Management

GDPR is nearly here!

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GDPR is nearly here!

If your response is ‘what is GDPR?’ then you really need to read this!

The General Data Protection Regulation (GDPR) is one of the biggest changes to data protection regulations that we have seen in many years and comes into force on the 25th May 2018.

Our detailed understanding of its implications is evolving all the time and this Bulletin builds on, and supports, two previous Rural Ministries Bulletins which you should read first:

This Bulletin gives more information on obtaining ‘consent’ and the exceptions to this requirement.

How do I get consent?
The GDPR requires that you have explicit consent for nearly all the data you hold and you can only contact people for the purposes they have agreed to. Large national charities (eg The National Trust) may want to contact people on their database for a variety of reasons: new products, special offers, events, membership and each of these may require separate consent. Most rural churches do not have that level of communications and so a simpler approach to consent may be appropriate.

Rural Ministries has collected a number of forms that are in use, either by ourselves or by churches we know, and which we turned into example forms. We do not claim they are perfect but and you may wish to adapt these for use by your church.

  • Rural Ministries data review form – this is the form we used in 2017 to contact everyone on our postal mailing list. Download here

  • Rural Ministries ‘Contact us’ card – this could be amended for churches to use. In many cases you will only need name and email address for first contact. Download here

  • Event consent form – people signing in for basic event such as a Light Party don’t want to complete long forms when queuing to get in, so how about this simple way of capturing permission to stay in touch. Again, just a name and an email address is all that you need to collect to invite them to the next event. Download here

  • Possible church data consent form – this allows you to collect and store more details as they develop a closer relationship with you. Download here

With the right forms getting consent for new contacts is relatively straightforward. For existing contacts, you need to go through the process of contacting people. Do not be worried about having to delete a large part of your contact list – the chances are that if they do not reply then they are not interested, or may even have moved away.

Other reasons for holding data
There are some cases where data can be stored and used without obtaining consent. This includes where data processing is necessary:

  • for the performance of a contract to which the individual is party.

  • for compliance with legal obligations – eg Gift Aid or Anti Money Laundering regulations

  • for the purposes of ‘legitimate interests’ – this applies where there is a reasonable expectation that the individual will want you to store their data. Examples could be the local companies that you use for servicing the boiler or fire extinguishers, and your contacts in your local Churches Together group or denominational regional office.

What data should I store?
Firstly, you should only store data you have permission for (see wording on the Church Data Consent form above), but you should also record the basis for holding the data. On a spreadsheet this may be a box where you enter ‘2018 light party sign up’, ‘contact us card’, ‘Gift Aid’, ‘Legitimate Interest’ or other descriptor. You should also store the date entered and/or consent last received. Any forms containing consent should be stored securely.

You should also ensure that the issue of data protection and compliance with GDPR is discussed and minuted at a leaders meeting (ideally before the 25th May), its importance is recognised, and the steps towards compliance are agreed.

Heating systems and gas safety

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Heating systems and gas safety

The safety issues relating to gas are well known and include fire, explosion, carbon monoxide poisoning. It is therefore important that gas boilers, heaters and cookers are well maintained and safe to use regardless of whether they run of natural (mains) gas or Liquid Petroleum Gas (LPG). 

Health and Safety legislation (The Health and safety at Work Act 1974), places an obligation on all employers to ensure the safety of all persons, not just employees, using the premises.  Even if you do not consider your church to be an employer there are many legal grey areas and it is good practice to treat volunteer workers with the same protection as a paid worker. 

Gas Safety Regulations state that installations should be “maintained in a safe condition so as to prevent risk of injury to any person”. It is very difficult for an unqualified person to carry out adequate checks so the work should be undertaken by a Gas Safe engineer who is registered for that type of installation and for the work being undertaken. 

The testing and servicing intervals are not specified in legislation requirements exist for landlords (residential and commercial) including the need to have installations checked annually. It is therefore reasonable to expect churches to adopt the same requirements. 

Regardless of the servicing level carbon monoxide alarms are recommended by many insurers for rooms where there are combustion appliances. 

Oil installations do not have as many safety issues as gas systems and are not subject to the same regulations however it is still important to ensure they are serviced and maintained regularly not least because their efficiency can reduce more significantly that gas systems if not serviced.

Other heating system issues that are import, especially as winter approaches, is that pipes in unheated spaces such as roof or floor voids are lagged to prevent freezing and then bursting in very cold weather. 

Some churches supplement the main heating system with portable LPG heaters. There are many issues associated with these and they are not recommended.  
 

New term, new start?

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New term, new start?

Safeguarding is always an important issue, as children move up a new school year, September is a good time to review systems to help ensure the year runs as smoothly as possible. 

New helpers? New helpers often start in September and these need to have DBS checks in place as the terms rotas are prepared. Although there can be unchecked helpers this is not recommended for regular activities. Large-scale activities often require extra volunteers and churches often run joint activities and share workers, so it is important that everyone knows who is DBS checked. Make sure you have enough workers with DBS checks and who are trained to look out for signs of abuse, know how to respond and who to contact. Remember that safeguarding is also about protecting leaders and helpers from unfounded allegations or suspicions. Safeguarding should form part of a briefing for everyone involved in any type of activity and it should be on the agenda for all planning meetings. 

A safe environment? If activities may take place away from the usual site leaders must know where to get help, first aid, and what other people may be around. It is also important to check the new environment is safe and that any risks are identified and managed. 

Risk assessment. All activities should have a risk assessment and although this sounds difficult it is probably just writing down things that you are already doing. For many activities the form will be the same but some activities to different locations may need additional considerations. Remember that you may not be insured if you do not have an adequate risk assessment on file.

Consent forms? It is worth revisiting the consent forms that may already be on file since last year to check that you have all the contact details, necessary permissions for first aid, taking photographs etc and any information about allergies. A proper consent form is very reassuring to parents and an indication that an activity is being run properly. If you want to stay in touch with the parents and carers so you can invite them to future activities, make sure the form includes a tick box for this.  Remember that large scale events may not need as much information as regular events, so it may be useful to have a simpler registration form for these. 

Taking photos? Pictures of fun activities are great for church websites and social media but remember to check photos against the permission forms before use. Make sure that photos are appropriate; for example, don’t take and use photos of children in swimwear. It is best to use a camera and use a dedicated memory card, rather than personal mobile phones.

All safeguarding policies should be reviewed annually so it is a good idea to check that your organisation’s policy is up to date. If your organisation is a Rural Ministries partner and you don’t have a safeguarding policy (or if it needs replacing then) then we may be able to help through our Safeguarding partners CCPAS – just get in touch with us to find out more. 
 

Electrical safety Part 2:  Fixed electrical installations

Electrical safety Part 2: Fixed electrical installations

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Last month we looked at the issue of testing of portable appliances and now we turn our attention to the fixed wiring within churches. 

The standards for electrical wiring are constantly increasing meaning that systems are generally safer than before. That said, Ecclesiastical, a leading insurer of churches, reports that many church fires can be attributed to faulty wiring of equipment as well as causing electrical shocks and burns. 

Key areas that can cause problems are: 
• Faulty electrical wiring and apparatus.
• Poor earthing.
• Inadequate overcurrent protection. 
• Damage or wear and tear.
• Poor maintenance and testing.
• Contact with supplies.

Health and Safety legislation (The Health and safety at Work Act 1974), places an obligation on all employers to ensure the safety of all persons, not just employees, using the premises.  Even if you do not consider your church to be an employer there are many legal grey areas and it is good practice to treat volunteer workers with the same protection as a paid worker. Do it because you want to – not because you have to.

Electrical regulations (The Electricity at Work Regulations 1989) also require that “As may be necessary to prevent danger, all systems shall be maintained so as to prevent, so far as is reasonably practicable, such danger”.

The fixed electrical installation includes switches, sockets, light fittings and the distribution boards or fuse boxes along with the cabling itself. ‘Earthing’ is an important part of any electrical installation and in addition to the electrical system itself it is common for pipes and other large metal items to be earthed. 

Church Buildings Council and other bodies recommend that there an Electrical Installation Condition Report is carried out by a qualified contractor who is a ‘Full Scope’ member of NICEIC, ECA or NAPIT, at least every five years (three years where there is a Public Entertainment Licence). 

As with PAT testing the presence of a certificate is not enough as systems can be damaged and become dangerous in between tests. As well as being good practice, many insurers will want to see evidence of formal periodic visual inspections (VI) being carried out at least annually* by a competent, but not necessarily qualified, person. There should also be a system for church users to report concerns such as broken sockets, loose wires and damaged sheathing and ensuring that these problems are addressed. 

One measure that many churches encourage is the use of socket covers but theDepartment of Health and other bodies state that they SHOULD NOT be used as they can make electrical system more dangerous.

Nick Jones

*Electrical tests and gas safety checks for church buildings, Church Growth Trust

This guidance only seeks to provide generalised advice on the subject covered to assist churches in their operation. It is not a substitute for seeking specific advice on particular issue.

This article was originally published in e-news February 2018