Buddies Clubs & Services

Policy on Disclosure Information

General principles
Buddies Clubs & Services complies fully with the Code of Practice, issued by Scottish Ministers, regarding the correct handling, holding and destroying Disclosure information provided by Disclosure Scotland under Part V of the Police Act 1997, for the purposes of assessing applicants’ suitability for positions of trust.  It also complies fully with the Data Protection Act 2018 and other relevant legislation relating to the safe handling, use, storage, retention and disposal of Disclosure information and has a written policy on these matters. This policy is available to anyone who wishes to see it on request.

Usage
We use Disclosure information only for the purpose for which it has been provided.  The information provided by an individual for a position within Buddies Club is not used or disclosed in a manner incompatible with the purpose. We process personal data only with the express consent of the individual.  We notify the individual of any non-obvious use of the data, including further disclosure to a third party, identifying the Data Controller, the purpose for the processing, and any further relevant information.

Handling
Buddies Clubs & Services recognises that, under section 124 of the Police Act 1997, it is a criminal offence to disclose Disclosure information to any unauthorised person.  We therefore only pass Disclosure information to those who are authorised to see it in the course of their duties.  Buddies Clubs & Services will not disclose information provided under section 115 (8) of the Act, namely information which is not included in the Disclosure, to the applicant.

Retention
We do not keep Disclosures or Disclosure information for any longer than is required after a recruitment (or any other relevant) decision has been taken. In general, this is no longer than six months.  This is to allow for the resolution of any disputes or complaints.  Disclosure information will only be retained for longer than this period in exceptional circumstances, and in consultation with Disclosure Scotland.  The same conditions relating to secure storage and access will apply during any such period.

Disposal
Once the retention period has elapsed, we will ensure that Disclosure information is immediately destroyed in a secure manner i.e. by shredding, pulping or burning.  Buddies Clubs & Services will not keep Disclosure information which is awaiting destruction in any insecure receptacle (e.g. a waste bin or confidential waste sack).  We will not retain any image or photocopy or any other form of the Disclosure information.  We will, however, keep a record of the date of issue of the Disclosure, the name of the subject, the Disclosure type, the position for which the Disclosure was requested, the unique reference number of the Disclosure and details of the recruitment decision taken.

Umbrella Bodies
Before acting as an Umbrella Body (i.e. a body which countersigns applications for standard or enhanced Disclosures on behalf of another organisation), Buddies Clubs & Services will take all reasonable steps to ensure that the organisation on whose behalf we are acting can comply with the Scottish Code of Practice, and in full accordance with this policy.  We will also take all reasonable steps to satisfy ourselves that they will handle, use, store, retain, and dispose of Disclosure information in full compliance with the Code of Practice, and in full accordance with this policy.  We will also ensure that anybody or individual at whose request applications for Disclosures are countersigned, has such a written policy and, if necessary, will provide a model policy for that body or individual to use or adapt for this purpose.