Policies and Procedures




































    1. 1.1 Definitions: 

      • Automated Processing: any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing. 
      • Charity Personnel: all employees, workers, contractors, agency workers, consultants, volunteers, trustees, members and others. 
      • Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject's wishes by which they, by a statement or by a clear positive action, signify agreement to the Processing of Personal Data relating to them. 
      • Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the UK GDPR. We are the Controller of all Personal Data relating to our Charity Personnel and Personal Data used by the Charity for our own purposes. 
      • Criminal Convictions Data: means personal data relating to criminal convictions and offences and includes personal data relating to criminal allegations and proceedings.  
      • Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data. 
      • Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity.
      • Explicit Consent: consent which requires a very clear and specific statement (that is, not just action). 
      • UK GDPR: the retained EU law version of the General Data Protection Regulation ((EU) 2016/679).  
      • Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person's actions or behaviour.  
      • Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach. 
      • Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies: separate notices setting out information that may be provided to Data Subjects when the Charity collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, participant privacy notices or the website privacy policy) or they may be stand-alone, one-time privacy statements covering Processing related to a specific purpose. 
      • Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosingerasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties. 
      • Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure. 
      • Special Categories of Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.  


    This Data Protection Policy sets out how Planet Earth Games ("we", "our", "us", "the Charity") handle the Personal Data of our participants, suppliers, workers, volunteers and other third parties.  

    This Data Protection Policy applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present workers, volunteers, participants, supplier contacts, website users or any other Data Subject.  

    This Data Protection Policy applies to all Charity Personnel ("you", "your"). You must read, understand and comply with this Data Protection Policy when Processing Personal Data on our behalf. This Data Protection Policy sets out what we expect from you for the Charity to comply with applicable law. Your compliance with this Data Protection Policy is mandatory.  

    This Data Protection Policy is an internal document and cannot be shared with third parties (including regulators) without prior authorisation from the board of trustees. 

    1. 3. SCOPE 

    We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times 

    Please contact the board of trustees with any questions about the operation of this Data Protection Policy or the UK GDPR or if you have any concerns that this Data Protection Policy is not being or has not been followed. In particular, you must always contact the board of trustees in the following circumstances:  

    1. a) if you are unsure of the lawful basis which you are relying on to process Personal Data (including the legitimate interests used by the Charity) (see paragraph 5.1);  

    1. b) if you need to rely on Consent and/or need to capture Explicit Consent (see paragraph 6); 

    1. c) if you need to draft Privacy Notices (see paragraph 7);  

    1. d) if you are unsure about the retention period for the Personal Data being Processed (see paragraph 11); 

    1. e) if you are unsure about what security or other measures you need to implement to protect Personal Data (see paragraph 12.1); 

    1. f) if there has been a Personal Data Breach (paragraph 13); 

    1. g) if you are unsure on what basis to transfer Personal Data outside the UK (see paragraph 14); 

    1. h) if you need any assistance dealing with any rights invoked by a Data Subject (see paragraph 15);  

    1. i) whenever you are engaging in a significant new, or change in, Processing activity or plan to use Personal Data for purposes other than what it was collected for;  

    1. j) if you plan to undertake any activities involving Automated Processing including profiling; 

    1. k) if you need help complying with applicable law when carrying out direct marketing activities (see paragraph 20); or 

    1. l) if you need help with any contracts or other areas in relation to sharing Personal Data with third parties (including our vendors) (see paragraph 21). 


    We adhere to the principles relating to Processing of Personal Data set out in the UK GDPR which require Personal Data to be: 

    1. a) Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency);  

    1. b) collected only for specified, explicit and legitimate purposes (Purpose Limitation); 

    1. c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation);  

    1. d) accurate and where necessary kept up to date (Accuracy); 

    1. e) not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation); 

    1. f) Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality); 

    1. g) not transferred to another country without appropriate safeguards being in place (Transfer Limitation); and 

    1. h) made available to Data Subjects and allow Data Subjects to exercise certain rights in relation to their Personal Data (Data Subject's Rights and Requests). 

    We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability). 


    Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject. 

    You may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The UK GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.  

    The UK GDPR allows Processing for specific purposes, some of which are set out below: 

    1. a) the Data Subject has given his or her Consent; 

    1. b) the Processing is necessary for the performance of a contract with the Data Subject; 

    1. c) to meet our legal compliance obligations;  

    1. d) to protect the Data Subject's vital interests; or 

    1. e) to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects.  

    You must identify and document the legal ground being relied on for each Processing activity. 

    1. 6. CONSENT 

    A Controller must only process Personal Data on the basis of one or more of the lawful bases set out in the UK GDPR, which include Consent. 

    A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters.  

    Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured. Consent may need to be refreshed if you intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented.  

    When processing Special Category Data or Criminal Convictions Data, we will usually rely on a legal basis for processing other than Explicit Consent or Consent if possible. Where Explicit Consent is relied on, you must issue a Privacy Notice to the Data Subject to capture Explicit Consent.   

    You will need to evidence Consent captured and keep records of all Consents so that the Charity can demonstrate compliance with Consent requirements. 


    The UK GDPR requires Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. The information must be provided through appropriate Privacy Notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them. 

    Whenever we collect Personal Data directly from Data Subjects, we must provide the Data Subject with all the information required by the UK GDPR including the identity of the Controller, how and why we will use, Process, disclose, protect and retain that Personal Data through a Privacy Notice which must be presented when the Data Subject first provides the Personal Data.  

    When Personal Data is collected indirectly (for example, from a third party or publicly available source), we must provide the Data Subject with all the information required by the UK GDPR as soon as possible after collecting or receiving the data. We must also check that the Personal Data was collected by the third party in accordance with the UK GDPR and on a basis which contemplates our proposed Processing of that Personal Data.  


    Personal Data must be collected only for specified, explicit and legitimate purposes. It must not be further Processed in any manner incompatible with those purposes.  

    You cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes and they have Consented where necessary. 


    Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed. 

    You may only Process Personal Data when performing your duties requires it. You cannot Process Personal Data for any reason unrelated to your duties.  

    You may only collect Personal Data that you require for your duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes. 

    You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised.  

    1. 10. ACCURACY 

    Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate. 

    You will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data. 


    You must not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.  

    You will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require. This includes requiring third parties to delete that data where applicable.  

    You will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice.  


    Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.


    We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. You are responsible for protecting the Personal Data we hold. You must implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data. You must exercise particular care in protecting Special Categories of Personal Data and Criminal Convictions Data from loss and unauthorised access, use or disclosure. 

    You must follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested. 

    You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows: 

    1. a) Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it; 

    1. b) Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed; and 

    1. c) Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.  

    You must comply with and not attempt to circumvent the administrative, physical and technical safeguards we implement and maintain in accordance with the UK GDPR and relevant standards to protect Personal Data.  


    The UK GDPR requires Controllers to notify any Personal Data Breach to the Information Commissioner and, in certain instances, the Data Subject.  

    We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so. 

    If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the board of trustees. You should preserve all evidence relating to the potential Personal Data Breach.  


    The UK GDPR restricts data transfers to countries outside the UK to ensure that the level of data protection afforded to individuals by the UK GDPR is not undermined. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country.  

    You may only transfer Personal Data outside the UK if one of the following conditions applies: 

    1. a) the UK has issued regulations confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subject's rights and freedoms;  

    1. b) appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved for use in the UK, an approved code of conduct or a certification mechanism; 

    1. c) the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or 

    1. d) the transfer is necessary for one of the other reasons set out in the UK GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest. 


    Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to: 

    1. a) withdraw Consent to Processing at any time; 

    1. b) receive certain information about the Controller's Processing activities; 

    1. c) request access to their Personal Data that we hold; 

    1. d) prevent our use of their Personal Data for direct marketing purposes;  

    1. e) ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;  

    1. f) restrict Processing in specific circumstances; 

    1. g) challenge Processing which has been justified on the basis of our legitimate interests or in the public interest; 

    1. h) request a copy of an agreement under which Personal Data is transferred outside of the UK;  

    1. i) object to decisions based solely on Automated Processing, including profiling; 

    1. j) prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else; 

    1. k) be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms; 

    1. l) make a complaint to the supervisory authority; and 

    1. m) You must verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade you into disclosing Personal Data without proper authorisation).  

    You must immediately forward any Data Subject request you receive to the board of trustees. 


    The Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.  

    1. 17. RECORD KEEPING 

    The UK GDPR requires us to keep full and accurate records of all our data Processing activities.  

    You must keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects' Consents and procedures for obtaining Consents. 

    These records should include, at a minimum, the name and contact details of the Controller, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data's retention period and a description of the security measures in place.  


    We are required to ensure all Charity Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.  

    You must regularly review all the systems and processes under your control to ensure they comply with this Data Protection Policy and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.  


    We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles.  

    You must assess what Privacy by Design measures can be implemented on all programmes, systems or processes that Process Personal Data by taking into account the following: 

    • the state of the art; 
    • the cost of implementation; 
    • the nature, scope, context and purposes of Processing; and 
    • the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing. 

    Controllers must also conduct DPIAs in respect to high-risk Processing.  

    You should conduct a DPIA (and discuss your findings with the board of trustees) when implementing major system or business change programs involving the Processing of Personal Data including: 

    • use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes); 
    • Automated Processing including profiling;  
    • large-scale Processing of Special Categories of Personal Data or Criminal Convictions Data; and  
    • large-scale, systematic monitoring of a publicly accessible area. 

    A DPIA must include: 

    • a description of the Processing, its purposes and the Controller's legitimate interests if appropriate;  
    • an assessment of the necessity and proportionality of the Processing in relation to its purpose;  
    • an assessment of the risk to individuals; and  
    • the risk mitigation measures in place and demonstration of compliance. 


    We are subject to certain rules and privacy laws when marketing to participants.  

    For example, a Data Subject's prior consent is required for electronic direct marketing (for example, by email or text). The limited exception for existing customers known as "soft opt-in" allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.  

    The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information. 

    A Data Subject's objection to direct marketing must be promptly honoured. If an individual opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future. 


    Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.  

    You may only share the Personal Data we hold with other Charity Personnel if the recipient has a role-related need to know the information. 

    You may only share the Personal Data we hold with third parties, such as our service providers or partners, if: 

    1. a) they have a need to know the information for the purposes of providing the contracted services;  

    1. b) sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject's Consent has been obtained; 

    1. c) the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place; 

    1. d) the transfer complies with any applicable cross-border transfer restrictions; and  

    1. e) a fully executed written contract that contains UK GDPR-approved third party clauses has been obtained. 


    We keep this Data Protection Policy under regular review. This Data Protection Policy does not override any applicable national data privacy laws and regulations in countries where the Charity operates. 



















    The corporate information, records and data of Planet Earth Games is important to how we conduct business. 

    There are legal and regulatory requirements for us to retain certain data, usually for a specified amount of time. We also retain data to help Planet Earth Games operate and to have information available when we need it. However, we do not need to retain all data indefinitely, and retaining data can expose us to risk as well as be a cost to the organisation. 

    This Data Retention Policy explains our requirements to retain data and to dispose of data and provides guidance on appropriate data handling and disposal.  

    Failure to comply with this policy can expose us to fines and penalties, adverse publicity, difficulties in providing evidence when we need it and in running our business. 

    This policy may be amended at any time. 


    This policy covers all data that we hold or have control over. This includes physical data such as hard copy documents, contracts, notebooks, letters and invoices. It also includes electronic data such as emails, electronic documents, audio and video recordings. It applies to both personal data and non-personal data. In this policy we refer to this information and these records collectively as "data". 

    This policy covers data that is held by third parties on our behalf, for example cloud storage providers or offsite records storage. It also covers data that belongs to us but is held on personal devices.  

    This policy explains the differences between our formal or official records, disposable information, confidential information belonging to others, personal data and non-personal data. It also gives guidance on how we classify our data. 


    Through this policy, and our data retention practices, we aim to meet the following commitments: 

    We comply with legal and regulatory requirements to retain data. 

    We comply with our data protection obligations, in particular to keep personal data no longer than is necessary for the purposes for which it is processed (storage limitation principle). 

    We handle, store and dispose of data responsibly and securely. 

    We create and retain data where we need this to operate our business effectively, but we do not create or retain data without good business reason. 

    We allocate appropriate resources, roles and responsibilities to data retention. 

    We regularly monitor and audit compliance with this policy and update this policy when required. 


    We aim to comply with the laws, rules, and regulations that govern our organisation and with recognised compliance good practices. All Planet Earth Games employees, trustees and volunteers must comply with this policy, the Record Retention Schedule, any communications suspending data disposal and any specific instructions from the Board of Trustees. Failure to do so may subject us to serious civil and/or criminal liability. It is therefore the responsibility of everyone to understand and comply with this policy. 


    Formal or official records. Certain data is more important to us and is therefore listed in the Record Retention Schedule. This may be because we have a legal requirement to retain it, or because we may need it as evidence of our transactions, or because it is important to the running of our business. Please see paragraph 6.1 below for more information on retention periods for this type of data.  

    Disposable information. Disposable information consists of data that may be discarded or deleted at the discretion of the user once it has served its temporary useful purpose and/or data that may be safely destroyed because it is not a formal or official record as defined by this policy and the Record Retention Schedule. Examples may include: 

    Duplicates of originals that have not been annotated. 

    Preliminary drafts of letters, memoranda, reports, worksheets, and informal notes that do not represent significant steps or decisions in the preparation of an official record. 

    Spam and junk mail. 

    Please see paragraph 6.2 below for more information on how to determine retention periods for this type of data. 

    Personal data. Both formal or official records and disposable information may contain personal data; that is, data that identifies living individuals. Data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation). See paragraph 6.3 below for more information on this. 

    Confidential information belonging to others. Any confidential information that an employee, trustee of volunteer may have obtained from a source outside of Planet Earth Games must not, so long as such information remains confidential, be disclosed to or used by us. Unsolicited confidential information submitted to us should be refused, returned to the sender where possible, and deleted, if received via the internet.  


    Formal or official records. Any data that is part of any of the categories listed in the Record Retention Schedule contained in the Annex to this policy, must be retained for the amount of time indicated in the Record Retention Schedule. A record must not be retained beyond the period indicated in the Record Retention Schedule, unless a valid business reason (or notice to preserve documents for contemplated litigation or other special situation) calls for its continued retention.  

    Disposable information. The Record Retention Schedule will not set out retention periods for disposable information. This type of data should only be retained as long as it is needed for business purposes. Once it no longer has any business purpose or value it should be securely disposed of.  

    Personal data. As explained above, data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation). Where data is listed in the Record Retention Schedule, we have taken into account the principle of storage limitation and balanced this against our requirements to retain the data. Where data is disposable information, you must take into account the principle of storage limitation when deciding whether to retain this data.  

    What to do if data is not listed in the Record Retention Schedule. If data is not listed in the Record Retention Schedule, it is likely that it should be classed as disposable information. However, if you consider that there is an omission in the Record Retention Schedule, or if you are unsure, please contact the board of trustees. 


    Storage. Our data must be stored in a safe, secure, and accessible manner. Any documents and financial files that are essential to our business operations during an emergency must be duplicated and/or backed up on a regular basis. 

    Destruction. The destruction of confidential, financial, and employee-related hard copy data must be conducted by shredding if possible. Non-confidential data may be destroyed by recycling. The destruction of electronic data must be performed in accordance with good practice.  

    The destruction of data must stop immediately if we are involved in a legal claim or an official investigation (see next paragraph). Destruction may begin again once the requirement for preservation has been lifted. 


    If you believe, that certain records are relevant to current litigation or contemplated litigation (that is, a dispute that could result in litigation), government investigation, audit, or other event, you must preserve and not delete, dispose, destroy, or change those records, including emails and other electronic documents, until the board of trustees has confirmed that those records are no longer needed. Preserving documents includes suspending any requirements in the Record Retention Schedule and preserving the integrity of the electronic files or other format in which the records are kept.    

    In addition, you may be asked to suspend any routine data disposal procedures in connection with certain other types of events, such as our merger with another organisation or the replacement of our information technology systems. 


    Questions about the policy. Any questions about this policy should be referred to the board of trustees.  


    Reporting policy breaches. If you feel that you or someone else may have breached this policy, you should report the incident immediately to the board of trustees. 

    No one will be subject to and we do not allow, any form of discipline, reprisal, intimidation, or retaliation for reporting incidents of inappropriate conduct of any kind, pursuing any record destruction claim, or co-operating in related investigations. 


    Planet Earth Games establishes retention or destruction schedules or procedures for specific categories of data. This is done to ensure legal compliance (for example with our data protection obligations) and accomplish other objectives, such as protecting intellectual property and controlling costs. You should comply with the retention periods listed in the record retention schedule below.  

    If you hold data not listed below, please refer to the Planet Earth Games Data Retention Policy. If you still consider your data should be listed, if you become aware of any changes that may affect the periods listed below or if you have any other questions about this record retention schedule, please contact the board of trustees. 





    Signed contracts and related correspondence

    Six years after the contract ends.

    Limitations Act 1980


    Annual Accounts


    Best Practice

    Gift Aid Records

    Six years from the end of the financial year in which the transaction was made

    Best Practice

    Grant Applications and Awards

    A minimum of ten years

    Best Practice

    Invoices – capital items

    A minimum of ten years after the end of the tax year to which they relate

    Best Practice

    Correspondence relating to donations

    Six years from the end of the financial year in which the transaction was made

    Best Practice


    Board Minutes

    A minimum of ten years

    Best Practice

    Insurance Policies, Claims and Correspondence

    Three years after lapse or settlement

    Best Practice

    Employers Liability Insurance Certificate

    Forty years

    Employers Liability (Compulsory Insurance) Regulations 1998

    Health and Safety Records

    Three years

    Best Practice

    Details of Injuries or Accident Reports/Records

    Six years from time of accident occurring.

    Best Practice


    Information relating to recruitment.

    Seven months after notifying candidates of the outcome of the recruitment exercise

    Equality Act 1980

    Personnel records

    Six years after appointment has ceased.

    Best Practice










    1. c) PROCUREMENT 




    In collaboration with partners, we organise and deliver events, experiences and activities that create positive behaviour change. 


    The Chief Executive Officer is responsible for ensuring that the sustainability policy is implemented. However, all employees and Trustees have a responsibility to ensure that the aims of the policy are met. 


    We are committed to: 

    • Comply with and continually strive to exceed all relevant regulatory requirements, 
    • Continually improve and monitor our sustainability performance,
    • Consider sustainability factors in all business decisions
    • Increase awareness of sustainable behaviours for all stakeholders through education and training



    Our biggest potential impact is through the events, experiences and activities we deliver. Planet Earth Games (PEG) will endeavour to ensure all physical and virtual events we organise comply with the highest sustainability standards and aim to minimise environmental impact and maximise positive impact. 

      • Be at the forefront of best sustainable practice in sport: We will work closely with industry partners including the British Association of Sustainable Sport (BASIS) and individual National Governing Bodies to deliver the best current sustainable practice in UK sport. We recognise the aims, definitions and structure provided by The European Sports Charter, especially Article 10, which refers specifically to sport, and sustainable development. It requires that sporting activities be adjusted to the planet’s limited resources and are carried out in accordance with the principles of sustainable development and balanced management of the environment. We will also seek to collaborate with sector partners to develop innovative products and services to advance the wider sustainability in sport movement.   


    • Act in line with the 5 principles set out in the United Nations Sports for Climate Action framework.  


        1.                   Undertake systematic efforts to promote greater environmental responsibility;

        2.                   Reduce overall climate impact;

        3.                   Educate for climate action;

        4.                   Promote sustainable and responsible consumption;

        5.                   Advocate for climate action through communication.


        • Minimising the environmental impact of our operations and activities we organise:

        o   Mindful of the carbon impact – we will encourage attendees and stakeholders to consider their carbon footprint in reaching our events, encouraging low carbon transportation.

        o   Follow the waste hierarchy- We will ensure to follow the waste hierarchy in the organisation of our events . We aim to leave no trace on, or improve, the natural environment at every event location through encouraging activities like litter picking and plogging, whilst educating those attending as to how they can minimise their impact on the planet we all live on.   

        o   We will avoid single use plastics  - We will avoid items such as plastic water bottles or any single use items at our events.  We will also make this a prerequisite of any third-party vendor at our events. 

        o   Advocate and practice the use of recycled materials where it is environmentally sustainable to do so: Actively promote the use of recycled materials that are environmentally sustainable, including being a platform for like-minded organisations to showcase and promote products and services that are environmentally sustainable to our audiences. 

        o   Mindful of wider environmental footprint- we will organise the event conscious of wider resource use including water and energy


        • Educate, influence and inspire anyone who attends or engages with our events on more environmentally sustainable behaviour: We will endeavour to educate, influence and inspire all our audiences to consider more environmentally sustainable behaviour through our online and offline interactions with them.


        • Report our Impact: Each year we will publish an impact report of our work as a charity, starting with a focus on our events and within this will be data and insights around our direct and indirect environmental impact.



          PEG has no permanent office or place of work.  Activities delivered by the PEG are typically through venue hire or online platforms. However, we are committed to ensure our employees and trustees adhere to high sustainability standards and behaviours. 

          We will ensure to minimise our operational impacts on the environment through the generation of pollutants. This includes managing the use and carbon intensity of energy, the frequency and mode of transport deployment and our working processes such as us of remote meetings. 

          • Transportation - We will reduce the need to travel, promoting use of video conferencing and restricting to necessity trips only and use public transport and low carbon alternatives as the priority mode of transport
          • Office Supplies - We will follow the waste hierarchy - minimising the use of office supplies – paper, packing etc where possible, and favour products with the highest sustainability standards
          • Energy and Water – we will act with heightened awareness of resource use in any facilities worked in i.e. energy and water conservation
          • Training and sharing of best practice – our employees and trustees will endeavour to demonstrate best practice sustainable behaviours and help inform and educate each other

                c) PROCUREMENT

                Through selection and engagement, we will prioritise suppliers and third-party vendors that uphold the highest environmental standards and credentials, sharing or ethos. 

                We will work to the following principles: 


                    • Prioritise local suppliers where possible
                    • Prioritise responsibly sourced products
                    • Prioritise recycled products, minimise packaging
                    • Undertake appropriate due diligence on environmental claims
                    • Work collaboratively with suppliers to improve sustainability performance


                        5. PARTNERS AND AMBASSADORS

                        As PEG are committed to being an industry leader in sustainability in sport, we want to ensure that any partners we work with also uphold stringent sustainability standards. Each partner organisation will be expected to be meeting or working towards at least one of the following criteria: 


                            • ISO2012 standard
                            • B Corps Certification;
                            • Signatory of the United Nations; Sports for Climate Action Framework; working towards the five principles;
                            • Certified against Council for Responsible Sport Standard
                            • Understands their key sustainability impacts and has a policy to address them. 

                              We acknowledge the different stages our partners may be on their sustainability journey and welcome a discussion about their impact. PEG withholds the right to choose not work with an organisation who we feel doesn’t reflect our ethos and ambition. 

                              Each Ambassador whom we work with will be made aware of our ethos and sustainability policy and be an advocate for environmental sustainability and best practice. 

                              6. POLICY DEVELOPMENT AND IMPROVEMENT

                                  • We are committed to reviewing and updating this policy on at least an annual basis to ensure it remains in line with best practice
                                  • We will ensure to consulate with our employees, trustees and other stakeholders on the development of this policy and welcome feedback

                                  If you have any questions or feedback on this policy – please do get in touch via info@planetearthgames.org  


                                    4. SAFEGUARDING


                                    1. INTRODUCTION 

                                    2. WHAT WE WILL DO 

                                    3. MONITORING 


                                    1. INTRODUCTION 

                                    Our organisation acknowledges the duty of care to safeguard and promote the welfare of children, young people and adults at risk and is committed to ensuring safeguarding practice reflects statutory responsibilities, government guidance and complies with best practice outlined by NSPCC requirements.  

                                    The policy recognises that the welfare and interests of children, young people and adults are paramount in all circumstances. It aims to ensure that regardless of age, ability or disability, gender reassignment, race, religion or belief, sex, sexual orientation, socio-economic background, all children, young people and adults: have a positive and enjoyable experience of Planet Earth Games Trust events and activities in a safe and child-centred environment and are protected from abuse whilst participating. 

                                    We acknowledge that some children, young people and vulnerable adults, including disabled children or those from ethnic minority communities, can be particularly vulnerable to abuse and we accept the responsibility to take reasonable and appropriate steps to ensure their welfare. 

                                    2. WHAT WE WILL DO 

                                    As part of our Safeguarding Policy we will:  

                                      • Promote and prioritise the safety and wellbeing of children, young people and adults at risk,
                                      • Value, listen to and respect children, young people and adults at risk and their parents or carers,
                                      • Ensure robust safeguarding arrangements and procedures are in operation,
                                      • Adopt safeguarding best practice through our policies, procedures and code of conduct for staff and volunteers ensure everyone understands their roles and responsibilities in respect of safeguarding and is provided with appropriate learning opportunities to recognise, identify and respond to signs of abuse, neglect and other safeguarding concerns relating to children and young people
                                      • Provide effective management for staff and volunteers through supervision, support, training and quality assurance measures so that all staff and volunteers know about our policies, procedures and behaviour codes and follow them confidently and competently,
                                      • Ensure appropriate action is taken in the event of incidents or concerns of abuse and support provided to the individual(s) who raise or disclose the concern,
                                      • Ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored record and store information securely, in line with data protection legislation and guidance,
                                      • Prevent the employment or deployment of unsuitable individuals by recruiting and selecting staff and volunteers safely, ensuring all necessary checks are made,
                                      • Appoint a nominated safeguarding lead, a deputy and a lead trustee/board member for safeguarding develop and implement an effective online safety policy and related procedures,
                                      • Share information about safeguarding and good practice with children, young people, adults at risk and their parents or carers via leaflets, posters, group work and one-to-one discussions make sure that children, young people, adults at risk and their parents or carers know where to go for help if they have a concern.

                                            The policy and procedures will be widely promoted and are mandatory for everyone involved in Planet Earth Games Trust. Failure to comply with the policy and procedures will be addressed without delay and may ultimately result in dismissal or exclusion from the organisation. 

                                            3. MONITORING 

                                             This policy will be reviewed a year after development and then every three years, or in the following circumstances:

                                            • Changes in legislation and/or government guidance,
                                            • As required by the local safeguarding partnership, UK Sport and/or home country sports, councils and NSPCC guidance.
                                            • As a result of any other significant change or event internally or externally

                                            5. EQUITY, DIVERSITY AND INCLUSION


                                            1. RATIONALE

                                            2. POLICY OBJECTIVES

                                            3. PURPOSE OF THE POLICY

                                            4. LEGAL REQUIREMENTS

                                            5. DISCRIMINATION, HARASSMENT, BULLYING AND VICTIMISATION

                                            6. REASONABLE ADJUSTMENTS

                                            7. RESPONSIBILITY, IMPLEMENTATION AND COMMUNICATION

                                            8. ACTIONS

                                            9. MONITORING AND EVALUATION

                                            10. COMPLAINTS PROCEDURE  

                                            1. RATIONALE


                                              1.1 Addressing equity, diversity and inclusion helps a board to make better decisions. This requires commitment, but it means that a charity is more likely to stay relevant to those it serves and to deliver its public benefit. Recognising and countering any imbalances in power, perspectives and opportunities in the charity, and in the attitudes and behaviour of trustees, staff and volunteers, will help to ensure that Planet Earth Games (PEG) achieves its aims. 


                                              1.2 All trustees have the same responsibility for the charity, so they must have equal opportunity to contribute to decision making. Board diversity, in the widest sense, is important because it creates more balanced decision making. Where appropriate, this includes the communities and people the charity serves. This increases the charity’s legitimacy and impact. Equity and diversity are only effective and sustainable if the board works to be inclusive, ensuring that all trustees are welcomed, valued and able to contribute. 

                                              2. POLICY OBJECTIVES 


                                              2.1 PEG is fully committed to the principles of equity of opportunity and is responsible for ensuring that no job applicants, employees, workers, officer holders, volunteers or participants (together “Stakeholders”) are unlawfully discriminated against because of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex and sexual orientation (together the “Protected Characteristics” ). 


                                              2.2 In addition PEG recognises that we live in a diverse society and will endeavour to ensure that all Stakeholders are given the same opportunities regardless of their socio-economic backgrounds. 


                                              2.3 PEG will encourage partner organisations to adopt and demonstrate their commitment to the principles and practice of equality as set out in this EDI Policy. 


                                              3. PURPOSE OF THE POLICY 


                                              3.1 PEG recognises that individuals (and/or certain groups in our society who share one or more Protected Characteristic) may not have been able to participate equally and fully in sport and physical activity in the past. In some instances this may have been as a result of unlawful discrimination. 


                                              3.2 This policy has been produced to try to prevent and address any unlawful discrimination or other unfair treatment, whether intentional or unintentional, direct or indirect, against Stakeholders that may preclude them from participating fully in any PEG activities. 


                                              4. LEGAL REQUIREMENTS 


                                              4.1 PEG is required by law not to unlawfully discriminate against its Stakeholders and recognises its legal obligations under, and will abide to the requirements of, the Equality Act 2010, and any equivalent legislation (as amended) in any UK jurisdiction, Jersey, Guernsey or the Isle of Man and any later amendments to such legislation or subsequent equality related legislation that may be relevant to PEG. 


                                              4.2 PEG will seek advice each time this policy is reviewed to ensure it continues to reflect the current legal framework and good practice. 


                                              5.DISCRIMINATION, HARASSMENT, BULLYING AND VICTIMISATION 


                                              5.1 PEG recognises the following as being unacceptable: 


                                              5.1.1 Unlawful discrimination which can take the following forms: 

                                     Direct Discrimination: treating someone less favourably than you would treat others because of a Protected Characteristic. 

                                     Indirect Discrimination: applying a provision, criterion or practice which, on the face of it, applies equally to all but which, in practice can disadvantage individuals with a particular Protected Characteristic. Such requirements or conditions are lawful only if they can be objectively justified. 


                                              5.1.2 Harassment: engaging in unwanted conduct relating to a relevant Protected Characteristic or unwanted conduct of a sexual nature where the conduct has the purpose or effect of violating the recipient’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for the recipient, or any other individual affected by such conduct. PEG is committed to ensuring that its Stakeholders are able to conduct their activities free from harassment. 


                                              5.1.3 Bullying: the misuse of power or position to criticise persistently or to humiliate and undermine an individual’s confidence. 


                                              5.1.4 Victimisation: subjecting someone to a detriment because they have in good faith taken action under the Equality Act 2010 (or equivalent legislation) by bringing proceedings, giving evidence or information in relation to proceedings, making an allegation that a person has contravened the Equality Act 2010 (or equivalent legislation) or doing any other thing for the purpose of or in connection with the Equality Act 2010 (or any equivalent legislation). 


                                              5.2 PEG regards discrimination, harassment, bullying or victimisation, as described above, as serious misconduct. All complaints will be taken seriously and appropriate measures including disciplinary action may be brought against any Stakeholder who unlawfully discriminates against, harasses, bullies or victimises any other person. 


                                              6. REASONABLE ADJUSTMENTS 


                                              6.1 When any decision is made about an individual the only personal characteristics that may be taken into account are those that are consistent with any relevant legislation and are relevant to the substance of the decision being made. 


                                              6.2 PEG recognises that it has a duty to make reasonable adjustments for disabled persons. PEG will consider all request for adjustments and where possible will accommodate reasonable requests and will work with disabled Stakeholders to implement any adjustments that will enable tome to participate more fully in all PEG related activities. 


                                              7. RESPONSIBILITY, IMPLEMENTATION AND COMMUNICATION 


                                              7.1 The following responsibilities will apply: 

                                              7.1.1 The Board of PEG is responsible for ensuring that this EDI Policy is implemented, followed, and reviewed when appropriate. The PEG Board is also responsible for ensuring that this EDI Policy is enforced, and any breaches are dealt with appropriately.  

                                              7.1.2 A member of the Board will be appointed “Equality Champion” and will ensure that equality is included as an agenda item at Board meetings when appropriate and that the Board takes equality issues into consideration when making decisions. 

                                              7.1.3 The Chief Executive has overall responsibility for the implementation of this EDI Policy. 

                                              7.1.4 All Stakeholders have the responsibility to respect, follow and promote the spirit and intentions of this policy. Individual work programmes for PEG staff will be amended to include equality related tasks where appropriate 


                                              7.2 This EDI Policy will be implemented immediately following Board approval. Implementation requires the following actions: 

                                              7.2.1 PEG will regularly review its employment practices to ensure continuing compliance with relevant legislation, and where possible good practice. All job packs sent out by PEG will contain a policy statement similar to the following: 

                                              “Planet Earth Games is committed to providing equal opportunities for all and is committed to following best practice in the welfare of young people and adults at risk.” 

                                              7.2.2 No application for any post (including job applicants, consultant advisers and suppliers) will be placed at a disadvantage by requirements or conditions which are not necessary to the performance of the job, or which constitute unlawful discrimination. 

                                              7.2.3 Consultants and advisers (and where appropriate suppliers) to PEG will be required to abide by this Equality Policy and it will be referred to in service level agreements or contracts issued by PEG. 


                                              7.3 This EDI Policy will be communicated in the following ways: 

                                              7.3.1 The Policy will be included in any employee handbook. Reference will be made to this Equality Policy in any code of conduct. This EDI Policy is for guidance only and will not form part of any contract of employment with any employees of PEG. 

                                              7.3.2 The Policy will be highlighted in all staff and volunteer inductions. 

                                              7.3.3 A copy of the EDI Policy will be publicly available on the PEG website and copied in other formats will be available upon request. All Stakeholders will be made aware of the policy. 


                                              7.4 PEG will promote continuing professional development for all employees and volunteers to support equal opportunities within the organisation and, where appropriateprovide specialist facilities, equipment and training. 


                                              8. ACTIONS 


                                              8.1 PEG will produce, maintain and monitor an Equality Action Plan to ensure the objective of this Policy are consistently delivered throughout all areas of the organisation. 


                                              8.2 PEG recognises that, in some cases, to further the principle of equity, an unequal distribution of resources may be required. If appropriate and proportionate, PEG will consider positive action or may introduce special measures to assist any group with a Protected Characteristic which is currently underrepresented within any group of Stakeholders. 


                                              9.MONITORING AND EVALUATION 


                                              9.1 This EDI Policy will remain in force until it is amended, replaced or withdrawn. A review of this Policy will take place as a when required, but not less than once every three years. 


                                              9.2 The Equality Action Plan, created to ensure the objectives of this Policy are delivered, will be reviewed by the Chief Executive and the Equality Champion regularly, but in any event not less than once every 12 months. 


                                              9.3 On an annual basis, statistical and, if appropriate qualitative, information will be collected and a report will be produced by the Chief Executive for the Board. Once approved by the Board, the report will be published internally and external, to show the impact of this Equality Policy and progress towards achieving the Equality Action Plan. 


                                              10. COMPLAINTS PROCEDURE 


                                              10.1 To safeguard individual rights under this EDI Policy, any Stakeholder who believed they have suffered inequitable treatment within the scope of this Policy may raise the PEG Complaints Procdeure. 


                                              10.2 Appropriate disciplinary action will be taken against any PEG Stakeholder who violates this Policy. 


                                              10.3 An individual raising an employee grievance will bot be penalised for doing so unless it is untrue and not made in good faith. 


                                                 6. BULLYING

                                                1. STATEMENT OF INTENT 

                                                2. BULLYING – OUR APPROACH 

                                                3. WHAT WE WILL DO 

                                                4. WHAT WE EXPECT OF EVERYONE 

                                                5. SUPPORTING THOSE AFFECTED BY BULLYING 

                                                6. USEFUL CONTACTS 


                                                1. STATEMENT OF INTENT 


                                                Our anti-bullying policy sets out how we feel about bullying as an organisation, what we’ll do to tackle it and how we’ll treat anyone who experience or display bullying behaviour. 


                                                2. BULLYING – OUR APPROACH 


                                                All forms of bullying will be acted upon. Everybody in the organisation has a responsibility to work together to stop bullying, this includes both online and offline behaviour deemed as bullying.   


                                                Bullying behaviour can include:  



                                                      3. WHAT WE WILL DO 


                                                      Planet Earth Games Trust is committed to ALL of the following: 



                                                            4. WHAT WE EXPECT OF EVERYONE 


                                                            Our expectation of anyone who participates, volunteers at or is involved in any way in the delivery of the Planet Earth Games including Trustees at Planet Earth Games is as follows 



                                                                  5. SUPPORTING THOSE AFFECTED BY BULLYING 


                                                                  The Planet Earth Games Trust is committed to supporting anyone affected by bullying in the following ways: 



                                                                          USEFUL CONTACTS 


                                                                          NSPCC Helpline 0808 800 5000  

                                                                          Childline 0800 1111 / www.childline.org.uk  

                                                                          Kidscape www.kidscape.org.uk  

                                                                          Anti-Bullying Alliance www.antibullyingalliance.org 


                                                                             7. ANTI-SLAVERY AND HUMAN TRAFFICKING

                                                                            POLICY STATEMENT 

                                                                            Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. 


                                                                            We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.