I treat volunteers, of which I have over 60,000 as employees from an information governance perspective. So they receive the same mandatory training that any employee or contractor would receive as the risk is the same. We track the delivery of the training through our volunteer management systems rather than through our HR systems. I and our volunteers are clear that just because I deliver and track their compliance training needs and delivery, the relationship is purely a volunteering arrangement and if they are not trained, they are not suitably qualified to volunteer for certain roles.
This also applies to managing their suitability to drive Trust vehicles and their ability to work with vulnerable groups
None of this affects their status as a volunteer and does not make them an employee
Regards
Neil
________________________________________
Neil Bell Information Security Manager
Data Protection, Information Security, IT Security
National Trust, Heelis, Kemble Drive, Swindon, Wiltshire, SN2 2NA
e-mail [log in to unmask]<mailto:[log in to unmask]>
99% compliant just isn't
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of FOI Kid
Sent: 20 October 2015 14:55
To: [log in to unmask]
Subject: Re: [data-protection] Volunteers and DP
I agree with Phil and Tim. But one challenge is to talk to HR/legal because if your agreement or contract with the volunteer is of a certain type, you leave the door open to them saying they are employees and suing.
It is a balancing act between employment risks and IG.
Bilal Ghafoor
@foikid
07926113401
On Tue, Oct 20, 2015 at 2:34 pm, Phil Bradshaw <[log in to unmask]<mailto:[log in to unmask]>> wrote:
In an ideal world:
Do not let volunteers anywhere near personal data for which you are the DC but make sure they are:
Voluntary workers (not the same thing) with whom you can have a contract and who IMO would class as 'employees' for the purposes of DP. Take responsibility for their training etc.
if you have a pure volunteer working on your PD then he must be a data processor (see the definition) so you must have a contract so he is not a volunteer and so ....
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