1. 1. DATA PROTECTION 

2. 2. DATA RETENTION 

3. 3. SUSTAINABILITY AND ENVIRONMENTAL POLICY 

4. 4. SAFEGUARDING 

5. 5. EQUITY, DIVERSITY AND INCLUSION 

6. 6. ANTI- BULLYING 

7. 7. ANTI-SLAVERY AND HUMAN TRAFFICKING 

8. 8. COMPLAINTS 

9. 9. HEALTH AND SAFETY 

 

1. 1. DATA PROTECTION 

   
   

CONTENTS:

1. INTERPRETATION 

2. INTRODUCTION 

3. SCOPE 

4. PERSONAL DATA PROTECTION PRINCIPLES 

5. LAWFULNESS, FAIRNESS, TRANSPARENCY 

6. CONSENT 

7. TRANSPARENCY (NOTIFYING DATA SUBJECTS) 

8. PURPOSE LIMITATION 

9. DATA MINIMISATION 

10. ACCURACY 

11. STORAGE LIMITATION 

12. SECURITY INTEGRITY AND CONFIDENTIALITY 

13. REPORTING A PERSONAL DATA BREACH 

14. TRANSFER LIMITATION 

15. DATA SUBJECT'S RIGHTS AND REQUESTS 

16. ACCOUNTABILITY 

17. RECORD KEEPING 

18. TRAINING AND AUDIT 

19. PRIVACY BY DESIGN AND DATA PROTECTION IMPACT ASSESSMENT (DPIA) 

20. DIRECT MARKETING 

21. SHARING PERSONAL DATA 

22. CHANGES TO THIS DATA PROTECTION POLICY 

1. 
   

   1. 1. INTERPRETATION 

   1. 1.1 Definitions: 

   1. • Automated Processing: any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing. 
      • Charity Personnel: all employees, workers, contractors, agency workers, consultants, volunteers, trustees, members and others. 
      • Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject's wishes by which they, by a statement or by a clear positive action, signify agreement to the Processing of Personal Data relating to them. 
      • Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the UK GDPR. We are the Controller of all Personal Data relating to our Charity Personnel and Personal Data used by the Charity for our own purposes. 
      • Criminal Convictions Data: means personal data relating to criminal convictions and offences and includes personal data relating to criminal allegations and proceedings.  
      • Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data. 
      • Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity.
      • Explicit Consent: consent which requires a very clear and specific statement (that is, not just action). 
      • UK GDPR: the retained EU law version of the General Data Protection Regulation ((EU) 2016/679).  
      • Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person's actions or behaviour.  
      • Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach. 
      • Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies: separate notices setting out information that may be provided to Data Subjects when the Charity collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, participant privacy notices or the website privacy policy) or they may be stand-alone, one-time privacy statements covering Processing related to a specific purpose. 
      • Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties. 
      • Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure. 
      • Special Categories of Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.  

   15. 
       

   2. 2. INTRODUCTION 

   This Data Protection Policy sets out how Planet Earth Games ("we", "our", "us", "the Charity") handle the Personal Data of our participants, suppliers, workers, volunteers and other third parties.  

   
   

   This Data Protection Policy applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present workers, volunteers, participants, supplier contacts, website users or any other Data Subject.  

   
   

   This Data Protection Policy applies to all Charity Personnel ("you", "your"). You must read, understand and comply with this Data Protection Policy when Processing Personal Data on our behalf. This Data Protection Policy sets out what we expect from you for the Charity to comply with applicable law. Your compliance with this Data Protection Policy is mandatory.  

   This Data Protection Policy is an internal document and cannot be shared with third parties (including regulators) without prior authorisation from the board of trustees. 

   
   

   3. 3. SCOPE 

   We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times.  

   Please contact the board of trustees with any questions about the operation of this Data Protection Policy or the UK GDPR or if you have any concerns that this Data Protection Policy is not being or has not been followed. In particular, you must always contact the board of trustees in the following circumstances:  

   1. a) if you are unsure of the lawful basis which you are relying on to process Personal Data (including the legitimate interests used by the Charity) (see paragraph 5.1);  

   2. b) if you need to rely on Consent and/or need to capture Explicit Consent (see paragraph 6); 

   3. c) if you need to draft Privacy Notices (see paragraph 7);  

   4. d) if you are unsure about the retention period for the Personal Data being Processed (see paragraph 11); 

   5. e) if you are unsure about what security or other measures you need to implement to protect Personal Data (see paragraph 12.1); 

   6. f) if there has been a Personal Data Breach (paragraph 13); 

   7. g) if you are unsure on what basis to transfer Personal Data outside the UK (see paragraph 14); 

   8. h) if you need any assistance dealing with any rights invoked by a Data Subject (see paragraph 15);  

   9. i) whenever you are engaging in a significant new, or change in, Processing activity or plan to use Personal Data for purposes other than what it was collected for;  

   10. j) if you plan to undertake any activities involving Automated Processing including profiling; 

   11. k) if you need help complying with applicable law when carrying out direct marketing activities (see paragraph 20); or 

   12. l) if you need help with any contracts or other areas in relation to sharing Personal Data with third parties (including our vendors) (see paragraph 21). 

       
       

   4. 4. PERSONAL DATA PROTECTION PRINCIPLES 

   We adhere to the principles relating to Processing of Personal Data set out in the UK GDPR which require Personal Data to be: 

   
   

   1. a) Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency);  

   2. b) collected only for specified, explicit and legitimate purposes (Purpose Limitation); 

   3. c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation);  

   4. d) accurate and where necessary kept up to date (Accuracy); 

   5. e) not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation); 

   6. f) Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality); 

   7. g) not transferred to another country without appropriate safeguards being in place (Transfer Limitation); and 

   8. h) made available to Data Subjects and allow Data Subjects to exercise certain rights in relation to their Personal Data (Data Subject's Rights and Requests). 

      
      

   We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability). 

   
   

   5. 5. LAWFULNESS, FAIRNESS, TRANSPARENCY 

   Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject. 

   
   

   You may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The UK GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.  

   
   

   The UK GDPR allows Processing for specific purposes, some of which are set out below: 

   1. a) the Data Subject has given his or her Consent; 

   2. b) the Processing is necessary for the performance of a contract with the Data Subject; 

   3. c) to meet our legal compliance obligations;  

   4. d) to protect the Data Subject's vital interests; or 

   5. e) to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects.  

   
   

   You must identify and document the legal ground being relied on for each Processing activity. 

   
   

   6. 6. CONSENT 

   A Controller must only process Personal Data on the basis of one or more of the lawful bases set out in the UK GDPR, which include Consent. 

   
   

   A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters.  

   
   

   Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured. Consent may need to be refreshed if you intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented.  

   
   

   When processing Special Category Data or Criminal Convictions Data, we will usually rely on a legal basis for processing other than Explicit Consent or Consent if possible. Where Explicit Consent is relied on, you must issue a Privacy Notice to the Data Subject to capture Explicit Consent.   

   
   

   You will need to evidence Consent captured and keep records of all Consents so that the Charity can demonstrate compliance with Consent requirements. 

   
   

   7. 7. TRANSPARENCY (NOTIFYING DATA SUBJECTS) 

   The UK GDPR requires Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. The information must be provided through appropriate Privacy Notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them. 

   
   

   Whenever we collect Personal Data directly from Data Subjects, we must provide the Data Subject with all the information required by the UK GDPR including the identity of the Controller, how and why we will use, Process, disclose, protect and retain that Personal Data through a Privacy Notice which must be presented when the Data Subject first provides the Personal Data.  

   
   

   When Personal Data is collected indirectly (for example, from a third party or publicly available source), we must provide the Data Subject with all the information required by the UK GDPR as soon as possible after collecting or receiving the data. We must also check that the Personal Data was collected by the third party in accordance with the UK GDPR and on a basis which contemplates our proposed Processing of that Personal Data.  

   
   

   8. 8. PURPOSE LIMITATION  

   Personal Data must be collected only for specified, explicit and legitimate purposes. It must not be further Processed in any manner incompatible with those purposes.  

   
   

   You cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes and they have Consented where necessary. 

   
   

   9. 9. DATA MINIMISATION 

   Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed. 

   
   

   You may only Process Personal Data when performing your duties requires it. You cannot Process Personal Data for any reason unrelated to your duties.  

   
   

   You may only collect Personal Data that you require for your duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes. 

   
   

   You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised.  

   
   

   10. 10. ACCURACY 

   Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate. 

   
   

   You will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data. 

   
   

   11. 11. STORAGE LIMITATION 

   You must not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.  

   
   

   You will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require. This includes requiring third parties to delete that data where applicable.  

   
   

   You will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice.  

   
   

   12. 12. SECURITY INTEGRITY AND CONFIDENTIALITY 

   Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

   
    

   We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. You are responsible for protecting the Personal Data we hold. You must implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data. You must exercise particular care in protecting Special Categories of Personal Data and Criminal Convictions Data from loss and unauthorised access, use or disclosure. 

   
   

   You must follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested. 

   
   

   You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows: 

   1. a) Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it; 

   2. b) Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed; and 

   3. c) Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.  

      
      

   You must comply with and not attempt to circumvent the administrative, physical and technical safeguards we implement and maintain in accordance with the UK GDPR and relevant standards to protect Personal Data.  

   
   

   13. 13. REPORTING A PERSONAL DATA BREACH 

   The UK GDPR requires Controllers to notify any Personal Data Breach to the Information Commissioner and, in certain instances, the Data Subject.  

   
   

   We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so. 

   
   

   If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the board of trustees. You should preserve all evidence relating to the potential Personal Data Breach.  

   
   

   14. 14. TRANSFER LIMITATION  

   The UK GDPR restricts data transfers to countries outside the UK to ensure that the level of data protection afforded to individuals by the UK GDPR is not undermined. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country.  

   You may only transfer Personal Data outside the UK if one of the following conditions applies: 

   1. a) the UK has issued regulations confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subject's rights and freedoms;  

   2. b) appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved for use in the UK, an approved code of conduct or a certification mechanism; 

   3. c) the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or 

   4. d) the transfer is necessary for one of the other reasons set out in the UK GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest. 

      
      

   15. 15. DATA SUBJECT'S RIGHTS AND REQUESTS 

   Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to: 

   1. a) withdraw Consent to Processing at any time; 

   2. b) receive certain information about the Controller's Processing activities; 

   3. c) request access to their Personal Data that we hold; 

   4. d) prevent our use of their Personal Data for direct marketing purposes;  

   5. e) ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;  

   6. f) restrict Processing in specific circumstances; 

   7. g) challenge Processing which has been justified on the basis of our legitimate interests or in the public interest; 

   8. h) request a copy of an agreement under which Personal Data is transferred outside of the UK;  

   9. i) object to decisions based solely on Automated Processing, including profiling; 

   10. j) prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else; 

   11. k) be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms; 

   12. l) make a complaint to the supervisory authority; and 

   13. m) You must verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade you into disclosing Personal Data without proper authorisation).  

       
       

   You must immediately forward any Data Subject request you receive to the board of trustees. 

   
   

   16. 16. ACCOUNTABILITY 

   The Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.  

   
   

   17. 17. RECORD KEEPING 

   The UK GDPR requires us to keep full and accurate records of all our data Processing activities.  

   You must keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects' Consents and procedures for obtaining Consents. 

   These records should include, at a minimum, the name and contact details of the Controller, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data's retention period and a description of the security measures in place.  

   
   

   18. 18. TRAINING AND AUDIT 

   We are required to ensure all Charity Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.  

   You must regularly review all the systems and processes under your control to ensure they comply with this Data Protection Policy and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.  

   
   

   19. 19. PRIVACY BY DESIGN AND DATA PROTECTION IMPACT ASSESSMENT (DPIA) 

   We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles.  

   You must assess what Privacy by Design measures can be implemented on all programmes, systems or processes that Process Personal Data by taking into account the following: 

   • the state of the art; 
   • the cost of implementation; 
   • the nature, scope, context and purposes of Processing; and 
   • the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing. 

   Controllers must also conduct DPIAs in respect to high-risk Processing.  

   
   

   You should conduct a DPIA (and discuss your findings with the board of trustees) when implementing major system or business change programs involving the Processing of Personal Data including: 

   • use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes); 
   • Automated Processing including profiling;  
   • large-scale Processing of Special Categories of Personal Data or Criminal Convictions Data; and  
   • large-scale, systematic monitoring of a publicly accessible area. 

   A DPIA must include: 

   • a description of the Processing, its purposes and the Controller's legitimate interests if appropriate;  
   • an assessment of the necessity and proportionality of the Processing in relation to its purpose;  
   • an assessment of the risk to individuals; and  
   • the risk mitigation measures in place and demonstration of compliance. 

   • 
     

   20. 20. DIRECT MARKETING 

   We are subject to certain rules and privacy laws when marketing to participants.  

   For example, a Data Subject's prior consent is required for electronic direct marketing (for example, by email or text). The limited exception for existing customers known as "soft opt-in" allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.  

   The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information. 

   A Data Subject's objection to direct marketing must be promptly honoured. If an individual opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future. 

   
   

   21. 21. SHARING PERSONAL DATA  

   Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.  

   
   

   You may only share the Personal Data we hold with other Charity Personnel if the recipient has a role-related need to know the information. 

   
   

   You may only share the Personal Data we hold with third parties, such as our service providers or partners, if: 

   1. a) they have a need to know the information for the purposes of providing the contracted services;  

   2. b) sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject's Consent has been obtained; 

   3. c) the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place; 

   4. d) the transfer complies with any applicable cross-border transfer restrictions; and  

   5. e) a fully executed written contract that contains UK GDPR-approved third party clauses has been obtained. 

      
      

   22. 22. CHANGES TO THIS DATA PROTECTION POLICY  

   We keep this Data Protection Policy under regular review. This Data Protection Policy does not override any applicable national data privacy laws and regulations in countries where the Charity operates. 

    

   2. 2. DATA RETENTION 

    

   CONTENTS 

   1. ABOUT THIS POLICY 

   2. SCOPE OF POLICY 

   3. GUIDING PRINCIPLES 

   4. COMPLIANCE 

   5. TYPES OF DATA AND DATA CLASSIFICATIONS 

   6. RETENTION PERIODS 

   7. STORAGE, BACK-UP AND DISPOSAL OF DATA 

   8. SPECIAL CIRCUMSTANCES 

   9. WHERE TO GO FOR ADVICE AND QUESTIONS 

   10. BREACH REPORTING 

    

   ANNEX 

    

   1. ABOUT THIS POLICY 

   The corporate information, records and data of Planet Earth Games is important to how we conduct business. 

   There are legal and regulatory requirements for us to retain certain data, usually for a specified amount of time. We also retain data to help Planet Earth Games operate and to have information available when we need it. However, we do not need to retain all data indefinitely, and retaining data can expose us to risk as well as be a cost to the organisation. 

   This Data Retention Policy explains our requirements to retain data and to dispose of data and provides guidance on appropriate data handling and disposal.  

   Failure to comply with this policy can expose us to fines and penalties, adverse publicity, difficulties in providing evidence when we need it and in running our business. 

   This policy may be amended at any time. 

   
   

   2. SCOPE OF POLICY 

   This policy covers all data that we hold or have control over. This includes physical data such as hard copy documents, contracts, notebooks, letters and invoices. It also includes electronic data such as emails, electronic documents, audio and video recordings. It applies to both personal data and non-personal data. In this policy we refer to this information and these records collectively as "data". 

   This policy covers data that is held by third parties on our behalf, for example cloud storage providers or offsite records storage. It also covers data that belongs to us but is held on personal devices.  

   This policy explains the differences between our formal or official records, disposable information, confidential information belonging to others, personal data and non-personal data. It also gives guidance on how we classify our data. 

   
   

   3. GUIDING PRINCIPLES 

   Through this policy, and our data retention practices, we aim to meet the following commitments: 

   
   

   We comply with legal and regulatory requirements to retain data. 

   
   

   We comply with our data protection obligations, in particular to keep personal data no longer than is necessary for the purposes for which it is processed (storage limitation principle). 

   
   

   We handle, store and dispose of data responsibly and securely. 

   
   

   We create and retain data where we need this to operate our business effectively, but we do not create or retain data without good business reason. 

   
   

   We allocate appropriate resources, roles and responsibilities to data retention. 

   
   

   We regularly monitor and audit compliance with this policy and update this policy when required. 

   
   

   4. COMPLIANCE 

   We aim to comply with the laws, rules, and regulations that govern our organisation and with recognised compliance good practices. All Planet Earth Games employees, trustees and volunteers must comply with this policy, the Record Retention Schedule, any communications suspending data disposal and any specific instructions from the Board of Trustees. Failure to do so may subject us to serious civil and/or criminal liability. It is therefore the responsibility of everyone to understand and comply with this policy. 

   
   

   5. TYPES OF DATA AND DATA CLASSIFICATIONS 

   Formal or official records. Certain data is more important to us and is therefore listed in the Record Retention Schedule. This may be because we have a legal requirement to retain it, or because we may need it as evidence of our transactions, or because it is important to the running of our business. Please see paragraph 6.1 below for more information on retention periods for this type of data.  

   
   

   Disposable information. Disposable information consists of data that may be discarded or deleted at the discretion of the user once it has served its temporary useful purpose and/or data that may be safely destroyed because it is not a formal or official record as defined by this policy and the Record Retention Schedule. Examples may include: 

   Duplicates of originals that have not been annotated. 

   
   

   Preliminary drafts of letters, memoranda, reports, worksheets, and informal notes that do not represent significant steps or decisions in the preparation of an official record. 

   
   

   Spam and junk mail. 

   
   

   Please see paragraph 6.2 below for more information on how to determine retention periods for this type of data. 

   
   

   Personal data. Both formal or official records and disposable information may contain personal data; that is, data that identifies living individuals. Data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation). See paragraph 6.3 below for more information on this. 

   
   

   Confidential information belonging to others. Any confidential information that an employee, trustee of volunteer may have obtained from a source outside of Planet Earth Games must not, so long as such information remains confidential, be disclosed to or used by us. Unsolicited confidential information submitted to us should be refused, returned to the sender where possible, and deleted, if received via the internet.  

   
   

   6. RETENTION PERIODS 

   Formal or official records. Any data that is part of any of the categories listed in the Record Retention Schedule contained in the Annex to this policy, must be retained for the amount of time indicated in the Record Retention Schedule. A record must not be retained beyond the period indicated in the Record Retention Schedule, unless a valid business reason (or notice to preserve documents for contemplated litigation or other special situation) calls for its continued retention.  

   Disposable information. The Record Retention Schedule will not set out retention periods for disposable information. This type of data should only be retained as long as it is needed for business purposes. Once it no longer has any business purpose or value it should be securely disposed of.  

   Personal data. As explained above, data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation). Where data is listed in the Record Retention Schedule, we have taken into account the principle of storage limitation and balanced this against our requirements to retain the data. Where data is disposable information, you must take into account the principle of storage limitation when deciding whether to retain this data.  

   What to do if data is not listed in the Record Retention Schedule. If data is not listed in the Record Retention Schedule, it is likely that it should be classed as disposable information. However, if you consider that there is an omission in the Record Retention Schedule, or if you are unsure, please contact the board of trustees. 

   
   

   7. STORAGE, BACK-UP AND DISPOSAL OF DATA 

   Storage. Our data must be stored in a safe, secure, and accessible manner. Any documents and financial files that are essential to our business operations during an emergency must be duplicated and/or backed up on a regular basis. 

   Destruction. The destruction of confidential, financial, and employee-related hard copy data must be conducted by shredding if possible. Non-confidential data may be destroyed by recycling. The destruction of electronic data must be performed in accordance with good practice.  

   The destruction of data must stop immediately if we are involved in a legal claim or an official investigation (see next paragraph). Destruction may begin again once the requirement for preservation has been lifted. 

   
   

   8. SPECIAL CIRCUMSTANCES 

   If you believe, that certain records are relevant to current litigation or contemplated litigation (that is, a dispute that could result in litigation), government investigation, audit, or other event, you must preserve and not delete, dispose, destroy, or change those records, including emails and other electronic documents, until the board of trustees has confirmed that those records are no longer needed. Preserving documents includes suspending any requirements in the Record Retention Schedule and preserving the integrity of the electronic files or other format in which the records are kept.    

   In addition, you may be asked to suspend any routine data disposal procedures in connection with certain other types of events, such as our merger with another organisation or the replacement of our information technology systems. 

   
   

   9. WHERE TO GO FOR ADVICE AND QUESTIONS 

   Questions about the policy. Any questions about this policy should be referred to the board of trustees.  

   
   

   10. BREACH REPORTING  

   Reporting policy breaches. If you feel that you or someone else may have breached this policy, you should report the incident immediately to the board of trustees. 

   No one will be subject to and we do not allow, any form of discipline, reprisal, intimidation, or retaliation for reporting incidents of inappropriate conduct of any kind, pursuing any record destruction claim, or co-operating in related investigations. 

   
   

   11. RECORD RETENTION SCHEDULE 

   Planet Earth Games establishes retention or destruction schedules or procedures for specific categories of data. This is done to ensure legal compliance (for example with our data protection obligations) and accomplish other objectives, such as protecting intellectual property and controlling costs. You should comply with the retention periods listed in the record retention schedule below.  

   If you hold data not listed below, please refer to the Planet Earth Games Data Retention Policy. If you still consider your data should be listed, if you become aware of any changes that may affect the periods listed below or if you have any other questions about this record retention schedule, please contact the board of trustees. 

   
   

   TYPE OF DATA	RETENTION PERIOD	REASON / COMMENTS
   CONTRACTS
   Signed contracts and related correspondence	Six years after the contract ends.	Limitations Act 1980
   FINANCIAL RECORDS
   Annual Accounts	Permanently	Best Practice
   Gift Aid Records	Six years from the end of the financial year in which the transaction was made	Best Practice
   Grant Applications and Awards	A minimum of ten years	Best Practice
   Invoices – capital items	A minimum of ten years after the end of the tax year to which they relate	Best Practice
   Correspondence relating to donations	Six years from the end of the financial year in which the transaction was made	Best Practice
   CORPORATE RECORDS
   Board Minutes	A minimum of ten years	Best Practice
   Insurance Policies, Claims and Correspondence	Three years after lapse or settlement	Best Practice
   Employers Liability Insurance Certificate	Forty years	Employers Liability (Compulsory Insurance) Regulations 1998
   Health and Safety Records	Three years	Best Practice
   Details of Injuries or Accident Reports/Records	Six years from time of accident occurring.	Best Practice
   HR RECORDS
   Information relating to recruitment.	Seven months after notifying candidates of the outcome of the recruitment exercise	Equality Act 1980
   Personnel records	Six years after appointment has ceased.	Best Practice

   3. 
      

      3. SUSTAINABILTY AND ENVIRONMENTAL POLICY 

    

   CONTENTS 

   1. MISSION STATEMENT 

   2. RESPONSIBILITY 

   3. POLICY AIMS

   4. OUR COMMITMENT

   1. a) PLANET EARTH GAMES EVENTS 

   2. b) PLANENT EARTH GAMES BEHAVIOURS 

   3. c) PROCUREMENT 

   5. PARTNERS AND AMBASSADORS

   6. POLICY DEVELOPMENT AND IMPROVEMENT 
    

   
   1. MISSION STATEMENT 

   In collaboration with partners, we organise and deliver events, experiences and activities that create positive behaviour change. 

   
   2. RESPONSIBILITY 

   The Chief Executive Officer is responsible for ensuring that the sustainability policy is implemented. However, all employees and Trustees have a responsibility to ensure that the aims of the policy are met. 

   
   3. POLICY AIMS 

   We are committed to: 

   • Comply with and continually strive to exceed all relevant regulatory requirements, 
   • Continually improve and monitor our sustainability performance,
   • Consider sustainability factors in all business decisions
   • Increase awareness of sustainable behaviours for all stakeholders through education and training

   
   

   4. OUR COMMITMENT 
   

   • a) PLANET EARTH GAMES EVENTS 

   Our biggest potential impact is through the events, experiences and activities we deliver. Planet Earth Games (PEG) will endeavour to ensure all physical and virtual events we organise comply with the highest sustainability standards and aim to minimise environmental impact and maximise positive impact. 

   
   

   • • Be at the forefront of best sustainable practice in sport: We will work closely with industry partners including the British Association of Sustainable Sport (BASIS) and individual National Governing Bodies to deliver the best current sustainable practice in UK sport. We recognise the aims, definitions and structure provided by The European Sports Charter, especially Article 10, which refers specifically to sport, and sustainable development. It requires that sporting activities be adjusted to the planet’s limited resources and are carried out in accordance with the principles of sustainable development and balanced management of the environment. We will also seek to collaborate with sector partners to develop innovative products and services to advance the wider sustainability in sport movement.   

    

   • Act in line with the 5 principles set out in the United Nations Sports for Climate Action framework.  

  

1.                   Undertake systematic efforts to promote greater environmental responsibility;

2.                   Reduce overall climate impact;

3.                   Educate for climate action;

4.                   Promote sustainable and responsible consumption;

5.                   Advocate for climate action through communication.

 

• Minimising the environmental impact of our operations and activities we organise:

o   Mindful of the carbon impact – we will encourage attendees and stakeholders to consider their carbon footprint in reaching our events, encouraging low carbon transportation.

o   Follow the waste hierarchy- We will ensure to follow the waste hierarchy in the organisation of our events . We aim to leave no trace on, or improve, the natural environment at every event location through encouraging activities like litter picking and plogging, whilst educating those attending as to how they can minimise their impact on the planet we all live on.   

o   We will avoid single use plastics  - We will avoid items such as plastic water bottles or any single use items at our events.  We will also make this a prerequisite of any third-party vendor at our events. 

o   Advocate and practice the use of recycled materials where it is environmentally sustainable to do so: Actively promote the use of recycled materials that are environmentally sustainable, including being a platform for like-minded organisations to showcase and promote products and services that are environmentally sustainable to our audiences. 

o   Mindful of wider environmental footprint- we will organise the event conscious of wider resource use including water and energy

 

• Educate, influence and inspire anyone who attends or engages with our events on more environmentally sustainable behaviour: We will endeavour to educate, influence and inspire all our audiences to consider more environmentally sustainable behaviour through our online and offline interactions with them.

 

• Report our Impact: Each year we will publish an impact report of our work as a charity, starting with a focus on our events and within this will be data and insights around our direct and indirect environmental impact.

 

b) PLANET EARTH GAMES BEHAVIOURS  

PEG has no permanent office or place of work.  Activities delivered by the PEG are typically through venue hire or online platforms. However, we are committed to ensure our employees and trustees adhere to high sustainability standards and behaviours. 

We will ensure to minimise our operational impacts on the environment through the generation of pollutants. This includes managing the use and carbon intensity of energy, the frequency and mode of transport deployment and our working processes such as us of remote meetings. 

• Transportation - We will reduce the need to travel, promoting use of video conferencing and restricting to necessity trips only and use public transport and low carbon alternatives as the priority mode of transport
• Office Supplies - We will follow the waste hierarchy - minimising the use of office supplies – paper, packing etc where possible, and favour products with the highest sustainability standards
• Energy and Water – we will act with heightened awareness of resource use in any facilities worked in i.e. energy and water conservation
• Training and sharing of best practice – our employees and trustees will endeavour to demonstrate best practice sustainable behaviours and help inform and educate each other

c) PROCUREMENT

Through selection and engagement, we will prioritise suppliers and third-party vendors that uphold the highest environmental standards and credentials, sharing or ethos. 

We will work to the following principles: 

 

• Prioritise local suppliers where possible
• Prioritise responsibly sourced products
• Prioritise recycled products, minimise packaging
• Undertake appropriate due diligence on environmental claims
• Work collaboratively with suppliers to improve sustainability performance

WORKING WITH OUR PARTNERS AND AMBASSADORS 

5. PARTNERS AND AMBASSADORS

As PEG are committed to being an industry leader in sustainability in sport, we want to ensure that any partners we work with also uphold stringent sustainability standards. Each partner organisation will be expected to be meeting or working towards at least one of the following criteria: 

 

• ISO2012 standard
• B Corps Certification;
• Signatory of the United Nations; Sports for Climate Action Framework; working towards the five principles;
• Certified against Council for Responsible Sport Standard
• Understands their key sustainability impacts and has a policy to address them. 

We acknowledge the different stages our partners may be on their sustainability journey and welcome a discussion about their impact. PEG withholds the right to choose not work with an organisation who we feel doesn’t reflect our ethos and ambition. 

Each Ambassador whom we work with will be made aware of our ethos and sustainability policy and be an advocate for environmental sustainability and best practice. 

6. POLICY DEVELOPMENT AND IMPROVEMENT

• We are committed to reviewing and updating this policy on at least an annual basis to ensure it remains in line with best practice
• We will ensure to consulate with our employees, trustees and other stakeholders on the development of this policy and welcome feedback

If you have any questions or feedback on this policy – please do get in touch via info@planetearthgames.org  

 

4. SAFEGUARDING

CONTENTS 

1. INTRODUCTION 

2. WHAT WE WILL DO 

3. MONITORING 

 

1. INTRODUCTION 

Our organisation acknowledges the duty of care to safeguard and promote the welfare of children, young people and adults at risk and is committed to ensuring safeguarding practice reflects statutory responsibilities, government guidance and complies with best practice outlined by NSPCC requirements.  

The policy recognises that the welfare and interests of children, young people and adults are paramount in all circumstances. It aims to ensure that regardless of age, ability or disability, gender reassignment, race, religion or belief, sex, sexual orientation, socio-economic background, all children, young people and adults: have a positive and enjoyable experience of Planet Earth Games Trust events and activities in a safe and child-centred environment and are protected from abuse whilst participating. 

We acknowledge that some children, young people and vulnerable adults, including disabled children or those from ethnic minority communities, can be particularly vulnerable to abuse and we accept the responsibility to take reasonable and appropriate steps to ensure their welfare. 

2. WHAT WE WILL DO 

As part of our Safeguarding Policy we will:  

• Promote and prioritise the safety and wellbeing of children, young people and adults at risk,
• Value, listen to and respect children, young people and adults at risk and their parents or carers,
• Ensure robust safeguarding arrangements and procedures are in operation,
• Adopt safeguarding best practice through our policies, procedures and code of conduct for staff and volunteers ensure everyone understands their roles and responsibilities in respect of safeguarding and is provided with appropriate learning opportunities to recognise, identify and respond to signs of abuse, neglect and other safeguarding concerns relating to children and young people
• Provide effective management for staff and volunteers through supervision, support, training and quality assurance measures so that all staff and volunteers know about our policies, procedures and behaviour codes and follow them confidently and competently,
• Ensure appropriate action is taken in the event of incidents or concerns of abuse and support provided to the individual(s) who raise or disclose the concern,
• Ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored record and store information securely, in line with data protection legislation and guidance,
• Prevent the employment or deployment of unsuitable individuals by recruiting and selecting staff and volunteers safely, ensuring all necessary checks are made,
• Appoint a nominated safeguarding lead, a deputy and a lead trustee/board member for safeguarding develop and implement an effective online safety policy and related procedures,
• Share information about safeguarding and good practice with children, young people, adults at risk and their parents or carers via leaflets, posters, group work and one-to-one discussions make sure that children, young people, adults at risk and their parents or carers know where to go for help if they have a concern.

The policy and procedures will be widely promoted and are mandatory for everyone involved in Planet Earth Games Trust. Failure to comply with the policy and procedures will be addressed without delay and may ultimately result in dismissal or exclusion from the organisation. 

3. MONITORING 

 This policy will be reviewed a year after development and then every three years, or in the following circumstances:

• Changes in legislation and/or government guidance,
• As required by the local safeguarding partnership, UK Sport and/or home country sports, councils and NSPCC guidance.
• As a result of any other significant change or event internally or externally

5. EQUITY, DIVERSITY AND INCLUSION

CONTENTS 

1. RATIONALE

2. POLICY OBJECTIVES

3. PURPOSE OF THE POLICY

4. LEGAL REQUIREMENTS

5. DISCRIMINATION, HARASSMENT, BULLYING AND VICTIMISATION

6. REASONABLE ADJUSTMENTS

7. RESPONSIBILITY, IMPLEMENTATION AND COMMUNICATION

8. ACTIONS

9. MONITORING AND EVALUATION

10. COMPLAINTS PROCEDURE  

1. RATIONALE

    6.1.1 In the first instance, if you are unable to resolve the issue informally, you should write to the member of staff who dealt with you so that he or she has a chance to put things right. If your complaint concerns a trustee of Planet Earth Games rather than a member of  staff, you should write formally to the individual concerned. In your letter you should set out the details of your complaint, the consequences for you as a result, and the remedy you are seeking. 

    6.1.2 You can expect your complaint to be acknowledged within 4 working days of receipt. You should get a response and an explanation within 15 working days. 

    6.1.3 Our contact details can be found on the [.   ] part of the Planet Earth Games website. 

6.2 Stage 2 

    6.2.1 If you are not satisfied with the initial response to the complaint then you can write to Planet Earth Games’ Chief Executive and ask for your complaint and the response to be reviewed. You can expect the Chief Executive to acknowledge your request within 4 working days of receipt and a response within 15 workings days. 

    6.2.2 Our aim is to resolve all matters as quickly as possible. However, inevitably some issues will be more complex and therefore may require longer to be fully investigated. Consequently, timescales given for handling and responding to complaints are indicative. If a matter requires more detailed investigation, you will receive an interim response describing what is being done to deal with the matter, and when a full reply can be expected and from whom. 

6.3 Final Stage 

6.3.1 If you are not satisfied with the subsequent reply from Planet Earth Games’ Chief Executive, then you have the option of writing to the Chair of the Board of Trustees, stating the reason why you are dissatisfied with the outcome. Our contact details can be found on the Planet Earth Games Website. You must do this within 10 days of receiving the written response from the Planet Earth Games’ Chief Executive. 

6.3.2 The Chair of the Board of Trustees (or their nominee) will respond normally within 10 working days to inform you of the action which will be taken to investigate your complaint, and when you can expect to hear the outcome of the investigation. 

6.3.3 Note. If your original complaint was against the Chair of the Board of Trustees, then the final stage will be handled by the Vice Chair of Planet Earth Games. 

9. HEALTH AND SAFETY 

CONTENTS

1. STATEMENT OF INTENT

2. RESPONSIBILITIES

3. PROCEDURES

1. STATEMENT OF INTENT 

Planet Earth Games Trust has no permanent office or place of work. Our activities are delivered virtually or in-person at third party sites through hiring or other arrangements.

Planet Earth Games Trust will provide clear instructions, information, governance, training and diligence checks to ensure the organisation, its Trustees and third-party suppliers engaged with delivery activity are competent and suitable for involvement.

Planet Earth Games will take responsibility for the safety of participants, supporters, suppliers, volunteers and any representative of Planet Earth Games at our events or activities that are within our control.

We will ensure in our event planning, delivery and management we have the correct procedures in place to best ensure a safe and enjoyable experience for all stakeholders and effective procedures in place to respond to any health and safety incident.

2. RESPONSIBILITIES 

· Overall Lead: The overall and final responsibility for Planet Earth Games health and safety policy is Planet Earth Games Chair, or Vice Chair in absence of Chair.

· Day to Day Lead: The day-to-day lead in ensuring this policy is put into practice is led by Planet Earth Games Chief Executive Chris Broadbent. This may also involve the use of a qualified third-party supplier such as an Event Manager contracted for events and activities, who will be delegated responsibility to ensure the correct application of this policy.

· Ongoing review: To ensure health and safety standards are maintained and improved in line with best practice, the Governance Sub Committee Lead will take responsibility for ongoing maintenance of the policy. This means at minimum, an annual review in consultation with the Governance Sub Committee and – where appropriate – the wider Board of Trustees. 

· Wider workforce:  All Planet Earth Games workforce including Trustees, employees, volunteers* and suppliers* will be expected to:

· co-operate with supervisors and managers on all health and safety matters;

· take reasonable care of their own health and safety; and

· report all health and safety concerns to an appropriate person (as detailed above)

* To be informed of all health and safety protocols in documentation and in pre-event briefings for all in-person events

 
PROCEDURES

• Risk Assessments: Activity and location risk assessment will be carried out specific to each individual event and activities, by the Chief Executive or by a contracted supplier and signed off by the Chief Executive.
• Insurance: The Trust commits to the following insurance policies in our current incarnation. We will review these on an annual basis or sooner, should our status alter in any way:
• Public Liability - We will secure insurance that also covers Data Protection Act liabilities. We will secure Public Liability insurance of up to £5,000,000 in order to be covered in the circumstance if a member of the public is injured or became ill due to the Trust’s negligence at one of our events or activities.
• Trustee Liability - Financial protection to individual board members in the event that they are sued due to mismanagement in their role as a director or trustee which is detrimental to the organisation they serve or parties having an interest in it.
• Employee and Volunteer - Employers' liability insurance covers the cost of compensating volunteers and employees who are injured at or become ill through work.
• Consultation: Utilising guidance from HSE (Government Agency Health and Safety Executive) accidents and ill health at Planet Earth Games activities and events will be reported under RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations) http://www.hse.gov.uk/riddor. Typically, only ‘responsible persons’ including people in control of work premises and event sites should submit reports under RIDDOR.  Therefore, the Trust would not typically be expected to report an occurrence, as this would be reported by those managing the facility / event location.
• Documentation: To best ensure health and safety at in-person events, the Chief Executive and – where appropriate – a third party supplier, ie. Events Manager will develop, deliver and circulate Event Management Plan documentation to the workforce managing all aspects of an event. This will be underpinned by a training session, delivered before each event either virtually and/or at a pre-event briefing.

Documentation will likely include, but not be exclusive to:

• Venue assessment and site plan
• Emergency Plan
• Site Evacuation Plan
• Accident and Incident Procedure
• Communications Plan
• Safeguarding and Welfare Policies and Procedures
• Traffic Management Plan
• Site Permissions and Permits