Policies and Guidelines

CONSTITUTION OF THE WESTERN FRONT ASSOCIATION

Founded by John Giles. Inaugurated 11th November 1980

Registered Charity Number: 298365

Revised April 2023

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This Privacy Notice tells you about our use of information and your rights in respect of certain information that The Western Front Association (the “Association”) and our branches may hold about you, whether or not you are a member of the Association.

We are committed to protecting your personal information, using it only in accordance with our responsibilities and being transparent about what we do with it.

We are required to provide you with the information in this Privacy Notice under applicable law which includes:

• the Data Protection Act 1998, which will be replaced by the General Data Protection Regulation (EU) 2016/679 from 25 May 2018
• the Privacy and Electronic Communications (EC Directive) Regulations 2003.

We won’t do anything with your information you wouldn’t reasonably expect.

Processing of your personal information is carried out by or on behalf of the Association at national and branch level.

This notice tells you about how we collect, use and protect your personal information.

If you have any queries about our Privacy Notice, please get in touch with The Western Front Association's national office.

Email: contact form

Phone: 0207 118 1914

Post: BM Box 1914, London, WC1N 3XX

How and when we collect information

When you directly give us information

We may collect and store information about you when you interact with us, at national and branch level, which could be when you:

• become a member or renew your membership of the Association
• support our work through a donation
• agree to be on our speaker list
• fundraise on our behalf
• register for or participate in an event or conference or in the activities of the Association or one or more of our branches
• tell us information about yourself
• submit an enquiry
• register for or participate in the activities of the Association or one of our branches
• make a complaint
• become a volunteer

When you indirectly give us information

When you interact with us on social media platforms such as YouTube, Facebook, Instagram, Twitter or LinkedIn we may also obtain some personal information about you. The information we receive will depend on the privacy preferences you have set on each platform and the privacy policies of each platform. To change your settings on these platforms, please refer to their privacy notices.

We may also obtain information about you if you visit our national or branch websites by reference to the pages you visit and/or how you navigate the site.

What information we might collect

When you engage with us by email, phone, mail, in person or online, or if you attend any of our events, we may collect information about you (referred to in this Privacy Notice as personal information). This may include your name, address, email address, telephone number, date of birth, financial information related to your membership of the Association or the purchase of Association-related products, your job title and details of your education and career, why you are interested in the Association and/or the work of the Association`s branches, and/or other information relating to you personally which you may choose to provide to us.

The Association`s national office and our branches maintain membership, mailing and other lists related to the work of the Association and our branches. This may be in electronic form (on a computer or similar device) or in traditional paper form. Typically, this will contain personal information such as the name, address, email address and phone number of members and non-members who participate or have expressed interest in the activities of the Association and/or a branch of the Association.

Data protection law recognises that certain types of personal information are more sensitive. This is known as 'sensitive' or 'special category' personal information and covers information revealing racial or ethnic origin, religious or philosophical beliefs and political opinions, trade union membership, information concerning health or sexual orientation. Sensitive information will only be collected where necessary. For example, we may need to collect health information from you when you register for or attend an event, act as a volunteer or otherwise are involved in activities of the Association at national or branch level. Clear notices will be provided at the time we collect this information, stating what information is needed, and why.

If you're 16 or under

If you're aged 16 or under, you must get your parent/guardian’s permission before you provide any personal information to us.

How and why we use your information

At national and branch level, we will use your personal information for the following purposes:

• To manage your membership of the Association or your involvement in our activities at national and/or branch level
• To tell you by mail, email and other methods about the activities of Association and/or the branches of the Association, and providing you with news related to the above and matters of interest connected to the Great War
• To send you our magazines, electronic bulletins and commodities
• To record and to provide you with a response and/or resolution if you contact us with an order, query, request or complaint, or if you request not to receive further information from us
• To generally advance the objectives of the Association, including in connection with the many activities of the Association and/or our branches, and for other essential record keeping purposes
• To fulfil any legal obligation to which we are subject

Who do we share your information with?

We will only use your information for the purposes for which it was obtained. Where appropriate we will share your information between national and branch level but we will not, under any circumstances, sell or share your personal information with any third party for their own purposes. Some of our service providers may have access to your data in order to perform services on our behalf such as processing payments. We will only share your data where legally required. We will comply with requests where disclosure is required by law.

How we protect your information

We use technical and other prudent security safeguards to ensure that your personal information is secure. We take appropriate measures to ensure that people with access to your personal information, at both national and branch level, are aware that such information is only used in accordance with this Privacy Notice.

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessed appropriately.

How long will we keep your information?

In respect of your personal information, we will retain it for no longer than necessary for the purposes for which it was collected, including in relation to your membership of the Association and/or your involvement with any branch, taking into account guidance issued by the Information Commissioner’s Office.

Your rights to your personal information

Data protection legislation gives you the right to request access to personal information about you which is processed by Association and/or its branches and to have any inaccuracies corrected.

You also have the right to ask us to erase your personal information, ask us to restrict our processing of your personal information or to object to our processing of your personal information.

If you wish to exercise these rights, please contact the Association`s national office (details above) or a branch in writing.

We will respond as soon as practical and in any event within 40 days of receipt of your written request.

How to make a complaint or raise a concern

If you would like more information, or have any questions about this policy, to make a formal complaint about our approach to data protection, to raise privacy concerns or to make a complaint in relation to how we have handled your personal information, please contact please contact the national office (details above) or a branch in writing.

If you are not happy with the response you receive, then you can raise your concern with the relevant statutory body which is the Information Commissioner’s Office.

Changes to our Privacy Notice

This Privacy Notice may change from time to time, and we will endeavour to tell you as soon as practicable if that occurs.

The Trustees and Executive Committee of The Western Front Association (the Charity) unreservedly commit to protecting its members, volunteers, employees and the people with whom it comes into contact through its activities from all forms of abuse, physical, sexual or emotional arising out of that contact.

The Charity will not tolerate any form of abuse directed at its volunteers, employees, members or those who come into contact with the charity and its activities. Disciplinary action will be taken where such abuse is identified.

Incidents of abuse must be reported at the earliest possible opportunity to the Executive Committee in particular the Chairman or his deputy (contact details are available in publications and through the website)so that safeguarding concerns may be investigated and if appropriate disciplinary action taken. Disciplinary action may include where necessary the prompt reporting to the appropriate authority.

Wherever practicable the identity of complainants will be protected.

Drawn up June 2019

Owner A Bolton

Reviewed September 2020

Next review 2025

Safeguarding Procedure

Where there is a likelihood of the operations of the Charity coming into contact with children or vulnerable adults a risk Assessment will be carried out. This may rely on the generic assessment at Appendix 1 or a ‘job specific’ assessment where greater risks are likely. The result of this risk assessment should be recorded in writing.

Where risks are identified the appropriate mitigation measures must be put in place, recorded and supervised by the lead member acting for the WFA.

Should the Executive Committee or its Chairman be advised of a potential safeguarding issue an investigation by the Chairman or suitable deputy should be carried out as soon as practicable. The evidence and record of the investigation should be in writing.

Internal disciplinary action could range from a verbal note of advice to the immediate suspension from the charity. Where concern is found to have foundation the Chairman or his designated deputy will on legal advice notify the appropriate authority which may be the DBS, the local safeguarding children or adult team or the Police.

Where a Branch Committee become aware of a safeguarding issue they shall notify the Chairman or his deputy with immediate effect. The Branch Chair or an appointed deputy may for reasons of practicality conduct investigation on behalf of the Chairman but all notification to external bodies must be from the Executive Committee.

Where safeguarding complaints do not involve children or vulnerable adults the Executive Committee or its Chairman will appoint a tribunal to investigate the issue and recommend appropriate disciplinary action or recommendations to prevent a recurrence.

Any member, trustee, volunteer or employee subject to disciplinary action has the right to appeal, this appeal will be heard by the Executive Committee, any vote taken would exclude the original tribunal members. They will have the right to overturn or uphold the disciplinary action taken.

Drawn up June 2019

Owner A Bolton Education Trustee

Due for review Summer 2020

Risk Assessment of the WFA National Activities

The WFA interacts with the public including children and possibly vulnerable adults in the following ways:

• By holding conferences which whilst predominately aimed at members are open to non-members which may include children.
• By participation in events such as the Heaton Park, Passchendaele or WDYTYA exhibitions.
• By organising Battlefield Tours.
• By making available to the public access to the website.
• By the making available of Podcasts.
• The WFA publish Stand To and Bulletin but these are available only to members. It is not uncommon however for back numbers of these magazines to be given away to the general public at events.
• The WFA has contact with the public via social media.

Of these potential contacts only the first three provide any safeguarding risk and only then at a low to negligible likelihood although the severity of the implications means it cannot be disregarded entirely.

The limited nature of contacts makes grooming a negligible risk even where children are present.

The subject matter of the WFA conferences militate against them being used inappropriately to promote issues of safeguarding.

Battlefield Tours are organised by commercial companies on behalf of the Association and therefore the responsibility primarily rests with the organiser.

Up until now Safeguarding has been covered by a number of different Constitutional and Policy documents but it has been decided to produce a specific Safeguarding Policy for The Western Front Association in order to ensure we fully meet the requirements of the Charity Commission.

Charities are required to have a Safeguarding Policy together with a Procedure for its implementation. It is also necessary to carry out and record a Risk Assessment.

The Executive Committee has adopted the Policy, Procedure and Risk Assessment and these will shortly be available on the website.

There can be no doubt that, notwithstanding, the legal obligations, the reputational risk to a charity is enormous if an incident occurs. The adoption by Branches of this Safeguarding Policy and Procedures will help to protect Branch Committees and individual members from the worst effects of malicious claims as well as fulfilling our obligations of protection for those who come into contact with this charity.

A downloadable document Safeguarding and protecting people for charities and trustees is available from Gov.UK. https://www.gov.uk/guidance/safeguarding-duties-for-charity-trustees and it is recommended that Branch Committees familiarise themselves with it. Safeguarding does not only apply to the protection of children from sexual harassment but has wider implications.

The particular nature of the WFA and its semi-autonomous branch network at home and overseas (including Ireland) present a particular challenge to the organisation with regard to compliance with HM Governments requirements. These notes relate to England and Wales but Branches overseas, Scotland and Ireland should check their local regulations.

In some cases individual branches have more contact with children, than the operation of the Executive Committee [EC] nationally. There is an increasing emphasis on contact with schools and the recruitment of younger members but it should be recognised that there is a concomitant increase in risk for the WFA, the Branch and individual members if robust safeguarding measures are not in place.

It seems likely that for the purpose of safeguarding compliance Branch Committees would be considered volunteers to the WFA charity.

Normal common sense precautions such as never being alone with children or vulnerable adults not only protects the child but also the branch member from unsubstantiated allegations which would be embarrassing to both the member and the WFA as a whole.

Photography of children can be particularly sensitive. Branches which hold events and wish to photograph children for example wearing tin hats or equipment should protect themselves by obtaining consent to take a child’s photograph, particularly if it is intended to publish the photograph externally or even in the WFA publications.

The following notes on Policy and Risk Assessment are intended to assist Branch Committees but are suggested as the minimum requirement.

If Branches have any questions relating to the subject of Safeguarding they can be directed to the Education Trustee.

Suggested Policy on Safeguarding for Branch Committees

1. Branch Committees should formally adopt the WFA Safeguarding Policy and subsequent revisions published on The Western Front Association Website.
2. Branch Committees should designate a member to have particular responsibility for issues relating to Safeguarding.
3. Branch Committees should be aware of and implement the Safeguarding Procedures which accompany the Safeguarding Policy on the WFA website. Branch Committee members must pay particular attention to the obligations placed upon them to immediately report to the Executive Committee any incidents of which they become aware and to assist the Executive Committee in any investigation.
4. Branch Committees must carry out risk assessments in respect of Safeguarding for all their activities. A generic Risk Assessment is included with the Safeguarding Policy but where a more specific risk assessment is required it should be recorded in writing and retained for at least twelve months.
5. It is necessary that Branch Committees review the Policy, Procedure and Risk Assessment on an annual basis, it is suggested it may be included as an item in Branch AGM Minutes.

Suggested Risk Assessment for Branches

Individual branches interact with the public and hence potentially children and vulnerable adults in the following ways:

• By holding regular meetings to hear educational talks about Great War subjects. These meetings may include some social interaction. Meetings whilst predominantly targeted at members are open to the public.
• By organising external events to promote the charity’s goal of promoting remembrance of the Great War.
• By participating at events organised by others to promote the WFA and its goals.
• By organising trips to the battlefields.
• By producing newsletters and by presence on social media.

Although the attendance at branch meetings by unaccompanied children or vulnerable adults is possible the safeguarding risk is low because of the public nature of the meetings.

The participation by a branch in events which may specifically be targeted at children, such as school educational visits, by definition must be treated with due regard to the safeguarding of the participants. Where teachers or other responsible supervisors with suitable DBS checks are present the risk of safeguarding would predominantly be shouldered by the school or institution and therefore the safeguarding risk to the WFA Branch is low.

Where a branch participates in a non-supervised activity with children or vulnerable adults a ‘job specific’ risk assessment should be carried out. Any risk assessment producing an appreciable outcome should result in a plan being put into force to bring the risk down to low or negligible. Such action could include inter-alia ensuring members are never alone with children, avoiding closed rooms recruiting qualified supervisors.

Branch trips should only accept unaccompanied children or vulnerable adults in the most exceptional circumstances and only after extensive job specific risk assessment and mitigation measures.

Up until now Safeguarding has been covered within the WFA by a number of different Constitutional and Policy documents however it has been decided to produce a specific Safeguarding Policy for The Western Front Association in order to ensure we fully meet the requirements of the Charity Commission.

All charities are required to have a Safeguarding Policy together with a Procedure for its implementation. 

It is also necessary for charities to carry out and record a Risk Assessment based on the activities of the individual charity.

The Executive Committee has adopted this Policy, Procedure and Risk Assessment and in addition to being published here in Bulletin they are available on the WFA website. These documents will be reviewed and if necessary updated on an annual basis.

It is obviously an unfortunate necessity for the WFA to address this issue but equally there can be no doubt that, notwithstanding, the legal obligations, the reputational risk to a charity is enormous if an incident occurs. 

The Executive Committee wish to make clear that this Policy is not being published as a result of any known incidents within the WFA.  It is being published in this form merely to bring together existing practice and to ensure compliance with the requirements of the Charity Commission. 

In addition to the publication of the National Safeguarding Policy documents the Executive Committee strongly recommend that all Branch Committees adopt their own Safeguarding Policy Procedure and Risk Assessment.

Safeguarding for Branch Committees

To assist Branch Committees a suggested ‘Branch Safeguarding Policy, Procedure and Risk Assessment’ will be issued to Branches.

The adoption by Branches of the suggested Safeguarding Policy and Procedures will help to protect Branch Committees and individual members from the worst effects of malicious claims as well as fulfilling our obligations of protection for those who come into contact with this charity.

A downloadable document Safeguarding and protecting people for charities and trustees is available from Gov.UK. https://www.gov.uk/guidance/safeguarding-duties-for-charity-trustees  and it is recommended that Branch Committees familiarise themselves with it. Safeguarding does not only apply to the protection of children from sexual harassment but has wider implications.

The particular nature of the WFA and its semi-autonomous branch network at home and overseas (including Ireland) present a particular challenge to the organisation with regard to compliance with HM Governments requirements. These notes relate to England and Wales but Branches overseas, Scotland and Ireland should check their local regulations.

 In some cases individual branches have more contact with children, than the operation of the Executive Committee nationally. There is an increasing emphasis on contact with schools and the recruitment of younger members but it should be recognised that there is a concomitant increase in risk for the WFA, the Branch and individual members if robust safeguarding measures are not in place.

It seems likely that for the purpose of safeguarding compliance Branch Committees would be considered as volunteers to the WFA charity. 

Normal common sense precautions such as never being alone with children or vulnerable adults not only protects the child but also the branch member from unsubstantiated allegations which would be embarrassing to both the member and the WFA as a whole.

Photography of children can be particularly sensitive. Branches which hold events and wish to photograph children for example wearing tin hats or equipment should protect themselves by obtaining consent to take a child’s photograph, particularly if it is intended to publish the photograph externally or even in the WFA publications. 

The following notes on Policy and Risk Assessment are intended to assist Branch Committees but are suggested as the minimum requirement.

If Branches have any questions relating to the subject of Safeguarding they can be directed to the Education Trustee.

The Western Front Association's logo must not be used by members or non-members in any commercial publication or advertisement or for commercial purposes without the written consent of the Association. Such consent, if granted, may be withdrawn in the discretion of the Association.

For permission, please contact the WFA's office in writing.

The Trustees and Executive Committee of The Western Front Association (the Charity) unreservedly commit to operating this charity in full compliance with the Equality Act of 2010 (the Act) recognising their duty to provide an environment and procedures which do not discriminate against any Trustee, employee, appointee, volunteer, member or anyone else who from time to time comes into contact with the Charity, on the grounds of ethnicity, gender, religion, disability, age or sexual orientation.

The Trustees do not believe that the Charity should claim any special exemption provided for under the act.

The Charity encourages application for membership and participation from anyone irrespective of ethnicity, gender, religion, disability, age, sexual orientation or academic knowledge who share the Charity’s objective in educating members and the wider public on the Great War.

The Charity commits to the promotion of Diversity, Equality and as wide an access as it is realistically able to provide for all stakeholders and will not tolerate any form of discrimination directed at its volunteers, employees, appointees, members or those who come into contact with the charity and its activities. It recognises that discrimination may be indirect and will not tolerate speech or other behaviour that undermines respect for any of the protected characteristics defined in the Equality Act. Disciplinary action will be taken against the relevant member or members where such discrimination or inappropriate speech or behaviour is identified within WFA activities and/or in contexts where a connection is made with the WFA.

Incidents of discrimination must be reported at the earliest possible opportunity to the Executive Committee in particular the Chair or his deputy (contact details are available in publications and through the website) so that concerns may be investigated and, if appropriate, disciplinary action taken.

Wherever practicable, the identity of complainants will be protected.

The Western Front Association Diversity Procedures

The Charity does not monitor new or existing members as to their ethnicity, gender, religion, disability or sexual orientation. Any information which the Charity has access to is only to the extent that can be inferred from members choice of title and first names. The Charity may from time to time carry out voluntary membership surveys which may provide some Diversity information.

The Charity is a membership organisation which offers open membership. All are free to join and participate without any form of discrimination but it realises that its activities, aims and objectives have a limited appeal within the wider community.

Specific Commitments by The Western Front Association at the national level, to equality, diversity and access.

The Charity at national level will ensure that any venues selected for its AGM or Conferences are suitably equipped for disabled access.

The Charity will try to ensure where practicable hearing loops are available or make other arrangements for hearing and sight impaired members. As a minimum, designated seats will be made available at the front.

The Charity will seek to obtain speakers with as wide an ethnic background as possible and whose subjects reflect a diverse appreciation of all participants in the Great War.

The Charity will seek contributions for its magazines and podcasts from as wide a section of the community as are able to provide the authoritative contributions necessary.

The Charity will aim to provide talks and articles that reflect the diversity of all those who were involved in the Great War including by recognising the role of women both at the Fronts and in support services.

The Charity will be sensitive to the fact that original materials may include terminology, values and attitudes which would not be acceptable in the present day. The Charity will make it clear that such historical terminology, values and attitudes are not representative of those held by the Charity today.

Specific Commitments expected from the Branch Network.

The Charity has approximately 50 local semi-autonomous branches within the UK with more branches in Ireland, Europe and the wider world.

The Charity expects branches in jurisdictions outside England and Wales to follow their relevant equality and diversity legislation guidelines in addition to the Charity’s Policy.

Within the local conditions Branches will, wherever practicable seek to ensure venues for meetings and local conferences have suitable disabled access and arrangements to assist those hard of hearing or with sight impairment. As a minimum, reserved front row seating will be available.

Branches will never discriminate directly or indirectly against any member or speaker or attendee on the grounds of ethnicity, gender, religion, disability, age or sexual orientation.

Branches are encouraged to seek to reflect diversity in identifying the variety of contributions made to the war including by recognising the wide ethnic and religious backgrounds of the participants and the role of women both at the Fronts and in support services.

The Western Front Association

Social Media Guidelines

The Western Front Association (WFA) encourages the use of social media by both members and officers of the WFA users and visitors to further interest, and educate the public in, the history of the Great War. Social media can help us raise our profile, engage with a wider audience and provide information. It is WFA policy that use of WFA social media platforms by members, officers users or visitors is conducted in accordance with the WFA`s Social Media Guidelines. These Guidelines should be read in conjunction with the WFA`s other policies.

Social Media Guidelines

Guidance for members, officers and visitors on using social media in relation to the WFA

Introduction

Definitions

Digital Editor – an appointee of the EC with responsibility for managing the WFA`s social media

EC - means the Executive Committee of the WFA

Members - all members of the WFA

Officers - all trustees, appointees and employees of the WFA

Social media - web-based tools and applications which enable users to create and share content (words, images and video content), and network with each other through the sharing of information, opinions, knowledge and common interests. Examples of social media include Facebook, Twitter, LinkedIn and Instagram.

Social Media Manager – the Digital Editor and any other Member or individual with responsibility from time to time for any aspect of the WFA`s social media

Visitors - non-Members who use social media in relation to the WFA, by posting on the WFA`s Twitter, Facebook or other accounts or platforms.

WFA Users - Members and Officers who use social media in relation to the WFA.

Why does the WFA use social media?

Social media helps in communicating the WFA's work and engaging with our audience (members and non-members), participating in relevant conversations and raising the profile of the WFA. We have a Digital Editor and other Social Media Managers who act with the authority of the EC to assist in this.

Why does the WFA need social media guidelines?

While we encourage the use of social media by (i) WFA Users and (ii) Visitors interested in the work of the WFA, we have certain standards, outlined in these Guidelines, which we request both WFA Users and Visitors to observe. Publication and commentary on social media carries similar obligations to any other kind of publication or commentary in the public domain.

Point of contact for social media

Our Social Media Managers are responsible for the day-to-day publishing, monitoring and management of our social media channels. If you have specific questions about any aspect of these channels, please contact to the Digital Editor or any other Social Media Manager.

The social media guidelines

These guidelines can be updated from time to time by the EC, as it sees appropriate.

Guidelines

Using the WFA's social media channels — appropriate conduct

1. The Social Media Managers are responsible for managing and supervising the WFA's social media channels.

2. The Social Media Managers regularly monitor our social media spaces for mentions of the WFA so we can follow what is being posted about the WFA, and to catch and identify issues or problems. If WFA Users become aware of any comments online that they think should be brought to the attention of the WFA, whether on WFA's social media channels or elsewhere, they should contact the Digital Editor (who may also liaise with the most appropriate Social Media Manager).

3. WFA Users are encouraged to be ambassadors for the WFA and ensure they reflect WFA values in terms of what and how they post. WFA Users and Visitors should be aware that any information they post online could affect how people perceive the WFA, and should use common sense and good judgement in their use of social media in a WFA context.

4. These Guidelines do not intend to inhibit personal use of social media, and constructive criticism is welcomed, but when using the WFA's social media channels, WFA Users are expected to (and Visitors are requested to) abide by the following:

• not to make offensive or derogatory comments relating to sex, gender, race, disability, sexual orientation, age, religion or belief;

• not to abuse, bully or harass another individual;

• not to use foul or obscene language or make threats, or be malicious or offensive;

• not to post images that are discriminatory or offensive or links to such content;

• not to libel anybody (when a false written statement that is damaging to a person's reputation is published online or in print);

• not to disclose personal information relating to other WFA Users and Visitors unless expressly authorised to do so;

• to express opinions and deal with differences of opinion respectfully, and not insult or demean people or treat them badly; and

• to be respectful of others and their opinions, and not be abusive;

• to behave appropriately, and in ways that are consistent with WFA's values, policies and reputation.

Members and Visitors are reminded that the trustees are all unpaid volunteers.

5. In the event that the Guidelines are not complied with by WFA Users or Visitors using the WFA`s social media accounts, the Digital Editor (after consultation with any other relevant Social Media Manager) has a discretion to mute, block, ban or delete (depending on the particular social media channel) WFA Users or Visitors on or from the WFA's social media channels, for such period as the Digital Editor sees fit.

6. A WFA User who feels he/she has been unfairly incorrectly muted, blocked, banned or deleted on or from the WFA's social media channels (depending on the particular social media channel) can register a written complaint with the Chairman which will be adjudicated by a delegated sub-committee of the EC after consultation with the Digital Editor and any other relevant Social Media Manager. Their decision is final. 

Use of personal social media accounts — appropriate conduct

1. The Guidelines set out in paragraphs 3 and 4 above apply to the use of personal social media accounts in respect of matters related to the WFA. 

2. In the event that the Guidelines are not complied with by WFA Users or Visitors using personal social media accounts in respect of matters related to the WFA, the Digital Editor (after consultation with any other relevant Social Media Manager) has a discretion to mute or block WFA Users or Visitors on or from the WFA's social media channels, for such period as the Digital Editor (after consultation with any other relevant Social Media Manager) sees fit.

4. A WFA User who feels he/she has been unfairly or incorrectly muted, blocked, banned or deleted (depending on the particular social media channel) on or from the WFA's social media channels because of the use of personal social media accounts can register a written complaint with the Chairman which will be adjudicated by the Chairman and one other member of the EC after consultation with the Digital Editor and any other relevant Social Media Manager. Their decision is final. 
5. Officers using social media channels must make it clear when they are speaking in a personal capacity and not on behalf of the WFA. 

Introduction

The Western Front Association sets itself high standards in all its work and that includes aspiring to secure mutual respect between branches, members and other organisations and people with whom we may come into contact. The Executive Committee recognises that as a large organisation, sometimes things may go wrong and we welcome these being brought to our attention so that they can be put right and so that all parties involved can learn from them. Many issues that cause concern arise as a result of misunderstandings or miscommunication and wherever possible, we hope that every effort will be made to resolve matters informally.

The procedures detailed below are intended for those situations where informal resolution has failed or is not considered appropriate. In developing them we have been mindful of the need to balance our desire to be thorough and fair with a recognition that resolving complaints within our organisation draws upon the time, effort, resources and goodwill of unpaid volunteers.

Aim and Commitment

The aim of this document is to define the types of complaints that may be made and the procedure for dealing with them. In relation to complaints, the Executive Committee (EC) of The Western Front Association (WFA) is committed to ensuring that:

1. Members and non-members should feel free to make a complaint.
2. If a member or non-member makes a complaint, it will be welcomed, acknowledged, treated in confidence and responded to in accordance with the provisions of this procedure.
3. Complaints are dealt with as soon as possible and as fairly as possible.
4. Unless the outcome of the complaint procedure dictates otherwise, every effort will be made to ensure that the complainant’s relationship with the association is not adversely affected because they made a complaint.

Definitions

1. A complaint can be defined as an 'expression of dissatisfaction, whether justified or not' (UK government definition). It may also provide the association with an opportunity to learn and improve the service and/or goods it provides for its members and the general public.
2. The Complainant is the party making the complaint against an individual or the WFA or WFA branch. They may be a WFA member, branch or member of the general public.
3. Days are defined as calendar days including Bank Holidays.
4. The Complainee is the party who is the subject of the Complaint.

Participation

1. Participation in the complaints process is voluntary.
2. Participation in the process is taken as an acceptance of the legitimacy of the WFA Complaints Process and an implicit acceptance to abide by the decision of the Panel.
3. A Complainant may withdraw a complaint at any time but may not resubmit the same complaint again.
4. A Complaints Process may be postponed or halted for exceptional reasons (e.g. ill health). This is to be agreed with the Panel Chair.
5. If the Complainee in a complaint chooses not to submit evidence or participate then this will not prevent the process reaching its completion.

Types of Complaints

1. Branch against branch.
2. Member against member.
3. Member against the EC or a member of the EC.
4. Member of the EC against another member of the EC.

Remit

1. The WFA can only consider complaints that fit within its statutory charitable purpose and remit and that concern WFA activities, branches or members.
2. The WFA is also unable to consider a complaint if the end result desired by the Complainant cannot be fulfilled by the WFA.
3. If, on receipt of a complaint, the EC believes there may be unlawful activity involved, the matter will be immediately reported to the relevant authorities (e.g. police, social services).
4. The WFA is unable to consider any complaint that is the subject of civil or criminal legal proceedings.
5. A complaint cannot be taken against a policy decision of the EC. Any concerns about policy issues should be raised at the AGM

Making a complaint

1. Where an individual or branch feel they have a grievance for a complaint, they must compile a WFA Complaint Form (see Appendix). This form is available from the WFA Honorary Secretary.
2. Complaint Forms can be submitted by post or by email.
3. All complaints must be forwarded to the Honorary Secretary of the EC.
4. If the complaint refers to the Honorary Secretary, the form should be sent to the Chair or Vice Chair.
5. If the Secretary, another trustee, a branch chair or a member receives a complaint verbally or by phone they will advise the complainant to submit their complaint to the Secretary on the Complaint Form
6. The Complainant should make the Honorary Secretary aware of any access issues they have which may impact on their ability to follow these procedures and the Secretary will consider reasonable adjustments.

Evidence

1. Parties making complaints and those subject to complaints are responsible for providing their own evidence, witnesses and other material to support their case.
2. All evidence is submitted in writing and may include letters, statements, emails, etc. No evidence may be submitted in video form, by telephone or in person unless arrangements are made in advance (e.g. if the Complainant has a sight or hearing impairment).
3. All complaints and evidence are to be presented in English.

Timeline

1. Unless circumstances dictate otherwise, complaints should be dealt with as soon as possible following the acknowledgment of the complaint. In the event of an unavoidable delay, the Complainant and Complainee will be informed of the new timescale.
2. Trustee and panels dealing with complaints will set out a timeline by which evidence and replies should be received, normally a period of ten days for each stage. Unless in exceptional circumstances (eg. illness), any evidence or replies received after that date will not be accepted.
3. The Complaints Panel will have ten days to complete their final report once in receipt of all the information provided by Complainant and Complainee.

Complaint Panels

1. The composition of a Complaint Panel will vary based on the nature of the complaint (see below).
2. Complaint Panels will be constituted by the EC.
3. Panel members should not include individuals who have an association with the Complainant. Any conflicts of interest must be declared. However, given the size of the WFA it may be impossible to avoid appointing Panel Members who have some association with a Complainant/Complainee.
4. A Complaints Panel will mainly consider the evidence put forward by the Complainant/s and Complainee.
5. The Complaints Panel will nominate one of its members to act as Chair. The Chair of the panel will be responsible for handing all communication relevant to the complaint, drafting its final report and submitting same to the Complainant, Complainee and EC.

Adjudication

In adjudicating a complaint, a Complaints Panel or a Trustee:

1. Must reach their judgment based largely on the written evidence submitted ot them.
2. May carry out research to investigate the evidence submitted before them where they feel if may be helpful to making a decision but they are under no obligation to do so.
3. May consider additional evidence in the public domain.
4. May request additional clarification and evidence from Complainants and Complainees where they feel it is helpful (e.g. original copies of emails, letters).

The WFA Legal Trustee will be available for consultation by any Trustee or panel considering a complaint and should review any final report before it is sent to the EC, the Complainant and Complainee.

Resolution

A Complaints Panel or Trustee considering a complaint may decide to:

1. Fully uphold the complaint(s).
2. Partially uphold the complaint(s).
3. Partially reject the complaint(s).
4. Fully reject the complaint(s).
5. Make recommendations as to a resolution i.e. an apology.
6. Make recommendations to the EC.

If the panel is unable to reach a unanimous decision, the decision may be taken by a majority. A majority decision will be forwarded to the Legal Trustee and EC for review prior to it being sent to the Complainant and Complainee.

Complaint Process

The Trustee/panel considering a complaint will ensure the following:

1. That the Complainee/s will be provided with a copy of the complaint which will be extracted from the complaint form. A copy of the form will not be sent to the Complainee/s.
2. That a timeline is put in place for the Complainant and the Complainee, to submit evidence, respond to communications and also the date by which the Panel will reach its verdict. Both Complainant and Complainee will be asked to indicate if there are circumstances (e.g. Holidays) that will prevent them from adhering to this timeline.
3. That the Complainee/s will be given the opportunity to respond to the complaint by email with the understanding that the content of the email will be copied to the complainant.
4. If necessary, the Complainant/s will then be given the opportunity to respond by email on the understanding that the content of the email will be copied to the Complainee.
5. Finally, if necessary, the Complainee/s will be given one more opportunity to respond to the latest comments of the complainant by email with the understanding that the content of the email will be copied to the complainant.
6. Once this process is complete, the Trustee/panel considering the complaint will make its decision and/or recommendations. A written report noting such decision and recommendations will then be forwarded to the WFA Legal Trustee for consideration. Following this, the report will be forwarded the EC for review.
7. Once the report has been reviewed by the EC, the Trustee or panel considering the complaint will forward a copy to the Complainant and Complainee.
8. Where applicable, if possible and unless exceptional circumstances dictate otherwise, the EC will implement any recommendations made by the panel.

Branch against Branch complaint

This will be considered by the Branch Coordinator. If the Branch Coordinator has a conflict of interest another Trustee will be nominated to deal with the complaint. Upon appointment, the Branch Coordinator or the Trustee acting on their behalf will administer the complaint in accordance with paragraphs 11 to 13 above. In addition, he/she will ensure that the Chair of the Branch being complained will nominate one member of the branch to conduct all communications in relation to the complaint.

Member against Member Complaint

This will be considered by a panel comprised of three members of the EC appointed by the Chair. Upon nomination, the panel will exercise its responsibilities in accordance with paragraphs 10 to 13 above.

Member against the EC or a member of the EC.

This will be considered by a panel comprised of three Branch Chairs. The Honorary Secretary will be responsible for seeking chairs willing to sit on the panel. If the Honorary Secretary is the subject of the complaint, another Trustee will undertake this task. Upon nomination, the panel will exercise its responsibilities in accordance with paragraphs 10 to 13 above.

Member of the EC against another member/s of the EC

This will be considered by a panel comprised of three branch chairs. The Secretary will be responsible for seeking chairs willing to sit on the Panel. If the Secretary is the complainant or subject of the complaint, another Trustee will undertake this task. Upon nomination, the panel will exercise its responsibilities in accordance with paragraphs 10 to 13 above.

Confidentiality

1. All complaints and documents relevant to complaints must be treated in the strictest confidence and must not be shared with other parties unless the matter is being reported to a statutory authority or the matter is the subject of a criminal investigation.
2. Members investigating complaints must at all time observe the relevant GDPR legislation and when sharing email content, they must ensure that addresses are not shared.

Documentation

1. On completion of a complaint process, the Secretary will retain an electronic and hard copy of all the relevant documentation. The electronic copy will be stored on a separate hard drive and the hard copy will be stored in a secure location.
2. Statistics on complaints will be collected as part of the WFA’s standard monitoring of its activity.

Other Documents and Policies

This policy should, where relevant, be read in conjunction with the WFA constitution and other polices and documents that may be issued by the EC from time to time.

Complaints Form

A copy of the complaints form can be obtained from the WFA Secretary.

You have the right to cancel within seven days of your contract with the WFA. If you do cancel your order, you will have your payment returned and your WFA membership will be cancelled.