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Cookie Policy

Cookie policy

This cookie policy ("Policy") describes what cookies are and how and they're being used by theraisingyouth.co.ukwebsite ("Website" or "Service") and any of its related products and services (collectively, "Services"). This Policy is a legally binding agreement between you ("User", "you" or "your") and this Website operator ("Operator", "we", "us" or "our"). You should read this Policy so you can understand the types of cookies we use, the information we collect using cookies and how that information is used. It also describes the choices available to you regarding accepting or declining the use of cookies.

What are cookies?

Cookies are small pieces of data stored in text files that are saved on your computer or other devices when websites are loaded in a browser. They are widely used to remember you and your preferences, either for a single visit (through a "session cookie") or for multiple repeat visits (using a "persistent cookie").

Session cookies are temporary cookies that are used during the course of your visit to the Website, and they expire when you close the web browser.

Persistent cookies are used to remember your preferences within our Website and remain on your desktop or mobile device even after you close your browser or restart your computer. They ensure a consistent and efficient experience for you while visiting the Website and Services.

Cookies may be set by the Website ("first-party cookies"), or by third parties, such as those who serve content or provide advertising or analytics services on the Website ("third party cookies"). These third parties can recognize you when you visit our website and also when you visit certain other websites.

What type of cookies do we use?

Necessary cookies

Necessary cookies allow us to offer you the best possible experience when accessing and navigating through our Website and using its features. For example, these cookies let us recognize that you have created an account and have logged into that account to access the content.

Functionality cookies

Functionality cookies let us operate the Website and Services in accordance with the choices you make. For example, we will recognize your username and remember how you customized the Website and Services during future visits.

Analytical cookies

These cookies enable us and third party services to collect aggregated data for statistical purposes on how our visitors use the Website. These cookies do not contain personal information such as names and email addresses and are used to help us improve your user experience of the Website.

Social media cookies

Third party cookies from social media sites (such as Facebook, Twitter, etc) let us track social network users when they visit or use the Website and Services, or share content, by using a tagging mechanism provided by those social networks.

These cookies are also used for event tracking and remarketing purposes. Any data collected with these tags will be used in accordance with our and social networks’ privacy policies. We will not collect or share any personally identifiable information from the user.

What are your cookie options?

If you don't like the idea of cookies or certain types of cookies, you can change your browser's settings to delete cookies that have already been set and to not accept new cookies. To learn more about how to do this or to learn more about cookies, visitinternetcookies.org

Changes and amendments

We reserve the right to modify this Policy or its terms relating to the Website and Services at any time, effective upon posting of an updated version of this Policy on the Website. When we do, we will revise the updated date at the bottom of this page. Continued use of the Website and Services after any such changes shall constitute your consent to such changes.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.

Contacting us

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to our use of cookies, you may do so via the contact form.

 This policy is effective from 28th May 2020

Privacy Policy

Your privacy is important to us. It is Raising Youth's policy to respect your privacy regarding any information we may collect from you across our website, https://www.raisingyouth.co.uk, and other sites we own and operate.

We only ask for personal information when we truly need it to provide a service to you. We collect it by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used.

We only retain collected information for as long as necessary to provide you with your requested service. What data we store, we’ll protect within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.

We don’t share any personally identifying information publicly or with third-parties, except when required to by law.

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and practices of these sites, and cannot accept responsibility or liability for their respective privacy policies.

You are free to refuse our request for your personal information, with the understanding that we may be unable to provide you with some of your desired services.

Your continued use of our website will be regarded as acceptance of our practices around privacy and personal information. If you have any questions about how we handle user data and personal information, feel free to contact us.

This policy is effective as of 28 May 2020.

Terms of Service

1. Terms


By accessing the website at https://www.raisingyouth.co.uk, you are agreeing to be bound by these terms of service, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this website are protected by applicable copyright and trademark law.


2. Use Licence


Permission is granted to temporarily download one copy of the materials (information or software) on Raising Youth's website for personal, non-commercial transitory viewing only. This is the grant of a licence, not a transfer of title, and under this licence you may not:


  • Modify or copy the materials;
  • Use the materials for any commercial purpose, or for any public display (commercial or non-commercial);
  • attempt to decompile or reverse engineer any software contained on Raising Youth's website;
  • Remove any copyright or other proprietary notations from the materials; or
  • Transfer the materials to another person or "mirror" the materials on any other server.


This licence shall automatically terminate if you violate any of these restrictions and may be terminated by Raising Youth at any time. Upon terminating your viewing of these materials or upon the termination of this licence, you must destroy any downloaded materials in your possession whether in electronic or printed format.



3. Disclaimer

The materials on Raising Youth's website are provided on an 'as is' basis. Raising Youth makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties including, without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights.

Further, Raising Youth does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its website or otherwise relating to such materials or on any sites linked to this site.


4. Limitations


In no event shall Raising Youth or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption) arising out of the use or inability to use the materials on Raising Youth's website, even if Raising Youth or a Raising Youth authorised representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.


5. Accuracy of materials


The materials appearing on Raising Youth's website could include technical, typographical, or photographic errors. Raising Youth does not warrant that any of the materials on its website are accurate, complete or current. Raising Youth may make changes to the materials contained on its website at any time without notice. However Raising Youth does not make any commitment to update the materials.


6. Links


Raising Youth has not reviewed all of the sites linked to its website and is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by Raising Youth of the site. Use of any such linked website is at the user's own risk.


7. Modifications


Raising Youth may revise these terms of service for its website at any time without notice. By using this website you are agreeing to be bound by the then current version of these terms of service.


8. Governing Law



These terms and conditions are governed by and construed in accordance with the laws of England and you irrevocably submit to the exclusive jurisdiction of the courts in that State or location.

Data Protection

1. Introduction

1.1 Background to the General Data Protection Regulation (‘GDPR’) 

The General Data Protection Regulation 2016 replaces the EU Data Protection Directive of 1995 and supersedes the laws of individual Member States that were developed in compliance with the Data Protection Directive 95/46/EC. Its purpose is to protect the “rights and freedoms” of natural persons (i.e. living individuals) and to ensure that personal data is not processed without their knowledge, and, wherever possible, that it is processed with their consent. 

1.2 Definitions used by the organisation (drawn from the (GDPR) Material scope (Article 2)

The GDPR applies to the processing of personal data wholly or partly by automated means (i.e. by computer) and to the processing other than by automated means of personal data (i.e. paper records) that form part of a filing system or are intended to form part of a filing system. Territorial scope (Article 3) – the GDPR will apply to all controllers that are established in the EU (European Union) who process the personal data of data subjects, in the context of that establishment. It will also apply to controllers outside of the EU that process personal data in order to offer goods and services, or monitor the behaviour of data subjects who are resident in the EU. 

1.3 Article 4 definitions Establishment

The main establishment of the controller in the EU will be the place in which the controller makes the main decisions as to the purpose and means of its data processing activities. The main establishment of a processor in the EU will be its administrative centre. If a controller is based outside the EU, it will have to appoint a representative in the jurisdiction in which the controller operates to act on behalf of the controller and deal with supervisory authorities. 

Personal data

Any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

Special categories of personal data

Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, bio-metric data for the purpose of uniquely identifying a natural person, data concerning health or data 8 concerning a natural person's sex life or sexual orientation. 

Data controller

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law. 

Data subject

Any living individual who is the subject of personal data held by an organisation. 

Processing

Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction

Profiling

Is any form of automated processing of personal data intended to evaluate certain personal aspects relating to a natural person, or to analyse or predict that person’s performance at work, economic situation, location, health, personal preferences, reliability, or behaviour. This definition is linked to the right of the data subject to object to profiling and a right to be informed about the existence of profiling, of measures based on profiling and the envisaged effects of profiling on the individual. 

Personal data breach

A breach of security leading to the accidental, or unlawful, destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed. There is an obligation on the controller to report personal data breaches to the supervisory authority and where the breach is likely to adversely affect the personal data or privacy of the data subject. 

Data subject consent

Means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data.

Child

The GDPR defines a child as anyone under the age of 16 years old, although this may be lowered to 13 by Member State law. The processing of personal data of a child is only lawful if parental or custodian consent has been obtained. The controller shall make reasonable efforts to verify in such cases that consent is given or authorised by the holder of parental responsibility over the child.

Third party

A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Filing system

Any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis. 

2. Policy statement 

2.1 The Raising Youth management team are committed to compliance with all relevant EU and Member State laws in respect of personal data, and the protection of the “rights and freedoms” of individuals whose information Raising Youth collects and processes in accordance with the General Data Protection Regulation (GDPR). 

2.2 Compliance with the GDPR is described by this policy and other relevant policies such as the Information Security Policy, along with connected processes and procedures. 

2.3 The GDPR and this policy apply to all of Raising Youth's personal data processing functions, including those performed on customers’, clients’, employees’, suppliers’ and partners’ personal data, and any other personal data the organisation processes from any source. 

2.4 Data Protection Officer/GDPR Owner is responsible for reviewing the register of processing annually in the light of any changes to Raising Youth's activities (as determined by changes to the data inventory register and the management review) and to any additional requirements identified by means of data protection impact assessments. This register needs to be available on the supervisory authority’s request. 

2.5 This policy applies to all Volunteers/Employees/Staff and any other interested parties of Raising Youth such as outsourced suppliers. Any breach of the GDPR will be dealt with under Raising Youth’s disciplinary policy and may also be a criminal offence, in which case the matter will be reported as soon as possible to the appropriate authorities. 

2.6 Partners and any third parties working with or for Raising Youth, and who have or may have access to personal data, will be expected to have read, understood and to comply with this policy. No third party may access personal 10 data held by Raising Youth without having first entered into a data sharing or data confidentiality agreement, which imposes on the third party obligations no less onerous than those to which Raising Youth is committed, and which gives Raising Youth the right to audit compliance with the agreement. 

3. Responsibilities and roles under the General Data Protection Regulation

3.1 Raising Youth is a data controller under the GDPR. 

3.2 Managers and all those in managerial or supervisory roles throughout Raising Youth are responsible for developing and encouraging good information handling practices within Raising Youth.

3.3 Data Protection Officer/GDPR Owner Job Description, a role specified in the GDPR, is a member of the senior leadership team, who is responsible for ensuring that compliance with data protection legislation and good practice can be demonstrated. This accountability includes: 

3.3.1 Development and implementation of the GDPR as required by this policy; and 

3.3.2 Security and risk management in relation to compliance with the policy. 

3.4 Data Protection Officer/GDPR Owner, has been allocated responsibility for Raising Youth’s compliance with this policy on a day-to-day basis and, in particular, has direct responsibility for ensuring that Raising Youth complies with the GDPR, as do Managers in respect of data processing that takes place within their area of responsibility. 

3.5 The Data Protection Officer/GDPR Owner have specific responsibilities in respect of procedures such as the Subject Access Request Procedure and are the first point of call for Employees/Staff seeking clarification on any aspect of data protection compliance. 

3.6 Compliance with data protection legislation is the responsibility of all Employees/Staff of Raising Youth who process personal data. 

3.7 Employees/Staff of Raising Youth are responsible for ensuring that any personal data about them and supplied by them to Raising Youth is accurate and up-to-date.

4 Data protection principles 

All processing of personal data must be conducted in accordance with the data protection principles as set out in Article 5 of the GDPR. Raising Youth’s policies and procedures are designed to ensure compliance with the principles. 

4.1 Personal data must be processed lawfully, fairly and transparently

Lawful:

Identify a lawful basis before you can process personal data. These are often referred to as the “conditions for processing”, for example consent. 

Fairly:

In order for processing to be fair, the data controller has to make certain information available to the data subjects as practicable. This applies whether the personal data was obtained directly from the data subjects or from other sources. The ICO provides guidance on ‘Privacy notices, transparency and control’ here.

The GDPR has increased requirements about what information should be available to data subjects, which is covered in the ‘Transparency’ requirement. 

Transparency:

The GDPR includes rules on giving privacy information to data subjects in Articles 12, 13 and 14. These are detailed and specific, placing an emphasis on making privacy notices understandable and accessible. Information must be communicated to the data subject in an intelligible form using clear and plain language. 

Raising Youth’s Privacy Notice Procedure and Privacy Notice is available on the college website. The specific information that Raising Youth will provide to the data subject must, as a minimum, include: 

4.1.1 The identity and the contact details of the controller and, if any, of the controller's representative; 

4.1.2 The contact details of the Data Protection Officer; 

4.1.3 The purposes of the processing for which the personal data are intended as well as the legal basis for the processing; 

4.1.4 The period for which the personal data will be stored; 

4.1.5 The existence of the rights to request access, rectification, erasure or to object to the processing, and the conditions (or lack of) relating to exercising these rights, such as whether the lawfulness of previous processing will be affected; 

4.1.6 The categories of personal data concerned; 

4.1.7 The recipients or categories of recipients of the personal data, where applicable; 

4.1.8 Where applicable, that the controller intends to transfer personal data to a recipient in a third country and the level of protection afforded to the data; 

4.1.9 Any further information necessary to guarantee fair processing. 

4.2 Personal data can only be collected for specific, explicit and legitimate purposes

Data obtained for specified purposes must not be used for a purpose that differs from those formally notified to the supervisory authority as part of Raising Youth’s GDPR register of processing. Privacy Procedure GDPR sets out the relevant procedures. 

4.3 Personal data must be adequate, relevant and limited to what is necessary for processing 
4.3.1 The Data Protection Officer/GDPR Owner is responsible for ensuring that Raising Youth does not collect information that is not strictly necessary for the purpose for which it is obtained. 
4.3.2 All data collection forms (electronic or paper-based), including data collection requirements in new information systems, must include a fair processing statement or link to privacy statement and approved by the Data Protection Officer / GDPR Owner. 
4.3.3 The Data Protection Officer / GDPR Owner will ensure that, on an annual basis all data collection methods are reviewed by resource owners to ensure that collected data continues to be adequate, relevant and not excessive 
4.4 Personal data must be accurate and kept up to date with every effort to erase or rectify without delay
4.4.1 Data that is stored by the data controller must be reviewed and updated as necessary. No data should be kept unless it is reasonable to assume that it is accurate. 
4.4.2 It is also the responsibility of the data subject to ensure that data held by Raising Youth is accurate and up to date. Completion of a registration or application form by a data subject will include a statement that the data contained therein is accurate at the date of submission.
4.4.3 Employees/Staff should be required to notify Raising Youth of any changes in circumstance to enable personal records to be updated accordingly. It is the responsibility of Raising Youth to ensure that any notification regarding change of circumstances is recorded and acted upon. 
4.4.4 The Data Protection Officer / GDPR Owner is responsible for ensuring that appropriate procedures and policies are in place to keep personal data accurate and up to date, taking into account the volume of data collected, the speed with which it might change and any other relevant factors. 
4.4.5 On at least an annual basis, the Data Protection Officer / GDPR Owner will review the retention dates of all the personal data processed by Raising Youth, by reference to the data inventory, and will identify any data that is no longer required in the context of the registered purpose. This data will be securely deleted/destroyed in line with the Secure Disposal of Storage Media Procedure. 
4.4.6 The Data Protection Officer / GDPR Owner is responsible for responding to requests for rectification from data subjects within one month (Subject Access Request Procedure). This can be extended to a further two months for complex requests. If Raising Youth decides not to comply with the request, the Data Protection Officer / GDPR Owner must respond to the data subject to explain its reasoning and inform them of their right to complain to the supervisory authority and seek judicial remedy. 
4.4.7 The Data Protection Officer / GDPR Owner is responsible for making appropriate arrangements that, where third-party organisations may have been passed inaccurate or out-of-date personal data, to inform them that the information is inaccurate and/or out of date and is not to be used to inform decisions about the individuals concerned; and for passing any correction to the personal data to the third party where this is required. 
4.5 Personal data must be kept in a form such that the data subject can be identified only as long as is necessary for processing
4.5.1 Personal data will be retained in line with the Retention of Records Procedure and, once its retention date is passed, it must be securely destroyed as set out in this procedure. 

4.5.2 The Data Protection Officer / GDPR Owner must specifically approve any data retention that exceeds the retention periods 14 defined in Retention of Records Procedure, and must ensure that the justification is clearly identified and in line with the requirements of the data protection legislation. This approval must be written. 

4.6 Personal data must be processed in a manner that ensures the appropriate security 
The Data Protection Officer / GDPR Owner will carry out a risk assessment taking into account all the circumstances of South Essex College’s controlling or processing operations.
In determining appropriateness, the Data Protection Officer / GDPR Owner should also consider the extent of possible damage or loss that might be caused to individuals (e.g. staff or customers) if a security breach occurs, the effect of any security breach on Raising Youth itself, and any likely reputation damage including the possible loss of customer trust.
When assessing appropriate IT technical measures, the Data Protection Officer / GDPR Owner will consider the following: 
• Password protection • Automatic locking of idle terminals
• Removal of access rights for USB and other memory media 
• Virus checking software and firewalls 
• Role-based access rights including those assigned to temporary staff 
• Encryption of devices that leave the organisations premises such as laptops 
• Security of local and wide area networks 
• Privacy enhancing technologies such as pseudonymization and anonymization; 
• Identifying appropriate international security standards relevant to Raising Youth

When assessing appropriate organisational measures the Data Protection Officer / GDPR Owner will consider the following:
• The appropriate training levels throughout Raising Youth
• Measures that consider the reliability of employees (such as references etc.); 
• The inclusion of data protection in employment contracts; 
• Identification of disciplinary action measures for data breaches; 
• Monitoring of staff for compliance with relevant security training completion; 
• Physical access controls to electronic and paper based records; 
• Storing of paper based data in lockable fire-proof cabinets; 
• Restricting the use of portable electronic devices outside of the workplace; 
• Adopting clear rules about passwords; 
• Making regular backups of personal data and storing the media off-site; 
• The imposition of contractual obligations on the importing organisations to take appropriate security measures when transferring data outside the EEA.
These controls have been selected on the basis of identified risks to personal data, and the potential for damage or distress to individuals whose data is being processed. 

4.7 The controller must be able to demonstrate compliance with the GDPR’s other principles (accountability)

The GDPR includes provisions that promote accountability and governance. These complement the GDPR’s transparency requirements. The accountability principle in Article 5(2) requires you to demonstrate that you comply with the principles and states explicitly that this is your responsibility. 
Raising Youth CIC will demonstrate compliance with the data protection principles by implementing data protection policies, adhering to codes of conduct, implementing technical and organisational measures, as well as adopting techniques such as data protection by design, DPIAs, breach notification procedures and incident management response plans. 
The ICO has published guidance on Accountability and Governance here:
Data subjects’ rights 
5.1 Data subjects have the following rights regarding data processing, and the data that is recorded about them: 
5.1.1 To make subject access requests regarding the nature of information held and to whom it has been disclosed. 
5.1.2 To prevent processing likely to cause damage or distress.
5.1.3 To prevent processing for purposes of direct marketing.
5.1.4 To be informed about the mechanics of automated decision-taking process that will significantly affect them.
5.1.5 To not have significant decisions that will affect them taken solely by automated process.
5.1.6 To request compensation if they suffer damage by any contravention of the GDPR. 
5.1.7 To take action to rectify, block, erase, including the right to be forgotten, or destroy inaccurate data. 
5.1.8 To request the supervisory authority to assess whether any provision of the GDPR has been contravened.
5.1.9 To have personal data provided to them in a structured, commonly used and machine-readable format, and the right to have that data transmitted to another controller. 
5.1.10 To object to any automated profiling that is occurring without consent. 
5.2 Raising Youth ensures that data subjects may exercise these rights: 
5.2.1 Data subjects may make data access requests as described in Subject Access Request Procedure; this procedure also describes how Raising Youth will ensure that its response to the data access request complies with the requirements of the GDPR. 
5.2.2 Data subjects have the right to complain to Raising Youth related to the processing of their personal data, the handling of a request from a data subject and appeals from a data subject on how complaints have been handled in line with the Complaints Procedure. 
6 Consent 
6.1 Raising Youth understands ‘consent’ to mean that it has been explicitly and freely given, and a specific, informed and unambiguous indication of the data subject’s wishes that, by statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. The data subject can withdraw their consent at any time. 
6.2 Raising Youth understands ‘consent’ to mean that the data subject has been fully informed of the intended processing and has signified their agreement, while in a fit state of mind to do so and without pressure being exerted upon them. Consent obtained under duress or on the basis of misleading information will not be a valid basis for processing. 
6.3 There must be some active communication between the parties to demonstrate active consent. Consent cannot be inferred from non-response to a communication. The Controller must be able to demonstrate that consent was obtained for the processing operation. 
6.4 For sensitive data, explicit written consent (Consent Procedure) of data subjects must be obtained unless an alternative legitimate basis for processing exists. 
6.5 In most instances, consent to process personal and sensitive data is obtained routinely by Raising Youth using standard consent documents e.g. when a new student signs a learning agreement, or during 17 induction for participants on programmes. 
7. Security of data
7.1 All Employees/Staff are responsible for ensuring that any personal data that Raising Youth holds and for which they are responsible, is kept securely and is not under any conditions disclosed to any third party unless that third party has been specifically authorised by Raising Youth to receive that information and has entered into a confidentiality or data sharing agreement. 
7.2 All personal data should be accessible only to those who need to use it, and access may only be granted in line with the Access Control Policy. All personal data should be treated with the highest security and must be kept: 
• In a lockable room with controlled access; and/or • In a locked drawer or filing cabinet and/or;
• If computerised, password protected in line with corporate requirements in the Access Control Policy
7.3 Care must be taken to ensure that PC screens and terminals are not visible except to authorised Employees/Staff of Raising Youth.
7.4 Manual records may not be left where they can be accessed by unauthorised personnel and may not be removed from business premises without explicit authorisation. 
7.5 Personal data may only be deleted or disposed of in line with the Retention of Records Procedure. Manual records that have reached their retention date are to be shredded and disposed of as ‘confidential waste’. Hard drives of redundant PCs are to be removed and data wiped or destroyed as required by our disposal form. 
7.6 Processing of personal data ‘off-site’ presents a potentially greater risk of loss, 18 theft or damage to personal data. Staff must be specifically authorised to process data off- site. 
8. Disclosure of data
8.1 Raising Youth must ensure that personal data is not disclosed to unauthorised third parties which includes family members, friends, government bodies, and in certain circumstances, the Police. All Employees/Staff should exercise caution when asked to disclose personal data held on another individual to a third party. It is important to bear in mind whether or not disclosure of the information is relevant to, and necessary for, the conduct of Raising Youth’s business. 
8.2 All requests to provide data for one of these reasons must be supported by appropriate paperwork and all such disclosures must be specifically authorised by the Data Protection Officer / GDPR Owner.
9. Retention and disposal of data
9.1 Raising Youth shall not keep personal data in a form that permits identification of data subjects for longer a period than is necessary, in relation to the purpose(s) for which the data was originally collected. 
9.2 Raising Youth may store data for longer periods if the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of the data subject. 
9.3 The retention period for each category of personal data are set out in the Retention of Records Procedure along with the criteria used to determine this period including any statutory obligations Raising Youth has to retain the data. 
9.4 Raising Youth’s data retention and data disposal procedures will apply in all cases. 
9.5 Personal data must be disposed of securely in accordance with the sixth principle of the GDPR – processed in an appropriate manner to maintain security, thereby protecting the “rights and freedoms” of data subjects. Any disposal of data will be done in accordance with the secure disposal procedure.
10. Data transfers
10.1 All exports of data from within the European Economic Area (EEA) to non European Economic Area countries (referred to in the GDPR as ‘third countries’) are unlawful unless there is an appropriate “level of protection for the fundamental rights of the data subjects”. The ICO provides guidance on ‘Transfers of personal data to third countries or international organisations’ here
The transfer of personal data outside of the EEA is prohibited unless one or more of the specified safeguards, or exceptions, apply.
10.1.1 An adequacy decision The European Commission can and does assess third countries, a territory and/or specific sectors within third countries to assess whether there is an appropriate level of protection for the rights and freedoms of natural persons. In these instances no authorisation is required. Countries that are members of the European Economic Area (EEA) but not of the EU are accepted as having met the conditions for an adequacy decision. A list of countries that currently satisfy the adequacy requirements of the Commission are published in the Official Journal of the European Union.
10.1.2 Model contract clauses Raising Youth may adopt approved model contract clauses for the transfer of data outside of the EEA. Exceptions In the absence of an adequacy decision, Privacy Shield membership, binding corporate rules and/or model contract clauses, a transfer of personal data to a third country or international organisation shall only take place on one of the following conditions: 
• The data subject has explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards; 
• The transfer is necessary for the performance of a contract between the data subject and the controller or the implementation of precontractual measures taken at the data subject's request; 
• The transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person; 
• The transfer is necessary for important reasons of public interest; 
• The transfer is necessary for the establishment, exercise or defence of legal claims;
• The transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent.
11. Information asset register/data inventory 
11.1 Raising Youth is aware of any risks associated with the processing of particular types of personal data. 

11.1.1 Raising Youth assesses the level of risk to individuals associated with the processing of their personal data. Data protection impact assessments (DPIAs) are carried out in relation to the processing of personal data by Raising Youth, and in relation to processing undertaken by other organisations on behalf of Raising Youth
11.1.2 Raising Youth shall manage any risks identified by the risk assessment in order to reduce the likelihood of a non-conformance with this policy.
11.1.3 Where a type of processing, in particular using new technologies and taking into account the nature, scope, context and purposes of the processing is likely to result in a high risk to the rights and freedoms of natural persons, Raising Youth shall, prior to the processing, carry out a DPIA of the impact of the envisaged processing operations on the protection of personal data. A single DPIA may address a set of similar processing operations that present similar high risks. 
11.1.4 Where, as a result of a DPIA it is clear that Raising Youth is about to commence processing of personal data that could cause damage and/or distress to the data subjects, the decision as to whether or not Raising Youth may proceed must be escalated for review to the Data Protection Officer/GDPR Owner. 
11.1.5 The Data Protection Officer / GDPR Owner shall, if there are significant concerns, either as to the potential damage or distress, or the quantity of data concerned, escalate the matter to the Raising Youth executive.
11.1.6 Appropriate controls will be selected and applied to reduce the level of risk associated with processing individual data to an acceptable level, by reference to Raising Youth's documented risk acceptance criteria and the requirements of the GDPR.
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