The Army Parachute Association Privacy Policy

The APA is committed to protecting your privacy and ensuring you understand how your personal data is collected, used, and stored. This policy explains our practices in compliance with UK GDPR, the Data Protection Act 2018, and the Data (Use and Access) Act 2025. 

1. Data Controller and Contact Information 

The Army Parachute Association is the data controller of the personal information you provide. Our registered address is Army Parachute Association, Airfield Camp, Netheravon, Wiltshire, SP4 9SF, and you can contact us at coo.apa@netheravon.com or 01980 670734. You may contact us at any time regarding your personal data or to exercise your data rights. 

2. Information We Collect 

We collect information you provide directly, such as your name, contact details, transaction information, and communication preferences. We also collect information automatically when you use our website, including IP address, browser type, geographical location, referral source, pages visited, and time spent on the site. This information is collected through tools such as Google Analytics to help us administer the website, improve usability, and understand user behaviour. 

We use cookies to store preferences and track website usage. Essential cookies are necessary for the website to function. Non-essential cookies, such as analytics or marketing cookies, are only set with your consent. 

3. How We Use Your Personal Data 

We use your personal data to provide our services, fulfil transactions, personalise your experience, and communicate information relevant to your interests. Where you have consented, we may send marketing communications. Your data may also be used to comply with legal obligations, protect our legal rights, and prevent fraud. We do not sell your personal data to third parties for marketing purposes. 

4. Legal Basis for Processing 

Your data is processed on the basis of contract when fulfilling purchases or subscriptions, on the basis of consent when sending marketing communications or using non-essential cookies, and on the basis of legitimate interests for improving our website and preventing fraud. We may also process data to comply with legal obligations or protect our legal rights. 

5. Sharing Your Data 

Your personal information may be shared with service providers who help us operate our website, process payments, or analyse data. We may disclose information to legal authorities if required by law or in connection with legal proceedings. Any international transfers of personal data, such as to the United States for analytics purposes, are protected with UK GDPR-approved safeguards to ensure your information remains secure. 

6. Data Retention and Security 

We retain personal information only as long as necessary to fulfil the purposes outlined in this policy, including legal or contractual obligations. Data is stored on secure servers and electronic transactions are encrypted. While we take all reasonable precautions to protect your information, internet transmission cannot be guaranteed to be completely secure. 

7. Your Rights 

You have the right to access, correct, or request deletion of your personal data. You may also restrict or object to processing, withdraw consent at any time, request data portability, and complain to the ICO if you believe your rights are not being respected. You can exercise these rights by contacting our COO at coo.apa@netheravon.com . 

Marketing communications will only be sent if you have opted in. You can withdraw consent or unsubscribe at any time via the links provided in emails or by contacting us directly. 

8. Cookies and Analytics 

Our website uses cookies to improve your experience and understand how the site is used. Essential cookies are required for the website to function. Non-essential cookies, including analytics and marketing cookies, are only set with your consent. 

You can choose to accept all cookies, reject non-essential cookies, or manage your preferences via the “Cookie Settings” link on our website. Consent is stored in your browser for 12 months, and you may withdraw it at any time by adjusting your preferences or clearing your cookies. 

Most browsers allow you to block cookies manually; however, blocking cookies may reduce website functionality. 

9. Changes to This Policy 

We may update this policy from time to time to reflect legal, regulatory, or operational changes. The latest version will always be posted on this page, and significant changes may also be notified by email. 

MODERN SLAVERY POLICY

1.Introduction  

Modern slavery is a crime and a violation of fundamental human rights. The Army Parachute Association is committed to the abolition of modern slavery, servitude, forced and compulsory labour, and human trafficking. The Army Parachute Association is committed to acting ethically and with integrity, as well as ensuring that effective controls are in place to ensure modern slavery is not taking place within our own business.  

Modern slavery is a crime and a violation of fundamental human rights. The Army Parachute Association is committed to the abolition of modern slavery, servitude, forced and compulsory labour, and human trafficking. The Army Parachute Association is committed to acting ethically and with integrity, as well as ensuring that effective controls are in place to ensure modern slavery is not taking place within our own business.  

2.Scope 

This policy applies to the staff, volunteers, customers and visitors at The Army Parachute Association, and it is their responsibility to prevent, detect and report any concerns involving modern slavery. The Army Parachute Association is responsible for ensuring this policy complies with any legal and ethical obligations and that the aforementioned persons comply with the policy. If an individual is unsure whether a particular act or treatment of workers constitutes as modern slavery, they are advised to report the concern to the Management Team or follow the Army Parachute Association Whistleblower Policy. 

3.The Army Parachute Association 

Due to the nature of our business, The Army Parachute Association believes itself to have a low risk of modern slavery within 

the business. The Army Parachute Association is committed to ensuring transparency in our approach to tackling modern slavery by making this policy accessible to all. The Army Parachute Association’s recruitment process ensures that all employees are legally entitled to work in the UK and to safeguard them from any coercion or abuse. 

The Army Parachute Association will not enter into business with any organisation which is involved with or knowingly supports modern slavery in any of its forms. 

4.Our actions 

The Army Parachute Association upholds this policy by: 

Educating staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect modern slavery is taking place Continuing to take action to embed a zero-tolerance policy towards modern slavery. 

Providing a whistleblower policy which provides a way to raise any concerns regarding modern slavery within The Army Parachute Association 

Any employee or volunteer who breaches the policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. 

MODERN SLAVERY STATEMENT

The Army Parachute Association is committed to preventing modern slavery, human trafficking, and forced labour in our organisation and supply chains. 

Our Approach 

1. We operate a zero-tolerance policy towards modern slavery. 

2. All staff and volunteers are legally entitled to work in the UK and are protected from coercion or exploitation. 

3. We train staff and volunteers to recognise and report any concerns. 

4. We provide a confidential whistleblowing process for raising concerns. 

Our Supply Chains 

1. We carefully select suppliers and require them to comply with anti-slavery standards. 

2. We conduct risk assessments and monitor suppliers to prevent modern slavery. 

Measuring Effectiveness 

1. 100% of staff receive training on modern slavery awareness. 

2. Suppliers are reviewed for compliance, and any concerns are investigated promptly. 

Governance 

This statement has been approved by the Army Parachute Association Board and will be reviewed annually. 

WHISTLE BLOWING POLICY

1. What is Whistleblowing? 

In this policy ‘Whistleblowing’ means the reporting by employees of suspected misconduct, illegal acts or failure to act within the Army Parachute Association. 

The aim of this Policy is to encourage employees and others who have serious concerns about any aspect of the Army Parachute Association’s work to come forward and voice those concerns. 

Employees are often the first to realise that there may be something seriously wrong within the Army Parachute Association. ‘Whistleblowing’ is viewed by the Army Parachute Association as a positive act that can make a valuable contribution to the Army Parachute Association’s efficiency and long-term success. It is not disloyal to colleagues or the Army Parachute Association to speak up. The Army Parachute Association is committed to achieving the highest possible standards of service and the highest possible ethical standards in public life and in all of its practices. To help achieve these standards it encourages freedom of speech. 

If you are considering raising a concern you should read this Policy first. It explains: 

– the type of issues that can be raised 

– how the person raising a concern will be protected from victimisation and harassment 

– how to raise a concern, and 

– what the Army Parachute Association will do. 

2. What is the aim of the Policy and when does it apply? 

2.1. Aims of the Policy 

The Policy is designed to ensure that you can raise your concerns about wrongdoing or malpractice within the Army Parachute Association without fear of victimisation, subsequent discrimination, disadvantage or dismissal. 

It is also intended to encourage and enable you to raise serious concerns within the Army Parachute Association rather than ignoring a problem or ‘blowing the whistle’ outside. 

This Policy aims to: 

– encourage you to feel confident in raising serious concerns at the earliest opportunity and to question and act upon concerns about practice 

– provide avenues for you to raise those concerns and receive feedback on any action taken 

– ensure that you receive a response to your concerns and that you are aware of how to pursue them if you are not satisfied 

– reassure you that you will be protected from possible reprisals or victimisation if you have made any disclosure in good faith. 

2.2. Scope of this Policy 

This Policy is intended to enable those who become aware of wrongdoing in the Army Parachute Association affecting some other person or service, to report their concerns at the earliest opportunity so that they can be properly investigated. 

The Whistle Blowing Policy is not intended to replace existing procedures: 

– If your concern relates to your own treatment as an employee, you should raise it under the existing grievance or harassment procedures 

– If a client has a concern about services provided to them, it should be raised as a complaint to the Army Parachute Association 

– Complaints of misconduct by Army Parachute Association are dealt with under a separate procedure 

2.3. Who can raise a concern under this Policy? 

The Policy applies to all: 

– employees of the Army Parachute Association* 

– employees of contractors working for the Army Parachute Association, for example, agency staff, builders and drivers 

– employees of suppliers 

– those providing services under a contract or other agreement with the Army Parachute Association in their own premises, for example care homes, and 

– voluntary workers working with the Army Parachute Association 

* If you are employed in, working with or assisting Nottinghamshire schools there is a specific whistleblowing code for you because of the special relationship that exists with the schools’ governing bodies. 

2.4. What should be reported? 

Any serious concerns that you have about service provision or the conduct of officers or members of the Army Parachute Association or others acting on behalf of the Army Parachute Association that: 

– make you feel uncomfortable in terms of known standards; 

– are not in keeping with the Army Parachute Association’s Constitution and policies; 

– fall below established standards of practice; or 

– are improper behaviour. 

These might relate to: 

– conduct which is an offence or a breach of the law (a criminal offence has been committed or failing to comply with any other legal obligation) 

– disclosures related to miscarriages of justice 

– racial, sexual, disability or other discrimination 

– health and safety of the public and/or other employees 

– damage to the environment 

– unauthorised use of public funds or other assets 

– possible fraud and corruption 

– neglect or abuse of clients, or 

– other unethical conduct. 

This list is not exhaustive. 

3. Protecting the Whistleblower 

3.1. Your legal rights 

This policy has been written to take account of the Public Interest Disclosure Act 1998 which protects workers making disclosures about certain matters of concern, when those disclosures are made in accordance with the Act’s provisions and in the public interest. 

The Act makes it unlawful for the Army Parachute Association to dismiss anyone or allow them to be victimised on the basis that they have made an appropriate lawful disclosure in accordance with the Act. 

Rarely, a case might arise where it is the employee that has participated in the action causing concern. In such a case it is in the employee’s interest to come into the open as soon as possible. The Army Parachute Association cannot promise not to act against such an employee, but the fact that they came forward may be taken into account. 

3.2. Harassment or Victimisation 

The Army Parachute Association is committed to good practice and high standards and to being supportive of you as an employee. 

The Army Parachute Association recognises that the decision to report a concern can be a difficult one to make.  If you honestly and reasonably believe what you are saying is true, you should have nothing to fear because you will be doing your duty to your employer, your colleagues and those for whom you are providing a service. 

The Army Parachute Association will not tolerate any harassment or victimisation of a whistleblower (including informal pressures) and will take appropriate action to protect you when you raise a concern in good faith and will treat this as a serious disciplinary offence which will be dealt with under the disciplinary rules and procedure. 

3.3. Support to you 

Throughout this process: 

– you will be given full support from senior management 

– your concerns will be taken seriously, and 

– the County Army Parachute Association will do all it can to help you throughout the investigation 

If appropriate, the Army Parachute Association will consider temporarily re-deploying you for the period of the investigation. 

For those who are not County Army Parachute Association employees, the Army Parachute Association will endeavour to provide appropriate advice and support wherever possible. 

3.4. Confidentiality 

All concerns will be treated in confidence, and every effort will be made not to reveal your identity if that is your wish.  If disciplinary or other proceedings follow the investigation, it may not be possible to take action as a result of your disclosure without your help, so you may be asked to come forward as a witness. If you agree to this, you will be offered advice and support. 

3.5. Anonymous Allegations 

This Policy encourages you to put your name to your allegation whenever possible. If you do not tell us who you are it will be much more difficult for us to protect your position or to give you feedback. This policy is not ideally suited to concerns raised anonymously. 

Concerns expressed anonymously are much less powerful, but they may be considered at the discretion of the Army Parachute Association.  In exercising this discretion, the factors to be taken into account would include: 

– the seriousness of the issue raised 

– the credibility of the concern, and 

– the likelihood of confirming the allegation from other sources 

3.6. Untrue Allegations 

If you make an allegation in good faith and reasonably believing it to be true, but it is not confirmed by the investigation, the Army Parachute Association will recognise your concern, and you have nothing to fear.  If however, you make an allegation frivolously, maliciously or for personal gain, appropriate action that could include disciplinary action, may be taken. 

4. Raising a Concern 

4.1. Who should you raise your concern with? 

This will depend on the seriousness and sensitivity of the issues involved and who is suspected of the wrongdoing.  You should normally raise concerns with: 

– Your Line Manager 

– Your OIC Organisation 

– The Chief Operating Officer via email at coo.apa@netheravon.com or by telephone on 01980 670734 

The address for correspondence is Army Parachute Association, Airfield Camp, Netheravon, Wiltshire, SP4 9SF. 

If, exceptionally, the concern is about the Chief Executive of the Army Parachute Association your concern should be raised with the Leader of the Army Parachute Association who will decide how the investigation will proceed. This may include external investigation. 

If you are unsure who to contact, the independent charity Protect can advise you. They offer a free and confidential helpline on 020 3117 2520. 

4.2. How to raise a concern 

You may raise your concern by telephone, in person or in writing.  The earlier you express your concern, the easier it is to take action.  You will need to provide the following information: 

– the nature of your concern and why you believe it to be true 

– the background and history of the concern (giving relevant dates) 

Although you are not expected to prove beyond doubt the truth of your suspicion, you will need to demonstrate to the person contacted that you have a genuine concern relating to suspected wrongdoing or malpractice within the Army Parachute Association and there are reasonable grounds for your concern.  

You may wish to consider discussing your concern with a colleague first and you may find it easier to raise the matter if there are two (or more) of you who have had the same experience or concerns. 

You may invite your trade union, professional association representative or a friend to be present for support during any meetings or interviews in connection with the concerns you have raised. 

5. What the Army Parachute Association will do 

The Army Parachute Association will respond to your concerns as quickly as possible.  Do not forget that testing your concerns is not the same as either accepting or rejecting them. 

The overriding principle for the Army Parachute Association will be the public interest. In order to be fair to all employees, including those who may be wrongly or mistakenly accused, initial enquiries will be made to decide whether an investigation is appropriate and, if so, what form it should take. 

The investigation may need to be carried out under terms of strict confidentiality, i.e. by not informing the subject of the complaint until (or if) it becomes necessary to do so. In certain cases, however, such as allegations of ill treatment of others, suspension from work may have to be considered immediately. Protection of others is paramount in all cases. 

Where appropriate, the matters raised may: 

– be investigated by management, internal audit, or through the disciplinary/grievance process 

– be referred to the police 

– be referred to the external auditor 

– be referred and put through established child protection/abuse procedures 

– form the subject of an independent inquiry 

Within ten working days of a concern being raised, the person investigating your concern will write to you: 

– acknowledging that the concern has been received 

– indicating how the County Army Parachute Association proposes to deal with the matter 

– supplying you with information on staff support mechanisms   

– telling you whether further investigations will take place and if not, why not. 

The amount of contact between you and the officers considering the issues will depend on the nature of the matters raised, the potential difficulties involved and the clarity of your information.  It is likely that you will be interviewed to ensure that your disclosure is fully understood. 

Any meeting can be arranged away from your workplace, if you wish, and a union or professional association representative or a friend may accompany you in support. 

The Army Parachute Association will do what it can to minimise any difficulties that you may experience as a result of raising a concern.  For instance, if you are asked to give evidence in criminal or disciplinary proceedings, the Army Parachute Association will arrange for you to receive appropriate advice and support. 

You need to be assured that your disclosure has been properly addressed.  Unless there are any legal reasons why this cannot be done, you will be kept informed of the progress and outcome of any investigation. 

6. The Responsible Officer 

The Chief Operating Officer has overall responsibility for the maintenance and operation of this Policy.  

7. How the Matter can be Taken Further 

This Policy is intended to provide you with an avenue within the Army Parachute Association to raise concerns. The Army Parachute Association hopes you will be satisfied with any action taken.  If you are not, and you feel it is right to take the matter outside the Army Parachute Association, the following are the Army Parachute Association’s prescribed contacts: 

– the External Auditor: Grant Thornton UK LLP 
The Colmore Building, 20 Colmore Circus, Birmingham, West Midlands, B4 6AT 
0121 212 4000 
www.grantthornton.co.uk 

– the police 

– other relevant bodies prescribed by legislation – the Army Parachute Association’s Monitoring Officer will be able to advise you who you can contact 

If you raise concerns outside the Army Parachute Association you should ensure that it is to one of these prescribed contacts.  A public disclosure to anyone else could take you outside the protection of the Public Interest Disclosure Act and of this Policy. 

You should not disclose information that is confidential to the Army Parachute Association or to anyone else, such as a client or contractor of the Army Parachute Association, except to those included in the list of prescribed contacts. 

This Policy does not prevent you from taking your own legal advice. 

8. Review of the Policy 

The County Army Parachute Association’s Policy Committee will review this Policy annually. 

9. Corporate Recording and Monitoring 

The Chief Operating Officer will maintain a corporate register containing all concerns that are brought to her attention. All officers allocated to look into a concern must ensure the Monitoring Officer is provided with sufficient details for the corporate register. 
 
The Chief Operating Officer will review the corporate register and produce an annual report for Policy Committee. The report will include a summary of the concerns raised, to which department they related, the post to which the concerns related (if not confidential) and any lessons learned. The report will not include any employee names. The aim of this is to ensure that: 

– the Army Parachute Association and/or the relevant department learns from mistakes and does not repeat them, and 

– consistency of approach across the departments 

The corporate register together with the annual reports will be available for inspection by internal and external audit, after removing any confidential details.