Privacy Policy

Some key take outs: 

• We get information from you in order to provide a service to you. That could include mailing you out an order, or providing you with support in a workshop setting. 
• We gather this information when you make a purchase from us, or when you access our services like workshops.
• We also use cookies and tools like Google Analytics to better understand who uses this website. We use this data to continually improve the work of HATW and make sure we’re giving you the most useful and relevant information possible.
• You’ve got the right to know what of your personal information we hold and what we do with it, and if you want us to know what information we have, or want us to get rid of it you can let us know any time by emailing admin@hatw.co.uk 
• Any personal information we have is stored securely – including password protecting all information stored digitally, and locking away any personal information shared physically. 
• We’ll only store your personal information for as long as is necessary, and it will be securely destroyed or deleted once we’ve provided the service to you that you shared that information with us for. 

Our promise:

We promise to respect all personal information. That includes any personal information you share with us, or that is shared with us by other organisations. We will keep your data safe and secure and not use it for any purpose you would not reasonably expect us to. 

What is personal information? 

Personal information means any information that may be used to identify you, such as your name, title, telephone number, email address, or mailing address, etc. 

Given the work that we do, we may also ask you about sensitive information (special category data) such as details about mental health issues, diagnoses, etc. 

You may also choose to share photos, videos or stories with us, which also count as personal information.

Why we collect your personal information and how we use it

As with all of our activities, the aim of us collecting and retaining data is to be able to provide a service of the the greatest benefit to the Heads Above The Waves community. We only retain data where there is a legitimate interest and lawful basis to do so. The lawful basis on which we process your data is that of a contract – e.g. to provide a service to you, at your request.

Listed below are examples of the ways in which we may use your personal data. The list is not exhaustive but is aimed to give you an overview of the types of ways we may use your data.

• To be able to send you items you’ve ordered from us online
• Contact you about any issues with items you’ve purchased from us 
• Keep a record of any communications between us and you, for example emails and phone calls in relation to our website, in relation to fundraising activities you are involved in, or other services (for example: design work, or sharing your story)
• keeping a record of other interactions too, such as requests for leaflets or attending an event
• contacting you to keep you up to date with the organisation’s activities, and information that might relate to mental health support for you.
• processing financial transactions such as purchases, donations, or entering a paid event.
• Contact you about volunteering activities if you’ve expressed an interest in volunteering with us.
• Managing and improving how we communicate with you – how you prefer to be contacted, and what information you want to receive. We might contact you about our campaigns, events, appeals, volunteering, news, information and advice. 
• Researching the interests, behaviours, demographics (for example: age, gender identity, location) and trends of the people who are using our services. 

We will always check with you that you are happy with us retaining and using any data about you before we do so.

You have the option to say no to us retaining your information or for us to remove the information that you have shared with us, though please bear in mind that if you choose not to agree to this, it may affect our ability to carry out the tasks above for your benefit, or the work of Heads Above The Waves.

 

Where we get your information from:

You have the right to be informed about the collection and use of your personal information. Before we collect personal information from you, we will always give you the opportunity to confirm you are happy for us to do so, and provide you with privacy information.

There are two main ways in which we collect personal information about you: directly or indirectly (including the use of third parties).

Directly

You may give us your information in order to:

• purchase our products
• seek information or support from us (such as via our Helpline)
• sign up for one of our events
• share your story on our website
• in relation to fundraising (for instance: fundraise on our behalf, make a donation
• offer to support us through volunteering
• or otherwise communicate with us.

 

Indirectly

Your information may be shared with us by other organisations, when you have consented for them to do so. You should check the privacy information for these organisations when providing consent to understand how they may use your data. These organisations may include third party organisations such as:

• Schools, colleges, universities, youth groups, etc. 
• Fundraising sites (such as Givey)
• Transaction websites such as PayPal 

 

We will also ensure that organisations are complying with the relevant legislation when sharing your information with us. We may also use publicly available information. For example, we are subject to many legal and regulatory obligations and standards. 

We may ethically screen supporters to minimise the risk of associating ourselves with an individual or organisation that conflicts with our values.

How we store your data, and how long for

We are committed to storing your data securely, and ensuring that it is accessible only by those working on behalf of the Heads Above The Waves, who have agreed to work with data responsibly and securely according to our policies. We ensure that all locations in which your data are stored are secure and compliant with the relevant legislation.

We only store information as long as it is required for the purpose it was originally obtained for. Therefore, the length of time we store your information for depends upon what the information is and what purpose it is retained for. We regularly review the information that we hold and will ensure that any data no longer required is securely deleted or disposed of.

How we keep your data safe

We ensure that the appropriate safe guards are in place to ensure that the information you share with us is kept safe, and only accessed by those who have permission to do so. We check that all places where we store data are compliant with the latest legislation (GDPR), and in keeping with our high standards.  For example, all digital information is password protected through trusted services that are compliant with the latest legislation, and any physical information is securely locked away, and only accessed by those working on behalf of Heads Above The Waves who have agreed to work with data responsibly and securely according to our policies.

We never have, and never will share data with other organisations for marketing purposes. There are only very specific situations in which we may share your information. We may share your information, with your consent, to other professionals we work with as part of our service to you. 

For instance, with your permission, we may contact a parent, teacher or a professional working with you, as part of our workshops. This will always be with your explicit agreement. The exceptions to this are if there is a safeguarding concern or we are bound by law and in these circumstances we will still seek to gain your consent first, but if you choose not to consent we must follow our safeguarding policy or legal obligations. A copy of our safeguarding policy can be provided on request.

Sometimes if you are sharing a photo or story with us, we will ask whether you are happy for us to share this publicly via ‘all media’. We use all media sources available to us as a charitable organisation to inform, raise understanding of mental health issues and to generally raise the profile of the work of the Heads Above The Waves.

We will always make this clear to you where we are asking whether you are happy for us to share information in this way.

Use of our website

We use Google Analytics to gain usage information about our website, so that we can better understand the need for our services and improve the site. We also collect domain information (e.g. IP address) as part of our analysis of the use of the website. This data enables us to become more familiar with how people visit our site, how often they visit and what parts of the site they visit most often. This information is collected automatically and requires no action on your part. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

We also collect demographics information, such as age, gender, and location to better understand who is using our site and ensure that what we do is going to be helpful & relevant to you. We obtain this information via pixels, tags, cookies or by services that are offered by websites and social media networks.

We don’t currently use this data for adverts or remarketing purposes, but the tools we use to collect them (namely: Google Analytics) may be used for such purposes.

You should also check the settings on your browser, devices and/or operating systems to check what information you are giving permission to share when you browse the internet.

Use of Children’s Data

Where we are providing an information and advice service to children and young people, or they otherwise wish to be involved in our charitable activities, we will only process their personal information if we have written parental consent and if we need the data in order to provide a service to them. In relation to fundraising, we will always take the appropriate precautions if young people are interested in supporting us, and seek guidance from best practice organisations (such as the Institute of Fundraising).

In addition to this, schools, youth groups, colleges etc, may share information with us in order to provide support to a student. If it’s still relevant, prior to the child turning 16, we will contact them to find out if they would like us to retain this information and stay in touch with them. If they do not opt-in, then we will delete this information accordingly. 

Your Legal Rights

You have the right to be in control of your information. Outlined below are your legal rights and information on how you can act upon them. If you would like to speak to us about any of these issues, you can contact us on admin@hatw.co.uk 

The right to access your personal information

You have the right to request a copy of the personal data we hold on you. We will fulfil any requests within one month.

The right to edit and update your personal information

The accuracy of your personal information is important to us, if the information we hold is inaccurate or incomplete, please let us know and we will update it as soon as possible.

The right to be forgotten

You do have the right to request the deletion or removal of your personal information where there is no compelling reason for its continued processing. We will review each request on a case by case basis.

We will endeavour to comply with your request without delay and in any event, within one month of receiving your request.

 

The right to complain to a supervisory authority if you believe we have not handled your personal information in accordance with the data protection laws

You can always speak to us about issues relating to data protection. This includes if you wish to ask a question, make a complaint or raise a concern about how we process your personal information. You can contact us on admin@hatw.co.uk

If you are not happy with how we have handled your complaint, or you believe that your data protection or privacy rights have been infringed, or for other reasons would rather not contact us, you have the right to complain to the Information Commissioner’s Officer (ICO), which oversees the protection of personal data in the UK.

Updating your preferences or unsubscribing

You can change your contact preferences by contacting us. You can also change your preferences through links in the bottom of emails we send to you.

Updates and changes to our policy

We reserve the right to update this policy and will review it regularly. You should check this policy which will always be available on our website or by request. If there are any major changes to our policy, if appropriate we will add a notice on our website or contact you.

This privacy policy was last updated in September 2020.

Inappropriate content

If you post or send any content that we believe to be in breach of any laws or otherwise inappropriate, such as defamatory content, we may use your personal information to inform relevant third parties such as the police.

Controller of personal information

We are Heads Above The Waves – a non-profit Community Interest Company, based in Cardiff. We exist to raise awareness of self-harm and mental health issues in young people, and promote positive, creative alternative coping techniques. 

Our registered office is Unit 3, Douglas Buildings, Royal Stuart Lane, Cardiff, CF10 5EL. 

We are registered as a CIC in England and Wales with company number 9534155

If you have any questions about this privacy policy or data protection, you can contact us on admin@hatw.co.uk

Recruitment

We will use appropriate means to advertise for volunteers locally that take into account the principles of our Equal Opportunities Policies. The applicant will be fully briefed on the role before applying and will be interviewed by at least one of the three Directors. If a reference is required for further support for an application it will be requested and taken up. A DBS (Disclosure and Barring Service) Check will be required for every volunteer or person working for Heads Above The Waves in contact with children and young people.

Induction and Training

There will be an induction prepared and delivered by at least one of the Directors. This will include:

• The role of the volunteer and what will be required of them.
• A list of all staff members and volunteers, and the best methods to contact them.
• Copies of all the relevant policies including this Volunteer policy, Confidentiality policy, Health and Safety policy, Equal Opportunities policy, Child Protection policy and Self-harm policy.
• Logistics and essential procedures plan i.e. timekeeping, rota, activities for the day etc.
• Induction training and details of ongoing training or potential training opportunities.
• Information about the relevant Code of Practice for the required tasks.
• Other information as appropriate.

There will be a trial period of two weeks to give Heads Above The Waves and the volunteer time to discover if they are suited to each other. A review will be made one week into the trial period and also at the end to determine whether or not to continue working together.

Expenses

We value our volunteers and want to ensure that there are no barriers to volunteer involvement. All out-of-pocket expenses, if required, will be reimbursed, including expenses for travel and meals in accordance with the Expenses Policy. In order to claim expenses, an expenses form must be completed and given to one of the three Directors.

Support

The Directors, the organisations Voluntary Counsellor, Em Jones, and the other volunteers will offer support to the volunteers. There will be a briefing session at the beginning and a de-briefing at the end of each session, in line with the Staff Safeguarding Policy. The Directors and the Voluntary Counsellor will support all volunteers and will have regular meetings with the volunteers to discuss any problems or issues that may arise. The Directors receive support from the Voluntary Counsellor and from each other.

Insurance

Heads Above The Waves has a valid insurance policy which is available upon request.

Confidentiality

Heads Above The Waves’ work requires an explicit confidentiality policy, which all workers, including Directors, volunteers and staff, are obliged to observe which is available upon request.

Resolving Problems

The relationship between the organisation and its volunteer workers is entirely voluntary and does not require a contract. However, it is important that the organisation is able to maintain its agreed standards of service to the clients who use it, and it’s also important that volunteers should feel safe and enjoy making their contribution to Heads Above The Waves.

If your role as a volunteer does not meet the organisation’s standards, here is how it will be dealt with:

• Initially with a meeting with one of the Directors who will discuss the concerns.
• If it does not resolve the concern then a meeting with all Directors will be convened.
• If your work still does not meet with our standards then we shall stop using your services.
• At all times you will be able to freely state your case and can have a friend or representative to accompany you.

If you are dissatisfied with any aspect of your work you should:

• Initially explain your dissatisfaction with one of the Directors.
• If that does not resolve the concern then a meeting with all Directors should be convened.
• If after this your dissatisfaction remains unresolved, and we are unable to resolve your grievance, then it would be inappropriate for you to continue to volunteer.

At all times you will be freely able to state your case and can have a friend or representative to accompany you.

This volunteer policy is freely accessible to all. It will be reviewed at least annually, in order to adapt or improve it.

Heads Above The Waves (HATW) acknowledges that dealing with issues around self-harm, and any potential associated issues can be stressful to staff members. The wellbeing of staff is vital to the ethos of HATW, as well as meaning we can continue with our work. All staff should feel safe, supported, and confident in carrying out all work for HATW.

Workshops

After completion of any workshop, every HATW worker involved with that session will be required to complete a debrief form, summarising what they felt went well, what could be improved, any unexpected outcomes, and any stand out quotes/comments (good or bad) from the young people involved in the session.

These forms are to be filled in immediately after the session has ended, so that any concerns and issues may be addressed straight away. Any issues that arise that appear to be child protection issues will be handled according to the HATW Child Protection Policy.

All forms will be stored securely in a locked drawer, in accordance with the HATW Data Protection Policy.

All workshop staff should also verbally debrief with each other as well as with any other sessional staff involved, e.g. youth workers, teachers, other agency staff.

If someone is carrying out a workshop by themselves, then they should verbally debrief with someone else within HATW that same day, either in person or on the phone.

During a verbal debrief, all concerns should be addressed, and a plan of action made to resolve these concerns. This may include following up with a third party (such as a school) and so, whenever possible, all third parties involved in the workshop should also be present during a verbal debrief.

In the case of other work such as assemblies and one-to-one work, verbal debriefs should be done wherever possible, but written notes are not necessary, unless a particular issue is raised that causes concern.

Events

Staff may need to attend events, such as gigs or festivals, to promote HATW. While these are less likely to be as intense as workshops, members of the public may still disclose self-harming behaviours or distressing events.

Should a disclosure occur, staff should be sure to debrief to each other about it, especially if unsure on how to best react or follow up. Disclosures of child abuse or neglect should be dealt with in line with the Child Protection Policy.

Wherever possible, staff should operate in pairs – especially at larger events. Staff should take shifts when possible, to share a workload of both sales of merchandise and discussions with the public.

Staff should take regular breaks, especially following an intense conversation with a member of the public.

Communication with Service Users

The nature of the HATW means that staff will be in contact with vulnerable people, dealing with a range of stressful and difficult situations.

For the protection and wellbeing of both HATW staff and service users, never give your personal details to service users, or promise any form of additional support. This includes, but isn’t limited to, phone numbers, addresses, and social media details.

If a service user does request further support from you, direct them to the HATW website and/or to existing organisations who are able to provide such support.

When someone contacts the HATW website or social media, they should be conversed with normally, and in plain English. However, if someone should disclose abuse, or cause serious concern for their own wellbeing or the wellbeing of others, you’ll need to follow the Child Protection Policy, and make them aware of this.

Where possible, try not to get into conversation with the person contacting HATW about their particular situation or issues, and instead recommend that they approach someone who is able to provide more comprehensive support.

Don’t tell someone what they should or shouldn’t do. Instead, suggest things that may work for them, based on other experiences shared with HATW.

While staff should feel prepared to talk about self-harm and offer low level support at any time or place, there must be a clear separation between your role as a HATW worker and your personal life.

To this end, it is important for staff to take time every day, especially if carrying out “front line” work (such as workshops, or stalls at events), to relax and unwind doing something they enjoy, and not related to HATW work.

It’s at your discretion whether you take on a supportive or listening role within your personal life, but it should be made clear that it is not within your role as a HATW worker.

Staff should avoid entering into relationships with service users, outside of their role within HATW.

Staff Support

Staff should constantly keep in touch with each other, via any medium, to check in on each other, and provide peer-to-peer support for one another.

Should you require additional support or someone else to talk to, either contact an outside listening service, or get in touch with the voluntary counsellor for HATW, and request time to talk through your concerns. Conversations with the voluntary counsellor are bound by the same confidentiality and privacy guidelines as all HATW work.

Staff who have a history of past self-harm

HATW believes that particularly effective support can be provided for service users when staff have a good understanding of what it is like to experience self-harm, either through personal experience or through training. For this reason (and in line with the Equal Opportunities Policy) staff may have personal experience of a struggle with self-harm themselves. Care will be taken during the employment process to ensure that staff are comfortable talking openly about self-harm on a regular basis, due to the nature of the role. However, certain topics, language or imagery may still be distressing and these should be made aware to the Directors before any contact with service users.

If you find yourself being triggered, or distressed by anything happening through HATW’s work, you should excuse yourself from the session and discuss the issue with one of the Directors or the voluntary counsellor as soon as possible.

For this reason, HATW work will always be conducted with at least 2 members of staff on hand (or if this is not possible, a supporting member of staff should be found – from a partner agency, school, etc).

HATW believes that everyone should be able to talk honestly and openly about their experience with self-harm, including staff, but it’s important to state that no-one – staff or service user – should feel pressured into sharing personal experiences beyond what they’re comfortable to do.

Bullying

Bullying can happen anywhere, including in the workplace, and HATW has a zero tolerance policy on bullying from one member of staff to another. If you feel concerned about bullying, you should immediately contact your line manager, who will take steps to prevent it continuing.

Support Agencies for Staff and Service Users

National Self-Harm Network – 0800 622 6000 – nshn.co.uk – support@nshn.co.uk
The Mix – 0808 808 4994 – themix.org.uk
ChildLine – 0800 1111 – childline.org.uk
Samaritans – 116123 – samaritans.org – jo@samaritans.org
NightLine – nightline.ac.uk/nightlines to find your local branch
SupportLine – 01708 765 200 – supportline.org.uk
CALL Helpline – 0800 132 737 – callhelpline.org.uk – Text “Help” to 81066
MIND Info Line – 0300 123 3393 – mind.org.uk
SANE – 0300 3047000 – sane.org.uk

It is the policy of Heads Above The Waves (HATW) to attach the greatest importance to the Health, Safety, and Welfare at work of all its own and its customers employees, as well as any service users. We believe that it is the Management’s responsibility to ensure this policy is adhered to, which should be deemed as equally important as the company’s commercial activities. The designated Health and Safety Officer for HATW is Si Martin – si@hatw.co.uk

The promotion of health and safety at work is the responsibility of both employer and employee.

The HATW statement of general policy is:

• To provide adequate control of the health and safety risks arising from our work activities
• To consult with all our employees on matters affecting their health, safety, and wellbeing
• To provide and maintain safe working environments, equipments, and systems of work, to ensure they are safe and without risk to health
• To provide information, instruction, training and supervision to ensure that all staff can safely carry out their duties
• To prevent accidents and cases of all work related ill health
• To ensure that all reasonable steps are taken to ensure adequate resources (time, money, and manpower) are available for this policy to be implemented
• Hazards, which may exist in connection with the activities carried out by HATW, are identified and eliminated through risk assessments. Where hazards still remain, they will be brought to the attention of the person who may be exposed.
• To ensure adequate first aid provision on all work sites
• To maintain safe and healthy working conditions
• To review and revise this Health and Safety Policy as necessary at regular intervals.

It is the aim of HATW to promote the highest standards of health, safety, and welfare throughout the entire organisation in the performance of its activities.

The overall aim of this document is to ensure that all HATW staff are able to recognise and act appropriately to all cases of self-harm in young people that we are working with.

Objectives

• To recognise any form of self-harm or harmful behaviours.
• To help staff to understand and prepare for the fact that self-harming is almost always a symptom of some underlying emotional or psychological issue.
• To put in place a framework for intervention.
• For this document to be a practical way to help service users access support.

What is Self-Harm?

Self-harm is the act of deliberately causing harm to oneself either by causing a physical injury, by putting oneself in dangerous situations and/or self-neglect, and can include but is not limited to:

• cutting
• scratching
• burning or scalding their skin
• banging or bruising
• scrubbing, picking or scouring their skin
• deliberate bone-breaking
• punching themselves
• sticking things into their body
• swallowing inappropriate objects or liquids
• taking too many tablets
• biting themselves
• pulling their hair or eye lashes out
• alcohol and substance misuse
• controlled eating patterns- anorexia, bulimia, over-eating
• indulging in any risky behaviours/ risky sexual behaviours
• an unhealthy lifestyle (for example, not taking good physical care of oneself)
• deliberately provoking aggressive reactions from others (intentionally getting into fights)

Things for us to Remember

• Anyone from any background or of any age can self-harm, including very young children.
• Self-harm affects people from all family backgrounds, religions, cultures and demographic groups.
• Self-harm affects all sorts of people across a range of gender identities.
• People who self-harm can often keep their problems to themselves which may mean opening up can be difficult.
• You cannot just tell someone who self-harms to stop – it’s not that easy.

Links to Emotional Distress

Those who self-harm are usually suffering emotional or psychological distress and it is vital that all such distress is taken seriously to assist in alleviating it or to minimise the risk of increasing distress and potentially suicide.

Emotional/psychological risk factors associated with self-harm can include but are not limited to:

• recent trauma e.g. death of a friend or relative, parental divorce
• negative thought patterns and low self-esteem
• bullying or being rejected by peers
• difficulty in making relationships/loneliness
• abuse- sexual, physical, emotional or through neglect
• sudden changes to social situations and/or academic performance
• relationship difficulties (with family or friends)
• learning difficulties
• school or work pressures to achieve (for example: from teachers or parents/guardians)
• substance abuse (including tobacco, alcohol or drugs)
• issues around sexuality or gender identity
• depression/anxiety – though it may not be formally diagnosed
• inability to express oneself
• lack of positive coping mechanisms

Other casual or risk factors:

• inappropriate advice or encouragement from internet websites or chat-rooms
• experimentation, ‘dares’ or bravado, copycat behaviour
• a history of abuse or mental health issues in a family
• parental separation or family alienation or distancing/ poor parental relationships and arguments
• neglect or domestic abuse and/or substance misuse in the home
• media influence
• issues surrounding religion or cultural identity

Warning Signs

Self-harm may present but not always visible. Therefore staff should be vigilant and should take any warning signs seriously. These may include but are not limited to:

• visible signs of injury
• a change in dress habits that may be intended to disguise injuries
• changes in eating or sleeping habits
• increased isolation from friends or family; becoming socially withdrawn
• changes in activity or mood (e.g. becoming more introverted)
• struggling in school or lowering of academic achievements
• a withdrawal from out of school activities or after school clubs could be a sign of distress or isolation
• alternatively, an increased amount of activities, workload and pressures leaving little time for the young person to relax or have any personal time
• talking or joking about self-harm or suicide
• drug and alcohol abuse
• expressing, verbally or otherwise, feelings of failure, uselessness, loss of hope and low self-worth

All staff should take these signs seriously; however, we are dealing with young people who self-harm, on a daily basis. If it is already identified that a young person self-harms and they are discussing past or current behaviours in a group setting, one on one in mentoring or in a conversation, then a disclosure of self-harm shouldn’t necessarily cause serious concern for staff.

If they disclose that they are a serious risk to themselves or others then it should be escalated as a child protection and safeguarding issue.

If they disclose that the self-harming behaviour is a result of abuse or neglect (as defined in the Child Protection Policy) then it should be escalated as a child protection issue.

In the event of an escalation, the relevant organisations to be contacted would be the school contact, and also one of the following:

• the police
• social services
• NSPCC

If you aren’t sure whether a disclosure should be escalated then talk to one of the Directors, as every young person’s case will be individual and will be handled as such.

Prevention

The risk of self-harm can be significantly reduced by the creation of a supportive environment in which an individual’s self-esteem is raised and healthy peer relationships are fostered. This can be achieved through respect, honesty and openness. Staff awareness of issues leading to self-harm is increased through accessing training, following the child safeguarding polices created by HATW and sharing stories of how people have overcome their issues on the HATW website (www.hatw.co.uk)

HATW doesn’t aim to necessarily enforce stopping self-harming, but rather, our aim is to introduce other, more positive alternatives, for service users to find their own way, and stop self-harming in their own time.

HATW will provide service users with a wide range of internal and external sources of help that can be contacted or used through a variety of methods. Staff will all have access to contact information for external agencies that can offer advice and/or assist with issues including self-harm.

Procedures for Dealing with Self-Harm

The first thing to remember is that if someone has chosen to tell you that they are self-harming then you will be someone that they trust and feel comfortable talking to. It is not easy to tell someone for the first time about something very private like self-harm. The person may have considered for a long time whether to talk about it or not and the fact that they have disclosed to you, even though it might be difficult, might be the first steps to finding help and changing their situation.

If a disclosure is made take it in your stride. Keep your body language open and remain emotionally neutral.  They are not alone in self-harming and neither are you as someone trying to support them. Self-harm is a coping mechanism but it does not necessarily mean that the person is feeling suicidal or mean that they are at serious risk. However, staff should remain vigilant for signs that an issue is more serious.

If a young person discloses that they self-harm there are some initial key things to remember including:

Understanding Self-harm

• Self-harm is a coping mechanism.
• It is not about attention-seeking.
• There is a difference between self-harm and suicide.
• Understand that it is a long and hard journey to stop self-harming. Be aware that someone will only stop self-harming when they feel ready and able to do so.

Practical responses to self-harm disclosure

• It’s OK to ask for time to let the news sink in
• Take things at the young person’s pace
• Ask what you can do to help
• Don’t give a no-self-harm ultimatum
• Encourage them to seek professional help.
• Don’t worry about saying the wrong thing
• Show them genuine concern
• Be open and make time to listen to them
• Encourage them to make their own decisions and ask what they want you to do, and how they want help
• Be calm and patient with them
• Give them a message of hope- that things will get better, for example, the stories shared through HATW.
• Try not to show disappointment or distaste.
• Don’t shout or demand answers
• Don’t force anyone to talk about anything they aren’t ready to
• Avoid confiscating equipment as it might mean that the young person will find something else to use that they may not be used to, and may cause more damage.
• Do not force anyone to stop what they are doing. Instead talk about what triggers them, what things they think they might find helpful instead and if they want any further help or support.

When self-harming behaviours are being discussed remember to:

• Let the person who self-harms know that you want to listen to them and hear how they are feeling when they feel ready and able to talk
• Some people will just want to be heard and empathised with. If they’re comfortable talking, let them talk. If they’re not comfortable talking, try not to push them by asking questions that may overwhelm them.
• Be clear about why they are discussing this with you, and what they are looking to get out of the conversation.
• Be compassionate and respect what the person is telling you, even though you may not understand or find it difficult to accept what they are doing.
• Self-harm is not the only way for people to deal with emotional distress. Try to encourage the young person to seek alternative and more constructive coping mechanisms. However, do not expect them to be able to stop self-harming immediately.
• Be careful with your choice of language and keep your tone respectful. Discussing self-harm in graphic detail can be distressing and triggering. Do not use violent and/or graphic language or imagery (e.g. ‘slashing your wrists’ etc.)

Some Practical Things That You Might do While Supporting Someone Who Self-Harms

• Ask them how they would like you to help them. It’s okay to ask questions and not know all the answers. The person who is self-harming is probably the one who knows best how they want to be supported, so just ask.
• Don’t accuse the person of being attention seeking, there are common misconceptions that someone who self-harms does it because they want people to notice them but the reality is that many people self-harm but do everything they can to ensure that no one else finds out. Even if self-harm is being used by someone to get attention, that person is still struggling; self-harm is not a positive way to get the attention they are looking for and they need our support just as much as any other person.
• While you are there for them and you will do your best to support the person who is self-harming, remember that you are not able to do everything alone. You can encourage the person to think about seeking help – perhaps from an understanding GP, parent, youth worker or teacher – but don’t force them to if they don’t want to. Just let them know that you are there for them and that there is more support out there when they are ready.
• Don’t tell them to stop. Self-harm is a coping mechanism, it is something they have come to rely on to deal with difficult things at the moment. Other healthier coping mechanisms will need to be found before the person can stop self-harming and this process can take a long time, and can only happen when the person is ready.
• Don’t focus only on the self-harm or ask the person to show you their scars/injuries. You should instead try to look at the underlying issues or the reasons behind the self-harm. By helping them to talk about the emotions/feelings/thoughts that are leading to them hurting themselves, you may be able to help them manage these things in a healthier way.
• Some people may want further help with their self-harm and in this case you may be able to help by putting them in touch with organisations that that may be able to help further (see ‘Helplines’).
• If they want to talk to their parents or Doctors about their self-harm it may be helpful for you to discuss with the young person what they expect, how they think it will go and how they hope it will go and put some action plans in place to achieve this, and talk about the best language to use or the best approach.
• If they don’t want to stop self-harming immediately it may be best to make sure they stay safe and reduce the damage to their body e.g. Using clean utensils, not cutting too deep, keeping wounds clean and free from infection.

If physical harm occurs during a HATW session, the young person should be taken to the Health Centre or to A&E for medical assessment and care. If it is severe or life threatening, ring 999 immediately.

If a young person harms themselves in front of other service users, then all witnesses should be spoken to individually, and supported appropriately, to ensure that they’re not at an increased risk of self-harming as result of the incident.

Things to Suggest Instead of Self-Harm

There isn’t a “one size fits all” solution to self-harm. Try to help the young person come up with things that might work for them. If the young person cannot or will not find their own solution, some suggestions could be made like writing, screaming into a pillow, going for a really fast run or painting/listening to music really loudly.

They could also consider:

• Talking to a family member, a friend or a helpline. If they are on their own perhaps phoning or emailing/texting/messaging a friend or helpline could be helpful.
• Distract themselves by going out, singing or listening to music, or by doing anything (harmless) that interests them.
• Relax and focus their mind on something pleasant or try some yoga poses or meditation techniques- creating their very own comforting place.
• Find another way to express their feelings, perhaps through creative means.
• Give themselves some ‘harmless pain’- eat a hot chilli, have a cold shower/holding ice cubes, or drawing red lines on their skin.
• Focus their mind on positives eg. things they have to look forward to, things they have in their lives that they enjoy doing, things they are grateful for.
• Write a diary/letter to explain what is happening- even if no-one else ever sees it.

Confidentiality and Reporting

While working on behalf of Heads Above The Waves, every conversation should be prefaced with the confidentiality guidelines, so that the young person is aware of what will and will not be disclosed outside of that conversation.

Confidentiality is about keeping things that you are told between the people involved, unless someone is at risk or in danger (this could be the person who is self-harming or anyone else). Be honest and tell them if you need to tell someone else.

While you listen and talk to the person about how they are feeling, you should never promise to keep everything they are telling you a secret.

If you believe that the person self-harming is in need of medical attention or has taken an overdose then you will need to tell someone. Primarily the child protection officer but also potentially a teacher, youth worker or parent.

If the person mentions that they are suicidal, you must take it seriously. Establish whether they have a plan in place to complete suicide, and if they do tell a responsible adult (primarily the child protection officer but also a teacher, youth worker etc.), even if they tell you not to. If there is no plan in place it is still worth discussing with one of the aforementioned people. Perhaps suggest that you go to talk to someone together.

In relation to confidentiality, where there is no child protection issue raised, although it is better if parents or a carer are notified and involved to support the young person, each individual case and approach needs to be handled carefully and sympathetically to support the well being of the young person. The decision about involving parents/guardians should be taken into consultation with the young person’s school. If a decision to contact parents/guardians is reached, then the school will make the contact, wherever possible.

In the case of severe self-harm requiring medical intervention/ A&E, parents will be informed immediately, unless it is known that self-harm is symptomatic of abuse in the home, at which point, you may take the decision to make a referral directly to the appropriate authority without informing the parents.

If a member of staff becomes aware of or is alerted to a new or escalated self-harming issue, or a young person discloses new or escalated self-harm, they should make a written report. This report should include the date of the event, what was disclosed, how concerned staff member is about it. A report should be made even if the incident eventually turns out to be an isolated one that was not indicative of a serious underlying emotional or abusive cause.

If a young person suggests there is evidence of self-harm beneath their clothing, a member of staff should accept such statements and must never ask the pupil to remove clothing to reveal wounds/bruises etc. A school nurse or a Doctor may investigate such evidence in a sensitive and appropriate manner in the Health Centre or A&E.

A Health Centre may be a school’s medical office, or a local/nearest Doctors’ surgery.

Regarding and Reporting Incidents of Self-Harm Disclosed to HATW Staff

A Self-Harm Report Form should be completed and will be kept as a record of all incidents in a private locked drawer that only the Directors will have access to.

The Directors may review this record to identify any trends or other areas of concern. They may also show the form to third parties such as the NSPCC, Police, School or Social Services but only in line with the Data Protection Policy.

 

Self-Care for Staff

Finally make sure that you take care of yourself. It is hard dealing with the fact that someone you know or are in regular contact with is self-harming. You shouldn’t be afraid of seeking some support for yourself. Remember, you will be able to better support the person who is self-harming if you are taking care of yourself too.

Should you require additional support or someone else to talk to, either contact an outside listening service, or get in touch with the voluntary counsellor for Heads Above The Waves, and request time to talk through your concerns. Conversations with the voluntary counsellor are bound by the same confidentiality and privacy guidelines as all Heads Above The Waves work.

 

Useful Resources and Helplines

National Self-Harm Network – 0800 622 6000 – nshn.co.uk – support@nshn.co.uk
The Mix – 0808 808 4994 – themix.org.uk
ChildLine – 0800 1111 – childline.org.uk
Samaritans – 116 123 – samaritans.org – jo@samaritans.org
NightLine – nightline.ac.uk/nightlines to find your local branch
SupportLine – 01708 765 200 – supportline.org.uk
CALL Helpline – 0800 132 737 – callhelpline.org.uk – Text “Help” to 81066
MIND Info Line – 0300 123 3393 – mind.org.uk
SANE – 0300 3047000 – sane.org.uk

Monitoring and Review

This policy will be reviewed annually (or earlier if necessary) by the Directors.

Policy Statement

Heads Above The Waves is a Community Interest Company that, through merchandise, workshops, online content, and research, aims to provide benefit to anyone struggling to cope with the pressures of everyday life, with a particular focus on young people in Wales and England from 11-25 years old demonstrating harmful behaviours to themselves.

This policy applies to all staff, including senior managers, paid staff, volunteers, sessional works, agency staff, students or anyone working on behalf of Heads Above The Waves.

Throughout this policy, the terms “child” and “young person” shall refer to anyone under the age of 18.

The purpose of this policy

To protect children and young people who receive the services of Heads Above The Waves. This includes children of any adults who use our services;
To provide staff and volunteers with the overarching principles that guide our approach to child protection.
Heads Above The Waves believes that a child or young person should never experience abuse of any kind, including face to face, and via the use of digital technology. We have a responsibility to promote the welfare of all children and young people to keep them safe. We are committed to practise a way that protects them.

Legal framework

This policy has been drawn up on the basis of law and guidance that seeks to protect children, namely:

• Children Act 1989
• United Convention of the Rights of the Child 1991
• Data Protection Act 1998
• Sexual Offences Act 2003
• Children Act 2004
• Protection of Freedoms Act 2012
• Relevant government guidance on safeguarding children

We recognise that:

• the welfare of the child is paramount, as enshrined in the Children Act 1989
• all children, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity, have a right to equal protection from all types of harm or abuse
• some children may have additional needs, especially around communication, due to disability and/or ethnic background
• some children are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues
• working in partnership with children, young people, their parents, carers and other agencies is essential in promoting young people’s welfare.

We will seek to keep children and young people safe by:

• valuing them, listening to and respecting them
• adopting child protection practices through procedures and a code of conduct for staff and volunteers
• developing and implementing an effective e-safety policy and related procedures
• providing effective management for staff and volunteers through supervision, support and training
• recruiting staff and volunteers safely, ensuring DBS checks are made for staff committing to regular and ongoing workshop assistance with Heads Above The Waves before the workshops commence.
• sharing information about child protection and good practice with children, parents, staff and volunteers
• sharing concerns with agencies who need to know, and involving parents and children appropriately

We are committed to reviewing our policy and good practice continually.

Steps Taken to Ensure Child Protection

Any workers/volunteers/employees/staff working on behalf of Heads Above The Waves will be required to produce a valid and up to date DBS Certificate, and may be subject to an interview carried out by the board of directors. Anyone working with children on behalf of Heads Above The Waves will be issued with a copy of the child protection policy, and any other relevant documentation.

Definitions of Abuse

Heads Above The Waves identifies 5 different forms of child abuse, all of which can cause long term damage to a child. Most types of child abuse can take one or several of the below forms, as defined by the NSPCC.

Sexual Abuse

A child is sexually abused when they are forced or persuaded to take part in sexual activities. This doesn’t have to be physical contact, and it can happen online. Sometimes the child won’t understand that what’s happening to them is abuse. They may not even understand that it’s wrong.

There are two different types of child sexual abuse: contact abuse and non-contact abuse. Contact abuse is where an abuser makes physical contact with a child, including penetration. Non-contact abuse covers other acts where the abuser doesn’t touch the child, such as grooming, exploitation, persuading children to perform sexual acts over the internet and flashing.

Child sexual abuse involves:

• Sexual touching of any part of the body, clothed or unclothed, including using an object
• Assault by penetration, including rape or penetration of the mouth with an object or part of the body
• Encouraging a child to engage in sexual activity, including:
  • Sexual acts with someone else
  • Making a child strip or masturbate
  • Intentionally engaging in sexual activity in front of a child
• Not taking proper measures to prevent a child being exposed to sexual activities by others
• Meeting a child following sexual grooming, with the intent of abusing them
• Taking, making, allowing someone to take, distributing, showing or advertising indecent images of children
• Paying for the sexual services of a child
• Encouraging a child into prostitution or pornography
• Encouraging a child to send sexually explicit content, including photographs, videos, or via webcams, messages or across any social media platforms.
• Showing a child images of sexual activity, including photographs, videos or via webcams.

Physical Abuse

Physical abuse is deliberately hurting a child causing injuries such as bruises, broken bones, burns, or cuts. It isn’t accidental – children who are physically abused suffer violence such as being hit, kicked, poisoned, burned, slapped, or having objects thrown at them, resulting in physical harm to the child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.

Online Abuse

Online abuse is any type of abuse that happens on the web, however it is accessed, including through social networks, playing online games or using mobile phones. Children and young people may experience cyberbullying, grooming, sexual abuse, sexual exploitation, or emotional abuse.

Children can be at risk of online abuse from people they know, as well as from strangers. Online abuse may be part of abuse that is taking place in the real world, or it may be that the abuse only happens online.

Neglect

Neglect is the ongoing failure to meet a child’s basic needs. A child may be left hungry or dirty, without adequate clothing, shelter, supervision, medical or health care. Neglect can also be defined as a child being put in danger, or not protected from physical or emotional harm. They may not get the love, care and attention they need from their parents. Neglect may involve not ensuring adequate supervision, including access to inadequate care givers. Neglect happens when parents or carers can’t or won’t meet a child’s needs. This may be because they don’t have the skills or support needed, or it may be due to other problems such as mental health issues, drug and alcohol problems, or poverty.

Neglect can be broadly split into 4 types:

Physical neglect

Failing to provide for a child’s basic needs such as food, clothing or shelter. Failing to adequately supervise a child or provide for their safety.
Educational neglect
Failing to ensure a child receives an education.

Emotional neglect

Failing to meet a child’s needs for nurture and stimulation, perhaps by ignoring, humiliating, intimidating or isolating them.

Medical neglect

Failing to provide appropriate health care, including dental care, and refusal of care or ignoring medical recommendations.

Emotional Abuse

Emotional abuse is the ongoing emotional maltreatment or emotional neglect of a child.

Emotional abuse includes:

• humiliating or constantly criticising a child
• threatening, shouting at a child or calling them names
• making the child the subject of jokes or using sarcasm to hurt a child
• blaming, scapegoating
• making a child perform degrading acts
• not recognising a child’s own individuality, trying to control their lives
• pushing a child too hard or not recognising their limitations
• exposing a child to distressing events or interactions such as domestic abuse or drug taking
• failing to promote a child’s social development
• not allowing them to have friends
• persistently ignoring them
• being absent
• manipulating a child
• never saying anything kind, expressing positive feelings or congratulating a child on success
• never showing any emotions in interactions with a child (also known as emotional neglect).

Recognising Abuse

Abuse may be bought to your attention when:

• A child might make a direct disclosure about him or herself
• A child might make a direct disclosure about another child
• A child might offer information that is worrying but not a direct disclosure
• A member of staff might be concerned about a child’s appearance or behaviour or about the behaviour of a parent or carer towards a child
• A parent or carer might make a disclosure about abuse that a child is suffering or at risk of suffering
• A parent might offer information about a child that is worrying but not a direct disclosure.

Signs that a child may be experiencing abuse include if she or he is:

• frequently dirty, hungry, or inadequately dressed
• left in unsafe situations or without medical attention
• constantly “put down”, insulted, sworn at, or humiliated
• seemingly afraid of parents, carers, or an authority figure
• severely bruised or injured, particularly in “hidden” areas, for example, the torso
• displaying sexual behaviour which doesn’t seem appropriate for their age
• growing up in a home where there is domestic violence
• living with parents or carers involved in serious drug or alcohol abuse.

This list is by no means comprehensive.

It is the duty and responsibility of all staff, volunteers, or workers, working with young people through Heads Above The Waves to be vigilant in spotting these signs, and take the appropriate steps, as outlined below.

When a Child Discloses Abuse

• Reassure the child that telling someone about it was the right thing to do.
• Tell the child that you now have to do what you can to keep them (or another child who is the subject of the allegation) safe.
• Let the child know what you are going to do next and who else needs to know about it.
• Let the child tell their whole story. Don’t try to investigate or quiz the child, but make sure that you’re clear as to what they are saying.
• Keep a record of everything the child says, using their own words as much as possible.
• Ask the child what they would like to happen as a result of what has been said, but don’t make or infer promises you can’t keep.
• Do NOT ask the child to repeat their account of events to anyone.
• Give the child the ChildLine phone number: 0800 1111
• If a disclosure happens in a school/ workshop setting then the institute’s child protection officer will be informed. We will keep the young person informed about this action.

Helping a Child in Immediate Danger or Need of Emergency Medical Treatment

• If the child is in immediate danger and is with you, remain with him/her and call the police on 999.
• If the child is elsewhere, contact the police and explain the situation to them.
• If they needs emergency medical attention, call an ambulance, and while you are waiting for it to arrive, get help from a first aider.
• If a first aider is not available, use any first aid knowledge that you may have yourself to help the child.
• You also need to contact your supervisor/manager or named person for child protection (Hannah Morgan for Heads Above The Waves) and let them know what is happening.

A decision will need to be made about who should inform the child’s family and the local authority children’s social care department, and when they should be informed. If you have involved the police and/or the health services, they should be part of this decision. Consider the welfare of the child in your decision making as the highest priority.

Issues that will need to be taken into account are:

• the child’s wishes and feelings
• the parent’s right to know (unless this would place the child or someone else in danger, or would interfere with a criminal investigation)
• the impact of telling or not telling the parent
• the current assessment of the risk to the child and the source of that risk
• any risk management plans that currently exist

Making a Referral

A referral involves giving Social Services or the Police information about concerns relating to an individual or family in order that enquiries can be undertaken by the appropriate agency followed by any necessary action.

In certain cases the level of concern will lead straight to a referral without external consultation being necessary.

Parents/carers should be informed if a referral is being made unless the parent/carer is the cause for concern.
If your concern is about abuse or risk of abuse from a family member or someone known to the children, you should make a telephone referral to your local Social Services Office.

However, inability to inform parents for any reason should not prevent a referral being made. It would then become a joint decision with Social Services about how and when the parents should be approached and by whom.

If your concern is about abuse or risk of abuse from someone NOT known to the child or child’s family, you should make a telephone referral directly to the police and consult with the parents.

Information Required

Be prepared to give as much of the following information as possible (in emergency situations all of this information may not be available). Unavailability of some information should not stop you making a referral.

• Your name, telephone number, position and request the same of the person to whom you are speaking
• The child’s full name and address, telephone number of family, date of birth of child and siblings
• Gender, ethnicity, first language, any special needs of the child
• Names, dates of birth and relationship of household members and any significant others
• The names of professionals known to be involved with the child/family eg: GP, Health Visitor, School
• The nature of the concerns; and foundation for them
• An opinion on whether the child may need urgent action to make them safe
• Your view of what appears to be the needs of the child and family
• Whether the consent of a parent with parental responsibility has been given to the referral being made

Action to be taken following the referral

• Ensure that you keep an accurate record of your concern(s) made at the time.
• Put your concerns in writing to Social Services following the referral (within 48 hours).
• Accurately record the action agreed or that no further action is to be taken and the reasons for this decision.

Keeping a Record of Your Concerns

Use the reporting form to record the concern and how it is dealt with. The relevant sections of the form should be completed and signed at each stage of the procedure. It can be used to forward information to the statutory child protection authorities if a referral to them is needed.

The form should be signed and dated by all those involved in its completion and kept confidentially on the child’s file, in a locked drawer or on a secure online server. The name of the person making the notes should be written alongside each entry.

If a Child is Unhappy with the Actions Taken

Heads Above The Waves will, wherever possible, keep up to date with the progress of a referral, and the actions taken as a result of it. This will be either in person, if regular contact with the child remains, or through a third party (e.g. a school). If a child is not happy with the service provided or the actions taken, Heads Above The Waves will commit to resolving this by either taking further action, or supporting the child to make an official complaint.

Allegations Against a Member of Staff

Heads Above The Waves will take steps to ensure that staff/workers are not vulnerable to false allegation. This includes developing the following code of conduct:

• A worker will never work with a child or young person unless another member of staff or professional is in the same building.
• All one-to-one work with children or young people will take place with visual access into the room.
• Heads Above The Waves staff must not touch or restrain young people, other than in exceptional circumstances, where not doing so could result in that young person, or someone else, being injured. Examples may include:
  • Holding back a young person if they are stepping out in front of vehicle
  • Any first aid action required
  • Restraint to prevent a young person seriously harming themselves

Any restraint used to prevent injury to a young person must been deemed ‘reasonable’. Staff should balance any decision to use physical restraint against the likelihood of serious harm to the young person if they do not do so, also taking into account the worker’s own safety.

Staff should not get involved physically in any fight between young people, but should seek immediate assistance from other colleagues. It is generally more effective to diffuse a volatile situation by using an authoritative tone, than by becoming involved at a physical level.

Heads Above The Waves will fully support and protect anyone, who in good faith, reports their concern that a member of staff is, or may be, abusing a child or young person. Where there is a complaint about a member of staff allegedly abusing children, there will be a disciplinary or misconduct investigation, which will involve the member of staff being suspended on full pay (if applicable), for the duration of the investigation. The investigation will be carried out by the Directors – unless it is felt that this would be a conflict of interest – in association with any affiliated bodies. The investigation will seek to determine the facts of the event leading to the allegation, and then the appropriate action to be taken as a result. Information will be shared within the service and Heads Above The Waves on a need to know basis only.

There may also be:

• A criminal investigation
• A child protection investigation

Useful Contact Details

Named person for child protection: Hannah Morgan – 07792365362 – Hannah@hatw.co.uk
South Wales Police non-urgent crime: 101
South Wales Police general enquiries: 01656 655 555
Cardiff Children Social Care Department: 02920 536490
NSPCC Helpline: 0808 800 5000 – help@nspcc.org.uk
ChildLine: 0800 1111 (textphone: 0800 400 222) – childline.org.uk

Training

All staff in Heads Above The Waves services should read this policy and sign to record having done so, and that they understand their responsibilities in relation to safeguarding children. All staff should attend Safeguarding Children training and regular refresher training.Reporting Child Protection Concerns

Heads Above The Waves needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact. This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures Heads Above The Waves:

• Complies with data protection law and follow good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach

Data Protection Law

The Data Protection Act 1998 describes how organisations — including Heads Above The Waves — must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

• Be processed fairly and lawfully
• Be obtained only for specific, lawful purposes
• Be adequate, relevant and not excessive
• Be accurate and kept up to date
• Not be held for any longer than necessary
• Processed in accordance with the rights of data subjects
• Be protected in appropriate ways
• Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

Policy Scope

This policy applies to:

• The head office of Heads Above The Waves
• All branches of Heads Above The Waves
• All staff and volunteers of Heads Above The Waves
• All contractors, suppliers and other people working on behalf of Heads Above The Waves

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• any other information relating to individuals

Data Protection Risks

This policy helps to protect Heads Above The Waves from some very real data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with Heads Above The Waves has some responsibility for ensuring data is collected, stored and handled appropriately. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles. However, these people have key areas of responsibility:

The Board of Directors is ultimately responsible for ensuring that Heads Above The Waves meets its legal obligations.

The Data Protection Officer is responsible for:

• Keeping the board updated about data protection responsibilities, risks and issues.
• Continually reviewing all data protection procedures and related policies.
• Arranging data protection training and advice for the people covered by this policy.
• Handling data protection questions from staff and anyone else covered by this policy.
• Dealing with requests from individuals to see the data Heads Above The Waves holds about them (also called ‘subject access requests’).
• Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

The IT Manager is responsible for:

• Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
• Performing regular checks and scans to ensure security hardware and software is functioning properly.
• Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

The Marketing Manager is responsible for:

• Approving any data protection statements attached to communications such as emails and letters.
• Addressing any data protection queries from journalists or media outlets like newspapers.
• Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General Staff Guidelines

• The only people able to access data covered by this policy should be those who need it for their work.
• Data should not be shared informally.
• Heads Above The Waves will provide training to all employees to help them understand their responsibilities when handling data.
• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
• In particular, strong passwords must be used and they should never be shared.
• Personal data should not be disclosed to unauthorised people, either within the company or externally.
• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data Storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
• Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

• Data should be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like a CD or USB hard drive), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently. Those backups should be tested regularly.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data should be protected by approved security software and a firewall.

Data Use

Personal data is of no value to Heads Above The Waves unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
• Personal data should never be transferred outside of the European Economic Area.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data Accuracy

The law requires Heads Above The Waves to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort Heads Above The Waves should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
Heads Above The Waves will make it easy for data subjects to update the information Heads Above The Waves holds about them. For instance, via the company website.
Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.

Subject Access Requests

If an individual contacts the company requesting the information held about them by Heads Above The Waves, this is called a subject access request. All individuals who are the subject of personal data held by Heads Above The Waves are entitled to:

• Ask what information the company holds about them and why
• Ask how to gain access to it
• Be informed how to keep it up to date
• Be informed how the company is meeting its data protection obligations

Subject access requests from individuals should be made by email, addressed to the data controller at admin@hatw.co.uk. The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing Data for Other Reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Heads Above The Waves will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing Information

Heads Above The Waves aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How the data is being used
• How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company. This is available on request. A version of this statement is also available on the company’s website.

1. Heads Above The Waves recognises that discrimination and victimisation is unacceptable and that it is in the interests of the Company and its employees and volunteers to utilise the skills of the total workforce. It is the aim of the organisation to ensure that no employee , volunteer, or applicant receives less favourable facilities or treatment (either directly or indirectly) in recruitment or employment on grounds of:

• Age
• Disability
• Gender/gender reassignment/ gender non-conforming/ gender fluidity
• Marital or civil partnership status
• Pregnancy/ maternity
• Race (including colour, nationality, ethnic or national origins)
• Religion, beliefs, or political opinion
• Mental health issues
• Sex, or sexual orientation
• Having or not having dependants

These will be referred to as Protected Characteristics.

2. Our aim is that our workforce will be truly representative of all sections of society and each employee feels respected and able to work to the best of their abilities.

3. We oppose all forms of unlawful and unfair discrimination or victimisation. To that end the purpose of this policy is to provide equality and fairness for all in our employment.

4. All employees, whether part-time, full-time, temporary or voluntary will be treated fairly and with respect. Selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability. All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the organisation.

5. This policy and the associated arrangements shall operate in accordance with statutory requirements. In addition, full account will be taken of any guidance or Codes of Practice issued by the Equality and Human Rights Commission, and Government Departments, and any other statutory bodies.

Rights of Disabled People and People Dealing with Mental Health Issues

Heads Above The Waves attaches particular importance to the needs of two specific groups: disabled people and people dealing with mental health issues.

Under the terms of this policy, managers are required to:

• Make reasonable adjustment to maintain the services of an employee who is disabled, or becomes disabled. For example: provision of training, provision of special equipment, and reduced working hours. (NB: Managers are expected to seek advice and guidance from external agencies to maintain disabled people in employment);
• Make reasonable adjustments to support and protect an employee dealing with mental health issues for example, offering the services of the organisation’s counsellor, supporting the requests of the individual, and structuring their work schedule around what’s best for them, within reason;
• Include disabled people and people dealing with mental health issues in training/ development programmes;
• Give full and proper consideration to disabled people and people dealing with or who have a past of mental health issues by making reasonable adjustments for their particular aptitudes and abilities to allow them to be able to do their job.

Our Commitment

Heads Above The Waves is opposed to all forms of unlawful and unfair discrimination. We believe in human rights for all those connected with this organisation and all members of society. No action shall be taken against them by any person connected with Heads Above The Waves which would devalue their contribution to society and to this organisation, or lead to a loss of their own self- respect, or respect for them from others.

To create an environment in which individual differences and the contribution of all our staff are recognised and valued.
Every employee is entitled to a working environment that promotes dignity and respect to all. No form of intimidation, bullying or harassment whether physical, mental or verbal will be tolerated.
Training, development and progression opportunities are available to all staff.
To promote equality in the workplace which we believe is good management practice and makes sound business sense.
We will review all our employment practices and procedures to ensure fairness at least every year.
Breaches of our equality policy will be regarded as misconduct and could lead to disciplinary proceedings.
Responsibility for making sure that Heads Above The Waves fulfils its obligations under this Policy rests with Hannah Morgan, Head of Human Resources.

Who does the Policy apply to?

All individuals within this organisation are responsible for compliance with this Policy, and for the positive attitude it requires. All external persons connected with Heads Above The Waves are encouraged to hold the same responsibility and commitment.

Responsibilities of Management

Responsibility for ensuring the effective implementation and operation of the arrangements will rest with the Directors. They will ensure that they and their staff operate within this policy and arrangements, and that all reasonable and practical steps are taken to avoid discrimination. Each Director will ensure that:

• All their staff are aware of the policy and the arrangements, and the reasons for the policy;
• Grievances concerning discrimination are dealt with properly, fairly and as quickly as possible’
• Proper records are maintained.

Responsibilities of Staff

Responsibility for ensuring that there is no unlawful discrimination rests with all staff and the attitudes of staff are crucial to the successful operation of fair employment practices. In particular, all members of staff should:

• Comply with the policy and arrangements;
• Not discriminate in their day to day activities or induce others to do so;
• Not victimise, harass or intimidate other staff or groups who have, or are perceived to have one or more of the aforementioned protected characteristics.
• Ensure no individual is discriminated against or harassed because of their association with another individual who has one or more of the protected characteristics.
• Inform their manager if they become aware of any discriminatory practice.

Third Parties

Third-party harassment occurs where a Heads Above The Waves employee is harassed, and the harassment is related to a protected characteristic, by third parties such as service users, clients or customers. Heads Above The Waves will not tolerate such actions against its staff, and the employee concerned should inform their manager/ one of the Directors at once that this has occurred. Heads Above The Waves will fully investigate and take all reasonable steps to ensure such harassment does not happen again.

What will we do?

We will make sure that all our staff and sub-contractors are aware of our Equal Opportunities Policy, and where applicable will make them aware of their responsibilities.
All job applicants, employees and others who work for and/or with us will be treated fairly and will not be discriminated against on any of the grounds named above. Decisions about recruitment and selection, promotion, training or any other benefit will be made objectively and without unlawful discrimination.

We will maintain information on staff who have been involved in certain key policies: Disciplinary, Grievance and Bullying & Harassment.

Related Policies and Arrangements

All employment policies and arrangements have a bearing on equality of opportunity. Heads Above The Waves policies will be reviewed regularly and any discriminatory elements removed.

How will we know if the Policy is working?

The working of the Equal Opportunities Policy will be monitored by the Hannah Morgan, Head of Human Resources on an annual basis, or sooner if necessary, by collecting and analysing information on employees, about the Protected Characteristics.

If monitoring shows that Heads Above The Waves, or areas within it, are not representative, or that sections of our workforce are not progressing properly within the Organisation, then an action plan will be developed to address these issues. This will include a review of recruitment and selection procedures, policies and practices as well as consideration of taking legal Positive Action.

Dealing with complaints

It is recognised that many individuals may be unwilling to make a complaint regarding equal opportunities, for a variety of reasons, including:

• Fear that others will consider that behaviour trivial
• Fear of retaliation and/or public humiliation
• Fear that the complaint will not be taken seriously

Such concerns may make an individual choose to leave the organisation, or change their job. Heads Above The Waves regards this as unacceptable. It is important that everyone working with us should feel able to raise concerns without fear and in the knowledge that their complaint will be taken seriously.
All complaints will receive prompt attention and will be properly investigated. We will seek to resolve them as quickly as possible. Discrimination and victimisation will be treated as disciplinary offences and they will be dealt with by the directors.

Sometimes it may be possible for an employee affected by the behaviour of another simply to ask the harasser to stop, or make it clear that the behaviour is unwelcome. If this is appropriate then the employee should do this. However, such an approach may not be appropriate and employees should feel able to raise matters at any time with their line manager or with Hannah Morgan, Head of Human Resource.