Privacy policy

The Stones Community Trust (Charity) trading as Stones In The Community (“we”, “our”, “us”) take your privacy very seriously.

This Privacy Notice sets out how we use and look after the personal information we collect from you. We are the data controller, responsible for the processing of any personal data you give us. We take reasonable care to keep your information secure and to prevent any unauthorised access to or use of it.

What personal data we hold on you

Personal data means any information about an individual from which that individual can be identified. We collect, use, store and transfer some personal data of our Participants (and their parents or guardians) and Volunteers. You provide information about yourself when you register with the Charity and by filling in forms at an event or online, or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, date of birth, address, e-mail address, phone number, gender, and the contact details of a third party in the case of emergency. We may also ask for relevant health information, which is classed as special category personal data for the purposes of your health, wellbeing, welfare and safeguarding. Where we hold this data, it will be with the explicit consent of the Participant or Volunteers, if applicable, the Participant’s parent or guardian. Where we need to collect personal data to fulfil Charity responsibilities and you do not provide that data, we may not be able honour or administer your enrolment.

Why we need your personal data

We will only use personal data for any purpose for which it has been specifically provided.

The reason we need ParticipanThe reason we need Participants’ or Volunteers personal data is to be able to run our Charity and administer events and provide the services you are signing up to when you register with the Charity. Our lawful basis for processing your personal data is that we have a contractual obligation to you as a Participant to provide the services you are registering for. We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Who we share your personal data with

When you become a Participant or Volunteer, your information, may be passed to our Grant funding agencies for support for our funding. We do not share your personal data with any selected third parties, suppliers and sub-contractors. We may however disclose your personal information to third parties to comply with any legal obligation; or to protect the rights, property, or safety of our Participants or others. The Charity’s data processing may require your personal data to be transferred outside of the UK. Where the Club does transfer your personal data overseas, it is with the sufficient appropriate safeguards in place to ensure the security of that personal data.

Communications

From time to time, we will contact our Participants and Volunteers. Communications will include but not be limited to renewal notifications etc. Communications will mainly be by email but could also include telephone. For Participants and Volunteers, we may set-up private messaging groups, exclusively for individual events, to communicate information.

Protection of your personal data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

How long we hold your personal data

We keep personal data on our Participants and Volunteers whilst they continue to be a Participant or Volunteer or are otherwise actively involved with the Charity. We will delete this data after a Participant or Volunteer has left or otherwise ended their involvement or sooner if specifically requested and we are able to do so. We may need to retain some personal data for longer for legal or regulatory purposes.

Your rights regarding your personal data

As a data subject, you may have the right at any time to request access to, rectification or erasure of your personal data; to restrict or object to certain kinds of processing of your personal data, including direct marketing; to the portability of your personal data and to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office about the processing of your personal data. As a data subject you are not obliged to share your personal data with the Charity. If you choose not to share your personal data with us, we may not be able to register or administer your involvement. We may update this Privacy Notice from time to time. If you have any questions about this Privacy Notice and/or the data the Charity holds on you, please contact:

Mike Littleboy, Chair Of Trustees
The Stones Community Trust
mike.littleboy@stonesinthecommunity.org
March 2025

Feedback & complaints policy

Date written: June 2025

Date of last update: June 2025

Date agreed and ratified by Chair of Trustees: June 2025

Date agreed and ratified by Board of Trustees: June 2025

Date of next full review: June 2027 This policy will be reviewed every other year and/or following any updates to national and local guidance and procedures.

Key Contacts:

Tori Campbell, Operations Manager – tori.campbell@stonesinthecommunity.org

Mike Littleboy, Chair of Trustees – mike.littleboy@stonesinthecommunity.org

Introduction 

The Stones Community Trust (SCT) also trading as Stones In The Community (SITC) objectives are to promote and support good outcomes in terms of health, development and educational achievement for all raising both physical and mental wellbeing. 

Policy statement

The SCT/SITC is committed to providing a high-quality service to all people we work with, including young people we support, our partners and volunteers.  We acknowledge and accept that on some occasions, things do not go to plan.  The purpose of this policy is to ensure all of our community and members of the public know how to provide feedback or make a complaint and ensure that the feedback or complaint is responded to appropriately and in a timely manner by the SCT/SITC.  Responsibility for this policy rests with the SCT/SITC’s Board of Trustees.

Definition and examples of feedback and complaints 

Feedback, for the purpose of this policy, is defined as an expression of a specific opinion or view on procedures, employees, partners, fundraising activities or quality of the SCT/SITC’s services. We are committed to ensuring the quality of our service and we want to be the best organisation to volunteer, support and most importantly be supported by.  Which is why feedback, including when we get things wrong, is important to us.  We will ensure all comments are recorded and considered, enabling improvements to be made where appropriate. 

A complaint, for the purpose of this policy, is defined as an expression of dissatisfaction about the SCT/SITC’s services, whether it is found to be justified or not.  This policy covers complaints by young people we support, our partners, volunteers and members of the public in relation to: 

• The standard of service we provide
• The behaviour of staff and volunteers working for the SCT/SITC
• Any other aspects of our work

How do I give feedback or make a complain?

Feedback and complaints can be submitted to the SCT/SITC in the following ways:

• Online – using our contact us form – Contact – Stones Community Trust
• Email – info@stonesinthecommunity.org
• Phone – 01622 606449
• Letter – writing to The Stones Community Trust, The Gallagher Stadium, James Whatman Way, Maidstone, Kent ME14 1LQ

If you are dissatisfied with any aspects of our work or services, we want to make sure that we investigate your complaint thoroughly and provide you with a timely response.  To allow us to do this, please provide as much information as possible when contacting us including: 

• The reason for your complaint
• Where and when it happened
• The name(s) of anyone involved (if known)
• The outcome you are hoping for
• Your contact details (name, address, daytime telephone number and/or email)

What happens next?

Complaints received about our Partners’ services, their staff or their volunteers will be directed to the relevant Partner who should instigate their own Complaints Policy and Procedures. Depending on the nature of the complaint against our Partners, the SCT/SITC may decide to investigate.  Due to confidentiality and legal restrictions, the SCT/SITC may not disclose the outcome of the investigation or any information gained during the investigation.

We will try to resolve the problem as quickly as possible and provide you with a full response within two working days.  However, sometimes we might need some extra time to investigate, in which case, we will let you know when you should expect to hear from us.  We aim to resolve all complaints within 28 working days of receipt.

If, for any reason, you aren’t happy with the resolution of your complaint, let us know as soon as possible.  Please tell us why you were not satisfied with our response and what you would like us to do to put things right.  Please either respond directly to the member of staff you have been liaising with or contact our Operations Manager as outlined above.  Your complaint will be escalated to the relevant Trustee.  The Trustee will review your complaint and respond within 7 workings days.  If you are not satisfied with the response from the Trustee, your complaint will be escalated to the Board of Trustees.  The Board of Trustees will review your complaint and respond within 7 working days.

Closing a complaint

The SCT/SITC will consider each complaint carefully and decide upon an appropriate course of action.  All complaints will be reviewed.  In some cases, it may not be possible to investigate or substantiate complaints, or it may fall outside of our responsibilities.  If you have made a complaint and provided contact details, you will be informed of any part of the investigation which may involve you directly.  However, due to confidentiality and legal restrictions, the SCT/SITC may not disclose the outcome of the investigation or any information gained during the investigation.  All complainants will be responded to as per the procedures and time frames set out above. 

If you are not satisfied with our response, you can contact the Charity Commission on 0300 066 9197 or visit their website www.charitycommission.gov.uk for advice. 

If your complaint relates to how we collect and use your personal information, you have the right to report your concerns to the UK data protection regulator, The Information Commissioner’s Office (ICO) www.ico.org.uk. 

All complaints related to our fundraising practices can be escalated to the Fundraising Regulator on 0300 999 3407 or on their website www.fundraisingregulator.org.uk .  If you receive a response from us about a fundraising matter that you are not happy with, the Fundraising Regulator requires that you notify them of this within 8 weeks of hearing from us.

Unreasonable persistent complaints

There are a small number of complainants who, because of the frequency, nature and quality of their contact with the SCT/SITC, hinder our consideration of theirs, or other people’s, complaints. We refer to such complainants as ‘unreasonably persistent complainants’ and, exceptionally, we will take action to limit their contact with our staff and volunteers. 

The decision to restrict access to our staff and volunteers will be taken by the Chair of Trustees in consultation with the Operations Manager and will normally follow a prior warning to the complainant.  Any restrictions imposed will be appropriate and proportionate.  The options we are most likely to consider are: 

• requesting contact in a particular form (for example, letters only)
• requiring contact to take place with a named individual
• restricting telephone calls to specified days and times
• and/or asking the complainant(s) to enter into an agreement about their future contact with us

In exceptional cases, contact with a complainant may be terminated without restrictions first being imposed.  This will be dependent on the individual circumstances, but would be an option if the complainant’s behaviour is particularly severe, or includes threats to staff or volunteers. 

In all cases where we decide to treat someone as an unreasonably persistent complainant, we will write to tell the complainants why we believe their behaviour falls into that category, what action we are taking and the duration of that action.  We will also tell them how they can challenge the decision if they disagree with it.  If we decide to carry on treating someone as an unreasonably persistent complainant and we are still investigating their complaint six months later, we will carry out a review and decide if restrictions will continue. 

Where a complainant whose case is closed persists in communicating with us about it, we may decide to terminate contact with that complainant about the matter.  In such cases, we will read all correspondence from that complainant, but unless there is fresh evidence which affects our decision on the complaint, we will simply acknowledge it or place it on the file with no acknowledgement. 

New complaints from people who have come under this procedure will be treated on their merits.

Confidentiality

While the SCT/SITC will treat any information given to us sensitively, we cannot always guarantee to keep your identity confidential as we may need to disclose your identity if required to do so by law.  It should also be noted that your identity may be recognisable to others during the investigation due to the nature of the complaint, although we will endeavour to limit the risk of this where possible. 

All complaints will be logged by the Operations Manager for reporting and monitoring purposes. Details of complaints are kept in accordance with our data protection policy.

Health & safety policy

This is a core policy that forms part of the induction for all staff. It is a requirement that all members of staff have access to this policy and sign to say they have read and understood its contents.

Date written: July 2025 

Date of last update: July 2025 

Date agreed and ratified by Health and Safety Trustee: July 2025 

Date agreed and ratified by Board of Trustees: July 2025 

Date of next full review: July 2026 

Checked by Kent County Council LADO Health and Safety Advisory Service: July 2025

This policy will be reviewed at least annually and/or following any updates to national and local guidance and procedures and where necessary, improves our health and safety performance.  This Policy will also be reviewed after a serious incident or legislative change. 

Key Contacts: 

Mike Littleboy, Chair of Trustees – mike.littleboy@stonesinthecommunnity.org

Mike Cogger, Health & Safety Trustee – mike.cogger@stonesinthecommunity.org

Tori Campbell, Operatiomns Manager – tori.campbell@stonesinthecommunity.org

Introduction 

The Stones Community Trust (SCT) trading as Stones In The Community (SITC) acknowledges and accepts, as one of its responsibilities, the Health and Safety and well-being of everybody who partake in activities in the name of the Trust. 

We have a comprehensive Health and Safety policy that meets the statutory requirements as laid out in the Health and Safety at Work Act 1974. 

Scope 

The SCT/SITC is committed to providing a safe working, coaching, teaching and learning environment for all personnel, learners and any related third parties. 

It is ultimately the responsibility of the Operations Manager to ensure that this procedure is implemented, published and accessible to all personnel, participants and any relevant third parties.  However, the Staff and Coaches specific to each programme are responsible for ensuring this information is fully understood by their team and by the participants. 

Everybody has a legal responsibility, as stated under Section 7 of the Health and Safety at Work Act 1974, to do everything practicable to prevent an accident or injury to themselves and to fellow learners and/or personnel.  We consider potential health and safety hazards that may affect anyone who comes into contact with our business activities. 

Objectives 

The SCT/SITC aims to promote health and safety, so far as reasonably practicable, by: 

• providing and maintaining safe equipment and environment, including a means of access in a condition that is safe and without risk to health
• preventing accidents and cases of work-related ill health and safety hazards arising from work activities via effective risk identification, assessment and implementation of control measures
• implementing regular emergency and evacuation procedures in case of a significant incident
• protecting the health and safety and welfare of individuals and vulnerable people via systematic risk management
• engaging with participants, personnel and any related third parties, to provide relevant information, instruction, training and supervision, as is necessary to ensure health and safety
• providing adequate training and allocating appropriately qualified members of personnel to identify and control potentially hazardous situations/environments
• complying with statutory regulation on health and safety and welfare of learners, personnel and any related third parties

This list is not exhaustive and represents the general principles followed by The SCT/SITC in respect of health and safety. 

Procedure 

As we are a small to medium organisation operating across more than one site, we have dedicated individuals who are responsible for Health and Safety at each of our programmes.  This could be the Leader or Head Coach(es).  It is ultimately the responsibility of the Operations Manager to ensure that this procedure is implemented, published and accessible to all personnel, participants and any relevant third parties. 

However, as we are the Community Charity of Maidstone United FC, we (the SCT/SITC) have access to their Health and Safety Advisers including their Safety Officer, John Harvey who provides an external health and safety adviser/trainer that we can call upon to assist us. 

The SCT/SITC ensure that suitable and sufficient control measures are in place to reduce identified risks in the delivery of all courses/programmes.  Arrangements are in place to manage and control such risks associated with the nature and scale of the work that we do.  This includes regular training for our staff as well as volunteers, preparation and provision of risk assessments. Most of our Trustees and all of our Technical Staff have sufficient Health and Safety skills and qualifications. 

All personnel required to conduct risk assessments will be given the appropriate training and/or will be made aware of what is expected of them in advance.  All recorded risk assessments are made available to all relevant staff who must ensure that all control and/or recovery measures plans are complied with and related actions recorded. 

Where staff identify additional risks which were not previously identified or where a current risk assessment is not in place, a risk assessment must be conducted. 

The SCT/SITC endeavour to ensure subcontractors, suppliers and any other organisations providing services on our behalf have appropriate health and safety policies, training and knowledge and are, in all other respects, compliant with health and safety legislation.  This includes checking how up-to-date policy, procedures and risk assessments are; checking appropriate qualifications and experience of named health and safety practitioners; checking how up to date the health and safety training for employees; and checking enforcement history of the organisation. 

A copy of our Feedback and Complaints Policy is available to all. 

Safer recruitment policy

Policy Statement

The Stones Community Trust trading as Stones In The Community (SITC) are committed to promoting the welfare of all children and adults who use and interact with our services and for keeping them safe. 

In line with the equal opportunities policy, SITC is committed to equality, valuing diversity and working inclusively across all its activities – and this applies also to the selection, recruitment and induction of new staff and volunteers. 

It is recognised that some organisations are in the fortunate position to be able to employ staff. While these guidelines have special emphasis on recruiting volunteers to work with children and young people, they should also be applied to recruitment of paid staff.

What is Safer Recruitment? 

Safer Recruitment is a process designed to protect children’s and adults at risk welfare at every point, by supporting those leading an employment process to identify and deter or reject individuals from jobs or opportunities if they are deemed to not be suitable to work with children and adults at risk. 

Every Employer requires a recruitment policy in place to ensure job applicants are considered equally and fairly, and are not discriminated against based on their race, nationality, ethnicity, religion, gender, sexual orientation, marital or civil partner status, disability, or age. Safer Recruitment takes this further. 

Safer Recruitment pre-employment checks make sure that applicants’ references have been cross-checked and that they have proof of identity. It also ensures that criminal convictions have been declared and that candidates have an up-to-date DBS certificate prior to employment. 

Why is Safer Recruitment Important? 

Safer Recruitment practices are a key part of creating safe environments for children and adults at risk. By ensuring the safety of the staff and volunteers that work in places like football clubs and associated Community Club Organisations the people that need to be safeguarded have access to places where they can feel confident that they will be safe from harm. It is also important to establish Safer Recruitment standards and procedures because it is one of the most effective ways of preventing abuse or mistreatment in a variety of institutions.

Our Safer Recruitment process demonstrates that we are committed to keeping the people in our organisation safe.  

The FA’s Policy on DBS Checks 

As part of our safeguarding children strategy, The FA requires those working in eligible roles with children and young people to undertake a DBS Enhanced Check. This is in line with legislation and government guidance and is standard practice. 

The FA provides the framework and guidance for DBS Checks in football. The leagues and clubs must implement this to ensure those required to have DBS Checks actually have them.   

Where the DBS Check highlights relevant information, this is investigated further by the FA and a risk assessment is carried out to establish whether they will be accepted to work with children and young people in football. 

Activities that require a DBS Check 

Not everyone is eligible for an enhanced DBS check. 

The FA does not determine who is eligible, this is governed by legislation and government guidance and depends on the tasks that are due to be undertaken within a given job role. 

In brief, this means a DBS Check is required for anyone aged 16 years or over who undertakes any potentially unsupervised roles working directly with children and young people under the age of 18.

These activities include managing, training, coaching, and supervising as well as giving advice or guidance on wellbeing, caring for children, or driving a vehicle solely for children on behalf of a club or organisation.  All coaches and managers working directly with under-18 players must hold a current, FA-accepted DBS Check.  This includes managers/coaches who operate in the Open Age Game where they have under-18 players.  

What are the 8 Steps to Safer Recruitment?

Step 1 – Role profile