Key Policy and Procedure Documents
GDPR Policy
Daybreak Oxford is committed to following the principles set out in the Data Protection Act 2018 and the advice of the Information Commissioner’s Office (ICO).
The overall responsibility for Data Protection lies with the Charity’s Board of Trustees, who have appointed officers to ensure the correct compliance:
- Data Controller (Chair of the Trustees): Will be responsible for ensuring compliance throughout the organisation and will be responsible for investigating any data breaches
- Marketing and Communications Officer (Head Fundraiser): Will ensure that all communications and marketing materials, contain the correct data protection information and records of permissions to hold data remain current.
- Internal Data Processors (any authorised member of staff responsible for collecting and recording personal data), must ensure that the standards and principles set out in this Policy are maintained.
Privacy Statement:
Daybreak will ensure that personal information is both protected and secure. We promise we will not pass it on to any other organisation without permission, unless under exceptional circumstances where there is a legal obligation. We will only collect data which is necessary, for operational and commercial purposes, data both digital and in paper form, will be safely stored. We will not store or retain any personal information any longer than is necessary. We will also ensure that personal data is both accurate and remains current.
Where it is necessary to share data with other organisations such as transport providers, they will become Data Processors on our behalf. A specific written contract will be provided, signed by both parties, stating that the Data Processor will abide by Daybreak’s Data Protection Policy and standards. In addition, they will protect all personal data with the same level of security and care.
Daybreak will obtain relevant permissions to hold personal data, we will ensure that we inform individuals why we are collecting and storing their data. We will also clearly inform them how they may retract their permission at any time.
Any communications relating to Daybreak Clubs will only be sent where the correct permission is in place. Newsletters and fundraising communications will also be sent only with the correct permission, as defined in the rules of the Fundraising Regulations 2018 relating to direct marketing.
Daybreak currently uses Microsoft Office 365 with One Drive, plus Dropbox, for storage and has ensured as far as reasonably practical, that the storage facilities for these organisations provide robust protection in line with GDPR.
Several employees of Daybreak work from home and have access to stored data from their laptops. Remote workers will be trained in the requirements of GDPR and will be given guidance to ensure the security and integrity of any personal data used or processed in locations outside of Daybreak premises. Some authorised employees may also use their own devices to access and process personal data, and further instruction will be given on how to ensure compliance with the organisation’s Data Protection Policy and Procedure.
Any breaches of personal data will be investigated immediately by the Chair. Where appropriate the Charity’s Trustees/Directors will be fully informed of the breach. An assessment will be made of the impact of the breach and if it is determined necessary, the ICO will be informed.
The overall responsibility for Data Protection lies with the Charity’s Board of Trustees, who have appointed officers to ensure the correct compliance:
- Data Controller (Chair of the Trustees): Will be responsible for ensuring compliance throughout the organisation and will be responsible for investigating any data breaches
- Marketing and Communications Officer (Head Fundraiser): Will ensure that all communications and marketing materials, contain the correct data protection information and records of permissions to hold data remain current.
- Internal Data Processors (any authorised member of staff responsible for collecting and recording personal data), must ensure that the standards and principles set out in this Policy are maintained.
Privacy Statement:
Daybreak will ensure that personal information is both protected and secure. We promise we will not pass it on to any other organisation without permission, unless under exceptional circumstances where there is a legal obligation. We will only collect data which is necessary, for operational and commercial purposes, data both digital and in paper form, will be safely stored. We will not store or retain any personal information any longer than is necessary. We will also ensure that personal data is both accurate and remains current.
Where it is necessary to share data with other organisations such as transport providers, they will become Data Processors on our behalf. A specific written contract will be provided, signed by both parties, stating that the Data Processor will abide by Daybreak’s Data Protection Policy and standards. In addition, they will protect all personal data with the same level of security and care.
Daybreak will obtain relevant permissions to hold personal data, we will ensure that we inform individuals why we are collecting and storing their data. We will also clearly inform them how they may retract their permission at any time.
Any communications relating to Daybreak Clubs will only be sent where the correct permission is in place. Newsletters and fundraising communications will also be sent only with the correct permission, as defined in the rules of the Fundraising Regulations 2018 relating to direct marketing.
Daybreak currently uses Microsoft Office 365 with One Drive, plus Dropbox, for storage and has ensured as far as reasonably practical, that the storage facilities for these organisations provide robust protection in line with GDPR.
Several employees of Daybreak work from home and have access to stored data from their laptops. Remote workers will be trained in the requirements of GDPR and will be given guidance to ensure the security and integrity of any personal data used or processed in locations outside of Daybreak premises. Some authorised employees may also use their own devices to access and process personal data, and further instruction will be given on how to ensure compliance with the organisation’s Data Protection Policy and Procedure.
Any breaches of personal data will be investigated immediately by the Chair. Where appropriate the Charity’s Trustees/Directors will be fully informed of the breach. An assessment will be made of the impact of the breach and if it is determined necessary, the ICO will be informed.
Whistleblowing Policy
Objectives:
All staff have a duty to ensure standards of quality care by raising concerns regarding wrongdoing or malpractice. This main objective of this policy is to provide the means of ensuring that staff can confidentially raise genuine concerns of malpractice and/or misconduct through appropriate means, at the earliest point without fear of reprisal.
Policy:
Daybreak is committed to the principals of whistleblowing and supporting and providing mechanisms for employees to fulfil their duty without fear of any reprisals.
Daybreak is committed to a high standard of care, to honesty, openness and decency in all its activities. It is recognised that Resident safety must come first at all times and whilst it can be difficult for staff to raise concerns about the practice of others, including managers, the implications of not raising those concerns are potentially very serious for Daybreak, its employees and most importantly for those receiving our services.
Daybreak encourages a free and open culture in its dealings with its employees and all people with whom it engages in business and legal relations. In particular, Daybreak recognises that effective and honest communication is essential if any wrongdoing or malpractice is to be effectively dealt with and the organisation’s success ensured.
Daybreak believes raising concerns/speaking up is important to ensure the safety of our Residents, employees and public safety.
Daybreak recognises staff members are likely to be the first to realise that there may be something seriously wrong within the organisation but may feel that speaking up would be disloyal to colleagues or their employer - who may under certain circumstances face criminal charges. They may also fear harassment or victimisation and fear for a loss of job or reduction in work hours.
Daybreak will not tolerate the ill treatment including any bullying or harassment of anyone raising a concern. We will ensure that any individual who raises a concern, can do so confidentially in line with the Public Interest Disclosure Act 1998 (PIDA).
Daybreak will ensure that any individual who raises a genuine concern under the Whistleblowing Policy and Procedure will not be at risk of termination of their employment or suffer any form or reprisal which includes but not limited to 'loss or reduction of hours' or 'changes to regular working patterns' because of it.
Daybreak will support and enable members of staff and volunteers to speak out regarding misconduct and malpractice through a structured and regularly reviewed process.
Daybreak recognise that whistleblowing concerns are often raised when employees do not feel their earlier concerns have been listened to or that any action has been taken.
Daybreak will put in place mechanisms for our staff to discuss concerns when they arise and endeavour to give feedback on any actions if confidentiality will not be breached.
All staff have a duty to ensure standards of quality care by raising concerns regarding wrongdoing or malpractice. This main objective of this policy is to provide the means of ensuring that staff can confidentially raise genuine concerns of malpractice and/or misconduct through appropriate means, at the earliest point without fear of reprisal.
Policy:
Daybreak is committed to the principals of whistleblowing and supporting and providing mechanisms for employees to fulfil their duty without fear of any reprisals.
Daybreak is committed to a high standard of care, to honesty, openness and decency in all its activities. It is recognised that Resident safety must come first at all times and whilst it can be difficult for staff to raise concerns about the practice of others, including managers, the implications of not raising those concerns are potentially very serious for Daybreak, its employees and most importantly for those receiving our services.
Daybreak encourages a free and open culture in its dealings with its employees and all people with whom it engages in business and legal relations. In particular, Daybreak recognises that effective and honest communication is essential if any wrongdoing or malpractice is to be effectively dealt with and the organisation’s success ensured.
Daybreak believes raising concerns/speaking up is important to ensure the safety of our Residents, employees and public safety.
Daybreak recognises staff members are likely to be the first to realise that there may be something seriously wrong within the organisation but may feel that speaking up would be disloyal to colleagues or their employer - who may under certain circumstances face criminal charges. They may also fear harassment or victimisation and fear for a loss of job or reduction in work hours.
Daybreak will not tolerate the ill treatment including any bullying or harassment of anyone raising a concern. We will ensure that any individual who raises a concern, can do so confidentially in line with the Public Interest Disclosure Act 1998 (PIDA).
Daybreak will ensure that any individual who raises a genuine concern under the Whistleblowing Policy and Procedure will not be at risk of termination of their employment or suffer any form or reprisal which includes but not limited to 'loss or reduction of hours' or 'changes to regular working patterns' because of it.
Daybreak will support and enable members of staff and volunteers to speak out regarding misconduct and malpractice through a structured and regularly reviewed process.
Daybreak recognise that whistleblowing concerns are often raised when employees do not feel their earlier concerns have been listened to or that any action has been taken.
Daybreak will put in place mechanisms for our staff to discuss concerns when they arise and endeavour to give feedback on any actions if confidentiality will not be breached.
Safeguarding Policy
Objectives:
The main objectives of this policy are:
To ensure that all staff & volunteers working for or on behalf of Daybreak Oxford fully understand their responsibilities in relation to safeguarding adults at risk, and they know who to escalate concern to within Daybreak Oxford.
To manage the safety and well-being of adults in line with the Six Principles of Safeguarding.
To identify lessons to be learned from cases where adults have experienced abuse or neglect.
Support and empower each of our Clients to make choices and to have control over how they want to live their own lives. This supports the prevention of abuse and neglect occurring in the future which is a key underpinning principle of Making Safeguarding Personal (MSP). Daybreak Oxford intends to take this approach with all safeguarding concerns.
Policy:
Everybody has the right to live a life that is free from harm and abuse. Daybreak Oxford recognises that safeguarding adults at risk of abuse or neglect is everybody's business. Daybreak Oxford aims to ensure that all adults at risk of abuse or neglect are enabled to live and work, be cared for and supported in an environment free from abuse, harassment, violence or aggression. Daybreak Oxford's safeguarding Policies and Procedures will dovetail with the local multi-agency Policy and Procedures, which we understand take precedence over Daybreak Oxford's Policies and Procedures.
We aim to provide services that will be appropriate to the adult at risk and not discriminate because of disability, age, gender, sexual orientation, race, religion, culture or lifestyle. We will make every effort to enable Clients to express their wishes and make their own decisions to the best of their ability - recognising that such self-determination may well involve risk. We will work with Clients and others involved in their care, to ensure they receive the support and protection they may require; that they are listened to and treated with respect (including their property, possessions and personal information) and that they are treated with compassion and dignity at all times.
Daybreak Oxford will follow the Six Principles (outlined below) as set out in guidance to the Care Act 2014:
1. Empowerment
People being supported and encouraged to make their own decisions and informed consent.
2. Prevention
It is better to take action before harm occurs.
3. Proportionality
The least intrusive response appropriate to the risk presented.
4. Protection
Support and representation for those in greatest need.
5. Partnership
Local solutions through services working with their communities. Communities have a part to play in preventing, detecting and reporting neglect and abuse.
6. Accountability
Accountability and transparency in delivering safeguarding.
Daybreak Oxford understands the importance of working collaboratively to ensure that:
The needs and interests of adults at risk are always respected and upheld.
The human rights of adults at risk are respected and upheld.
A proportionate, timely, professional and ethical response is made to any adult at risk who may be experiencing abuse.
All decisions and actions are taken in line with the Mental Capacity Act 2005.
Each adult at risk maintains: Choice and Control, Safety, Health, Quality of Life, Dignity and Respect.
Our robust governance processes will make sure that staff working for and on behalf of Daybreak Oxford recognise and respond to the main forms of abuse which are set out in the Care Act 2014 (Statutory Guidance Chapter 14). This is not an exhaustive list but an illustration as to the sort of behaviour that could give rise to a safeguarding concern:
Physical abuse
Domestic violence
Sexual abuse
Psychological abuse
Financial or Material abuse
Modern Slavery
Discriminatory abuse
Organisational abuse
Neglect and Acts of Omission
Self-neglect
Daybreak Oxford is committed to the principles of Making Safeguarding Personal and aims to ensure that safeguarding is person-led and focused on the outcomes that Clients want to achieve. We will engage Clients in a conversation about how best to respond to their safeguarding situation in a timely way that enhances involvement, choice and control as well as improving quality of life, well-being and safety.
The main objectives of this policy are:
To ensure that all staff & volunteers working for or on behalf of Daybreak Oxford fully understand their responsibilities in relation to safeguarding adults at risk, and they know who to escalate concern to within Daybreak Oxford.
To manage the safety and well-being of adults in line with the Six Principles of Safeguarding.
To identify lessons to be learned from cases where adults have experienced abuse or neglect.
Support and empower each of our Clients to make choices and to have control over how they want to live their own lives. This supports the prevention of abuse and neglect occurring in the future which is a key underpinning principle of Making Safeguarding Personal (MSP). Daybreak Oxford intends to take this approach with all safeguarding concerns.
Policy:
Everybody has the right to live a life that is free from harm and abuse. Daybreak Oxford recognises that safeguarding adults at risk of abuse or neglect is everybody's business. Daybreak Oxford aims to ensure that all adults at risk of abuse or neglect are enabled to live and work, be cared for and supported in an environment free from abuse, harassment, violence or aggression. Daybreak Oxford's safeguarding Policies and Procedures will dovetail with the local multi-agency Policy and Procedures, which we understand take precedence over Daybreak Oxford's Policies and Procedures.
We aim to provide services that will be appropriate to the adult at risk and not discriminate because of disability, age, gender, sexual orientation, race, religion, culture or lifestyle. We will make every effort to enable Clients to express their wishes and make their own decisions to the best of their ability - recognising that such self-determination may well involve risk. We will work with Clients and others involved in their care, to ensure they receive the support and protection they may require; that they are listened to and treated with respect (including their property, possessions and personal information) and that they are treated with compassion and dignity at all times.
Daybreak Oxford will follow the Six Principles (outlined below) as set out in guidance to the Care Act 2014:
1. Empowerment
People being supported and encouraged to make their own decisions and informed consent.
2. Prevention
It is better to take action before harm occurs.
3. Proportionality
The least intrusive response appropriate to the risk presented.
4. Protection
Support and representation for those in greatest need.
5. Partnership
Local solutions through services working with their communities. Communities have a part to play in preventing, detecting and reporting neglect and abuse.
6. Accountability
Accountability and transparency in delivering safeguarding.
Daybreak Oxford understands the importance of working collaboratively to ensure that:
The needs and interests of adults at risk are always respected and upheld.
The human rights of adults at risk are respected and upheld.
A proportionate, timely, professional and ethical response is made to any adult at risk who may be experiencing abuse.
All decisions and actions are taken in line with the Mental Capacity Act 2005.
Each adult at risk maintains: Choice and Control, Safety, Health, Quality of Life, Dignity and Respect.
Our robust governance processes will make sure that staff working for and on behalf of Daybreak Oxford recognise and respond to the main forms of abuse which are set out in the Care Act 2014 (Statutory Guidance Chapter 14). This is not an exhaustive list but an illustration as to the sort of behaviour that could give rise to a safeguarding concern:
Physical abuse
Domestic violence
Sexual abuse
Psychological abuse
Financial or Material abuse
Modern Slavery
Discriminatory abuse
Organisational abuse
Neglect and Acts of Omission
Self-neglect
Daybreak Oxford is committed to the principles of Making Safeguarding Personal and aims to ensure that safeguarding is person-led and focused on the outcomes that Clients want to achieve. We will engage Clients in a conversation about how best to respond to their safeguarding situation in a timely way that enhances involvement, choice and control as well as improving quality of life, well-being and safety.
Harassment Policy
Objectives:
The main objectives of this policy are:
- To ensure staff are aware of the reporting procedure if they have been subjected to bullying and/or harassment.
- To ensure all staff understand what action will amount to bullying and/or harassment of another.
- To enforce Daybreak’s commitment to stamping out any acts of bullying and harassment between members of staff.
- To create an open and inclusive atmosphere in which all members of staff can thrive and feel supported.
Policy:
Daybreak deplores all forms of harassment, including sexual or racial harassment and harassment based on disability, age, gender, gender reassignment, religion or belief, pregnancy or maternity, marital or civil partner status and sexuality and seeks to ensure that the working environment is conducive to all its employees.
The following procedure informs employees of the type of behaviour that is unacceptable and provides employees who are the victims of any form of harassment with a means of redress.
Implementation of the policy is the duty of all staff, particularly managers and supervisors. All employees must comply with this policy. (The organisation encourages and welcomes the support of the recognised trade union(s) in seeking to eradicate harassment of all forms from the workplace).
Under the Equality Act 2010, harassment is unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual.
The Protection from Harassment Act 1997 also makes it unlawful to pursue a course of conduct which you know or ought to know would be harassment, which includes causing someone alarm or distress.
Under the Health and Safety at Work Act 1974 staff are entitled to a safe place and system of work. Individual members of staff may in some cases be legally liable for harassment of colleagues or third parties, and may be ordered to pay compensation by a court or employment tribunal.
The relevant protected characteristics are:
- Race, including colour, nationality, ethnic or national origin
- Sex
- Disability
- Age
- Religion or belief
- Sexual orientation
- Gender re-assignment
- Marital or civil partner status
- Pregnancy or maternity
The main objectives of this policy are:
- To ensure staff are aware of the reporting procedure if they have been subjected to bullying and/or harassment.
- To ensure all staff understand what action will amount to bullying and/or harassment of another.
- To enforce Daybreak’s commitment to stamping out any acts of bullying and harassment between members of staff.
- To create an open and inclusive atmosphere in which all members of staff can thrive and feel supported.
Policy:
Daybreak deplores all forms of harassment, including sexual or racial harassment and harassment based on disability, age, gender, gender reassignment, religion or belief, pregnancy or maternity, marital or civil partner status and sexuality and seeks to ensure that the working environment is conducive to all its employees.
The following procedure informs employees of the type of behaviour that is unacceptable and provides employees who are the victims of any form of harassment with a means of redress.
Implementation of the policy is the duty of all staff, particularly managers and supervisors. All employees must comply with this policy. (The organisation encourages and welcomes the support of the recognised trade union(s) in seeking to eradicate harassment of all forms from the workplace).
Under the Equality Act 2010, harassment is unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual.
The Protection from Harassment Act 1997 also makes it unlawful to pursue a course of conduct which you know or ought to know would be harassment, which includes causing someone alarm or distress.
Under the Health and Safety at Work Act 1974 staff are entitled to a safe place and system of work. Individual members of staff may in some cases be legally liable for harassment of colleagues or third parties, and may be ordered to pay compensation by a court or employment tribunal.
The relevant protected characteristics are:
- Race, including colour, nationality, ethnic or national origin
- Sex
- Disability
- Age
- Religion or belief
- Sexual orientation
- Gender re-assignment
- Marital or civil partner status
- Pregnancy or maternity
Reduced, Suspension or Withdrawal Policy (short form)
Objectives:
There may be occasions or circumstances where it would no longer be appropriate for Daybreak to continue offering support to someone and this might lead to a reduction, suspension or withdrawal of service. The aim of the procedure which follows is to set out the circumstances under which reduction, suspension or withdrawal of service will be invoked. Any reduction, suspension or withdrawal of service will be invoked in line with one of the following principles:
Application
2.1 This Procedure applies at any time when it comes to Daybreak's attention that:
(a) a Beneficiary's behaviour or capability is preventing, or is likely to prevent, Daybreak from complying with its safety or legal requirements.
(b) a Beneficiary's behaviour or capability is, or is likely to be, detrimental to the rights and interests of Daybreak or of others.
(c) a Beneficiary is infringing, or acting contrary to, one or more of the Policies; or
(d) a Beneficiary has failed to make payments to Daybreak for 3 months, as required of them for the use of Daybreak’s Services.
Reduced, Suspension, Withdrawal of Service Decision
3.1 Reduced service Decision may only be taken when it is necessary. It may be taken by a centre manager.
3.4 Suspension or Withdrawal Decision will be at Daybreak's sole discretion and may be given without notice where circumstances require.
Notice
4.1 When a Decision is taken, the Centre manager will notify the Beneficiary to whom it applies within 2 working days.
Appeals
5.1 A Beneficiary who has received a Decision may, within 30 days appeal in writing to Daybreak's CEO for the Decision to be reversed or modified.
There may be occasions or circumstances where it would no longer be appropriate for Daybreak to continue offering support to someone and this might lead to a reduction, suspension or withdrawal of service. The aim of the procedure which follows is to set out the circumstances under which reduction, suspension or withdrawal of service will be invoked. Any reduction, suspension or withdrawal of service will be invoked in line with one of the following principles:
- To safeguard the welfare of our beneficiaries.
- To safeguard the welfare of our staff and volunteers.
- To care for Daybreak’s resources of which we have been entrusted by the donors and supporters.
Application
2.1 This Procedure applies at any time when it comes to Daybreak's attention that:
(a) a Beneficiary's behaviour or capability is preventing, or is likely to prevent, Daybreak from complying with its safety or legal requirements.
(b) a Beneficiary's behaviour or capability is, or is likely to be, detrimental to the rights and interests of Daybreak or of others.
(c) a Beneficiary is infringing, or acting contrary to, one or more of the Policies; or
(d) a Beneficiary has failed to make payments to Daybreak for 3 months, as required of them for the use of Daybreak’s Services.
Reduced, Suspension, Withdrawal of Service Decision
3.1 Reduced service Decision may only be taken when it is necessary. It may be taken by a centre manager.
3.4 Suspension or Withdrawal Decision will be at Daybreak's sole discretion and may be given without notice where circumstances require.
Notice
4.1 When a Decision is taken, the Centre manager will notify the Beneficiary to whom it applies within 2 working days.
Appeals
5.1 A Beneficiary who has received a Decision may, within 30 days appeal in writing to Daybreak's CEO for the Decision to be reversed or modified.
If you would like to see full Daybreak policy documents, please contact our main office.
01865 776744 or admin@daybreak-oxford.org.uk.
01865 776744 or admin@daybreak-oxford.org.uk.
