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EESN aims to be an equal opportunity employer, service provider and has a policy for this purpose.

It is a commitment to the development and use of employment procedures and practices which do not discriminate on grounds of sex or marriage, race or disability and which provide genuine equality of opportunity for all employees, or service users. The objectives of this Equal Opportunities Policy are to ensure that no applicant, service user or employee receives less favourable treatment, and that wherever possible, they are given the help they need to attain their full potential to the benefit of the charity and themselves.

The committee management of EESN is responsible for the effective operation of its equal opportunities policy.

1.0 The Policy
1.1 Vacancy advertising
a) Where possible all vacancies will be advertised simultaneously internally and externally.

1.2 Selection and recruitment
a) Selection criteria (job description and employee specification) will be kept under constant review to ensure that they are justifiable on non-discriminatory grounds as being essential for the effective performance of the job.
b) Wherever possible, more than one person will be involved in the selection interview and recruitment process.
c) Reasons for selection and rejection of applicants for vacancies must be recorded.

1.3 Positive action - training, promotion and conditions of service
a) Underrepresented groups will be encouraged to apply for training and employment opportunities within the charity. Actual recruitment to all jobs will be strictly on merit.
b) Wherever necessary, use will be made of lawful exemptions to recruit suitably qualified people to cater for the special needs of particular groups.
c) Wherever possible, efforts will be made to identify and remove unnecessary/unjustifiable barriers and provide appropriate facilities and conditions of service to meet the special needs of disadvantaged and/or underrepresented groups.

1.4 Personnel records
Where necessary, employees will be able to check/correct their own record of their personnel records details. Otherwise access to this information will be strictly restricted.

1.5 General
The co-operation of all employees is essential for the success of this policy. However, ultimate responsibility for achieving the policy's objectives, and for ensuring compliance with the relevant Acts of Parliament as well as the various codes of practice lies with the charity. Behaviour or actions against the spirit and/or the letter of the laws on which this policy is based will be considered serious disciplinary matters, and may, in some cases, lead to dismissal.

2.0 Equal Pay Statement
EESN supports the principle of equal opportunities in employment, service provided and believes as part of that principle that male and female staff should receive equal pay for the same or broadly similar work, for work rated as equivalent and for work of equal value.

The charity understands that a right to equal pay between men and women free of sex bias is a fundamental principle of European Community law and is conferred by United Kingdom legislation.

EESN believes it is in the organisation's interest and is good working practice that pay is awarded fairly and equitably.

We recognise that in order to achieve equal pay for employees doing equal work we should operate a pay system which is free from sex bias.

2.1 Action to implement policy
In order to put our commitment to equal pay into practice we will:
• examine our existing and future pay practices
• inform employees of how these practices work and how their own pay is arrived at
• discuss and agree the equal pay policy with employees, volunteers or staff representatives were appropriate.

EESN intends through the above action to avoid unfair discrimination, to reward fairly the skills, experience and potential of all staff and thereby increase the efficiency and productivity and enhance the charity's reputation and image.

EESN will treat everyone the same (according to its rules) regardless of their sex, ethnic background, age, faith, disability or other factors.

Definition of Terms

Child:

A child is defined as anyone under 18 years of age.

Vulnerable Adults:

The term Vulnerable Adult refers to any person aged 18 over whom for the time being:

• Is unable to safeguard their own welfare or properly manage their financial affairs; and

• Is in one or more of the following categories:

o A person in need of care and attention by reason of either infirmity or the effects of ageing

o A person suffering from an illness or mental disorder

o A person substantially handicapped by a disability

Vulnerable Adults may be in need of health or social support services and may be unable to take care of himself/herself and to protect themselves from harm or exploitation.

A number of studies suggest that children and vulnerable adults are at increased risk of abuse. Various factors contribute to this such as stereotyping, prejudice, discrimination, isolation and a powerlessness to protect themselves or adequately communicate that abuse has occurred.

Principles

The welfare of children and vulnerable adults is everyone’s responsibility, particularly when it comes to protecting them from abuse. Children and vulnerable adults have a lot to gain from college. It provides an excellent opportunity for them to learn new skills, become more confident and maximize their own unique potential. This Policy is based on the following principles:

• The welfare of children and vulnerable adults is the primary concern.

• All children and vulnerable adults, whatever their age, culture, disability, gender, language, racial origin, socio-economic status, religious belief and/or sexual identity have the right to protection from abuse.

• It is everyone’s responsibility to report any concerns about abuse to the Child parents and Senior Officer. It is the responsibility of the Social Work Department and the Police to conduct, where appropriate, a joint investigation.

• All incidents of alleged poor practice, misconduct and abuse will be taken seriously and responded to swiftly and appropriately.

• All personal data will be processed in accordance with the requirements of the Data Protection Act 1998.

• Promote the education and welfare of children and vulnerable adults by providing opportunities for them to take part in college activities.

• Respect and promote the rights, wishes and feelings of children and vulnerable adults.

• Promote and implement appropriate procedures to safeguard the well-being of children and vulnerable adults and protect them from abuse.

• Recruit, train and support its staff to adopt best practice to safeguard and protect children and vulnerable adults from abuse and to minimize risk to themselves.

• Require staff to adopt and abide by this Child and Vulnerable Adult Protection Policy.

• Respond to any allegations of misconduct or abuse of children or vulnerable adults in line with this Policy as well as implementing, where appropriate, the relevant disciplinary and appeals procedures.

• Demeaning or suggestive remarks should never be made to or in the presence of children and vulnerable adults;

• Staff, volunteers should always consider the appropriateness of being with a child or vulnerable adult on their own, especially if this involves being out of earshot or vision of a colleague:

• Sufficient adults should be available to provide proper supervision of children and vulnerable adults on trips, especially residential excursions;

• Staff, volunteers should always be able to justify physical contact with a child or vulnerable adult in any situation;

• Physical contact to comfort and reassure a child or vulnerable adult should be agreeable to both parties and should be limited;

• Physical contact in order to provide care for a child or vulnerable adult should only involve a level of contact necessary to provide such care;

• Some children and vulnerable adults with additional support needs will require a higher level of physical care than other students but the physical contact involved should be limited to that necessary to provide such care;

• Physical contact involving restraint should involve the minimum of force necessary to protect a child or vulnerable adult who is at imminent risk of inflicting harm to self or others or damaging property;

• If a member of staff, or volunteer has to use physical restraint another member of staff, where possible, should be summoned to witness and assist;

Appropriate Staff, Volunteer Response to a Child or vulnerable adult who Alleges Abuse

When a child or vulnerable adult is disclosing details of abuse, especially sexual abuse to a member of staff it is important that staff know how to respond to them. This is in the child or and vulnerable adult’s best interests not only at the time of disclosure but in order to promote their future ability to deal with the abuse and the aftermath of the disclosure.

A volunteer is someone who, without expectation of financial compensation beyond reimbursement of expenses, performs a task at the request of and on behalf of the EESN.

This gift relationship is non-contractual, being based on trust and understanding; and depends on mutual expectations. It is beneficial to both parties.

Volunteers are critical to the mission of the EESN. The organization does not exist to provide volunteering opportunities for their own sake, but rather volunteer participation is valued because it helps the EESN to accomplish its mission in the most cost-effective and engaging manner.

EESN:
i. recognizes that without volunteers we would be unable to meet our main objective.
ii. understands that volunteering is an enjoyable activity meeting the individual’s as well as the organization’s needs.
iii. is committed to making volunteering worthwhile.
iv. sees volunteers as complementing not replacing paid staff and adding significant value to our activities.
v. invests volunteers, as far as possible, with the same rights as other members of the organization and in return asks volunteers to recognize their responsibilities towards the EESN.

VOLUNTEER RIGHTS
All volunteers are entitled to equal treatment irrespective of sex, sexual orientation, disability, marital status, religion, community background or political beliefs.
They have a right to:
i. protection from exploitation from paid employees
ii. adequate training and support for the tasks they are to undertake
iii. Health and Safety information to maximize their safety and welfare
iv. reimbursement of reasonable, agreed out of pocket expenses
v. be valued by everyone within the EESN

4. VOLUNTEER RESPONSIBILITIES
Volunteers have the responsibility to:
i. agree to the EESN’s policy on volunteering
ii. respect confidentiality
iii. be reliable, honest and mindful of the EESN’s good name (e.g. not smoking whilst representing the EESN)
iv. not commit themselves to an unmanageable workload and to only work to a specified job description
v. report back as required and keep in regular contact with designated EESN staff
vi. treat everyone they meet when representing the EESN with courtesy and respect

5. RECRUITMENT AND SELECTION
The EESN uses a variety of methods to recruit volunteers dependent upon task and location; recruitment is based solely on merit. Individuals must be over 18.
Recruitment will generally involve an informal interview either face to face or by telephone.
Aims of the selection procedures are:
i. to provide potential volunteers with sufficient information on both the EESN and specific job opportunities for them to make an informed decision on whether or not to pursue their application
ii. to allow applicants and the volunteer manager to assess whether or not the applicant has the requisite skills, or potential skills after training, to fulfill the job’s requirements
iii. to agree upon a probationary period acceptable to both applicant and the EESN.

REFERENCES AND SCREENING
Checks or screening may seem intrusive but are necessary for the following reasons:
i. The public need to know that they and the money they donate are in safe hands.
ii. They provide the volunteer with a degree of credibility.
iii. They act as a basis of trust for volunteers and their colleagues.

CRIMINAL RECORDS BUREAU
In line with most major charities, any volunteer who will be working regularly with young people or people who are vulnerable or who has access to BHF funds may have to undergo checks with the Criminal Records Bureau.

INDUCTION, TRAINING AND SUPPORT
Volunteers are made to feel welcome and provided with an induction pack, job-specific guidelines and resources.
Training is geared to specific roles; progress is monitored and when necessary additional training will be given to ensure volunteers have the skills and information they need to enjoy and carry out their tasks.
There is always a designated member of staff on the other end of a phone to offer advice and support.

RECOGNITION
EESN recognizes the importance of acknowledging the valuable contribution of our volunteers and does so in a variety of ways appropriate to each individual.

EXPENSES
It is EESN’s policy to reimburse reasonable out of pocket expenses incurred whilst undertaking voluntary tasks, subject to the production of receipts.
These may include:
i. traveling expenses
ii. miscellaneous expenses e.g. telephone calls, postage, refreshments, etc, which must have been previously agreed

EESN has to receive receipts for all expenses. Lunch will be covered only when volunteer’s work will last minimum 4h.

EESN may cover additional expenses like cab fares at absolute discretion and for approved ‘good reason’.

Any incident involving EESN volunteer should be reported immediately to Committee Management, put in writing and if needed to appropriate authorities.

EESN will not share volunteers details with anyone without their prior agreement.

EESN volunteer should always act in the best interest of the organisation, service users and community.

East Europe Support Network (EESN) is committed to providing confidential services to its users. EESN believes that principles of confidentiality must be integrated across all aspects of

the services we provide and management. EESN believes its users deserve the right to confidentiality to protect their interests and safeguard EESN's services.

"EESN offers a confidential service-nothing you say to us will be shared with any other organisation or individual without your express permission."

A statement of EESN's commitment to confidentiality will be incorporated into all publicity materials.

EESN understands confidentiality to mean that no information regarding a service user shall be given directly or indirectly to any third party, which is external to the staff, without that service user's prior express consent to disclose such information.

EESN recognises that all users should be able to access EESN's services in confidence and that no other person should ever know that they have used EESN's services.

EESN recognises that staff informally discussing cases may indirectly give out information. Ali staff should ensure that no discussions relating to a user can take place outside of EESN's premises. The Management Committee will not receive details of individual users or their case.

EESN recognises that users need to feel secure in using EESN's services and has confidential interview rooms so users can be sure that no one may overhear them.

EESN will not confirm the user's presence in EESN or use of our services without first obtaining the user's express consent.

However EESN reserves the right to disclose to Social Services any allegation or admission of child abuse made by a user.

EESN is committed to effective statistical recording of service users. The information enables us to monitor the take up of services, identify new developments, services and policy issues arising from similar organisations. The statistics enable us to apply to charitable trusts and Councils for grant funding and provide the service that our users require.

The Chief Officer shall ensure that all statistical records given to 3^rd parties, including the Management Committee shall be produced in anonymous form so that no individuals can be identified.

Where case studies are used to illustrate services in our Annual Report the Chief Officer will ensure they are presented in such a way that would make it impossible for an individual to be recognised.

It is the Chief Officer's responsibility to ensure all case records are kept in locked filing cabinets. All case records must be locked away at the end of each working day. All information relating to service users will be left in locked drawers including notebooks, copies of correspondence, calculation sheets etc.

Case records will be held for six years after the closure of the case and then shredded.

It is the responsibility of the staff worker to ensure that where any action is agreed to be taken by EESN on behalf of the client, that client must first sign an authorisation form. This must then be

Staff are responsible for checking with clients whether it is acceptable to call them at home or at work in relation to their case. Staff must make sure they make no reference to EESN when making telephone contact with their clients.

Staff are responsible for checking with clients that it is acceptable to write to them at home or at work in relation to their case.

EESN recognises that there may be occasions when an advisor feels they may need to breach confidentiality. Situations where this may occur include where a client divulges information about child abuse (see `Definition' above) a conflict of interest or where a client's information means there is legal effects (see `Legal Framework' below).

EESN recognises that any breach of confidentiality may damage the relation of EESN and its services and therefore has to be treated with seriousness and urgency.

On those occasions where a member of staff feels confidentiality should be breached the following steps must be taken:

a. The member of staff/volunteer should raise the matter with the Chief Officer Manager immediately.

b. The member of staff/volunteer must discuss with the Chief Officer the issues involved in the case and explain why they feel confidentiality should be breached and moreso what would be achieved by doing so. A record must be kept by the Chief Officer of this discussion.

c. The Chief Officer is responsible for discussing with the staff member what options is available in each set of circumstances.

d. The Chief Officer is responsible for making a decision on whether confidentiality should be breached. If the Chief Officer decides that confidentiality is to be breached then they should take the following steps:

1. The Chief Officer should contact the chairperson of the Management Committee, or failing that the Vice-Chair. The Chief Officer should brief the Chair/Vice Chair on the full facts of the case, ensuring they do not breach confidentiality in doing so. The Chief Officer should seek authorisation to breach confidentiality from the Chair/Nice Chair.

2. If the Chair/Vice Chair agrees to breaching confidentiality a full report on the case should be made and any action agreed undertaken. The Chief Officer is

3. If the Chair/Vice Chair does not agree to breach confidentiality then this is the Final Decision of EESN.

4. Under no circumstances should any breach of confidentiality be discussed with EESN's Operation's Manager. This is to ensure that any future Complaint arising from the

EESN will monitor this policy to ensure that it meets its legal requirements including the Data Protection Act 1998, the Children's Act, Rehabilitation of Offender's Act and Prevention of Terrorism Act. Training will include these aspects and how each one should be dealt with.

All members of the Management Committee will receive a copy of the Confidentiality Policy. Current and new workers will be introduced to the Confidentiality Policy via induction and training. The policy will be reviewed annually and amendments should be proposed and agreed by the Management Committee.

Smoking: -EESN operates a No-Smoking Policy throughhout its offices and Centre.

Use of Drugs: - Staff are encouraged to discuss any mediication which could cause side effects, or where support is needed with the Co-directors.

Consuming Alcohol: - Staff must not drink alcohol during their working hours.

Dishonesty and Deception: - Any dishonest or deceptive act or any attempt at such will be treated as gross misconduct, which may result in instant dismissal in accordance with EESN's Disciplinary & Grievance Procedure.

Gifts from Users: - All and any gifts of a value in excess of £2 made to staff by users of EESN services remain the property of EESN and must be handed to the Co-Directors.

Safety: - All staff are responsible for their own safety whilst at work. All breaches of EESN's Health & Safety Policy will be treated as serious by the Management Committee and may lead to disciplinary proceedings.

1) Establish that a home visit is essential and that an appointment at EESN is not comfortable for a person.

2) Write "Home Visit" against your name on EESN's Message Board in Reception and state your expected time of return.

3) Write in EESN's Diary held in Reception that you are on a Home Visit, giving the name, address and telephone number where you can be contacted.

4) If you have misgivings about a particular home visit, but still feel it is appropriate to call, take another staff member with you following the same procedure as 1,2,and 3 above.

5) If during a home visit you have cause for concern you should carefully close the meeting and leave. Following such a home visit you should debrief with a Co-Director afterwards or in the absence with another staff member and consider whether any follow-up action is necessary for the service user or you.

6) If you have any serious doubts about making a particular home visit do discuss it first with a Co-Director. But the bottom line remains "If in doubt-DON'T".

East Europe Support Network acknowledges that records held by the Organisation will be retained while they are used in the operation of the Organisation and that records will be destroyed at the completion of their useful life. Both retention and disposal of records will be done in compliance with pertinent Company and Charity legislation and as specified in the following regulation.

1. The Management Committee, Chief Officer, Operation's Manager and the staff responsible for the record is authorized to destroy the records in accordance with the following schedules.

2. Company and Charity Acts, Customs & Excise, Inland Revenue, etc., require that certain documents be retained for audit and other purposes. It should be understood, therefore, that where an Act specifies a period longer than that given in this Regulation, the Act takes precedence. If there is any doubt as to what procedure is necessary, the appropriate authority should be contacted.

3. It is understood documents in the indefinite and other classifications may be microfilmed, or electronically and digitally stored, provided written permission is received from the governing authority.

4. Documents not listed in this appendix and not required to be retained for periods specified by law should be considered for retention/disposal taking into account their future value for legal, historical or statistical purposes and availability of similar data elsewhere.

The following retention schedule outlines the minimum amount of time that EESN records must be retained:

East Europe Support Network is committed to providing quality services to users.

1. The purpose of a complaints procedure is to enable people using services or taking part in activities to be heard when they feel things have gone wrong.

2. EESN represents the interests of Eastern European people living and/or working in UK. EESN provides a range of services including welfare rights, housing advice, information, counselling, advice on funding, workshop activities and policy development.

3. EESN recognises that making a complaint about services can be a difficult process. EESN is committed to investigating and dealing with .complaints in a sensitive and appropriate way. Every effort will be made to ensure that the persons) involved in carrying out any investigation of a complaint will be impartial and will follow the rules laid down in the complaints procedure to ensure that justice is achieved in an objective way.

4.1 If any person using EESN services wishes to make a complaint, they should do so informally, in the first instance to the person who usually provides the service.

4.2 If any person wishes to make a formal complaint or the nature of the complaint is such that they do not feel it is appropriate to complain to the person they usually deal with, they should write to EESN Co-Directors

providing full details of the issues about which they wish to complain. The complaint will be registered in a complaint's log book, located in the Co-Director's office.

4.3 If writing a letter is difficult and, if preferred, a person using the services may make a verbal complaint at an-interview with a member of EESN who will detail the complaint in writing.

4.4 If EESN Co-Directors are the subject of the complaint, it should be made in writing to the Chair of the Management Committee.

5.1 The Co-director will acknowledge receipt of the written complaint by responding by letter to the complainant within five working days from the date of receiving the complaint.

5.2 The Co-Director will arrange for an appropriate investigation to be made of the circumstances of the complaint. The Co-Director may conduct the investigation, or may nominate an officer of EESN or a Management Committee Member to conduct the investigation.

5.3 The person conducting the investigation should not otherwise be involved in any way with the complaint.

5.4 If the Co-Directors are the subject of the complaint, the investigation will be arranged by the Chair of the Management Committee. A Management Committee Member will conduct the investigation in these circumstances.

5.5 If a staff member/EESN worker is the subject of the complaint, the staff member/EESN worker has the right to trade union representation.

5.6 The investigation will identify the events and issues leading up to and including the circumstances of the complaint, and will be compiled into a written report which should be kept on file for a period of twelve months. All other written records and correspondence should be kept for a period of twelve months also.

5.7 A full written response will be provided to the complainant as soon as possible and in any case within ten working days of receipt of the initial complaint. If, during the investigation, it is identified that it will not be possible to prepare a response within ten working days, this should be communicated in writing to the complainant giving reasons for the delay and an indication as to when the full response would be forthcoming.

6.1 If the complainant is not satisfied with the full response to the complaint, they may appeal in writing, stating reasons, to the Chair of the Management Committee.

6.2 The Chair of the Management Committee in conjunction with EESN Co-Director will arrange for a panel of two Management Committee Members to meet and examine the appeal within fifteen working days of receipt of the complaint. The panel will also include a third person who is independent of the project, for example, another voluntary organisation representative. If a Management Committee Member has conducted the investigation, that person would be unable to participate in the appeal panel.

6.3 The appellant may bring to the Appeal an advocate or friend for support, and may call witnesses to provide evidence at the appeal meeting.

6.4 The individual who has conducted the investigation and/or Co-Directors, will provide evidence to the panel of how the matter has been dealt with and may call witnesses to provide evidence.

6.5 The panel will then meet, without the appellant or staff member/EESN worker present to decide whether the response was appropriate and will make recommendations for further action if appropriate. The panel's decision will be communicated to the appellant in writing within five working days following the meeting of the appeal panel. The panel's decision will be final.

6.6 If the matter persists in being unresolved, arbitration by an independent organisation/agency/body (for example, a Council) could be sought by the parties involved, i.e. EESN and/or the appellant.

The purpose of these guidance notes is to underpin EESN's Data Protection Policy and to provide a guide to best practice in Data Protection.

The Data Protection Act, 1984, introduced basic principles of data protection, which set standards that all registered users were required to observe. It was designed to protect individuals from any disadvantage which might result from their personal details being held on computer, for example if the information became out of date, was lost, or was made available to people or used for purposes other than those it was collected for. The Act also set up the framework for compulsory registration of data users, and established the Data Protection Registrar to organise this process and to ensure compliance.

1. The Data Protection Act, 1998, replaces the 1984 Act, and builds upon and expands the controls on personal data under the 1984 Act. Under the 1998 Act, the data protection principles have been extended and 'personal data' includes information held in certain manual filing systems. Individuals are given enhanced rights to receive details of data held about them and why it is being held, and to prevent its use. The processing of data will only be fair if certain conditions have been met, and some information is classed as 'sensitive data' and there are particular restrictions on the use of it. There are also restrictions on the transfer of data to countries outside the European Economic Area. The 1998 Act replaces the office of the Data Protection Registrar with that of the Data Protection Commissioner, and the registration of data users is replaced by notification.

2. All staff will process data about their users on a regular basis, when the user first makes contact with a Project or service, when dealing with case-work, when registering new members, writing reports or references, or as part of a supervisory role. EESN will ensure, through its procedures, that all users are informed that EESN undertakes this sort of processing and are notified of the categories of processing, as required by the 1998 Act. The information that staff will deal with on a day to day basis will be 'standard' and will cover categories such as:

Details about membership registration, case-work notes and any associated comments,

• Notes of personal supervision, including matters of behaviour and discipline

3. Information about a user's physical or mental health, sexual life, political or religious views, trade union membership, ethnicity or race is 'sensitive' data and can only be collected and processed with the user's express consent. If staff need to record this information they should use a standard form.

4. All staff have a duty to make sure that they comply with the data protection principles, which are set out in EESN's Data Protection Policy. In particular, staff must ensure that records are:

• Kept and disposed of safely and in accordance with EESN's Recording 8~ Retention Policy.

5. Staff must not disclose personal data unless for institutional purposes in line with EESN policy. The only exception to this will be if a member of staff is satisfied that the disclosure of the personal data is necessary:

In the best interests of the user or staff member, or a third person, or the organisation: AND

• He or she has either informed the Data Subject of this, or has been unable to do so and disclosure is urgent and necessary.

6. The need to ensure that data is kept securely means that precautions must be taken against physical loss or damage, and that both access and disclosure must be restricted. All staff should ensure that:

• Personal information is not disclosed either orally or in writing or accidentally or otherwise to any unauthorised third party.

• Password protected, with passwords being regularly changed, so that only authorised people can view or alter confidential data; or

• Kept only on a disk which is itself kept securely in a desk or cabinet to avoid physical loss or damage.

8. To avoid unauthorised disclosure, care must be taken to site PC's and terminals so that they are not visible except to authorised people. Screens should not be left unattended when personal data is being processed. Similarly, care must be taken to ensure that manual records, e.g. staff or student files, or printout

containing personal data, are not left where they can be accessed by unauthorised staff.

9. When manual records, or printout containing personal data, are no longer required, they should be shredded or bagged and disposed of securely.

10. Particular care must be taken of any data taken away from the University, for example manual records to be used at home, or computerised data to use on portable computers or home machines. Ensure that all work is kept confidential and, in the case of computerised information, that files are not exposed to risk from virus infection.

11. There are some exemptions from the 1998 Act for personal data processed for academic, scientific, historical or statistical research. Provided that personal data has been obtained fairly and lawfully, then the subsequent use of that data for research purposes will not breach the second data protection principle. Data collected for the purposes of one piece of research can be used for other research, and may be kept indefinitely. However, there must be no direct consequences for the individuals in respect of whom the research is carried out

and the personal data must not be processed in a way which is likely to cause damage or distress to any data subject.

12. In order to avoid subject access provisions, the results of research or statistics should not be made available in a form which identifies the individuals concerned. Wherever possible, researchers should follow a principle of 'pseudonymity' in handling personal data and; for example, avoid the storage of names and addresses directly on computer by relying on reference codes instead.

13. Care should be taken when writing confidential references. Under Data Protection legislation, a confidential reference given by EESN to a third party, for the purposes of education, employment, training, appointment to a public office or any service being provided by the individual who is the subject of the reference, should remain confidential and is exempt from the subject access provisions, in that the subject cannot gain access from the person writing the reference. However, there are occasions when references will have to be disclosed, for example in a court of law.

14. Current advice suggests that some protection from disclosure may be obtained by clearly marking references CONFIDENTIAL in the header.

15. Before processing any personal data, all staff should consider the following checklist:

• If it is sensitive, do you have the data subject's express consent? • Has the subject been told that this type of data will be processed? • Are you authorised to collect/store/process the data?

• Have you checked with the data subject that the data is accurate? • Are you sure that the data will be secure?

• If you do not have the data subject's consent to process, are you satisfied that it is in the best interests of the user or staff member to collect and retain the data?

EESN needs to keep certain personal data, for example about its staff, members and users, to fulfil its purpose and to meet its legal obligations to funding bodies and government. To comply with the law, information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully. To do this, EESN must comply with the Data Protection Principles which are set out in the Data Protection Act 1998.

• Be obtained and processed fairly and lawfully and shall not be processed unless certain conditions are met.

• Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose.

• Be adequate, relevant and not excessive for those purposes. • Be accurate and kept up to date.

• Not be kept for longer than is necessary for that purpose. • Be processed in accordance with the data subject's rights.

• Not be transferred to a country outside the European Economic Area, unless that country has equivalent levels of protection for personal data.

EESN and all its staff who process or use personal information must ensure that they follow these principles at all times. In order to ensure that this happens, EESN has developed this Data Protection Policy.

This policy has been approved by the Management Committee and any breach will be taken seriously and may result in more formal action.

Any member of staff, member or user who considers that the policy has not been followed in respect of personal data about themselves should raise the matter with the Operation's Manager or Data Controller in the first instance.

Notification of Data Held and Processed All staff, members and users are entitled to:

• Be informed what the organisation is doing to comply with its obligations under the 1998 Data Protection Act.

Responsibilities of Staff, Members and Users All staff, members and Users are responsible for:

• Checking that any personal data that they provide to the Organisation is accurate and up to date.

• Informing the Organisation of any changes to information which they have provided, e.g. changes of address.

• Checking any information that the Organisation may send out from time to time, giving details of information that is being kept and processed.

If, as part of their responsibilities, staff collect information about other people (e.g. about user's case-work or personal circumstances, or about members of staff in their Project), they must comply with the Policy and with the Data Protection Guidance Notes.

Users who use the Organisation's computer facilities may, from time to time, process personal data. If they do so they must notify EESN Data Controller.

The need to ensure that data is kept securely means that precautions must be taken against physical loss or damage, and that both access and disclosure must be restricted. All staff are responsible for ensuring that:

• Personal information is not disclosed either orally or in writing or otherwise to any unauthorised third party.

Detailed advice on data security is contained in the Data Protection Guidance Notes. Rights to Access Information

Staff and members and other users of the Organisation have the right to access any personal data that is being kept about them on computer and, with effect from 24 October 2001, will also have access to paper-based data held in certain manual filing systems. Any person who wishes to exercise this right should make the request in writing to the Operation's Manager, using the standard form which is available from the Organisation's Data Controller. EESN will make a charge on each occasion that access is requested.

The Organisation aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 40 days of receipt of a completed form unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual making the request.

Information that is already in the public domain is exempt from the 1998 Act. Any individual who has good reason for wishing details in such publications to remain confidential should contact the Organisation's Data Controller.

The need to process data for normal purposes has been communicated to all staff, to members at registration and to users when they first make contact. In some cases, if the data is sensitive, for example information about health, race or gender, express consent to process the data must be obtained. Processing may be necessary to operate EESN policies, such as health and safety and equal opportunities.

The Organisation will keep some forms of information for longer than others. The Organisation's Designated Data Controller

EESN is the data controller under the Act and is therefore ultimately responsible for implementation. However, day to day matters will be dealt with by the Operation's Manager and any questions or concerns about the interpretation or operation of this policy should be taken up in the first instance with this person.

In order to receive a grant from EESN a person in need has to fill a form, which can be obtained from our office.

Form has to be accepted to one committee member who is eligible to sign cheques.