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Published by Bardsey Bird Observatory, 2019-04-27 07:40:12

BBFO Policy Documents

BBFO Policy Documents


For Bardsey Bird and Field Observatory

The following policy documents which were adopted by the Trustees of BBFO on 17 February
2019 will help with the general running and governance of the charity

Steven Stansfield – Director of operations for Bardsey Lodge and Bird Observatory

on behalf of BBFO Trustees
Email - [email protected]

Table of Contents

COMPLAINTS POLICY ............................................................................................................ 2
INVESTMENT POLICY .............................................................................................................. 8
PRIVACY POLICY.................................................................................................................. 10
RISK MANAGEMENT POLICY ............................................................................................... 21
RISK REGISTER ....................................................................................................................... 25
SAFEGUARDING POLICY ..................................................................................................... 35
RINGING SPECIFIC SAFEGUARDING POLICY .................................................................... 37
STATEMENT ON VULNERABLE BENEFICIARIES ..................................................................... 43
VOLUNTEERING POLICY ...................................................................................................... 44

Complaints Policy

Bardsey Bird & Field Observatory views complaints as an opportunity to learn
and improve for the future, as well as a chance to put things right for the person
or organisation that has made the complaint.

Our policy is:
• To provide a fair complaints procedure which is clear and easy to use
for anyone wishing to make a complaint
• To publicise the existence of our complaints procedure so that people
know how to contact us to make a complaint
• To make sure everyone at Bardsey Bird & Field Observatory knows what
to do if a complaint is received
• To make sure all complaints are investigated fairly and in a timely way
• To make sure that complaints are, wherever possible, resolved and that
relationships are repaired
• To gather information which helps us to improve what we do

Definition of a Complaint
A complaint is any expression of dissatisfaction, whether justified or not, about
any aspect of Bardsey Bird & Field Observatory.

Where Complaints Come From
Complaints may come from any person or organisation who has a legitimate
interest in Bardsey Bird & Field Observatory.

A complaint can be received verbally, by phone, by email or in writing.

This policy does not cover complaints from staff, who should use Bardsey Bird
& Field Observatory's Discipline and Grievance policies.

All complaint information will be handled sensitively, telling only those who
need to know and following any relevant data protection requirements.

Overall responsibility for this policy and its implementation lies with the Trustees
of Bardsey Bird and Field Observatory


This policy is reviewed regularly and updated as required.

Adopted on: 17 February 2019

Last reviewed: 17 February 2019

Bardsey Bird and Field Observatory Policy Documents

Conflict of interest policy, declaration form and register of interests

This policy applies to Trustees, members of Friends of Bardsey Group and all

Why we have a policy
Trustees, members of the Friends of Bardsey Group and the Director of
Operations have a legal obligation to act in the best interests of Bardsey Bird
and Field Observatory, and in accordance with its governing document, and
to avoid situations where there may be a potential conflict of interest.

Conflicts of interests may arise where an individual’s personal or family interests
and/or loyalties conflict with those of Bardsey Bird and Field Observatory.
Such conflicts may create problems; they can:

• inhibit free discussion
• result in decisions or actions that are not in the interests of Bardsey Bird and

Field Observatory
• risk the impression that Bardsey Bird and Field Observatory has acted


The aim of this policy is to protect both the organisation and the individuals
involved from any appearance of impropriety.

The declaration of interests
Accordingly, we are asking Trustees, members of the Friends of Bardsey Group
and Director of Operations to declare their interests and any gifts or hospitality
offered and received in connection with their role in. A declaration of interests
form is provided for this purpose, listing the types of interest you should declare.

To be effective, the declaration of interests needs to be updated at least
annually, and when any material changes occur.

If you are not sure what to declare, or whether/when your declaration needs
to be updated, please err on the side of caution. If you would like to discuss
this issue, please contact the Honorary Secretary or Chair of Trustees for
confidential guidance.

This register of interests shall be used to record all gifts of a value over £50 and
hospitality over £50 received by the trustees and/or staff member.

Bardsey Bird and Field Observatory Policy Documents

Interests and gifts will be recorded on the charity’s register of interests, which
will be maintained by Andrew Lawrence, Honorary Secretary. The register will
be accessible by written request to the Secretary.

Data protection
The information provided will be processed in accordance with data
protection principles as set out in the General Data Protection Regulations Act
2018 and the Data Protection Act 1998. Data will be processed only to ensure
that Trustees, members of The Friends of Bardsey Group and Director of
Operations act in the best interests of Bardsey Bird and Field Observatory. The
information provided will not be used for any other purpose.

What to do if you face a conflict of interest
If you believe you have a perceived or real conflict of interest you should:

• declare the interest at the earliest opportunity
• withdraw from discussions and decisions relating to the conflict.

The charity secretary will take special care to ensure that minutes or other
documents relating to the item presenting a conflict are appropriately
redacted for the person facing the conflict. A balance needs to be made to
ensure that the person still receives sufficient information about the activities of
the charity generally without disclosing such sensitive information that could
place the individual in an untenable position.

If you are user of Bardsey Bird and Field Observatory services you should not be
involved in decisions that directly affect the service that you receive. You
should declare your interest at the earliest opportunity and withdraw from any
subsequent discussion, unless expressly invited to remain in order to provide
information. In this case you may not participate in, or influence, the decision
or any vote on the matter. You will not be counted in the quorum for that part
of the meeting and must withdraw from the meeting during any vote on the
conflicted item.

There are situations where you may participate in discussions from which you
could indirectly benefit, for example where the benefits are universal to all
users, or where your benefit is minimal. This action will be agreed by the chair
and minuted accordingly.

If you fail to declare an interest that is known to Honorary Secretary and/or
Chair of Trustees they will declare that interest.

Bardsey Bird and Field Observatory Policy Documents

Decisions taken where a trustee or member of staff has an interest
In the event of the board having to decide upon a question in which a trustee
or member of staff has an interest, all decisions will be made by vote, with a
simple majority required. A quorum must be present for the discussion and
decision; interested parties will not be counted when deciding whether the
meeting is quorate. Interested board members may not vote on matters
affecting their own interests.

All decisions under a conflict of interest will be recorded by the Honorary
Secretary and reported in the minutes of the meeting. The report will record:
• the nature and extent of the conflict
• an outline of the discussion
• the actions taken to manage the conflict.

Where a trustee benefits from the decision, this will be reported in the annual
report and accounts in accordance with the current Charities SORP.

All payments or benefits in kind to trustees will be reported in the charity’s
accounts and annual report, with amounts for each trustee listed for the year
in question.

Where a member of Bardsey Bird and Field Observatory staff is connected to
a party involved in the supply of a service or product to the charity, this
information will be fully disclosed in the annual report and accounts.

Independent external moderation will be used where conflicts cannot be
resolved through the usual procedures.

Managing contracts

If you have a conflict of interest, you must not be involved in managing or
monitoring a contract in which you have an interest. Monitoring arrangements
for such contracts will include provisions for an independent challenge of bills
and invoices, and termination of the contract if the relationship is

Bardsey Bird and Field Observatory Policy Documents

Register of interests:

Name ofDescription of interest Does the interest relate toIs the interest
the trustee or a personcurrent?
trustee/staff closely connected to the
trustee (describe)?

Bardsey Bird and Field Observatory Policy Documents

Bardsey Bird and Field Observatory Trustee declaration of interests form

I as employee/trustee*
*delete as appropriate

of Bardsey Bird and Field Observatory have set out below my interests in
accordance with the organisation’s conflicts of interest policy.

Category Please give details of the interest

and whether it applies to yourself

or, where appropriate, a member
of your immediate family,
connected persons or some other

close personal connection

Current employment and any previous employment in
which you continue to have a financial interest.

Appointments (voluntary or otherwise) e.g.

trusteeships, directorships, local authority

membership, tribunals etc.

Membership of any professional bodies, special interest
groups or mutual support organisations.

Investments in unlisted companies, partnerships and other
forms of business, major shareholdings and beneficial


Gifts or hospitality offered to you by external bodies and
whether this was declined or accepted in the last twelve

Do you use the organisation’s services?

Any contractual relationship with the charity or its

Any other conflicts that are not covered by the above.

To the best of my knowledge, the above information is complete and correct.
I undertake to update as necessary the information provided, and to review
the accuracy of the information on an annual basis. I give my consent for it to
be used for the purposes described in the conflicts of interest policy and for no
other purpose.




Bardsey Bird and Field Observatory Policy Documents

Investment Policy

Charity Registration Number: 249790
Date of Investment Policy Statement: 1 January 2015

1. Introduction
1.1 Bardsey Bird & Field Observatory is an unincorporated charity which
raises funds through visitors to the Observatory, undertaking scientific projects
and general fund-raising to spend on the continued running of the
Observatory in furtherance of its aims.
1.2 The Charity has approximately £60,000 of assets.
1.3 The Trustees of the Charity are governed by the Trustee Act 2000 which
sets out the general power of investment.

2. Investment Objectives
2.1 As the assets are limited and immediate access may be required,
capital preservation is of paramount importance and the ability to invest these
assets is restricted.

3. Risk
3.1 The Charity holds assets to fund the running and maintenance of the
Observatory. As such capital volatility cannot be tolerated and if assets were
to be invested they would be invested to minimise risk.
3.2 The Charity's assets should be held in cash or near cash investments
denominated in sterling. The Charity's cash balances should be deposited with
institutions with a minimum AAA rating. If investments are made it would be in
a diversified money market fund.

4. Liquidity Requirements
4.1 The Charity will draw down the cash in line with the planned expenditure
4.2 Maturities of any investments would need to match this timetable.

5. Time Horizon
5.1 The Charity will continue to fundraise to meet the costs incurred in
running the Observatory. The asset base has an indefinite time horizon.

6. Management, Reporting and Monitoring
6.1 The Charity will manage its own cash deposits and has a nominated
signatory to sign instructions to the deposit taking institution. Trustees, through
the director of finance, will monitor the cash position and prospective cash
flow schedule and report this annually at a meeting of Trustees.

Bardsey Bird and Field Observatory Policy Documents

7. Approval and Review
7.1 This Investment Policy Statement was prepared by the Trustees of
Bardsey Bird & Field Observatory to provide a framework for the management
of its assets. It will be reviewed on an annual basis to ensure continuing
Approved by the Trustee Board: 17 February 2019

Bardsey Bird and Field Observatory Policy Documents

Privacy Policy

This privacy policy explains how and why we use your personal data, to make
sure you stay informed and can be confident about giving us your information.

Privacy and Security
The privacy and security of your personal information is extremely important to
us. Bardsey Bird Observatory is committed to protecting the privacy and
security of any personal details that we hold. We will meet or exceed the
requirements of all current UK and EU legislation on data protection and
privacy of communications – the EU General Data Protection Regulation (from
25 May 2018), the UK Data Protection Act and Privacy of Electronic
Communication Regulation

Our website can be used without the need to disclose any personal
information. Personal data, such as names, addresses and email details are
only gathered in order to fulfil specific information requests or subscriptions to
our products and services.

We’ll keep this page updated to show you all the things we do with your
personal data. This policy applies if you’re a supporter of the Observatory
(member, donor, volunteer, customer or employee), visit our website, email,
call or write to us. We will never sell your personal data.

Who are ‘we’?
In this policy, whenever you see the words ‘we’, ‘us’, ‘our’, ‘BBFO’, ‘the
Observatory’ ‘Bardsey Lodge’, it refers to The Bardsey Bird and Field

The Bardsey Bird and Field Observatory is a charitable organisation registered
in England and Wales (Reg. No. 249790.) with the aim to Monitor the wildlife of
Bardsey Island.

The Observatory carries out a range of trading activities to generate income
for the charity including sale of gifts and souvenirs at its shop and online,
income from commercial partnerships including sponsorship, and renting
accommodation rooms at Bardsey Lodge.

What personal data do we collect?
Your personal data (any information which identifies you, or which can be
identified as relating to you personally for example, name, address, phone
number, email address) will be collected and used by us. We’ll only collect the
personal data that we need.

Bardsey Bird and Field Observatory Policy Documents

We collect personal data in connection with specific activities such as
memberships, placing an order, booking holidays, donations, volunteering,
conducting research, employment etc.

You can give us your personal data by filling in forms on our website, by
registering to use our website, participate in discussion, taking part in research
(ringing and bird census), entering a competition, promotion or survey or by
corresponding with us (by phone, email or by joining as a member / supporter
/ customer.

This personal data you give us may include name, title, address, date of birth,
age, gender, employment status, demographic information, email address,
telephone numbers, personal description, photographs, CCTV images,
opinions, usernames and passwords.

If you buy membership as a gift or are the parent of one of our junior supporters,
including volunteers, your details will be recorded and your association with
that relationship will be recorded.

We may automatically collect the following information via our web services:
Technical information, including the Internet protocol (IP) address used to
connect your computer to the Internet, your login information, browser type
and version, time zone setting, browser plug-in types and versions, operating
system and platform and if you access our website via your mobile device we
will collect your unique phone identifier Information about your visit, including,
but not limited to the full Uniform Resource Locators (URL) and query string,
clickstream to, through and from our website (including date and time),
products you viewed or searched for, page response times, download errors,
length of visits to certain pages, page interaction information (such as but not
limited to, scrolling, clicks, and mouse-overs), methods used to browse away
from the page, and any phone number used to call our customer service
number Information about your purchases including but not limited to revenue
figures, the types of products purchased, membership application, purchase
ID, Holiday booking ID, and Renewal ID.

Personal data created by your involvement with us
Your activities and involvement with BBFO will result in personal data being
created. This could include details of how you’ve helped us by volunteering or
being involved with our campaigns and activities. If you decide to donate to
us then we’ll keep records of when and how much you give to a particular

Bardsey Bird and Field Observatory Policy Documents

Information we generate
We conduct research and analysis on the information we hold, which can in
turn generate personal data. For example, by analysing your interests and
involvement with our work we may be able to build a profile which helps us
decide which of our communications are likely to interest you. The sections
Research and Profiling gives more detail about how we use information for
profiling and targeted advertising, including giving you more relevant digital

Sensitive personal data
At times we’ll collect sensitive personal data for Equal Opportunities
monitoring, as well as researching whether we deliver great experiences for
everyone, but this is only ever analysed at an aggregate level.

If you’re a volunteer then we may collect extra information about you (e.g.
references, criminal records checks, details of emergency contacts, medical
conditions etc.). This information will be retained for legal or contractual
reasons, to protect us (including in the event of an insurance or legal claim)
and for safeguarding purposes.

Children’s personal data

Family membership
Children aged under18 are included on family memberships and are members
of BBFO. We may collect their names and dates of birth. We don’t ask children
on family memberships for consent to marketing communications, so they
don’t receive them.

Junior and Young Person membership
Junior membership is available to everyone under the age of 18. Under 13s can
have their membership bought for them as a gift by an adult, while those aged
between 13 and 17 can buy membership online, by phone or at our shop.
Young Person membership is available from the age of 17.
When a Junior or Young Person member becomes 18, we’ll carry over their
marketing consents if they have made them.

Marketing to young people and fundraising
We won’t send marketing emails, letters or make calls to people under the age
of 13. We will not send any marketing communications requesting donations
to young people aged between 13 and 17 and won’t profile anyone under
the age of 18.

Bardsey Bird and Field Observatory Policy Documents

Our newsletters may sometimes include competitions or ideas about how to
raise money, but they are a member benefit. Most newsletter content is about
our work, conservation and ideas to help you make the most of your

How we use your personal data
We’ll only use your personal data on relevant lawful grounds as permitted by
the EU General Data Protection Regulation (from 25 May 2018)/UK Data
Protection Act and Privacy of Electronic Communication Regulation.
Personal data provided to us will be used for the purpose or purposes outlined
in any fair processing notice in a transparent manner at the time of collection
or registration where appropriate, in accordance with any preferences you
express. If asked by the police, or any other regulatory or government authority
investigating suspected illegal activities, we will provide your personal data.

Your personal data may be collected and used to help us deliver our
charitable activities, help us raise funds, or complete your order or request.
Below are the main uses of your data which depend on the nature of our
relationship with you and how you interact with our various services, websites
and activities.

Personal data that we hold on members and guests is primarily used for:

Administration and fulfilment of membership
Notification of Observatory news, events and activities
Notification and updates for the ‘Adopt-a-Manxie’ scheme
Contacting guests regarding their stay at Bardsey Lodge
Cross referencing ringing data and the ringer
Cross referencing observers and their records
In-house analysis

Personal data may also be used for:

Marketing communications
Your privacy is important to us, so we’ll always keep your details secure. We’d
like to use your details to keep in touch about things that may matter to you.
If you choose to hear from us we may send you information based on what is
most relevant to you or things you’ve told us you like. We may also show you
relevant content online. This might be about visiting our places, volunteering
with us, membership, events, conservation work, fundraising, our shop and
staying at the Lodge.

Bardsey Bird and Field Observatory Policy Documents

We’ll only send these to you if you agree to receive them and we will never
share your information with other companies outside the Bird Observatories
Council for inclusion in their marketing. (We may however share cookie data
with third parties to help with our own advertising targeting). If you agree to
receive marketing information from us you can change your mind at a later
date. However, if you tell us you don’t want to receive marketing
communications, then you may not hear about events or other work we do
that may be of interest to you. Personal data provided to us may also be
profiled to help us with advertising targeting. For example, your membership
data may be used to ensure we don’t serve you online membership
advertisements. Or we may use your personal data to find online users with a
similar profile to yourself who may be interested in our products or services.
We may sometimes use third parties to capture some of our data on our behalf,
but only where we are confident that the third party will treat your data
securely, in accordance with our terms and in line with the requirements set
out in the GDPR.

We’ll always act upon your choice of how you want to receive
communications (for example, by email, post or phone). However, there are
some communications that we need to send. These are essential to fulfil our
promises to you as a member, volunteer, donor or buyer of goods or services
from the Observatory. Examples are (but not exclusively):

Transaction messaging, such as Standing Order processing, shop purchase
confirmations and holiday booking confirmations
Membership-related mailings such as renewal reminders, Bardsey Beacon and
Bardsey’s Wildlife and notice of our Annual General Meeting

Membership including newsletters and magazines
We use the personal data you provide as a member provide to service your
membership. This includes sending renewal information to annual members by
mail and email, sending Observatory publications and information about our
Annual General Meeting. It’s also used to manage your membership online.

Fundraising, donations and legacy pledges
Where we have your permission, we may invite you to support vital
conservation work by making a donation, buying a raffle ticket, getting
involved in fundraising activities or leaving a gift in your will.

Occasionally, we may invite some supporters to attend special events to find
out more about the ways in which donations and gifts in wills can make a
difference to specific projects and to our cause. We’ll also send you updates

Bardsey Bird and Field Observatory Policy Documents

on the impact that you make by supporting us in this way, unless you tell us not

If you make a donation, we’ll use any personal information you give us to
record the nature and amount of your gift, claim gift aid where you’ve told us
you’re eligible and thank you for your gift. If you interact or have a
conversation with us, we’ll note anything relevant and store this securely on our
systems. If you tell us you want to fundraise to support our cause, we’ll use the
personal information you give us to record your plans and contact you to
support your fundraising efforts. If you’ve told us that you’re planning to, or
thinking about, leaving us a gift in your will, we’ll use the information you give
us to keep a record of this – including the purpose of your gift, if you let us know
this. If we have a conversation or interaction with you (or with someone who
contacts us in relation to your will, for example your solicitor), we’ll note these
interactions throughout your relationship with us, as this helps to ensure your gift
is directed as you wanted.

Charity Commission rules require us to be assured of the provenance of funds
and any conditions attached to them. We follow a due diligence process
which involves researching the financial soundness, credibility, reputation and
ethical principles of donors who’ve made, or are likely to make, a significant
donation to BBFO.

As part of this process we’ll carry out research using publicly available
information and professional resources. If this applies to you, we’ll remind you
about the process when you make your donation.

Management of volunteers
We need to use your personal data to manage your volunteering, from the
moment you enquire to the time you decide to stop volunteering with us. This
could include: contacting you about a role you’ve applied for or we think you
might be interested in, expense claims you’ve made, weeks you’ve booked
and to recognise your contribution.

We may also share this with funders to help them monitor how their funding is
making a difference.

Retail sales, holidays and events management
We process customer data in order to fulfil holiday bookings and retail
activities. Your data will be used to communicate with you throughout the
process, including to confirm we’ve received your order and payment, to
confirm dispatch, to clarify where we might need more detail to fulfil an order

Bardsey Bird and Field Observatory Policy Documents

or booking, or to resolve issues that might arise with your order or booking. For
fully catered weeks may also hold dietary requirements.

We sometimes carry out research with our supporters, customers, staff and
volunteers to get feedback on their experience with us. We use this feedback
to improve the experiences that we offer and ensure we know what is relevant
and interesting to you.

If you choose to take part in research, we’ll tell you when you start what data
we will collect, why and how we’ll use it. All the research we conduct is
optional and you can choose not to take part. For some of our research we
may ask you to provide sensitive personal data (e.g. ethnicity, age, gender).
You don’t have to provide this data and we also provide a ‘prefer not to say’
option. We only use it at an aggregate level for reporting (e.g. equal
opportunities monitoring).

We know it’s important to our supporters to use our resources in a responsible
and cost-effective way. We may use profiling and targeting to help us
understand our supporters and make sure that:

Our communications (e.g. emails) and services (e.g. our website) are relevant,
personalised and interesting to you
our services meet the needs of our supporters
we only ask for further support and help from you if it’s appropriate
we use our resources responsibly and keep our costs down

To do this we’ll analyse how you interact with us (e.g. on our website, places
you visit through use of data from membership card scanning, etc) and use
both geographic and demographic information to let you know what’s
happening in your local area and understand your interests.

We use specific tools to profile how you interact with us online, for example,
Adobe Analytics, Google Analytics. Much of the information we collect is
aggregated, however we may also collect some personal data for the use of
personalising your experience, optimising our marketing campaigns, and to
ensure the site is functioning as intended.

The personal information that is collect includes transactional information (i.e.
order number) for Memberships, Donations, Renewals, Holidays Bookings and
Online Shop Purchases.

Bardsey Bird and Field Observatory Policy Documents

If you’ve agreed that we can contact you for marketing purposes, we may
also gather additional information about you from external sources, for
example: updates to address and contact information, or publicly available
information regarding your wealth, earnings and employment at an
aggregate level. We may use this information to assess your capacity to
support us and invite you to do so.

Recruitment and employment
In order to comply with our contractual, statutory, and management
obligations and responsibilities, we process personal data, including ‘sensitive’
personal data, from job applicants and employees.

Such data can include, but isn’t limited to, information relating to health, racial
or ethnic origin, and criminal convictions. In certain circumstances, we may
process personal data or sensitive personal data, without explicit consent.
Further information on what data is collected and why it’s processed is given

Contractual responsibilities: Our contractual responsibilities include those
arising from the contract of employment. The data processed to meet
contractual responsibilities includes, but is not limited to, data relating to:
payroll, bank account, postal address, sick pay; leave, maternity pay, pension
and emergency contacts.

Statutory responsibilities: Our statutory responsibilities are those imposed
through law on the organisation as an employer. The data processed to meet
statutory responsibilities includes, but is not limited to, data relating to: tax,
national insurance, statutory sick pay, statutory maternity pay, family leave,
work permits, equal opportunities monitoring.

Management responsibilities: Our management responsibilities are those
necessary for the organisational functioning of the organisation. The data
processed to meet management responsibilities includes, but is not limited to,
data relating to: recruitment and employment, training and development,
absence, disciplinary matters, e-mail address and telephone number.

Sensitive personal data
The Act defines ‘sensitive personal data’ as information about racial or ethnic
origin, political opinions, religious beliefs or other similar beliefs, trade union
membership, physical or mental health, sexual life, and criminal allegations,
proceedings or convictions.

Bardsey Bird and Field Observatory Policy Documents

In certain limited circumstances, we may legally collect and process sensitive
personal data without requiring the explicit consent of an employee.

We will process data about an employee’s health where it is necessary, for
example, to record absence from work due to sickness, to pay statutory sick
pay, to make appropriate referrals to the Occupational Health Service, and to
make any necessary arrangements or adjustments to the workplace in the
case of disability. This processing will not normally happen without the
employee’s knowledge and, where necessary, consent.

We will process data about, but not limited to, an employee’s racial and ethnic
origin, their sexual orientation or their religious beliefs only where they have
volunteered such data and only for the purpose of monitoring and upholding
our equal opportunities policies and related provisions.
Data about an employee’s criminal convictions will be held as necessary.

Disclosure of employees personal data to other bodies
In order to carry out our contractual and management responsibilities, we
may, from time to time, need to share an employee’s personal data with one
or more third party supplier.

To meet the employment contract, we are required to transfer an employee’s
personal data to third parties, for example, to pension providers and HM
Revenue & Customs.

In order to fulfil our statutory responsibilities, we’re required to give some of an
employee’s personal data to government departments or agencies e.g.
provision of salary and tax data to HM Revenue & Customs.

Updating your data and marketing preferences
We want you to remain in control of your personal data. If, at any time, you
want to update or amend your personal data or marketing preferences please
contact us by writing to BBFO at the address at the end of this document, or
by emailing [email protected],uk

Disclosure of members and Guests Personal Data
On occasion we will have to share personal data with third parties.

• We will share medical and other personal data with Medics from HMCG
of the Welsh (air) Ambulance service in the case of a Medi-evac of a
casualty from the island.

• We may share personal details with HMRC solely for the purposes of
recovering tax on Gift Aid.

Bardsey Bird and Field Observatory Policy Documents

• Members’ postal details are shared with our mailing house (for now
Burwell Print), for the delivery of the Observatory’s quarterly mailing of
the Bardsey Beacon, AGM and other Observatory related news.

• Bank details are only shared with the banks of the individuals who set up
standing orders.

• Ringing Data (required by The British Trust for Ornithology) will be passed
to the BTO, but no personal data will be sent to any other third parties
requesting ringing data.

• Colour ring sighting data will be passed to third parties, such as (but not
exclusively) RSPB, NRW and BTO.

• Census data, including observers initials for rare and scarce species will
be passed on to the BTO, County Recorders, The Welsh Records Panel
and the British Birds Rarities Committee.

• Observers initials and names regarding sightings will be published in the
annual report ‘Bardsey’s Wildlife’.

Otherwise, we will not share personal data with any other third party other than
if we have a legal obligation to do so.

Retention of Personal Data
We will retain the personal details of cancelled and lapsed members for a
period of 120 months in order to keep past members aware of special one-off
events such as ten-year anniversary parties and events, as well as to provide a
period of grace for late renewals. The cancellation of Friends of Bardsey
membership or Adopt-a-Manxie membership does not automatically cancel
the delivery of BBFO promotional emails, where consent has been obtained by
individuals for the Observatory to send these communications (see ‘Consent’
below). In this case, contact details will be retained until recipients unsubscribe
from BBFO mailing lists, which can be done easily at any point.

Retention of Personal Data for unsuccessful applicants for job posts and
We will retain the personal details of unsuccessful applicants for a period of 48
months in order to keep them informed of potential posts, job or volunteer
opportunities which may arise.

Personal Rights
You have a right to know all the personal details that we might hold on you.
You can obtain a printed copy of this information by writing to BBFO at the
address below or by sending an email request the email address below. If you
have any questions in relation to this privacy policy or how we use your
personal data contact [email protected]. We will reply within a maximum of
two weeks of receipt of the request.

Bardsey Bird and Field Observatory Policy Documents

We require members and non-members to give specific consent to be
contacted by email and telephone for the delivery of what are deemed
promotional communications (Observatory news and events notices and

Keeping your data secure
Sending information over the internet is generally not completely secure, and
we can’t guarantee the security of your data while it’s in transit.
Any data you send is at your own risk.
We have procedures and security features in place to keep your data secure
once we receive it.

Cookies and Tracking
Parts of our website and Blog (Bardsey’s Wildlife) use cookies that help us
monitor how the site is explored. Cookies are text files, not apps or programs
and are completely anonymous. Your web browser will allow you to control
how they are handled, and you may indicate that you do not wish them to be
used. More information can be obtained at

Links to other websites
Our website and blog contains links to third party websites that we think may
be of interest. This information will be supplied in good faith but it is up to you If
you do go to another website from this one, to read the privacy policy on that
website to find out what it does with your information.

Following a link to BBFO sites from another website
If you come to or from another website, we
may receive information from the other website. We don’t use this data. You
should read the privacy policy of the website you came from to find out more
about this.

Use of geo-location data
We use geo-location on both our main website, and the Blog site. If you let your
device share this information with us, we may use it to personalise your
experience with us. Your device or web browser will usually prompt you when
this is requested. You can change your location settings at any time in your
device or computer settings.

Bardsey Bird and Field Observatory Policy Documents

Risk management policy

This policy:
Is a formal acknowledgement that the trustee board is committed to
maintaining a strong risk management framework. The aim is to ensure that the
charity makes every effort to manage risk appropriately by maximising
potential opportunities whilst minimising the adverse effects of risks.

It should be used to support the internal control systems of the charity, enabling
the charity to respond to operational, strategic and financial risks regardless of
whether they are internally or externally driven.

Risk policy objective
To confirm and communicate the charity’s commitment to risk management.
To establish a consistent framework and protocol for determining appetite for
and tolerance of risk and for managing risk.
To assign accountability to management and staff for risks within their control
and provide a structured process for risk to be considered, reported and acted
upon throughout the organisation.

Risk policy statement
The trustees of the charity believe that sound risk management is integral to
both good management and good governance practice.

Risk management should form an integral part of the charity’s decision–
making and be incorporated within strategic and operational planning.

Risk assessment will be conducted on all new activities and projects to ensure
they are in line with the charity’s objectives and mission. Any risks or
opportunities arising will be identified, analysed and reported at an
appropriate level. A risk register covering key strategic risks will be maintained
and updated at least once a year and more frequently where risks are known
to be volatile.

The charity will regularly review and monitor the effectiveness of its risk
management framework and update it as considered appropriate.

Individual error and incident reports will be required from individual staff where
a reportable event is identified. The procedures for this are set out in a separate
‘reportable events policy’ which is specified within our crisis management
plan. Such incidents which are considered to pose a significant threat to the
charity, financial or otherwise, will be escalated in accordance with the crisis
management plan.

Bardsey Bird and Field Observatory Policy Documents

Organisational roles

The role of the trustee board
• To ensure that a culture of risk management is embedded throughout
the charity
• To set the level of risk appetite and risk tolerance for the organisation as
a whole and in specific circumstances
• To communicate the charity’s approach to risk and set standards of
conduct expected of staff
• To ensure risk management is included in the development of business
plans, budgets and when considering strategic decisions
• To approve major decisions affecting the charity’s risk profile or exposure
• To satisfy itself that less fundamental risks are being actively managed
and controlled
• To regularly review the charity’s approach to risk management and
approve any changes to this
• To receive reports from internal audit, risk subcommittee, external
consultants and any other relevant parties and to make
recommendations on this

Interaction with internal control systems
The charity expects to meet minimum standards required by legislation and
best practice in operational areas covering the following:

• IT and data protection
• Governance
• Financial accounting and reporting
• Health and safety
• Management of volunteers, etc
• Safeguarding

The risk of falling short of these standards is mitigated as far as possible by
ensuring that appropriate policies and working practices are adopted in each
of these key areas and that staff are adequately experienced and trained to
manage this. Where necessary, external advice is sought to supplement
internal expertise.

Bardsey Bird and Field Observatory Policy Documents

Risks are ranked by impact and likelihood of occurrence.

Likelihood and impact are assessed separately for each risk and graded from
1 to 5. 1 – lowest likelihood/impact and 5 – highest likelihood/impact.


Descriptor Score Impact
no impact
Insignificant 1 slight impact
some disruption to operation
Minor 2 potential for adverse publicity - avoidable with careful handling
operation disrupted
Moderate 3 adverse publicity not avoidable (local media)
operation interrupted for significant time
Major 4 major adverse publicity not avoidable (national media)
loss of beneficiary confidence
Extreme/ 5

Likelihood Score Example
Descriptor 1 may only occur in exceptional circumstances
Remote 2 expected to occur in a few circumstances
Unlikely 3 expected to occur in some circumstances
Possible 4 expected to occur in many circumstances
Highly 5 expected to occur frequently and in most circumstances

Bardsey Bird and Field Observatory Policy Documents

The 'heat map' below shows a different way of assessing risk by increasing the
weighting of impact. This works on a scoring of xy+y where x is likelihood and y
is impact. This formula multiplies impact with likelihood then adds a weighting
again for impact. The effect is to give extra emphasis to impact when assessing
risk. It should be remembered that risk scoring often involves a degree of
judgement or subjectivity. Where data or information on past events or
patterns is available, it will be helpful in enabling more evidence-based

In interpreting the risk heat map below, likelihood is x and impact is y. The
colour codes are:

Red - major or extreme/catastrophic risks that score 15 or more Yellow -
moderate or major risks that score between 8 and 14 Blue or green - minor or
insignificant risks scoring 7 or less

Extreme/ 15 20 25 30
Catastrophic 5 10 12 16
9 12
Major 4 8 6 8 20 24
3 4
Moderate 3 6 2 Unlikely 3 Possible 15 18

Minor 2 4 10 12

Insignificant 1 2 5 6
1 Remote 4 Probable 5 Highly Probable

Bardsey Bird and Field Observatory Policy Documents

Risk Register

Governance risks:

Potential Risk Potential Impact Steps to mitigate risk Action Timetable Follow-up
By review

The charity • the charity drifts• create a strategic plan whichTrustees
sets out the key aims,
lacks with no clear objectives and policies

direction, objectives, priorities create financial plans and
strategy and or plans •
use job plans and targets
forward • issues are
planning monitor financial and
addressed • operational performance

pstireacteegmicearel fewriethncneo• get feedback from
beneficiaries and funders
• needs nootf•

fully addressed

Trustee body • financial
lacks relevant difficulties
skills or
loss of reputation
commitment •
charity becomes• review and agree skillsTrustees
• required
moribund or fails to

achieve its purpose• draw up competence
framework and job
decisions are made descriptions

bypassing the

trustees • implement trustee training and
resentment or

apathy amongst• review and agree recruitment

poor decision

making reflected in

poor value for

money on service


Trustee body • trustee bodyconsider the structure of the trusteeTrustees
cannot operatebody and its independence
dominated by asagree mechanisms to manage
one or two effectively potential conflicts of interest
individuals, or
strategic body and
by • tmrusatdeeegareopvvpieeowrinniatnmngdednaotgcprureomeceerensctserusitinmleinnet with
connected outside of agree procedural framework for
individuals body

• conflicts of interest meetings and recording decisions

pursuit of personal


culture of secrecy
Trustees are •
or deference
arbitrary over-riding
from charity • of control
remuneration) poor reputation,ensure legal authority for paymentTrustees
morale and ethos or benefit
• aoenvdevvireraorlsnlemiemnptcaocnt toronlictamoorrpanlsneaidgmueetehrmnoetrinsteetas/rlmatepsrnpaarontivdveeproecxspetaedfnufisrneegss
• conflicts of interest and payments

possibility ofagree procedures and methods to

regulatory action establish fair remuneration

conducted separately from

'interested' trustee (remuneration

Bardsey Bird and Field Observatory Policy Documents

exercise etc)

Conflicts of • charity unable toagree protocol for disclosure ofTrustees
pursue its ownpotential conflicts of interest Staff
interests andput in place procedures for
• standing down on certain
decisions may and selection
be based


• impact on
• reputation
Ineffective •
private benefit
structure lack of informationuse organisation chart to create aTrustees
flow and poorclear understanding of roles andCEO
• decision makingduties
delegation and monitoring should
• procedures
• fromabendconcsiostnesnttituwtiiothnagl oodorpracletgicael
remoteness requirements
operational review structure and the need for

uncertainty as toconstitutional change
roles and duties

decisions made at
inappropriate level
or excessive

Activities • loss of fundsagree protocol for reviewing newTrustees
Potentially projects to
outside classepnoswuerers consistency with objects,
objects, • for beneficiary and
powers or •
liabilities to repayterms of funding
terms of gift create financial systems to identify

(restricted • loss of funderrestricted

funds) confidence funds and their application

• potential breach of

• and regulatory

• loss of beneficiary

• taxation

• (if non-qualifying

Loss of key • experience or skills• succession planning Trustees
lost •
staff document systems, plans and
operational impact projects

• on key projects and• implement training

priorities programmes

• loss of contact• agree notice periods and

base and handovers

• corporate • review and agree recruitment

Reporting • inadequate • put in place proper strategicAll staff
to trustees information
planning, objective setting
timeliness and • resulting in poor• and budgeting processes

relevance) • quality • timely and accurate project
decision making

• failure of trustees to• timely and accurate financial

fulfil reporting

Bardsey Bird and Field Observatory Policy Documents

• their control• assess and review projects and
authorisation procedures
have regular contact between
• trustee body• trustees and senior staff
and managers

• remote and ill


Operational Risks

Potential Risk Potential Impact Steps to mitigate risk Action Timetable Follow-up
By review

Contract risk • onerous terms and• create cost/project appraisalTrustees

• conditions procedures

liabilities for non• agree authorisation

performance procedures

non-compliance • get professional advice on
terms and conditions
with charity's
put in place performance
objects • monitoring arrangements

• unplanned subsidy consider insurable risks cover

of public provision •

Service • beneficiary • agree quality controlTrustees
provision complaints
customer - procedures
• loss of fee income • implement complaints
• procedures
loss of significant
• benchmark services and
contracts or claims• implement complaints review
under contract

negligence claims

• reputational risks

Project or • compatibility with• appraise project, budgetingTrustees
and costing procedures
service objects, plans and

development priorities • review authorisation
• funding and

financial viability • review monitoring and
reporting procedures
• project viability

Competition • skills availability

from similar loss of contract• monitor and assessTrustees
performance and quality of
organisations • income service

reduced fund- review market and methods
of service delivery
raising potential •
agree fund-raising strategy
• reduced public

profile •

• profitability of• ensure regular contact with

trading activities funders

• monitor public awareness and

profile of charity

Suppliers, • dependency on• use competitive tendering for
dependency, •
bargaining key supplier larger contracts
lack of supplier to• put in place procedures for
obtaining quotations
meet key
authorised suppliers listing
operational •
monitor quality/timeliness of
objectives • provision

• non-competitive use service level agreements

pricing/ quotes • consider use of buying
Capacity and • insufficient buying• consortia

use of resources power
under-utilised or• agree building and plant
lack inspection programme
building/office of

Bardsey Bird and Field Observatory Policy Documents

tangible fixed • plant and• agree repair and
• equipment maintenance programme
assets • obsolescence • agree capital expenditure
impacting on budgets
of •
• operational • undertake efficiency review
• performance


between staff

allocations and

key objectives

spare capacity
not being utilised
or turned to

loss or damage • review security arrangements

theft of assets • create asset register and
inspection programme
infringements of

intellectual • agree facility management
property rights

• have safe custody

arrangements for title

documents and land


• manage use of patent and
intellectual property

• review insurance cover

Fund-raising • unsatisfactory • implement appraisal,Trustees

Employment returns budgeting and authorisation
• reputational risks of procedures

campaign or• review regulatory compliance

methods used • monitor the adequacy of
• actions of agents financial returns achieved
(benchmarking comparisons)
and commercial

fund-raisers • stewardship reporting in
annual report
• compliance with

law and regulation

• employment • review recruitment processes Trustees

disputes • agree reference and

• health and safety qualification checking

issues procedures, job descriptions,

• claims for injury, contracts of employment,

stress, harassment, appraisals and feedback

unfair dismissal procedures

• equal opportunity• implement job training and
and diversity issues
implement health and safety
• adequacy of staff• training and monitoring

training be aware of employment law
• child protection•

issues • implement staff vetting and
legal requirements (e.g. DBS
• low morale checks)

• abuse of

vulnerable • agree a whistle-blowing

High staff • loss of experience• review interview andTrustees
• or key technical assessment processes

skills • agree fair and open
competition appointment for
recruitment costs key posts
and lead time

training costs

Bardsey Bird and Field Observatory Policy Documents

• operational • agree job descriptions and
performance appraisal and
impact on staff feedback systems

morale and conduct 'exit' interviews

service delivery • review rates of pay, training,
working conditions, job
• satisfaction
review and agree role,Trustees
Volunteers • lack of• competencies

competences, review and agree vetting
training and•
support review and agree training
and supervision procedures
• poor service for•
• agree development and
beneficiaries motivation initiatives

inadequate •
reference and

• recruitment and
Health, safety •
and • staff injury • comply with law andTrustees
environment product or service
train staff and compliance
• liability • officer

ability to operate put in place monitoring and
reporting procedures
(see Compliance•


• injury to

beneficiaries and

the public

Disaster • computer system• agree IT recovery plan Trustees
recovery failures or loss of•
planning and implement data backup
data procedures and security
• measures
destruction of

property, • review insurance cover

equipment, • create disaster recovery plan

records through including alternative

fire, flood or similar accommodation


Procedural and • lack of awareness• properly document policiesTrustees
and procedures
systems of procedures and
documentation audit and review of systems
policies •

actions taken

without proper


Information • systems fail to• appraise system needs andTrustees
technology options
• meet operational
• appraise security and
need • authorisation procedures

failure to innovate implement measures to
secure and protect data
or update systems •
agree implementation and
loss/corruption of development procedures

data e.g. donor• use service and support
create disaster recovery
• lack of technical• procedures

support consider outsourcing

breach of data• review insurance cover for
any insurable loss
protection law

Financial Risks

Bardsey Bird and Field Observatory Policy Documents

Potential Risk Potential Impact Steps to mitigate risk Action Timetable Follow-up
By review

Budgetary • budget does not• link budgets to businessTrustees
planning and objectives
control and match key monitor and report in a timely
financial and accurate way
reporting objectives and• use proper costing procedures
priorities for product or service delivery
• ensure adequate skills base to
decisions made on• produce and interpret
budgetary and financial
inaccurate reports
agree procedures to review
financial or• and action budget/cash flow
projections variances and monitor and
control costs
reporting regularly review reserves and
• decisions made
link reserves policy to business
based costinogn• plans, activities and identified
unreliable financial and operating risk
regularly review reserves policy
data or income and reserve levels

projections ensure adequate cash flowHon
projections (prudence ofTreasurer
• inability to meet• assumptions)
identify major sensitivities
commitments or ensure adequate information
key objectives flow from operational
• poor credit control monitor arrangements and
• reporting
poor cash flow and identify major dependencies Trustees
treasury implement adequate reserves
management policy
consider diversification plans
• ability to function ensure accurate costing of
• as going concern services and contracts
compare with other service
Reserves lack of funds or• providers
policy notify and agree price
liquidity to respond variations with funders
monitor funder satisfaction
to new needs or develop pricing policy for
activities including terms of
requirements • settlement and discounts

• inability to meet
commitments or
planned objectives

• reputational risks if
policy cannot be
Cash flow• justified

sensitivities inability to meet•

• commitments

lack of liquidity to

cover variance in•

costs •

• impact on


activities •

Dependency • cash flow and•

on income budget impact of•
loss of income
Pricing policy •
source •

• reliance on subsidy•


unplanned loss•

from pricing errors

cash flow impact•

on other activities

loss of contracts if•
uncompetitive •
affordability of

services to

beneficiary class

Bardsey Bird and Field Observatory Policy Documents

Guarantees • call made under• review approval and authorityTrustees
to third procedures
• lack of reserves or• agree procedures to ensure
consistency with objects,
liquidity to meet plans and priorities

• consistency with• ensure financial reporting of
priorities and contingency and

amendment to reserves policy

Pension • under-funded • use actuarial valuations

commitments defined benefit• review pension scheme
arrangements (e.g. money
scheme purchase schemes)

• impact on future

cash flows• review procedures for
admission to scheme and
failure to meet due controls over pension
dates of payment

• regulatory action
or fines

Inappropriate• resources • monitor and review businessTrustees
performance and return
or loss- withdrawn from

making non- key objectives • ensure adequacy of

charitable • resources and budgeting and financial
energy diverted reporting within the subsidiary
from profitable or activity budget

fund-raising or core• review and agree adequate
authorisation procedures for
activities any funding provided by
charity (prudence, proper
• regulatory action, advice, investment criteria)
• and accountability

reputational risk if

publicised • report funding and

performance as part of

charity’s own financial

reporting system

• appraise viability

consider transfer of

undertakings to separate


Investment • financial loss• review and agree investment
policies through

• inappropriate or• obtain proper investment
advice or management
• speculative

• investment • consider diversity, prudence
and liquidity criteria
Protection of• unforeseen severe

permanent adverse • implement adequate reserves
endowment investment policy

• conditions loss• use regular performance
• financial monitoring

through lack of

investment advice,

lack of diversity

cash flow

difficulties arising

from lack of


loss of future• review and agree investment
income stream or
obtain proper investment
capital values • advice or management

buildings unfit for consider diversity, prudence
and liquidity criteria
purpose •
use regular performance
income streams monitoring

inappropriate to•

meet beneficiary


Bardsey Bird and Field Observatory Policy Documents

• ensure maintenance and
surveyor inspection of

• review insurance needs
implement systems to identifyTrustees
Compliance • funds applied• restricted receipts

with donor outside restriction

imposed • repayment of grant• agree budget control,
restrictions • monitoring and reporting
future relationship arrangements
with donor and

• regulatory action
Fraud or error •
financial loss • review financial controlTrustees
• procedures
• reputational risk
• segregate duties
• loss of staff morale •
regulatory action • set authorisation limits
impact on funding •
agree whistle-blowing anti-
fraud policy

• review security of assets

Counter • financial loss identify insurable risks
party risk • • research counter party’sTrustees
disruption financial sustainability
activities to
operations contractual agreement
• consider staged payments

• agree performance measures

monitor and review


• establish monitoring and
review arrangements where
counter party is the charity’s
agent (‘conduit funding’

• •

Environmental and external factors

Potential Risk Potential Impact Steps to mitigate risk Action Timetable Follow-up
By review

Public • impact on• communicate with supportersTrustees
perception and beneficiaries
voluntary income
Adverse ensure good quality reporting
publicity • impact on use of• of the charity’s activities and
financial situation
services by
implement public relations
beneficiaries training/procedures

• ability to access•

grants or contract


• loss of donor• implement complaintsTrustees

confidence or procedures (both internal and

funding external)

• loss of influence • agree proper review
procedures for complaints
• impact on morale

of staff agree a crisis management
strategy for handling -
• loss of beneficiary including consistency of key
messages and a nominated
confidence spokesperson

Relationship • deterioration in• ensure regular contact andTrustees
with funders briefings to major funders
relationship may

impact on funding• report fully on projects

Bardsey Bird and Field Observatory Policy Documents

and support• meet funders’ terms and

available conditions

Demographic • impact of• profile donor base Trustees
demographic •
consideration distribution profile and understand
donors of beneficiary needs
• beneficiaries
• or• use actuarial analysis to
Government • establish future funding
increasing or requirements

• beneficiary class

• increasing or

decreasing donor


availability of• monitor proposed legal andTrustees
regulatory changes
contract and grant
consider membership of
funding • appropriate umbrella bodies

impact of tax

regime on

voluntary giving

impact of general

legislation or

regulation on



role of voluntary

Compliance risk (law and regulation)

Potential Risk Potential Impact Steps to mitigate risk Action Timetable Follow-up
By review

Compliance • fines, penalties or• identify key legal andTrustees
regulatory requirements
with censure from
legislation allocate responsibility for key
and licensing or activity• compliance procedures

regulations • regulators put in place compliance
monitoring and reporting
appropriate loss of licence to•
to the prepare for compliance visits
activities, size undertake
and structure obtain compliance reports
rp(issaekrset)iculoapr eraactitoivniatyl•• from regulators (where
of the charity • appropriate) - auditors and
employee or staff to consider and action at
appropriate level
consumer action
review and agreeTrustees
for negligence compliance procedures and
allocation of staff
reputational risks responsibilities

Regulatory • regulatory action•

reporting reputational risks
impact on funding

Financial and




will be


on how the

charity is


and may also


according to



Bardsey Bird and Field Observatory Policy Documents

Taxation • penalties, interest• review PAYE complianceTrustees
Professional and ‘back duty’
advice review VAT procedures
assessments •
file timely tax returns
• loss of income e.g.•
failure to utilise gift• understand exemptions and
reliefs available (direct tax
aid arrangements and VAT)

• loss of mandatory take advice on employment
status and contract terms and
or discretionary• tax

rate relief implement budget and
financial reporting identifying
• failure to utilise tax trading receipts, and tax
exemptions and• identify and ensure access toTrustees
professional advice
identify issues where advice is
• lack of investment• required

strategy or conduct compliance reviews

management •

failure to optimise

fiscal position •

• contract risks

• failure to address

compliance risks

Bardsey Bird and Field Observatory Policy Documents

Safeguarding Policy

The following outlines BBFO's approach to safeguarding children (under the
age of 18) who engage with the BBFO, in particular those that join staff on
fieldwork for one of BBFO's surveys.

This policy applies to all staff, volunteers and trustees of the BBFO.

The purpose of this policy is to protect children who engage with the BBFO from
abuse, and to protect adults who engage with children on behalf of the BBFO
from unfounded allegations of abuse.

Legal framework
This policy has been drawn up having regard to:

• Children Act 1989
• United Nations Convention on 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

We recognise that:
• BBFO has a duty to promote the welfare of children with whom we work
and to keep them safe
• All children, regardless of age, disability, gender, racial heritage, religious
belief, sexual orientation or identity, have an equal right to protection
from harm or abuse
• Some children are particularly vulnerable because of previous
experiences, their level of dependency, communication needs or other
• Working in partnership with children, their parents, carers and other
agencies is essential in promoting children’s welfare

BBFO will seek to keep children safe by:
• Valuing them, listening to and respecting them
• Adopting child protection procedures and a code of conduct for staff
and volunteers
• Safely recruiting or training any staff or volunteers that we are directing
to work regularly with children
• Appointing and training at least two Designated Safeguarding Officers

Bardsey Bird and Field Observatory Policy Documents

• Sharing information about child protection and good practice with staff,
volunteers, parents and children

• Sharing concerns with agencies who need to know, involving parents
and children as appropriate

• Keeping our policy and procedures under review

BBFO Code of conduct
The purpose of this Code of Conduct is to help to protect children from abuse
and inappropriate behaviour from adults, and to protect staff and volunteers
from unfounded allegations of abuse.

Applicability and enforcement
This code of conduct applies to all BBFO members of staff, volunteers and
trustees who engage with children on behalf of the BBFO. Any breaches of this
Code of Conduct must be reported to the BBFO’s Safeguarding Officer, Steven
Stansfield (07855 264151 [email protected]), or alternatively Dianne Charles
(01212 490490 [email protected]).
A breach of this Code of Conduct by staff may be regarded as a disciplinary
offence under the BBFO’s Staff Disciplinary Procedures in the BBFO Staff
Handbook. Serious breaches may also result in a referral to a statutory agency
including the police, the local authority children’s social care department and
the Independent Safeguarding Authority.

Staff and volunteers working with children must:
• Observe this general Code of Conduct, and any specific BBFO
guidelines for the relevant activity
• Ensure that any risk assessment for the activity takes children
appropriately into account
• Ensure that any contact with children is appropriate for the activity
• Ensure that there is more than one adult present (within sight or hearing)
during activities with children
• Listen to and respect children, treating them fairly and avoiding
• Use language that is appropriate for children and not offensive or
• Respect children’s right to personal privacy
• Report all concerns or allegations of abuse to the BBFO’s Safeguarding
Officer (Steven Stansfield (07855 264151 [email protected])

Staff and volunteers working with children must not:
• Work regularly with children (defined as more than once a week, or on
4 or more days in 30, or overnight) without completing the vetting
procedures required by law in the country of work.

Bardsey Bird and Field Observatory Policy Documents

• Develop inappropriate relationships with children
• Allow concerns or allegations of abuse to go unreported
• Make promises to children not to report disclosures of abuse

Ringing Specific Safeguarding Policy

(adapted from the BTO’s ‘Safeguarding of
young people within ringing guidance’)

Safeguarding of young people within ringing guidance Introduction Inspiring
and developing young people is important to the BBFO and to the future
health of the Observatory. Good systems and a broad awareness of
safeguarding issues are important for looking after the interests of young
people, volunteers and BBFO alike. Working with young people does require
some additional care to ensure that they are kept safe. In addition to thinking
carefully about health-and-safety issues, we must also follow procedures to
keep young people safe from those who would wish them harm. We recognise
that the Observatory would like to help develop the skills of young people, but
there is uncertainty about safeguarding issues. With effective systems in place,
the benefits associated with ringing, can continue to be enjoyed safely by
young people. This document also seeks to stimulate wider thinking about
safeguarding. The more informed our network is, the less likely there is to be a
problem. Abuse thrives on secrecy, and abusers are known to seek
opportunities where their activities will go unnoticed or unchallenged. Hence
it is really important that all ringers, whether professionals or amateurs,
Observatory Staff or visitors, and whether directly involved in training young
people or not, have some understanding of safeguarding and the measures
that are in place. This document addresses the Safeguarding of children, any
queries on adult safeguarding should be raised with BBFO Safeguarding leads.

This document sets out what ringers, in particular, need to know and do about
safeguarding, providing interpretation of the BBFO Safeguarding Policy
presented above.

‘young people’ or ‘children’ are used interchangeably in this policy, both refer
to those under the age of 18. ‘Adults’ refers to those that are 18 and over.
‘Volunteer’, for the purposes of this policy and according to DBS, is defined as
“any person engaged in an activity which involves spending time, unpaid
(except for travel and other approved out-of-pocket expenses), doing
something which aims to benefit some third party and not a close relative.”

Bardsey Bird and Field Observatory Policy Documents

‘Regulated activity’ - once a week or more, or on 4 or more days in 30, or

Many people are unclear around which aspects of safeguarding they need to
engage with from a legal point of view. In fact, safeguarding law, as it affects
the individual, is very clear and simple. The only legal duty on individuals is not
to work with young people if they are barred from doing so. The law does have
more to say regarding the responsibility of organisations, including charities.
The Disclosure and Barring Service (DBS) manages the lists of unsuitable
individuals who should not work with young people. Organisations who
arrange for adults to work regularly with young people have a responsibility to
ensure that they have checked with DBS that they are not known to be
unsuitable. BBFO’s interpretation of how this applies to ringing is set out above
and at

All ringing volunteers and staff should read and digest this policy; a breach
may be treated as a disciplinary matter under the Ringing Scheme rules and
serious breaches may result in a referral to Police.
Three key points as regards ringing activities are worthy of further expansion

1. Anyone wishing to act as the named Trainer of a young person
must obtain a Young Persons’ Training Endorsement (YPTE) in advance of
signing the young person up as a Trainee. This is the case irrespective of
whether the ‘working regularly’ threshold has been reached (see 3
below); this process requires a DBS check.
2. Staff and volunteers must ensure that there is more than one adult
present (within sight or hearing) during activities with a child. This point
applies whether or not the adult present holds a Young Persons’ Training
Endorsement (see below) or other DBS check. From this it follows that
training of a child by a single adult Trainer, or any adult in isolation, should
not take place. If there is no suitable group for the training to take place
within, then it is recommended that the young person’s parent/guardian
be asked to attend the training sessions also.
3. Staff and Volunteers must not work regularly with children (defined
as once a week or more, or on 4 or more days in 30, or overnight) without
completing the vetting procedures required by law in the country of work.
This applies to anyone present, not just the named Trainer, though only
the Trainer will receive a YPTE as a result of the checks. The onus to arrange
the vetting procedures rests with BBFO, as individuals cannot carry out DBS
checks on themselves. However, the BBFO’s policy requires you, as a
member of staff or volunteer, to inform us if you think you may fall into the
‘working regularly’ category and are not the named Trainer. Note that

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none of the above rules apply to parent-child relationships. allow a Trainer
to disregard the provisions of the BBFO Safeguarding Policy.

For ringers who are not named Trainers of young people, but for whom a DBS
check has been carried out (due to reaching the “working regularly”
threshold), BBFO will simply inform the ringer when the check has been
successfully concluded and will keep the date of the check on file, for
reference should it be required.

Parental consent before taking on a young person as a ringing Trainee, the
Trainer must obtain a signed consent form from the parent/guardian. If you
have any concerns regarding the application of appropriate safeguarding
measures, or anything else concerning training young people to become
ringers, then of course the simplest option may be to ask for parental
supervision at all times. Key things to consider and plan for when training a
young person or child all members of the ringing group must uphold the highest
standards at all times when young people are present, including the use of
appropriate language. If you have knowledge that any individuals have failed
a DBS check, or that are deemed unsafe around young people for any reason,
they must not be permitted to attend the same ringing sessions as young
people. Plans must ensure that a young person never trains alone with an
adult, where abuse could potentially occur or accusations could be made;
ensure another adult is within sight or hearing, or make arrangements for a
parent/guardian to always be present. Be aware that misunderstandings over
innocent behaviour are always possible and it is far better never to end up in
the situation in the first place.

● Be careful about physical contact that could be misconstrued, for example;
first aid, awkward net extractions, cramped hides, sheltering under umbrellas
(if physical contact is unavoidable, explain it)
● Think about arrangements for personal hygiene
● Be aware of other key times to plan for, such as arrivals and departures; do
your best to ensure you don’t end up on your own with a young person
● If you are alone with a young person due to circumstances beyond your
control, contact the parents to let them know, ask them to be present, let them
know how long it is likely to be and what you are doing to resolve it
● It is advisable to apply the “more than one adult present” rule to contact
outside of an actual ringing session; if using email, you could copy in the parent
or guardian of the young person and instead of direct messaging (Facebook,
Twitter, etc) engage in more visible conversations, e.g. group forums What to
do if a potential safeguarding incident arises
● If you have concerns about another ringer, or if anyone else accuses you of
inappropriate conduct, you must act.

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● The person accused should be removed from the situation and not have
further contact with any young people until the matter has been investigated
and resolved.
● Where possible keep other young people away from any incident.
● As soon as possible, make notes on any incident (if possible, get them signed
by witnesses or parents) and make sure both the Ringer in Charge and the
BBFO Safeguarding Leads are made aware.
● If the emergency services were involved, make sure you know what follow-
up is expected, if any.

All allegations have to be investigated, by BBFO and potentially also by the
police. It should be remembered that allegations can cause extreme stress for
the individuals involved. Discretion is paramount except for those with a need
to know. If you are young person, child, parent or guardian and have a
concern If you are a young person yourself (or a parent or guardian), and have
concerns about the actions of adults, you need to know that it is fine to bypass
the ringing Trainer or group; you can contact BBFO and speak to the
Safeguarding Lead, other trusted member of staff, the police or NSPCC (0800
800 5000).

If a young person discloses a safeguarding issue to you
Training to ring is intense and personal and can result in healthy relationships
between generations. One result of this is that a young person may disclose an
incident from another part of their life to you as a trusted adult. Investigating a
significant concern is the remit of a trained professional; it is not the
responsibility of a non-professional and this includes using questioning that
could be considered as being leading. If a young person wants to talk and
discloses something of concern, never promise to keep a secret and always
report it to an appropriate professional. Any such disclosures should not
become salacious gossip and the individual should be treated with dignity. The
NSPCC offer a free advice line 0808 800 5000 for adults in this situation. You
should always feel enabled to go directly to the police or social services. If the
young person appears to be at immediate risk then contact the police.
Volunteers must report all concerns or allegations of abuse to the BBFO’s
Safeguarding Leads, either Steven Stansfield (07855 264151
[email protected]), or alternatively Dianne Charles (01212 490490
[email protected]).

Raising awareness about safeguarding It is important to be aware of the legal
framework, and the BBFO’s policies and specific scheme rules. However, rules
and laws can only go so far. It is likely that most offenders are never caught
and would not be identified through the DBS checks. In many ways, the
application of good practice is of greater practical import than the legal

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checks themselves. The most effective way of improving safeguarding is
through everyone having a wide awareness of the potential issues involved,
and feeling free to talk about potential concerns and strategies, in
combination with having systems and procedures in place, visible and actively
reviewed. Evidence shows that potential abusers are deterred from
attempting to engage with young people in organisations/activities where
safeguarding procedures are visible and openly and comfortably discussed.
Abuse is nothing new; it has always happened. Fortunately, you are unlikely to
encounter instances of abuse, and most children and young people that you
will have contact with will be living relatively carefree lives. Nevertheless, abuse
is a reality and we all need to be aware of the potential. Abuse can be defined
as any behaviour, often but not always systematic or repeated, in a
relationship between two or more people where one party seeks to gain and
exert power, or control over the other, especially by means of cruelty, violence
or neglect. To some extent, types of abuse have changed with time and some
practices that were once thought acceptable are now not, such as smoking
in front of children in confined spaces, or corporal punishment. Other forms of
abuse, such as online and via mobile technologies were not previously
possible; the internet has provided myriad ways for abusers to form their own
networks. Training to ring birds often involves repeated sessions in remote
places under difficult conditions. Some adult ringers may be ambivalent to the
involvement of young people, and many may have little experience in how to
interact with them.

Abuse is classified into a number of categories, of which some of the most
significant and potentially relevant to ringing are as follows:

● Physical abuse - where a child is caused pain, is hurt or injured, by direct force
or by the use of some instrument, or by neglect. Hitting or kicking a child is never
acceptable, and activities such as “play fighting” between young people
should be firmly discouraged.
● Emotional abuse - where a child is caused distress, emotional trauma or
psychological harm by severe or persistent verbal abuse, disparagement or
neglect. This could include inappropriately sarcastic humour, which children
often misinterpret, name calling and favouritism.
● Sexual abuse - where a child is used to satisfy the sexual desire of another,
physically or otherwise. This includes exposure to pornography, ‘sexting’,
inappropriate sexual discussions or comments, as well as unwelcome physical
contact. Although the age of sexual consent is 16, sexual contact between
supervising adult ringers and children under 18 is always inappropriate, as an
abuse of power.
● Neglect - the persistent failure to meet a child’s basic physical and/or
psychological needs, likely to result in the serious impairment of the child’s

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health or development. If you are on a winter ringing session in your best
thermal gear, be aware of the child who has lower quality clothing. Children
chill and overheat faster than adults. Always consider the availability of
suitable equipment, drinking water, shelter, toilet facilities, etc.

Abusers fall into four main categories:

● Parents, family and their friends. In other words, people known to their victims
in a social or family context. These account for the majority of abusers.
● People in authority. This includes teachers, youth leaders, the clergy, medics,
police, and potentially, in our context, Trainers or other senior ringers.
● Strangers. These are the least common in person, but the most common
online. These are the predatory paedophiles, the most feared abductors. They
are usually, but not always male, usually over 40, perhaps loners, but it is
important to recognise that abusers come from every segment of society.
● Young people themselves. Whether they are experimenting sexually, learning
about power, influence and bullying, or are unaware of the impact of their
own actions, it is estimated that young people make up around 30% of all
Anyone can fall victim to abuse, but the most vulnerable often have
characteristics in common:
● They are likely to be on their own.
● They are likely to have multiple issues in their lives (children at risk at home are
likely to be at risk elsewhere).
● They may be reluctant to reveal their abuse. Many suffer in silence until well
into adulthood. The NSPCC reports that 72% of victims do not report abuse at
the time and 31% had not told anyone until adulthood.

BBFO Safeguarding Leads: Steven Stansfield (07855 264151
[email protected]), or alternatively Dianne Charles (01212 490490
[email protected]).
NSPCC 0808 800 5000
Links to local safeguarding children boards (for each region across the UK)
Useful links:
safeguarding-training/category_p athway-13

Bardsey Bird and Field Observatory Policy Documents

Further guidance available online:
These guidance notes have been adapted from the BTO Safeguarding for
ringers’ documents

Statement on Vulnerable Beneficiaries

Bardsey Bird & Field Observatory wishes to encourage anyone to visit and stay
at the observatory and believes such a visit is of benefit to all. However,
Bardsey Bird & Field Observatory will not take direct responsibility for
young/vulnerable people as it is not in the charitable objectives of the Charity.
It is a matter of principal that anyone under 18 wishing to stay at the
observatory must be accompanied by a responsible/authorised adult. Any
vulnerable adult wishing to stay at the observatory would need to be
accompanied by an authorised adult or carer.

Bardsey Bird and Field Observatory Policy Documents

Volunteering policy

This policy sets out the broad principles for voluntary involvement in Bardsey
Bird & Field Observatory. It is of relevance to all within the organisation,
including volunteers, staff, members, and those elected or appointed to
positions of responsibility.

This policy is endorsed by the Trustees of Bardsey Bird & Field Observatory and
will be reviewed every five years, to ensure that it remains appropriate to the
needs of Bardsey Bird & Field Observatory and its volunteers.

Bardsey Bird & Field Observatory acknowledges that volunteers contribute in
many ways, that their contribution is unique and that volunteering can benefit
users of services, staff, local communities and the volunteers themselves.
Bardsey Bird & Field Observatory values the contribution made by volunteers
and is committed to involving volunteers in appropriate positions and in ways
which are encouraging, supportive and which develop volunteering. Bardsey
Bird & Field Observatory recognises its responsibility to arrange its volunteering
efficiently and sensitively so that the valuable gift of the volunteer's time is best
used to the mutual advantage of all concerned.

Volunteering is an important expression of citizenship as well as an important
component of democracy. Volunteers are people who are, unpaid and of
their own free will, contribute their time, energy and skills to benefit the

Statement of values and principles
Volunteering is a legitimate and crucial activity that is supported and
encouraged by Bardsey Bird & Field Observatory and is not intended to be a
substitute for paid employment. The role of volunteers complements but does
not replace the role of paid staff.

Appropriate steps will be taken to ensure that paid staff are clear about the
role of volunteers, and to foster good working relationships between paid staff
and volunteers.

Volunteers will not be used during times of industrial action to do the work of
paid staff.

The volunteer role is a gift relationship, binding only in honour, trust and mutual
understanding. No enforceable obligation, contractual or otherwise, can be
imposed on volunteers to attend, give or be set a minimum amount of time to
carry out the tasks involved in their voluntary activity. Likewise, the organisation
cannot be compelled to provide either regular tasks, payment or other benefit
for any activity undertaken by the volunteer.

Bardsey Bird and Field Observatory Policy Documents

Although volunteers offer time freely and willingly without binding obligation,
there is a presumption of mutual support and reliability. Reciprocal
expectations are acknowledged – both of what the organisation expects of
volunteers and what volunteers expect of the organisation.

Volunteer Co-ordination
All volunteers will have a nominated member of staff to offer guidance and
advice to help the volunteer carry out tasks effectively. Volunteers will be
informed of who to contact to receive support and supervision.

The nominated post holder with overall responsibility for the development of
voluntary activities within the organisation is the Warden. This person is
responsible for the management and welfare of the organisation's volunteers

Recruitment & Selection
Bardsey Bird & Field Observatory is committed to equal opportunities and
believes that volunteering should be open to all regardless of race, gender,
religion, sexual orientation, political beliefs or offending background that does
not create a risk to vulnerable groups including children. The acceptance of
volunteer assistance for a particular role is made on merit, the sole selection
criterion being the individual's suitability to carry out agreed tasks. Information
about the volunteer not relevant to the performance of the volunteering tasks
concerned will be disregarded by the organisation in terms of recruitment and

Volunteering opportunities will be widely promoted in ways that makes them
accessible to all members of the community.

All volunteers will be asked to produce two references and will be invited to
attend an informal interview. If the volunteer will be carrying out activities with
vulnerable groups (children and/or adults) there may be other recruitment
procedures carried out including asking a volunteer to undergo an enhanced
Disclosure and Barring Services (DBS) check. More detailed information will be
made available specific to legislative requirements and to the particular
volunteer position.

Volunteers will have a clear and concise task description. The task description
will be prepared in conjunction with the volunteer and the designated person
referred to above.

New volunteers will be properly inducted into the organisation.

Volunteers will be properly briefed about the activities to be undertaken and
given all the necessary information to enable them to perform with

Training & Development
All volunteers will be made aware of and have access to all the organisation's
relevant policies, including those relating to volunteering, health & safety,
safeguarding vulnerable groups and equal opportunities.

Bardsey Bird and Field Observatory Policy Documents

The development of training and support for volunteers is a high priority for the
organisation in order to equip them with the necessary information and skills to
carry out their tasks. It will be the responsibility of the designated person
referred to above to see that this training is provided. It is the responsibility of
the volunteer to attend relevant training.

Training in the supervision of volunteers will be provided for all those who have
direct responsibility for volunteers.

Support, Supervision and Recognition
Volunteers will have a named person to whom they can take their volunteering
concerns and seek guidance and support.

Volunteers will have access to regular support and supervision. This will enable
both the volunteer and the supervisor to identify, monitor and evaluate the
volunteer's involvement, recognise achievements and identify individual
training needs, including that relevant to their particular volunteering role and
to their wider personal development. The frequency, duration and format of
these sessions will be negotiated between the volunteer and the designated
officer referred to above.

Volunteers will be given the opportunity, where relevant, to share their views
and opinions with the organisation's wider staff, at staff meetings etc.

A process will be developed in order to give formal recognition of the
contribution of the organisation's volunteers (e.g. internal awards, articles in
newspapers and newsletters, thank you letters etc.) or outline any existing

Bardsey Bird & Field Observatory recognises that the reimbursement of
expenses incurred in travelling to and from the place of volunteering or in the
course of volunteering is important from an equal opportunities point of view.
However, due to the isolated nature of the island and limited financial
resources, Bardsey Bird & Field Observatory can only (but is not compelled to)
cover the boat fees for travelling to the island, any volunteer will need to find
their own way to Aberdaron.

The organisation's liability insurance policies include the activities of volunteers
and liability towards them.

The organisation does not insure the volunteer's personal possessions against
loss or damage

The organisation will advise the volunteer on its confidentiality policy and
procedures, where relevant. This would include those relating to personal
information held by the organisation relating to the volunteer.

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Settling Differences
The organisation aims to treat all volunteers fairly, objectively and consistently.
The organisation seeks to ensure that volunteers' views are heard, noted and
acted upon promptly and aim for a positive and amicable solution based on
the organisation's guidelines for settling differences.

The designated officer referred to above is responsible for handling problems
regarding volunteer complaints or conduct and these should be referred to
him/her. In the event of a problem, all relevant facts should be obtained as
quickly as possible. Support will be provided by the organisation to the
volunteer while it endeavours to resolve the problem in an informal manner. If
an informal resolution proves impossible, the organisation's wider grievance or
complaints policies and procedures (which include volunteers) will be referred
to. If a volunteer’s behaviour is repeatedly or seriously unacceptable, they
may be asked to change their role, or to leave the organization.

Rights and Responsibilities
The organisation recognises the rights of volunteers to:
• know what is (and what is not) expected of them
• have adequate support in their volunteering
• receive appreciation
• volunteer in a safe environment
• be insured
• know their rights and responsibilities if something goes wrong
• receive relevant out-of-pocket expenses
• receive appropriate training
• be free from discrimination
• be offered the opportunity for personal development

The organisation expects volunteers to:
• be reliable
• be honest
• respect confidentiality
• make the most of training and support opportunities
• carry out tasks in a way that reflects the aims and values of the organisation
• carry out tasks within agreed guidelines
• respect the work of the organisation and not bring it into disrepute
• comply with the organisation's policies

Bardsey Bird and Field Observatory Policy Documents

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