BYAFA Policy on the Secure Handling, Use, Storage and Retention of Disclosure Information
On implementation of Disclosure checks, in accordance with the relevant Codes of Practice regarding the correct handling, holding and destroying Disclosure information, for the purposes of assessing applicants' suitability for positions of trust, the British Youth American Football Association (BYAFA) will ensure the following policy is adhered to.
BYAFA will ensure that all individuals with access to disclosure information are aware of this policy and receive any relevant training and support.
A copy of this policy will be made available to any applicant for a post that requires a disclosure, and upon request to any other person who wishes to see it.
Usage
Disclosures will only be requested when necessary and relevant to a particular post.
The information provided on a disclosure certificate will only be used for the specific purpose for which it has been provided.
BYAFA will ensure that an individual’s consent is given before seeking a disclosure, and will seek their consent before using disclosure information for any purpose other than that for which it was requested.
Disclosure information will only be shared with those authorised to see it in the course of their duties.
Handling
BYAFA recognises that it is a criminal offence to disclose Disclosure information to any unauthorised person. Disclosure information will only be passed on to those who are authorised to see it in the course of their duties.
Additional disclosure information provided will not be disclosed to the applicant unless it affects any decision making process.
Storage and Access
Disclosure information will not be kept on an individuals personnel file.
- Disclosure information will be stored in a locked non-portable storage container.
- Access to the storage container will be strictly controlled and limited to those authorised to see this information in the course of their duties.
Retention
BYAFA will not keep Disclosures or Disclosure information for any longer than is required after a membership, recruitment or any other relevant decision has been taken. In general, this is no longer than six months. This is to allow for the resolution of any disputes or complaints.
- Disclosure information will only be retained for longer than this period in exceptional circumstances, and only after consulting the relevant disclosure body
The same conditions relating to secure storage and access will apply during any such period.
Disposal
The BYAFA will ensure that Disclosure information is immediately destroyed in a secure manner i.e. by shredding, pulping or burning, once the retention period has lapsed.
Disclosure information that is awaiting destruction will not be kept in any insecure receptacle (e.g. a waste bin or confidential waste sack).
No image or photocopy of the Disclosure information will be made, however the following details will be retained:
- Date of issue of disclosure
- Name of subject
- Disclosure type
- Position for which disclosure was requested
- Unique reference number of disclosure
- Recruitment decision taken.
Umbrella Bodies
Before acting as an Umbrella Body (one which processes applications for Disclosure on behalf of another organisation), BYAFA would take all reasonable steps to ensure that the organisation on whose behalf we would be acting can comply to the relevant Codes of Practice, and in full accordance with this policy. We would also take all reasonable steps to satisfy ourselves the organisation will handle, use, store, retain and dispose of Disclosure information in full compliance with the relevant Codes of Practice, and in full accordance with this policy. We would also ensure that any body or individual, at whose request applications for Disclosure are countersigned, has such a written policy and, if necessary, will provide a model policy for that body or individual to use or adapt for this purpose.