupervised contact is unavoidable, steps will be taken to minimise risk. For example, work will be carried out in a public area, or in a designated room with a door open.
If it is predicted that an individual is likely to require unsupervised contact with children, he or she may be required to obtain a criminal record disclosure.

Physical Contact

All adults will maintain a safe and appropriate distance from children.
Adults will only touch children when it is absolutely necessary in relation to the particular activity.
Adults will seek the consent of the child prior to any physical contact and the purpose of the contact shall be made clear.

Managing Sensitive Information

The society has requested parental consent for the taking, using and storage of photographs or images of their children, for promotional purposes.
The society’s web-based materials and activities will be carefully monitored for inappropriate use.
The society will ensure confidentiality in order to protect the rights of its members, including the safe handling, storage and disposal of any sensitive information such as disclosures and barring documentation. See also the CDS Data Protection Policy.

Suspicion of Abuse

If you see or suspect abuse of a child while in the care of the society, please make this known to the person with responsibility for child protection. If you suspect that the person with responsibility for child protection is the source of the problem, you should make your concerns known to the Chairman.
Please make a note for your own records of what you witnessed as well as your response, in case there is follow-up in which you are involved.
If a serious allegation is made against any member of the society, chaperone, venue staff etc., that individual will be suspended immediately until the investigation is concluded. The individual will be excluded from the theatre, rehearsal rooms etc. and will not have any unsupervised contact with any other children in the production.

Disclosure of Abuse

If a child confides in you that abuse has taken place:

Remain calm and in control but do not delay taking action.
Listen carefully to what has been said. Allow the child to tell you at their own pace and ask questions only for clarification. Don’t ask questions that suggest a particular answer.
Don’t promise to keep it a secret. Use the first opportunity you have to share the information with the person with responsibility for child protection. Make it clear to the child that you will need to share this information with others. Make it clear that you will only tell the people who need to know and who should be able to help.
Reassure the child that ‘they did the right thing’ in telling someone.
Tell the child what you are going to do next.
Speak immediately to the person with responsibility for child protection. It is that person’s responsibility to liaise with the relevant authorities, usually social services or the police.
As soon as possible after the disclosing conversation, make a note of what was said, using the child’s own words. Note the date, time, any names that were involved or mentioned, and who you gave the information to. Make sure you sign and date your record.

Recording

In all situations, including those in which the cause of concern arises from a disclosure made in confidence, the details of an allegation or reported incident will be recorded, regardless of whether or not the concerns have been shared with a statutory child protection agency.
An accurate note shall be made of the date and time of the incident or disclosure, the parties involved, what was said or done and by whom, any action taken to investigate the matter, any further action taken e.g. suspension of an individual, where relevant the reasons why the matter was not referred to a statutory agency, and the name of the persons reporting and to whom it was reported.
The record will be stored securely and shared only with those who need to know about the incident or allegation.

Rights & Confidentiality

If a complaint is made against a member of the society, he or she will be made aware of his rights under the society’s disciplinary procedures.
No matter how you may feel about the accusation, both the alleged abuser and the child who is thought to have been abused have the right to confidentiality under the Data Protection Act 2018. Remember also that any possible criminal investigation could be compromised through inappropriate information being released.
In criminal law the Crown, or other prosecuting authority, has to prove guilt and the defendant is presumed innocent until proven guilty.

Accidents

To avoid accidents, chaperones and children will be advised of “house rules” regarding health and safety and will be notified of areas that are out of bounds. Children will be advised of the clothing and footwear appropriate to the work that will be undertaken.
If a child is injured while in the care of the society, a designated first-aider will administer first aid and the injury will be recorded in the society’s accident book.
This record will be countersigned by the person with responsibility for child protection.
If a child joins the production with an obvious physical injury a record of this will be made in the accident book. This record will be countersigned by the person with responsibility for child protection. This record can be useful if a formal allegation is made later and will also be a record that the child did not sustain the injury while participating in the production.

Criminal Record Disclosures

If the society believes it is in its best interests to obtain criminal record disclosures for chaperones or other personnel, it will inform the individual of the necessary procedures and the level of disclosure required. A Standard disclosure will apply for anyone with supervised access to children. An Enhanced disclosure will be required for anyone with unsupervised access.
The society will ensure that information contained in the disclosure is not misused.

Chaperones

If required chaperones will be appointed by the society for the care of children during the production process. By law the chaperone is acting in loco parentis and should exercise the care which a good parent might be reasonably expected to give to a child. The maximum number of children in the chaperone’s care shall not exceed 12.
Potential chaperones will be required to supply photographic proof of identity (eg. passport, driving licence) and two references from individuals with knowledge of their previous work with children, unless already well known to the society. They will also be asked to sign a declaration stating that there is no reason why they would be considered unsuitable to work with children.
Chaperones will be made aware of the society’s Child Protection Policy and Procedures.
Chaperones will not usually have unsupervised access to children in their care.
If unsupervised access is unavoidable, or if this is a requirement of the local authority, a criminal record disclosure will be sought.
Where chaperones are not satisfied with the conditions for the children, they should bring this to the attention of the producer. If changes cannot be made satisfactorily, the chaperone should consider not allowing the child to continue.
If a chaperone considers that a child is unwell or too tired to continue, the chaperone must inform the producer and not allow the child to continue.
Under the Dangerous Performances Act, no child of compulsory school age is permitted to do anything which may endanger life or limb. This could include working on wires or heavy lifting. Chaperones should tell the producer to cease using children in this way and should contact the local authority.
During performances, chaperones will be responsible for meeting children at the stage door and signing them into the building.
Children will be kept together at all times except when using separate dressing rooms.
Chaperones will be aware of where the children are at all times.
Children are not to leave the theatre unsupervised by chaperones unless in the company of their parents.
Children will be adequately supervised while going to and from the toilets.
Children will not be allowed to enter the adult dressing rooms.
Chaperones should be aware of the safety arrangements and first aid procedures in the venue, and will ensure that children in their care do not place themselves and others in danger.
Chaperones should ensure that any accidents are reported to and recorded by the society.
Chaperones should examine accident books each day. If an accident has occurred, the producer is not allowed to use that child until a medically qualified opinion has been obtained (not just the word of the parent or child).
Chaperones should have written arrangements for children after performances. If someone different is to collect the child, a telephone call should be made to the parent to confirm the arrangements.
Children should be signed out when leaving and a record made of the person collecting.
If a parent has not collected the child, it is the duty of the chaperone to stay with that child or make arrangements to take them home.