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Policies

On this page:

Data Protection policy

Code of Behaviour

Complaints Policy and Procedures

Equality Statement and Policy

Photography Consent and Policy

Refund Policy

Adults at Risk and Adults Safeguarding Policy

 

EYE MATTER

Data Protection policy

7th March 2024

Definition:  Personal Data refers to written and spoken content, along with images (please see ‘Photography Consent and Policy’ for further clarity)

 

Eye Matter is committed to processing data in accordance with its responsibilities under the GDPR (General Data Protection Regulations).

Article 5, of the GDPR, requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

General provisions of Personal Data

This policy applies to all personal data processed by Eye Matter.

  1. The Responsible Person shall take responsibility for Eye Matter’s ongoing compliance with this policy. The responsible person is Suzie Simons.
  2. This policy shall be reviewed at least annually. Lawful, fair and transparent processing.
  3. To ensure its processing of data is lawful, fair and transparent.
  4. Eye Matter shall store member’s data securely on OneDrive.
  5. Individuals have the right to access their personal data in their preferred format and any such requests made to Eye Matter shall be dealt with in a timely manner.

Lawful purposes of Personal Data

  1. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  2. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the charity’s systems.

Data minimisation

Eye Matter shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

 

Accuracy of Personal Data

  1. Eye Matter shall take reasonable steps to ensure personal data is accurate.
  2. Where necessary, for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

 

Archiving / removal of Personal Data

  1. To ensure that personal data is kept for no longer than necessary,
  2. Eye matter shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  3. The archiving policy shall consider what data should/must be retained, for how long, and why.
  4. Security of Personal Data
  5.  Eye Matter shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
  6. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
  7. When personal data is deleted this should be done safely such that the data is irrecoverable.
  8. Appropriate back-up and disaster recovery solutions shall be in place.

 

Breach of Personal Data

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Eye Matter shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.

EYE MATTER

Code of Behaviour

25th September 2025

Principles

Everyone working with Eye Matter whether as a member of staff, a volunteer or a member has a responsibility to ensure that everyone participating in Eye Matter’s activities, particularly children, young people and vulnerable adults, are protected from harm.

It is the responsibility of each adult working with Eye Matter to ensure that:

All persons who wish to work with Eye Matter, must accept and understand this policy.

They must also agree to put Eye Matter’s policies on safeguarding vulnerable adults into practice.

Meeting your responsibilities

To give positive guidance, the Code of Behaviour (below) provides a list of ‘do’s and don’ts’ to help you ensure that:

Code of behaviour

1:   Your Conduct

  1. DO treat everyone with dignity and respect;
  2. DO set an example you would wish others to follow;
  3. DO treat everyone equally and equitably;
  4. DO respect everyone’s right to personal privacy;
  5. DO remember someone else might misinterpret your actions, no matter how well-intentioned;

  1. DON’T make suggestive remarks or threats, even in fun;
  2. DON’T use inappropriate language – speaking, writing, phoning, email or internet;
  3. DON’T show favouritism.
  4. DON’T form a relationship with a young person or vulnerable adult that is an abuse of trust;

2:   Other People’s Behaviour

  1. DO allow young people and vulnerable adults to talk about any concerns they may have;
  2. DO encourage others to challenge any attitudes or behaviours they do not like;

 

  1. DON’T trivialise abuse;
  2. DON’T tolerate bullying;
  3. DON’T get drawn into inappropriate attention seeking behaviour, eg: tantrums and crushes;
  4. DON’T allow unacceptable situations within a relationship of trust, eg: a sexual relationship with a young person or vulnerable adult over the age of consent;

3:   Practical Arrangements

  1. DO put this code into practice at all times;
  2. DO follow recommended adult/young people ratios for meetings and activities;
  3. DO keep other members of staff/volunteers informed of where you are and what you are doing;
  4. DO plan activities that involve more than one other adult being present, or at least are within sight and hearing of others;
  5. DO have separate sleeping accommodation for young people, adults and leaders in any overnight activity;

 

  1. DON’T play physical contact games with young people or vulnerable adults;
  2. DON’T permit abusive peer activities, g.: initiation ceremonies, bullying;

 

4:   When Problems Arise

  1. DO remember this code even at sensitive moments, g.: when responding to bullying, bereavement or abuse;
  2. DO take any allegations, suspicions or concerns of abuse or inappropriate action seriously and refer or report them immediately.
  3. DO immediately report and seek support about any allegations of abuse or inappropriate behaviour made against you.

 

  1. DON’T let allegations, suspicions, or concerns about abuse go unreported;
  2. DON’T just rely on your good name to protect you.

 

Eye Matter does not assume any liability or responsibility to any person or entity for the information contained in this leaflet and you should not rely on any information contained in this leaflet. Eye Matter makes no representation as to, and does not assume any responsibility for, the accuracy, completeness or relevance of the information contained in this leaflet.

Please make sure that any sites you link to from this leaflet (or on our website) are appropriate to you, as we do not endorse such websites and have no control over their contents or how (or if) that site operates. Any links or references in this leaflet to a company, entity, service or product does not, in any way, imply an endorsement.

EYE MATTER

COMPLAINTS POLICY AND PROCEDURES

25th September 2025

Introduction and purpose of the policy

The Charity Commission report ‘Cause for Complaint’ published in 2006 states: ‘an effective complaints management system is a proven way of maintaining and building relationships with the people on whom the charity depends.’ Handling complaints well:

 

A complaint can be seen as an opportunity to learn and improve for the future, as well as a chance to put things right for the person or organisation that has made the complaint.  See Appendix 2 for the definition of a complaint.

 

The aim of this policy is:

 

Eye Matter have an ethos of inclusion, transparency and openness which is communicated to volunteers, staff and Members.  All complaints are taken seriously and dealt with in a fair, consistent and confidential manner.

The complaints procedure is communicated to staff and volunteers during induction and through the Safeguarding Policy.  If required one-to-one explanations can be provided.

 

Where Complaints Come From

Complaints may come from anyone who uses our services or works with Eye Matter including staff, other volunteers, members of Eye Matter, partners and visitors, donors, event attendees; indeed any person or organisation who has had some form of interaction with Eye Matter.  A complaint can be received verbally, by phone, by email or in writing.

 

Confidentiality

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

 

Responsibility

Overall responsibility for this policy and its implementation lies with Eye Matter’s founder Suzie Simmons. who may, if necessary, also involve any other relevant members of staff, volunteers and members.

 

How to make a complaint

Complaints must be made in writing and sent to Eye Matter’s Founder.

 

Receiving Complaints

All written complaints received should be recorded.  Where a verbal complaint is received, this should, where possible, be agreed to be an accurate account in writing with the complainant before further action is taken.

 

The person who receives a complaint should:

 

Resolving Complaints – The Procedure

Stage One

In many cases, a complaint is best resolved by the person responsible for the issue being complained about. If the complaint has been received by that person, they may be able to resolve it swiftly and should do so if possible and appropriate.

 

Whether or not the complaint has been resolved, the complaint information should be passed to Eye Matter’s Founder within 72 hours so that it can be logged centrally.

 

On receiving the complaint, Eye Matter’s Founder records it in the complaints book and, If it has not already been resolved, Eye Matter’s Founder may investigate or delegate an appropriate person to investigate further.  Where applicable, the person(s) involved in the complaint will be given a copy of the Problem Solving Policy and Procedures.

If the complaint relates to a specific person, they should be informed of the nature of the complaint and given a fair opportunity to respond.  Discretion should be exercised in releasing details of the complainant as necessary.

 

Complaints should be acknowledged by the person handling the complaint within one week. The acknowledgement should say who is dealing with the complaint and when the person complaining can expect a reply.

 

Ideally complainants should receive a definitive reply within four weeks. If this is not possible because, for example, an investigation has not been fully completed, a progress report should be sent with an indication of when a full reply will be given.

 

Whether the complaint is justified or not, the reply to the complainant should describe any investigation, conclusions and any action taken as a result.

 

Stage Two

If the complainant feels that the problem has not been satisfactorily resolved at Stage One, they can request that the complaint is reviewed.

The request for a review should be acknowledged within one week of receiving it. The acknowledgement should say who will deal with the case and when the complainant can expect a reply.  The person who dealt with the original complaint at Stage One should be kept informed of what is happening.

 

Depending on the severity or complexity of the complaint, an Appeals Committee may be convened to investigate the facts of the case themselves or delegate a suitably senior person to do so. This may involve reviewing the nature and findings of the initial investigations of the case and speaking with the person who dealt with the complaint at Stage One.

 

Ideally complainants should receive a definitive reply within four weeks.  If this is not possible because for example, an investigation has not been fully completed or the Appeals Committee do not meet within this timeframe, a progress report should be sent with an indication of when a full reply will be given.

 

Whether the complaint is upheld or not, the reply to the complainant should describe the action taken to investigate the complaint, conclusions from the investigation and any action taken as a result.

 

The decision taken at this stage is final, unless the Appeals Committee decides it is appropriate to seek external assistance to obtain a solution.

 

External Stage

If the complainant wishes they may contact the Charity Commission:

 

 

 

Variation of the Complaints Procedure

Eye Matter’s Founder may vary the procedure for good any reasonable reason; for instance to avoid a conflict of interest.

 

Monitoring and Learning from Complaints

Complaints should be reviewed annually to identify any trends which may indicate a need to take further action.

 

Appendix 1                 Practical Guidance for Handling Verbal Complaints

 

Appendix 2                 Definitions

Definition of a Complaint for the purposes of this policy

A complaint is any expression of dissatisfaction, about any aspect of Eye Matter and which includes at least one person, or an aspect of volunteering, work or service made by a person outside Eye Matter about the behaviour of the organisation, or an individual from Eye Matter.

 

An expression of dissatisfaction made by a staff member or volunteer(including members) about the behaviour of the organisation, or an individual staff member or volunteer, is called a grievance.  A grievance is an issue, complaint, dispute, concern or problem, which does not involve alleged serious misconduct.  This is the focus of the Grievance Policy and Procedures for Volunteers and staff.

 

Allegations of serious misconduct or behaviour and performance related issues should be resolved by reference to Eye Matter’s Founder or a member of the Trustees.

 

Where a staff member or volunteer has serious concerns about the illegal or abusive conduct of the organisation or an individual staff member or volunteer within it, but is unable to use the grievance procedure because the person they should report to is implicated in the malpractice, then they have recourse to the Whistleblowing Policy.

EYE MATTER

EQUALITY STATEMENT AND POLICY

7th March 2024

Introduction

Eye Matter recognise that in society, certain groups or individuals are denied equality on the grounds of race, gender, marital status, caring responsibilities, disability, gender re-assignment, age, social class, sexual orientation and religion/belief or any other factor irrelevant to the purpose in view.

 

Eye Matter respects the statutory requirements established in:

 

Eye Matter recognises that it has moral and social responsibilities that go beyond the provisions of the above-mentioned Acts and Regulations and that it should both support and contribute to the wider process of change through all aspects of its work and practices to eliminate discrimination, promote equality and diversity.

 

Eye Matter is committed to taking positive steps to ensure that:

 

Policy

This policy applies to all Trustees, Volunteers, Service-users and members of the general public.

 

Commitment

 

For this policy to be successful, it is essential that everyone is committed to and involved in its delivery. Eye Matter’s aims to work towards a just society, free from discrimination, harassment and prejudice. Eye Matter aims to embed this in all its policies, procedures, day-to-day practices and external relationships.

 

Aims

Eye Matter aims to:

 

Objectives

Eye Matter seeks to achieve these aims by:

 

Why have this policy?

Eye Matter recognises, respects and values diversity among its Trustees, Volunteers and Members.

Eye Matter has this policy because it is a people-led organisation that must always ensure it meets the needs of the community through fair and appropriate employment and development of the people who work and Volunteer for it.

 

PROCEDURES

Responsibility for Implementation

This policy covers the behaviour of all Employees, Volunteers or Service-users, and describes how they can expect to be treated. The overall responsibility for ensuring adherence to and implementation of this policy lies with the Trustees.

 

Method of Implementation

Eye Matter intends to implement this policy by:

 

Monitoring and Reviewing

Eye Matter has declared its commitment to establishing, developing, implementing and reviewing a policy of equality of opportunity.   Effective record keeping, monitoring and acting on information gathered are essential in order to measure effectiveness and plan progress.

The Management Committee of Trustees will review the policy annually.

EYE MATTER

Photography Consent and Policy

7th March 2024

Images that can identify a person or persons are a form of personal data.  Personal data is protected under legislation of data protection which sets out how Eye Matter can use these images.  In this document ‘Images’ refers to both still and filmed, photography.

For more information about our Data Protection please click here:

Eye Matter will:

If you do not consent to having your photograph taken please email:  suzie@eyematter.org.uk

EYE MATTER

Refund Policy

16th March 2024

Eye Matter reserves the right to not be obliged to refund any costs of tickets for events.    This decision can only be changed at the discretion of the Trustees of Eye Matter.

Eye Matter cannot take any responsibility for cancellations out of their control including; weather conditions, terrorism, or venue cancellation. Eye Matter will in these circumstances endeavour to refund but this is at their discretion.

EYE MATTER

ADULTS AT RISK & ADULTS SAFEGUARDING POLICY

9th January 2026

Definitions – for this document

An adult at risk:

POLICY STATEMENT

Implementation

Eye Matter SHALL:

Plan its work so as to minimise situations where the abuse of vulnerable adults might occur.

Although the number of people who actively seek to abuse vulnerable adults is very small, Eye Matter can reduce opportunities for abuse in various ways.

We will, for instance:

Safety on outings

At Eye Matter the safety of our members is our top priority. We therefore ask all members and volunteer sighted guides to please follow these simple steps to help keep everyone safe whilst on an Eye Matter outing:

1. All members who use a walking aid must please bring it with them on the day, unless alternative arrangements have been made, there will always be an element of walking e.g. from the station to the outing venue.

2. When travelling by train, bus, or coach, all members must please wait for their sighted guides to assist them to disembark safely. 

3. Sighted guides should step off onto the platform or pavement before assisting members to disembark.  Sighted Guides should please advise of the depth of the drop or step, the position of handrails etc.

4. Members are politely asked not to disembark independently unless they have been expressly advised that it is safe to do so by an Eye Matter volunteer.

5. This advice is identical for safely navigating steps and stairs whilst in an unfamiliar environment.

Thank you for your cooperation in helping us keep everyone safe on our outings.

Designated Person and their role

Eye Matter has a Designated Person who is responsible for dealing with any concerns about the protection of vulnerable adults. There is also a Deputy in the absence of the Designated Person.

The Designated Person for Eye Matter is Suzie Simons

Email: suzie@eyematter.org.uk   

Phone: 07968722664

The Deputy is:

Rachel Bowden Waterson

Email: rachel_bowden@hotmail.co.uk

Phone: 07870227295

The Designated Person will be available for vulnerable adults to speak with should they feel the need to talk with someone about an incident which has happened whilst attending events provided by Eye Matter, particularly if they feel they have been physically, sexually or emotionally abused or neglected by an adult.

Recording

Whistleblowing

Applying agreed procedures for protecting vulnerable adults to all Employees, Trustees, Members and Volunteers.

Disclosure of Information

There is a difference between confidentiality and secrecy. All personal and delicate information disclosed to us is confidential but may not always be secret.

Personal and delicate information about Employees, Trustees, Members or Volunteers will be:

Give Employees, Trustees and Volunteers clear roles

Supervision as a means of protection

a) A detailed application form should be completed

b) 2 references should be taken about the suitability of the applicant for the post being considered (if required)

c) An informal interview will provide an extended conversation to allow an opportunity to explore in more detail the applicant’s experience and motivation.

Criminal convictions & DBS Checks

All Employees, Trustees and Volunteers, are required to complete either an Employment Application form or a Volunteer Application form, before commencing work with Eye Matter.

 Details of criminal convictions (except those ‘spent’ under the Rehabilitation of Offenders Act 1974) must be provided so an adequate risk assessment can be undertaken. Dependent on the role and duties of that role, a DBS check may be required which Eye Matter will support.

Eye Matter’s Trustee Board reserves the right to dismiss a Volunteer and/or ban them from the property should they feel it is necessary.

Training

Training in the prevention of abuse and the action to take if abuse occurs should be included as part of the Training and Induction Programme for all Employees, Trustees and Volunteers.

All Employees, Trustees and Volunteers, will be informed of this policy and procedures at induction and with any updates required by law.

General

Policy Review

This policy and its implementation will be reviewed at least annually and whenever there are any legislative changes or amendments to guidance issued by relevant statutory bodies.

Date Policy Adopted: 10.04.2024