Policy Documents

Bressingham and Fersfield Parish Council
Health and Safety Policy

Introduction
This policy sets out the general principles and approach that Bressingham and Fersfield Parish Council
(the Council) follows in respect of Health and Safety legislation for activities for which the Council is
responsible.
It is the responsibility of all Councillors and employees of the Council to be aware of the following
policy statements on Health and Safety and of the organisational arrangements made to implement
these policies.

THE PARISH COUNCIL’S SAFETY POLICY STATEMENT

1. Bressingham and Fersfield Parish Council, in accordance with the requirements of The Health and
   Safety at Work Act (1974), and The Management of Health and Safety at Work Regulations (1998),
   accepts its duty to ensure safe and healthy working conditions for its employees. It also accepts its
   duty of care to other persons such as volunteers and contractors who work on behalf of the Council.
2. The Council will take all reasonable steps to ensure that it complies with the law on Health, Safety and
   Welfare and any relevant Regulations, Approved Codes of Practice and Guidance.
3. The Council will take all reasonable steps to ensure:
   3.1. That information, instruction, training, supervision, equipment and facilities necessary to
   achieve a safe working environment for employees, members of the public, contractors and
   volunteers are provided.
   3.2. That its work, in all its forms, is done in such ways that members of the public are not put at
   risk.
   3.3. That arrangements are in place for the safe use, handling, storage and disposal of all
   substances and equipment that may endanger health or welfare.
   3.4. That this policy is brought to the attention of all employees, members of the public,
   contractors, volunteers and Councillors and is reviewed annually.
4. The Council is responsible for managing safety, based on the council’s safety policy.
5. The Clerk shall keep copies of all risk assessments, method statements and Health and Safety
   documents, in labelled Health and Safety files.
6. All Councillors, employees, contractors and volunteers have a duty to take reasonable care for their
   own health and safety and that of any persons who may be affected by their acts or omissions.
7. Day to day matters of Health and Safety are dealt with by the Clerk acting on behalf of the Council.
8. Risk Assessments
   8.1. The Council will carry out risk assessment of its activities as and when necessary and review
   them annually.
   8.2. The Council will set up and monitor policies and procedures to mitigate and control any risks
   that are identified.
   8.3. The Council requires contractors to supply Risk Assessments, written Method Statements and
   Safe Systems of Work prior to starting any major works on behalf of the council.

Accessibility statement for Bressingham and Fersfield Community Website

This website is a community website funded and maintained by Bressingham and Fersfield Parish Council. We want as many people as possible to be able to use this website. For example, that means you should be able to:

• navigate most of the website using just a keyboard
• navigate most of the website using speech recognition software
• listen to most of the website using a screen reader (including the most recent versions of JAWS, NVDA and VoiceOver)

The layout and text of the website has been designed to be as simple as possible to understand.

AbilityNet has advice on making your device easier to use if you have a disability.

How accessible this website is

We know some parts of this website are not fully accessible:

• You can increase the text size to as much a 300% whilst maintaining readability
• You cannot modify the line height or spacing of text
• We can’t guarantee the full accessibility of our PDF documents or Word documents to screen reader software

What to do if you cannot access parts of this website

If you need information on this website in a different format like accessible PDF, large print, easy read, audio recording or braille:

• email bandf.pc@outlook.com

We’ll consider your request and get back to you in 14 days.

Reporting accessibility problems with this website

We’re always looking to improve the accessibility of this website. If you find any problems not listed on this page or think we’re not meeting accessibility requirements, contact: mail@bressinghamandfersfield.org

Enforcement procedure

The Equality and Human Rights Commission (EHRC) is responsible for enforcing the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (the ‘accessibility regulations’). If you’re not happy with how we respond to your complaint, contact the Equality Advisory and Support Service (EASS).

Technical information about this website’s accessibility

Bressingham Parish Council Parish Council is committed to making its website accessible, in accordance with the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.

This website is partially compliant with the Web Content Accessibility Guidelines version 2.1 AA standard.

Non-compliance with the accessibility regulations

None

Disproportionate burden

None

How we tested this website

This website was last tested on 19/07/2021. The test was performed using the Wave Accessibility software.

Elements tested:

• our main website platform
• Parish Council Meeting Agendas and Minutes

What we’re doing to improve accessibility

We continue to monitor this website’s accessibility and improve on it where we can. We follow a specific set of guidelines to ensure all our content meets the WCAG 2.1 Standard.

This statement was prepared on 19/07/2021. It was last updated on 01/08/2021.

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Bressingham and Fersfield Parish Council
Records Retention Policy

Version Control

Reviewed	Date	Actions	Status
1st October 2020	2020.01	New document	Draft

Reviewed	Date	Actions	Status

Contents

1. Introduction………………………………………………………………………………………………………………………. 2
2. Scope………………………………………………………………………………………………………..…………………… 2
3. Responsibilities………………………………………………………………………………………………………………….. 2
4. Retention Schedule …………………………………………………………………………………………………………… 32

1. Introduction
   This document describes the policy framework by which Bressingham and Fersfield Parish
   Council (the Council) manages is records, to comply with its legal and regulatory obligations
   and to contribute to its effectiveness.
2. Scope
   Records are defined as all those documents which facilitate the business carried out by the Council and
   which are thereafter retained (for a set period) to provide evidence of its transactions or activities.
   This policy applies to all records created, received or maintained by the Council in the course of
   carrying out its functions. These records may be created, received or maintained in hard copy or
   electronically. A small percentage of the Council records may be selected for permanent preservation
   as part of the Councils archives and for historical research.
3. Responsibilities
   The Council recognizes its corporate responsibility to maintain its records and record management
   systems in accordance with the regulatory environment.
   The Clerk to the Council (the Clerk) has overall responsibility for this policy and for records
   management. The Clerk will give guidance for good records management practice and will promote
   compliance with this policy so that information will be retrieved easily, appropriately and in a timely
   manner.
   Relevant individuals, including Councillors, Employees and any other individuals appointed or
   contracted to create, maintain or dispose of records, must ensure that records for which they are
   responsible are accurate and are maintained and disposed of in accordance with the Council’s
   records management guidelines.
   .
4. Retention Schedule
   The retention schedule refers to record series regardless of the media in which they are stored.
   

Document Category	Minimum Retention Period	Reason
Administration & Finance
Minutes of Council meetings	Indefinite	Archive
Minutes of committee meetings	Indefinite	Archive
Scales of fees and charges	6 years	Management
Receipt and payment accounts	Indefinite	Archive
Receipt books of all kinds	6 years	VAT
Bank Statements, including deposit/savings accounts	Last completed audit year	Audit
Bank paying-in books	Last completed audit year	Audit
Cheque book stubs	Last completed audit year	Audit
Quotations and tenders	6 years	Limitations Act 1980 (as amended)
Paid invoices	6 years	VAT
Paid cheques	6 years	Limitations Act 1980 (as amended)
VAT records	6 years generally but 20 years for VAT on rents	VAT
Petty cash, postage and telephone books	6 years	Tax, VAT, Limitations Act 1980 (as amended)
Wages books	12 years	Superannuation
Insurance policies	While valid	Management
Certificates for Insurance against liability for employees	40 years from date on which insurance commenced or was renewed	The Employers’ Liability (Compulsory Insurance) Regulations 1998 (SI.2753),
Investments	Indefinite	Audit, Management
Title deeds, leases, agreements, contracts	Indefinite	Audit, Management
Members allowances register	6 years	Tax, Limitation Act 1980 (as amended)
Employment
Staff employment contracts	6 years after ceasing employment	Management
Staff payroll information	3 years	Management
Staff references	6 years after ceasing employment	Management
Application forms (interviewed – unsuccessful)	6 months	Management
Application forms (interviewed – successful)	6 years after ceasing employment	Management
Disciplinary files	6 years after ceasing employment	Management
Staff appraisals	6 years after ceasing employment	Management
Health and Safety
Accident books	3 years from date of last entry	Statutory
Risk assessment	At least until a further risk assessment has taken place which renders the first one obsolete – though 10 years if there have been potentially dangerous exposures	Management
General Management
Councillors contact details	Duration of membership	Management
Lease agreements	12 years	Limitation Act 1980
Contracts	6 years	Limitation Act 1980
Email messages	At end of useful life	Management
Consent forms	At end of useful life	Management

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Bressingham and Fersfield Parish Council
GENERAL PRIVACY NOTICE

Version Control

Reviewed	Date	Actions	Status
1st October 2020	2020.01	New document	Draft

Reviewed	Date	Actions	Status

Contents

1. Processing of Personal Data ………………………………………………………………………………………………… 2
2. Who we Are ……………………………………………………………………………………………………………………. 2
3. How we use Personal Data ………………………………………………………………………………………………….. 2
4. The Legal basis for processing your personal data………………………………………………..……………………….. 4
5. Personal Data that we Process and Why……………………………………………………………..…………………….. 4
6. Sharing your personal data………………………………………………………………………………….……………….. 5
7. How long do we keep your personal data? …………………………………………………………………………………. 5
8. Your rights and your personal data …………………………………………………………………………….……………. 6
9. Transfer of Data Abroad ……………………………………………………………………………………………………… 7
10. Further processing………………………………………………………………………………………………….………….. 7
11. Changes to this notice………………………………………………………………………………………………….……… 7
12. Contact Information ………………………………………………………………………………………………………….. 72
13. Processing of personal data
    

1. Processing of personal data
   The processing of personal data is governed by legislation relating to personal data which applies in
   the United Kingdom including the General Data Protection Regulation (the “GDPR”) and other
   legislation relating to personal data and rights such as the Human Rights Act.
   “Personal data” is any information about a living individual which allows them to be identified from
   that data e.g. a name, photographs, videos, email address, or address.
   Identification can be directly using the data itself or by combining it with other information which
   helps to identify a living individual (e.g. a list of staff may contain personnel ID numbers rather than
   names but if you use a separate list of the ID numbers which give the corresponding names to identify
   the staff in the first list then the first list will also be treated as personal data).
2. Who we are.
   This Privacy Notice is provided to you by Bressingham and Fersfield Parish Council (the Parish Council).
   Website: https://bressinghamandfersfield.org
   Address: Bressingham and Fersfield Parish Council, c/o The Clerk to the Parish Council.
   Email: bandf.pc@outlook.com
   The Parish Council complies with Data Protection Law.
   We are a “data controller” for the data that we process about you.
   We will always take account of your interests and rights if we process your data.
3. How we use personal data.
   This General Privacy Notice sets out your rights and the Parish Council’s obligations to you.
4. Data Protection Law says that the personal data we hold about you must be:
   • Used lawfully, fairly and in a transparent way.
   • Collected only for valid purposes that we have clearly explained to you and not used in any
   way that is incompatible with those purposes.
   • Relevant to the purposes we have told you about and limited only to those purposes.
   • Accurate and kept up to date.
   • Kept only for as long as is necessary for the purposes we have told you about.
   • Kept and destroyed securely, including ensuring that appropriate technical and security
   measures are in place to protect your personal data to protect personal data from loss,
   misuse, unauthorised access and disclosure.
5. We use your personal data for some of or all the following purposes:
   • To deliver public services including to understand your needs to provide the services that
   1 Data Controller is the natural or legal person, public authority, agency or other body which, alone or jointly with
   others, determines the purposes and means of the processing of personal data.3
   you request and to understand what we can do for you and inform you of other relevant
   services.
   o To promote the interests of the Parish Council.
   o To maintain our own accounts and records.
   o To seek your views, opinions or comments.
   o To notify you of changes to our facilities, services, events, councillors and other role
   holders.
   o To send you communications which you have requested and that may be of interest
   to you. These may include information about campaigns, appeals, other new projects
   or initiatives.
   o To process relevant financial transactions including grants and payments for goods
   and services supplied to the Parish Council
   o To allow the statistical analysis of data so we can plan the provision ofservices.
   • To enable us to meet all legal and statutory obligations and powers including any delegated
   functions.
   • To confirm your identity to provide some services.
   • To contact you by post, email, telephone or using social media (e.g. Facebook, Twitter,
   WhatsApp).
   • To help us to build up a picture of how we are performing.
   • To prevent and detect fraud and corruption in the use of public funds and where necessary
   for the law enforcement functions.
   • To carry out comprehensive safeguarding procedures (including due diligence and
   complaints handling) in accordance with best safeguarding practice from time to time with
   the aim of ensuring that all children and adults-at-risk are provided with safe environments
   and generally as necessary to protect individuals from harm or injury.
   • Our processing may also include the use of CCTV systems for the prevention and prosecution
   of crime.
6. We work with other Data Controllers, including but not restricted to:
   • Local authorities
   • Community groups
   • Charities
   • Other not for profit entities
   • Contractors
   • Credit reference agencies
   We may need to share your personal data we hold with them so that they can carry out their
   responsibilities to the Parish Council.
   If we and the other data controllers listed above are processing your data jointly for the same
   purposes, then the Parish Council and the other data controllers may be “joint data controllers” which
   means we are all collectively responsible to you for your data. 4
   Where each of the parties listed above are processing your data for their own independent purposes
   then each of us will be independently responsible to you and if you have any questions, wish to
   exercise any of your rights (see below) or wish to raise a complaint, you should do so directly to the
   relevant data controller.
7. The legal basis for processing your personal data.
   The Parish Council is a public authority and has certain powers and obligations.
   Most of your personal data is processed for compliance with a legal obligation which includes the
   discharge of the Parish Council’s statutory functions and powers.
   Sometimes when exercising these powers or duties it is necessary to process personal data of
   residents or people using the Parish Council’s services.
   We may process personal data if it is necessary for the performance of a contract with you, or to take
   steps to enter into a contract. An example of this would be processing your data in connection with
   your use of our facilities, resources or equipment.
   Sometimes the use of your personal data requires your consent. In that situation we will obtain your
   consent to that use, first.
8. Personal data that we process and why.
   The Parish Council will process some, or all, of the following personal data where necessary to
   perform its tasks:
   • Names, titles, and aliases.
   • Photographs.
   • Contact details such as telephone numbers, addresses, and email addresses.
   • Where they are relevant to the services provided by a council, or where you provide them to
   us, we may process information such as gender, age, marital status, nationality,
   education/work history, academic/professional qualifications, hobbies, family composition,
   and dependents.
   • Where you pay for activities such as use of a council resource or facility, we may process
   financial identifiers such as bank account numbers, payment card numbers,
   payment/transaction identifiers, policy numbers, and claim numbers.
   Sensitive and Special Categories of Data
   The personal data we process may include sensitive or other special categories of personal data such as
   criminal convictions, racial or ethnic origin, mental and physical health, details of injuries, medication
   or treatment received, political beliefs, trade union affiliation, genetic data, biometric data, data
   concerning and sexual life or orientation.
   These types of data are described in the GDPR as “Special categories of data” and require higher levels
   of protection. We need to have further justification for collecting, storing and using this type of
   personal data.
   We may process special categories of personal data in the following circumstances:
   • In limited circumstances, with your explicit written consent.5
   • Where we need to carry out our legal obligations.
   • Where it is needed in the public interest.
   Including, as appropriate:
   • information about your physical or mental health or condition in order to take decisions on
   your fitness to take part in activities that we may offer you.
   • your racial or ethnic origin or religious or similar information, to monitor compliance with
   equal opportunities legislation.
   • To comply with legal requirements and obligations to third parties.
   Less commonly, we may process this type of personal data where it is needed in relation to legal
   claims or where it is needed to protect your interests (or someone else’s interests) and you are not
   capable of giving your consent, or where you have already made the information public.
   Do we need your consent to process your sensitive personal data?
   In limited circumstances, we may approach you for your written consent to allow us to process
   certain sensitive personal data. If we do so, we will provide you with full details of the personal data
   that we would like and the reason we need it, so that you can carefully consider whether you wish to
   consent.
9. Sharing your personal data.
   This section provides information about the third parties with whom the Parish Council may share
   your personal data.
   These third parties have an obligation to put in place appropriate security measures and will be
   responsible to you directly for the way in which they process and protect your personal data.
   It is likely that we will need to share your data with some, or all, of the following but we will do so
   only where necessary:
   • The Data Controllers listed in Section 4.
   • Our agents, suppliers and contractors. For example, we may ask a commercial provider to
   publish or distribute newsletters on our behalf, or to maintain our website or database
   software.
   • On occasion, other local authorities or not for profit bodies with which we are carrying out
   joint ventures e.g. in relation to facilities or events for the community.
10. How long do we keep your personal data?
    In general, we keep data only for as long as we need it. This means that we will delete it when it is no
    longer needed.
    Exceptions:
    • We will keep some records permanently if we are legally required to do so.
    • We may keep some other records for an extended period. For example, it is currently best
    practice to keep financial records for a minimum period of 8 years to support HMRC audits or
    provide tax information.
    • We may have legal obligations to retain some data in connection with our statutory obligations 6
    as a public authority.
    • The Parish Council is permitted to retain data to defend or pursue claims. In some cases, the
    law imposes a time limit for such claims (for example 3 years for personal injury claims or 6
    years for contract claims). We will retain some personal data for this purpose for as long as we
    believe it is necessary to be able to defend or pursue a claim.
11. Your rights and your personal data
    You have the following rights with respect to your personal data.
    When exercising any of the rights listed below, we may need to verify your identity for your security
    before processing your request. In such cases we will need you to respond with proof of your identity
    before you can exercise these rights.
12. The right to access personal data we hold on you.
    • At any point you can contact us to request the personal data we hold on you as well as why we
    have that personal data, who has access to the personal data and where we obtained the
    personal data from. Once we have received your request, we will respond within one month.
    • There are no fees or charges for the first request but additional requests for the same personal
    data or requests which are manifestly unfounded or excessive may be subject to an
    administrative fee.
13. The right to correct and update the personal data we hold on you.
    • If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your
    data will be updated.
14. The right to have your personal data erased.
    • If you feel that we should no longer be using your personal data or that we are unlawfully using
    your personal data, you can request that we erase the personal data we hold.
    • When we receive your request, we will confirm whether the personal data has been deleted or
    the reason why it cannot be deleted (for example because we need it for to comply with a legal
    obligation).
15. The right to object to processing of your personal data or to restrict it to certain purposes
    only.
    • You have the right to request that we stop processing your personal data or ask us to restrict
    processing.
    • Upon receiving the request, we will contact you and let you know if we are able to comply or if
    we have a legal obligation to continue to process your data.
16. The right to dataportability
    • You have the right to request that we transfer some of your data to another controller. We will
    comply with your request, where it is feasible to do so, within one month of receiving your
    request.
    • The right to withdraw your consent to the processing at any time for any processing of data to
    which consent was obtained.
    • You can withdraw your consent easily by telephone, email, or by post (see Section 12 Contact
    Details).7
17. The right to lodge a complaint with the Information Commissioner’s Office.
    • You can contact the Information Commissioners Office on 0303 123 1113 or via email
    https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office,
    Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
18. Transfer of Data Abroad
    Any personal data transferred to countries or territories outside the European Economic Area (“EEA”)
    will only be placed on systems complying with measures giving equivalent protection of personal
    rights either through international agreements or contracts approved by the European Union. Our
    website is also accessible from overseas so on occasion some personal data (for example in a
    newsletter) may be accessed from overseas.
19. Further processing
    If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we
    will provide you with a new notice explaining this new use prior to commencing the processing and
    setting out the relevant purposes and processing conditions. Where and whenever necessary, we will
    seek your prior consent to the new processing.
20. Changes to this notice
    This Privacy Notice is reviewed regularly. The current version is available on this website:
    https://bressinghamandfersfield.org/
21. Contact Information
    Please contact us if you have any questions about this General Privacy Notice or the personal data we
    hold about you, or to exercise all relevant rights, or make queries or complaints at:
    Email: bandf.pc@outlook.co

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Bressingham and Fersfield Parish Council

DATA PROTECTION POLICY

Version Control

Reviewed	Date	Actions	Status
1st October 2020	2020.01	New document	Draft

Contents

1. Aim and scope of policy………………………………………………………………………………..………………………. 2
2. Types of data held………………………………………………………………………………………………………………. 2
3. Data protection principles…………………………………………………………………….………………………………… 3
4. Procedures…………………………………………………………………………………………….………………………… 4
5. Access to data………………………………………………………………………………………………..…………………. 4
6. Data disclosures……………………………………………………………………………………………….………..………. 5
7. Data security …………………………………………………………………………………………………….……………… 5
8. International data transfers ………………………………………………………………………………………….………….. 6
9. Breach notification………………………………………………………………………………………………….…………… 6
10. Training ………………………………………………………………………………………………………………….………. 6
11. Records…………………………………………………………………………………………………………….……………. 6
12. Data Protection Officer……………………………………………………………………………………………….…………. 6
13. Data protection compliance ……………………………………………………………………….………………..………….. 6

1. Aim and scope of policy
   This policy applies to the processing of personal data in manual and electronic records kept by
   Bressingham and Fersfield Parish Council (the Parish Council). It also covers the Parish Council’s
   response to any data breach and other rights under the General Data Protection Regulation.
   This policy applies to the personal data of relevant individuals.
   The Parish Council makes a commitment to ensuring that personal data, including special categories
   of personal data and criminal offence data (where appropriate) is processed in line with GDPR and
   domestic laws and to conduct itself in line with this, and other related, policies. Where third parties
   process data on behalf of the Parish Council, the Parish Council will ensure that the third party takes
   such measures to maintain the Parish Council’s commitment to protecting data. In line with GDPR,
   the Parish Council understands that it will be accountable for the processing, management and
   regulation, and storage and retention of all personal data held in the form of manual records and on
   computers.
   Definitions:
   “Relevant individuals” are Parish Councillors, job applicants, existing and former employees,
   apprentices, volunteers, placement students, workers and self-employed contractors, agents, and
   other role holders within the Parish Council including former staff and former councillors.
   “Personal data” is information that relates to an identifiable person who can be directly or indirectly
   identified from that information, for example, a person’s name, identification number, location, online
   identifier. It can also include pseudonymised data.
   “Special categories of personal data” is data which relates to an individual’s health, sex life, sexual
   orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes
   genetic and biometric data (where used for ID purposes).
   “Criminal offence data” is data which relates to an individual’s criminal convictions and offences.
   “Data processing” is any operation or set of operations which is performed on personal data or on sets
   of personal data, whether or not by automated means, such as collection, recording, organisation,
   structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission,
   dissemination or otherwise making available, alignment or combination, restriction, erasure or
   destruction.
2. Types of data held
   Personal data is kept in paper and electronic files. The following types of data may be held by the
   Parish Council, as appropriate, on relevant individuals:
   • name, address, phone numbers – for individual and next of kin
   • CVs and other information gathered during recruitment or appointment
   • references from former employers
   • National Insurance numbers
   • job title, job descriptions and pay grades3
   • conduct issues such as letters of concern, disciplinary proceedings
   • holiday records
   • internal performance information
   • medical or health information
   • sickness absence records
   • tax codes
   • terms and conditions of employment
   • training details.
   Relevant individuals should refer to the Parish Council’s privacy notice for more information on the
   reasons for its processing activities, the lawful bases it relies on for the processing and dataretention
   periods.
3. Data protection principles
   All personal data obtained and held by the Parish Council will:
   • be processed fairly, lawfully and in a transparent manner
   • be collected for specific, explicit, and legitimate purposes
   • be adequate, relevant and limited to what is necessary for the purposes of processing
   • be kept accurate and up to date. Every reasonable effort will be made to ensure that
   inaccurate data is rectified or erased without delay
   • not be kept for longer than is necessary for its given purpose
   • be processed in a manner that ensures appropriate security of personal data including
   protection against unauthorised or unlawful processing, accidental loss, destruction or
   damage by using appropriate technical or organisation measures
   • comply with the relevant GDPR procedures for international transferring of personal data.
   In addition, personal data will be processed in recognition of an individuals’ data protection rights, as
   follows:
   • the right to be informed
   • the right of access
   • the right for any inaccuracies to be corrected (rectification)
   • the right to have information deleted (erasure)
   • the right to restrict the processing of the data
   • the right to portability4
   • the right to object to the inclusion of any information
   • the right to regulate any automated decision-making and profiling of personaldata.
4. Procedures
   The Parish Council has taken the following steps to protect the personal data of relevant individuals,
   which it holds or to which it has access:
   • It provides information to its employees on their data protection rights, how it uses their
   personal data, and how it protects it. The information includes the actions relevant individuals
   can take if they think that their data has been compromised in anyway.
   • It provides its employees with information and training to make them aware of the
   importance of protecting personal data, to teach them how to do this, and to understand how
   to treat information confidentially.
   • It can account for all personal data it holds, where it comes from, who it is shared with and
   also who it might be shared with
   • It carries out risk assessments as part of its reviewing activities to identify any vulnerabilities
   in its personal data handling and processing, and to take measures to reduce the risks of
   mishandling and potential breaches of data security. The procedure includes an assessment
   of the impact of both use and potential misuse of personal data in and by the Parish Council.
   • It recognises the importance of seeking individuals’ consent for obtaining, recording, using,
   sharing, storing and retaining their personal data, and regularly reviews its procedures for
   doing so, including the audit trails that are needed and are followed for all consent decisions.
   The Parish Council understands that consent must be freely given, specific, informed and
   unambiguous. The Parish Council will seek consent on a specific and individual basis where
   appropriate. Full information will be given regarding the activities about which consent is
   sought. Relevant individuals have the absolute and unimpeded right to withdraw that consent
   at any time.
   • It has the appropriate mechanisms for detecting, reporting and investigating suspected or
   actual personal data breaches, including security breaches. It is aware of its duty to report
   significant breaches that cause significant harm to the affected individuals to the Information
   Commissioner and is aware of the possible consequences.
   • It is aware of the implications international transfer of personal datainternationally.
5. Access to data
   Relevant individuals have a right to be informed whether the Parish Council processes personal data
   relating to them and to access the data that the Parish Council holds about them. Requests for access
   to this data will be dealt with under the following summary guidelines:
   • A subject access request should be made to the Clerk to the Parish Council (the Clerk).
   • The Parish Council will not charge for the supply of data unless the request is manifestly
   unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be
   provided to parties other than the employee making the request.
   • The Parish Council will respond to a request without delay. Access to data will be provided, 5
   subject to legally permitted exemptions, within one month as a maximum. This may be
   extended by a further two months where requests are complex or numerous.
   Relevant individuals must inform the Parish Council immediately if they believe that the data is
   inaccurate, either as a result of a subject access request or otherwise. The Parish Council will take
   immediate steps to rectify the information.
   For further information on making a subject access request, employees should consult with the Clerk.
6. Data disclosures
   The Parish Council may be required to disclose certain data/information to any person. The
   circumstances leading to such disclosures include:
   • any employee benefits operated by third parties
   • disabled individuals – whether any reasonable adjustments are required to assist them at
   work
   • individuals’ health data – to comply with health and safety or occupational health
   obligations towards the employee
   • for Statutory Sick Pay purposes
   • HR management and administration – to consider how an individual’s health affects his or
   her ability to do their job
   • the smooth operation of any employee insurance policies or pension plans.
   These kinds of disclosures will only be made when strictly necessary for the purpose.
7. Data security
   The Parish Council adopts procedures designed to maintain the security of data when it is stored and
   transported. In addition, employees must:
   • ensure that all files or written information of a confidential nature are stored in a secure
   manner and are only accessed by people who have a need and a right to accessthem
   • ensure that all files or written information of a confidential nature are not left where they
   can be read by unauthorised people
   • check regularly on the accuracy of data being entered into computers
   • always use the passwords provided to access the computer system and not abuse them by
   passing them on to people who should not have them
   • use computer screen blanking to ensure that personal data is not left on screen when not
   in use.
   Personal data relating to employees should not be kept or transported on laptops, smart devices, or
   portable, external or other devices, unless authorised by the Clerk.
   Where personal data is recorded on any such device it should be protected by:6
   • Ensuring that data is recorded on such devices only where necessary.
   • Using an encrypted system — a folder should be created to store the files that need extra
   protection and all files created or moved to this folder should be automatically encrypted.
   • Ensuring that laptops, smart devices and external drives are not left unattended where they
   can be stolen.
   Failure to follow the Parish Council’s rules on data security may be dealt with via the Parish Council’s
   disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on
   the severity of the failure.
8. International data transfers
   The Parish Council does not transfer personal data to any recipients outside the EEA.
9. Breach notification
   Where a data breach is likely to result in a risk to the rights and freedoms of individuals, it will be
   reported to the Information Commissioner within 72 hours of the Parish Council becoming aware of
   it and may be reported in more than one instalment.
   Individuals will be informed directly if the breach is likely to result in a high risk to the rights and
   freedoms of that individual.
   If the breach is sufficient to warrant notification to the public, the Parish Council will do so without
   undue delay.
10. Training
    New employees must read and understand the policies on data protection as part of their induction.
    All employees receive training covering basic information about confidentiality, data protection and
    the actions to take upon identifying a potential data breach.
    The nominated data controller/auditors/protection officers for the Parish Council are trained
    appropriately in their roles under the GDPR.
    All employees who need to use the computer system are trained to protect individuals’ private data,
    to ensure data security, and to understand the consequences to them as individuals and the Parish
    Council of any potential lapses and breaches of the Parish Council’s policies and procedures.
11. Records
    The Parish Council keeps records of its processing activities including the purpose for the processing
    and retention periods in its HR Data Record. These records will be kept up to date so that they
    reflect current processing activities.
12. Data Protection Officer
    Councils are exempt from the requirement to appoint a Data Protection Officer.
13. Data protection compliance
    The Clerk is the Parish Council’s appointed compliance officer in respect of its data protection
    activities. The Clerk can be contacted at email bandf.pc@outlook.com

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Bressingham and Fersfield Parish Council

Members’ Code of Conduct

1. You are a member or co-opted member of Bressingham and Fersfield
   Parish Council and hence you shall have regard to the following
   principles:
   i. selflessness,
   ii. integrity,
   iii. objectivity,
   iv. accountability,
   v. openness,
   vi. honesty, and
   vii. leadership.
2. Accordingly, when acting in your capacity as a member or co-opted member:
   2.1. You must act solely in the public interest and should never improperly confer an advantage or disadvantage on any person or act to gain financial or other material benefits for yourself, your family, a friend or close associate.
   2.2. You must not place yourself under a financial or other obligation to outside individuals or organisations that might seek to influence you in the performance of your official duties.
   2.3. When carrying out your public duties you must make all choices, such as making public appointments, awarding contracts or recommending individuals for rewards or benefits, on merit.
   2.4. You are accountable for your decisions to the public and you must co-operate fully with whatever scrutiny is appropriate to your office.
   2.5. You must be as open as possible about your decisions and actions and the decisions and actions of your authority and should be prepared to give reasons for those decisions and actions.
   2.6. You must declare any private interests, both pecuniary and non-pecuniary, that relate to your public duties and must take steps to resolve any conflicts arising in a way that protects the public interest, including registering and declaring interests in a manner conforming with the procedures set out in paragraph 3 below.
   2.7. You must, when using or authorising the use by others of the resources of your authority, ensure that such resources are not used improperly for political purposes (including party political purposes) and you must have regard to any applicable Local
   Authority Code of Publicity made under the Local Government Act 1986.2.8. You must promote and support high standards of conduct when serving in your public post, in particular as characterised by the above requirements, by leadership and example. Registering and declaring pecuniary and non-pecuniary interests
   3.1. You must, within 28 days of taking office as a member or co-opted member, notify your authority’s monitoring officer of any disclosable pecuniary interest as defined by regulations made by the Secretary of State, where the pecuniary interest is yours, your spouse’s or civil partner’s, or is the pecuniary interest of somebody with whom you are living with as a husband or wife, or as if you were civil partners.
   3.2. In addition, you must, within 28 days of taking office as a member or co-opted member, notify your authority’s monitoring officer of any disclosable pecuniary or non-pecuniary interest which your authority has decided should be included in the register.
   3.3. If an interest has not been entered onto the authority’s register, then the member must disclose the interest to any meeting of the authority at which they are present, where they have a disclosable interest in any matter being considered and where the matter is not a sensitive interest.
   3.4. Following any disclosure of an interest not on the authority’s register or the subject of pending notification, you must notify the monitoring officer of the interest within 28 days beginning with the date of disclosure.
   3.5. Unless dispensation has been granted, you may not participate in any discussion of, vote on, or discharge any function related to any matter in which you have a pecuniary interest as defined by regulations made by the Secretary of State. Additionally, your must observe the restrictions your authority places on your involvement in matters where you have a pecuniary or non pecuniary interest as defined by your authority.
   3.6. A sensitive interest is described in the Localism Act 2011 as a member or co-opted member of an authority having an interest, and the nature of the interest being such that the member or co-opted member, and the authority’s monitoring officer, consider that disclosure of the details of the interest could lead to the member or co-opted member, or a person connected with the member or co-opted member, being subject to violence or intimidation.