Policies

Approved 19 March 2019

Updated 31 October 2023

FOIM are opposed to any discrimination on grounds of race, religion, ethnicity, sexual or gender orientation, sex, age or disability, or any other such factor.

Our constitution does not restrict or curtail who may benefit from our activities in relation to Ilkley Moor.

Membership is open to all and the processes and conditions for becoming a member or leaving will not discriminate on the above basis or nor will members harass or victimise individuals who are members or wish to become members because of any such factors.

The rules and decisions made relating to joining and being removed from the committee (whether as an elected,invited or guest member) will not discriminate against any individual on the above basis.

Participation in all events run by FOIM (whether as a guest or member) shall not be constrained or curtailed in a discriminatory manner save where reasonably necessary on the grounds of age or disability from a health and safety or safeguarding perspective. Any such limitations will be set out in our Health & Safety Policy, Litter Picking Policy and Safeguarding Policy and shall be kept under review to ensure that they remain fair, balanced and proportionate.

FOIM consider the health and safety of all participants in its activities, whether as volunteers, members, attendees or otherwise to be paramount. The activities undertaken by FOIM where health and safety issues arise are as follows:

• Volunteer days led by FOIM
• Volunteer days led by Bradford Council Countryside and Rights of Way Service
• Learning activity days with charitable and educational bodies
• Guided walks

All these activities normally take place on Ilkley Moor.

FOIM take the health and safety of all participants in these activities into account when planning and undertaking them and have the following policies and procedures in place. These are tailored for each type of activity.

The activities undertaken include litter picking, footpath maintenance, plant and overgrowth management and control, drain clearance and padding pool clearing.

The attendees are usually retired and semi-retired individuals plus a few Craven College students. The attendees are normally regular attendees at the monthly volunteer days with a relatively low number of new or irregular attendees.

The following procedures are in place for these activities:

• The FOIM Project Officer is present at all these events. Tracey is a trained outdoors first aider.
• The power tools used are limited those owned by FOIM (currently three brush cutters) where use is by individuals who have experience of using them plus those tools owned and brought to days by the volunteers themselves and used by them.
• A risk assessment is applied for all events –a Risk Assessment template is used.
• All existing volunteers have undertaken a health and safety talk from Tracey and new volunteers receive such a briefing from Tracey.
• Attendance has to be pre-advised to Tracey.
• If any volunteers are considered to be in inappropriate health for any activity then they are advised not to participate.
• No children are allowed to participate.
• The days are normally restricted in length from 10 am till 1 pm and participants may take breaks whenever they wish so as to avoid over-strenuous activity or tiredness.
• The Project Officer has a mobile phone in case of emergencies.
• In inclement weather the days are cancelled, restricted in length or the activities or location of the activities altered to suit the conditions.
• When undertaking these activities care is taken to ensure that members of the public passing by remain at a safe distance.
• If any additional risks are identified whilst undertaking these activities (e.g. wasps nest discovered by a bench) then this is reported to the Bradford Council Countryside Service officer (Richard Perham and Danny Jackson is his absence).
• Any accidents resulting in harm to any participant or a third party are recorded by Tracey Gray and reported to the FOIM Secretary.

Approved [February 2021]

  Overview 

• FOIM consider the health and safety of all participants in its activities, whether as volunteers, members, attendees or otherwise to be paramount. The activities covered by this policy are unguided litter picking undertaken by FOIM members together with their families and/or friends. This activity is managed and monitored via the FOIM litter pickers WhatsApp group. For details contact Jonathan Copland on 07986 700867 or membershipsecretary@ilkleymoor.org.

Equipment/clothing

• The following equipment is provided and should always be used:

– thick gloves

– litter picking grabbers

– high visibility vests

– rubbish bags.

• Please ensure you wear weather appropriate clothing including suitable footwear.
• Always take your mobile phone with you.

Litter picking

• Please only use the equipment provided by FOIM. If you need more or replacement equipment or are not sure how to use it contact Owen Wells on 07951 436126 or via chair@ilkleymoor.org
• Use the grabbers to pick up all sharp litter and wear your gloves at all times. Be particularly careful when handling broken glass and other sharp or rusty items.

You should not handle or collect needles, batteries, condoms, asbestos or chemicals. If you find any such items please report them to Bradford Council on 01274 431000 – ask for Waste Services.                        .

• Please be careful to avoid working on difficult or steeply sloping ground on the Moor and choose easy access paths to and on the Moor wherever possible. Do not touch dog faeces (unless using the pooper scoopers provided), go near dead animals and avoid walking through heather or long grass in shorts given the risk of ticks and the risk of Lyme’s disease. if you think you have been bitten by a tick and you develop flu like symptoms; see a doctor immediately (and tell them to test for Lyme’s disease).
• Be careful and avoid low hanging tree branches and thorny bushes
• If working in Ilkley town be careful when working near roads, avoid close proximity to traffic and wear your high visibility vest. Children should not work by a road-side.
• Please do not litter pick at night or during inclement weather or, unless you are in areas where other members of the public are likely to be present, alone.
• Any children litter picking with you must be accompanied by a parent or guardian.

Ensure that you only handle litter that you can readily lift, do not overfill rubbish bags and use good lifting practices when moving full bags.

Collected rubbish

• The bags of collected rubbish should be knotted when full. Be careful if they contain sharp objects.
• They should be left by a Bradford Council rubbish bin and please, if you can, contact Bradford Council using the QR scan code details on the bin to let them know you have done this and they will collect them.

Covid protection

• Only operate in line with the Government guidance and restrictions in force from time to time.
• Observe the social distancing requirements and any limits on the numbers/people who can work together or where you may litter pick.
• Wash your hands well and use hand sanitiser at the start and finish of your activities.
• Do not share your equipment with others.
• Do not litter pick if you are feeling unwell, or suspect that you may have Covid symptoms.

On completion of your good work

• Wash your hands thoroughly
• Clean, disinfect and treat any scratches or cuts.
• Report any hazardous items located to Bradford Council on 01274 431000- ask for Waste Services.
• If anyone has been hurt, you have anything you wish to report to FOIM or any ideas as to how we can organise things better or more safely please contact Jonathan Copland on 07986 700867, membership@ilkleymoor.org or via the FOIM litter pickers WhatsApp group.

The majority of the monthly volunteer days fall into this category. The activities tend to be more focused on footpath maintenance, drainage and undergrowth management together with fencing and dry stone wall maintenance/erection.

Mechanical equipment such as a chain saw may be present but will be used by the Bradford Council Countryside and Rights of Way Service officer. This is Richard Perham. The FOIM Project Officer Tracey Gray is often present in addition.

The procedures for these activities are controlled by Bradford Council and their officer present. Bradford Council have detailed Task Risk Assessments (current version April 2018, reviewed annually) which they apply to these activities and cover the health and safety aspects.

There are undertaken with school and scout groups and charitable youth groups such as the National Citizen Service and the LS29 Group.

The activities are focussed around fun informative events to allow participants to learn about Ilkley Moor, its flora and fauna together with training on and participation in surveying species on the Moor.

The number of these events in any depends of the current funding available to FOIM to cover the cost of the Project Manager being present to allow the activities to take place.

The basis of operation of these events and the procedures in place are as follows:

• The responsibility for the control, supervision, organisation and care of the participants on the day rests with the school/group/charity in question.
• This is made clear to the participating organisation prior to the event.
• Where the FOIM Project Manager believes that the organisation wishing to participate cannot provide the right level of supervision for those wishing to take part then the proposed event will be declined.
• FOIM provide, through our Project Manager, the specialist learning relating to the fauna/flora in question.
• FOIM undertake a risk assessment which is shared with the participating organisation prior to the event (see attachment for the risk assessment template used).
• A pre-event survey of the proposed sites of the activities is undertaken by the FOIM Project Officer to identify any potential transitory or new hazards (e.g. broken glass in adjacent shelters).
• The participating organisation undertakes its own risk assessment.
• The participants are given a health and safety talk by the FOIM Project Officer at the start of the event in question.

FOIM offer a number of guided walks on the Moor each year. These are usually led or involve the FOIM Project Officer. Some are led by FOIM Committee members or appropriate third parties (e.g. Fitness Walk with Nordic Walking led by Sabine Fugel who leads such walks in her professional life, and specialist walks which are led by Moors for the Future representatives who undertake this type of activity).

The number of attendees per walk is usually quite limited (less than 10).

The procedures that are in place for these walks are:

• They are all led by or with the FOIM Project Officer (a trained outdoor first aider) save as noted above.
• A risk assessment is prepared for these events (using the FOIM risk assessment template) and all participants on the day are advised of the risks to be aware off.
• The nature of the walk (strenuous, moderate or easy) is set out in the literature detailing it as is the question of whether dogs are allowed on the walk and whether prior booking is required or not.
• The walk leader has the ability to curtail or change the walk is any of the participants demonstrates that they may not be suitably fit or equipped to undertake it.
• Children are only permitted where accompanied by an adult.
• Where necessary the walk leader will check the walk route prior to the day of the actual walk.
• The walk leader always carries a mobile phone in case of emergencies.
• Any injuries or problems with a particular walk are advised to the FOIM Secretary.

In addition to providing guided walks a number of suggested walking routes are provided on the FOIM website. From a health and safety perspective the following points are flagged on the website:

• Nature of the walk
• Distance
• Approximate walking time
• Need to wear suitable outdoor footwear
• Check the weather forecast and wear/take suitable clothing
• Need to be able to read a map
• Take a mobile phone.

Memorials and Memorial Benches Policy

Adopted 12 September 2022
(Updated 20 June 2023)

Background 

Requests for the siting of memorials and memorial benches in particular on Ilkley Moor are becoming increasingly popular in line with the increased appreciation and usage of the Moor. Whilst the desire to remember loved ones in this manner is fully understood the current position is that there is a danger of a large proliferation of memorial benches on the Moor to the extent that they will impact on its natural scenic and ecological value.

We have therefore agreed with Bradford Countryside Services that a clear policy to manage and deal with these requests is required between our two organisations so requests can be dealt with consistently and sensibly whilst recognising the need to preserve the naturally open and wild nature of the Moor.

Bradford Council’s current policy

“The Council will limit the number and type of memorials at its parks, countryside and woodlands sites, subject to the following:

• The Council will limit the number and type of memorials at some parks, woodlands and countryside sites. Details of sites where memorials will be limited are set out in the schedule which accompanies this policy. Areas where no further memorials will be permitted will also be identified in the schedule.
• The Council will purchase and install the agreed memorial and re-charge the costs (including installation costs). Charges will be set out in advance of purchase.
• The Council will not maintain or replace memorials and reserves the right to remove them if they fall into disrepair or are damaged (having contacted or made attempts to contact the provider before doing so).
• The Council will remove unauthorised memorials from countryside, parks and woodland – in the case of floral tributes, after a suitable period.”

The Ilkley Moor countryside sites schedule states:”

• General approach is to limit further memorials (including trees) to locations where there is a demonstrable need. Final approval will be through site manager following discussions with appropriate consultative group (e.g. Friends).
• No further benches will be permitted at Cow and Calf and around Ilkley Tarn.
• Trees: where permitted must be approved native species and located in line with management plan. No plaques.”

Agreed approach

Bradford Countryside Services and FOIM have agreed the following approach to memorial requests:

Benches

• Requests – these will be handled by Bradford Countryside Service, liaising with FOIM, in line with the policies set out below.
• Locations – no new memorial bench sites will be permitted on Ilkley Moor. Undedicated existing benches may be adopted as memorial benches including by replacement with a new bench where the existing bench is dilapidated or in a poor state of repair. A schedule of undedicated bench sites will be created so it is available where requests are made.
• Style – any replacement benches must be of a simple style and made in materials that are easy to maintain. The details will be agreed specific to the site.
• Maintenance – whilst it is the practice of the FOIM volunteer work parties, under Bradford Countryside Services stewardship, to undertake maintenance work on benches on the Moor no commitment can be given in this regard.
• Donation – given the work undertaken by FOIM in maintaining benches on the Moor a donation will be sought in favour of FOIM as part of the approval process in addition to the requirement of meeting any repair or replacement and installation costs.

Trees/Other planting

• These should only be permitted where they fit in with the existing flora of the Moor so in practice should be restricted to the ghylls.
• Any planting of non-native species (eg daffodils) is not approved and we will seek to remove them whenever possible so as to retain the natural habitat of the Moor.

Memorial plaques on existing structures

• These may be considered where they help contribute towards the maintenance costs of these structures e.g. the shelter on the Lower Tarn, the shelter above the paddling pool. 

Review

This policy will be reviewed annually in conjunction with Bradford Countryside Services and when circumstances require it.

Archaeology Policy

 Approved and updated on 27^th March 2022

Overview 

As the West Yorkshire Archaeological Services survey of Ilkley Moor in 2006 reported:

“Ilkley Moor contains one of the most significant concentrations of prehistoric rock art in Britain, consisting of various forms of rock carvings probably dating to the late Neolithic period.”

The location of almost all carvings are recorded and logged by location in the publication ‘The Carved Rocks of Ilkley Moor’ published by WYMCC in 1986. This was superseded by ‘Prehistoric Rock Art of the West Riding: The Cup-and-Ring-Marked Rocks of the Valleys of the Aire, Wharfe, Washburn and Nidd published by WYMCC in 2003, and ‘The Carved Stones Investigation Project’ which ended in 2013. Details are also available on-line on the English Rock Art Database via the Archaeology Data Service (ADS) and via mobile apps such as Megaliths Pocket Guide.

In addition to the carved rocks, other prehistoric archaeological features such as enclosures, field systems, stone circles, artefact scatters, cairns and boundary stones are known and form important elements relating to the historic usages of the Moor. Many have Scheduled Ancient Monument status and are thus legally protected but these sites are in the minority and we acknowledge the difficulty of policing and enforcing such protections.

The challenges this gives rise to in balancing the conservation and protection of these features on the one hand, whilst celebrating their significance and value on the other are well recognised.

Bradford Council’s ‘Ilkley Moor Management Plan – 2016-26’ summarises the risks and issues faced very accurately in Section 6 so these are not repeated here.

The function of this policy is to set out the overall approach that FOIM will adopt both in relation to the rock art and other archaeological features on Ilkley Moor when carrying out its objectives and activities.

Our Approach

• The archaeology will be recognised and celebrated on a generic overall landscape basis rather than on a specific item by item identified basis so as to allow the vast majority of archaeological features that remain largely unknown about or hidden to remain so.
• Whilst we will lead and publicise walks which examine some of the most well- known archaeological sites these walks will aim to protect the archaeology in the following ways:

– they will focus on the most conspicuous and well-known features that most people can observe in any event, and

– the importance of the archaeology historically and the need to protect it will be stressed.

In practice, archaeological walks and tours tend to attract only those individuals who are genuinely interested and so they do not pose a significant material risk of damage.

• We will not increase the number or extent of the three walks we currently run and feature on our website (being, Across Crawshaw Moss & Neolithic Sites, Twelve Apostles and Beyond, and Cup & Ring Stones GPS Trail) without careful consideration as to the risks that these may generate.
• We will take no steps to cut back or clear encroaching vegetation or ground cover from any archaeological site. We will discourage any responsible authorities from doing so unless appropriate mitigating measures are introduced as well as obtaining any necessary consents from Bradford Countryside Services, West Yorkshire Archaeology Advisory Service and Historic England. Our promotion of peatland restoration will, to the limited extent it covers area where carvings feature, reduce dense heather and bracken coverage.
• Any signage on or relating to archaeological sites on the Moor should be generic, not specific to, or placed near to any monument.
• When undertaking footpath repair and maintenance we should avoid damage to or exposure of any archaeological feature.
• If upgrading or enhancing any little used paths we will consider whether rerouting of the path away from any sensitive archaeological site is appropriate.
• Before undertaking heather or bracken clearance in a mechanised-manner archaeological evaluations will be undertaken and mitigating measures taken where necessary.
• We will encourage Bradford Council to include in any filming consents on the Moor the identification and protection of any archaeological features that may be put at risk.
• With the increased use of the Moor by mountain bikers we should encourage Bradford Council to ensure that permitted routes do not damage, encroach upon or compromise the setting of any archaeological site.
• Our educational activities undertaken with third parties will stress the value of and need to protect and preserve the archaeology on the Moor for future generations.
• The change in status of Keighley Old Road so that it is no longer accessible as a public highway in the upper reaches of the Moor would limit potential damage by off road vehicles and we strongly support this initiative.
• As uncontrolled fires on the Moor can severely damage any archaeological site we strongly support Bradford Council’s prohibition on fires and BBQ’s on the Moor and support their #BeMoorAware campaign.
• Our website will direct individuals to contact us if they believe any archaeological features on the Moor have been or are being damaged.

Review

We will review this policy annually and also if any issues relating to the damage or unnatural deterioration of archaeological features are reported to verify whether it remains an appropriate approach.

Approved 14 March 2018

Updated 19 March 2019

Background

This paper sets out the nature and extent of personal data held by FOIM and the use and retention of it to confirm that processing of this data falls within the ‘legitimate interest’ basis for processing under Article 6(1)(f) of the GDPR.

For each type of data held by FOIM we must establish that:

• we have a legitimate interest in processing the data (the purpose test)
• the actual processing/use of that data is necessary for that purpose (the necessity test) and
• that the individual’s interests do not override this (the overriding interest test).

FOIM hold four types of personal data being:

1. members’ data
2. employee data
3. data held by the employee
4. suppliers’ data.

Members’ data analysis

FOIM hold the following personal information re our members:

• name and address
• telephone number
• email address
• date of joining
• membership type
• membership fees and donations made
• volunteering skills
• bank account details (where paying by standing order)
• the fact that PayPal has been used to make a payment where this is the case
• gift aid election
• a list of update emails sent to each member
• for corporate members the name and contact details of the individual who is the FOIM contact for them
• copies of emails with members relating to FOIM matters and their relationship with FOIM which occasionally will contain personal information within the email body.

This data is used for the following purposes:

• advising members of events and activities FOIM are undertaking
• advising members of and keeping them up-to-date about issues relating to Ilkley Moor
• advising members of the AGM and any other EGM’s held by FOIM together with the appropriate information about FOIM for such meetings
• advising members of volunteering opportunities whether at a member or committee level
• advising members of their membership renewal and reminding them where delays in this arise
• advising members of sponsorship opportunities
• insofar as it relates to committee members of FOIM, liaison between the FOIM committee members to allow them to carry out their function as committee members.

The data is not shared with any third parties for marketing of the services of either FOIM or the third parties.

Data is shared with FOIM’s bank, Unity Trust Bank, to allow it to process members’ standing orders, and with PayPal where members elect to use their services to pay membership fees or make a donation.

Data will not be shared with third parties unless they have a lawful right to require access to it (e.g. HMRC in relation to gift aid claims) or it is required purely to allow FOIM to communicate with members for any of the above listed purposes.

As a membership-based charity the use of the members data for the above purposes falls both within the aims for which the charity was established (see Article 5 of the FOIM Constitution) and also what members would reasonably consider appropriate.

The nature and the use of members data is summarised in the membership application form and spelt out in the privacy policy on the FOIM website.

Where members resign their data is held in a resigned members file and their data is deleted prior to the next AGM.

Where members do not expressly resign but fail to pay their subscription a reminder is sent following the AGM and later in the year (usually September). If they do not renew then no further updates are send post this date. Their data is then deleted immediately prior to the next AGM.

The exception to the data deletion rule is that the standing order requests and gift aid elections are held for 6 years so that any HMRC or banking queries that arise can be addressed.

There are no overriding member interests which contradict this approach. Systems are in place for the deletion of data relating to lapsed members within an appropriate timescale and for members to be able to opt out of receiving electronic communications where they wish.

In addition, FOIM holds the names and contact details of representative committee members who may not be not members of FOIM being representatives of the City of Bradford MDC, Ilkley Council and Wharfedale Naturalists together with email exchanges with these individuals relating to their activities as such.

Such details are only used for the purposes of liaising with such individuals in their representative capacity and email exchanges are retained where necessary for committee meeting records.

Employee data

FOIM have one-part time employee (Tracey Gray). The following information is held in relation to Tracey:

• name and address
• email address
• telephone numbers
• hours worked and activities undertaken in these hours
• bank account details
• salary and pension entitlement
• payments made in relation to salary, pension or expenses due
• qualifications held
• monthly summaries of activities provided to the FOIM committee
• email correspondence relating to FOIM and/or Tracey’s activities for it.

This information is used for the following purposes:

• monitoring and managing the activities of Tracey
• paying sums properly due to Tracey.

The information held is all necessary to monitor, manage and pay Tracey. It is not shared with any third parties other than those which have a lawful entitlement to such information (e.g. HMRC).

Data held by our employee

Tracey holds the following personal information relating to third parties on behalf of FOIM is her role as an employee:

• supplier information in line with and for the purposes set out in the supplier section below where Tracey is arranging the purchase of goods or services for FOIM
• contact details (name, telephone and email address) for individuals within organisations for whom Tracey is organising volunteer or learning activities on Ilkley Moor.

The latter information is only used for liaison with the organisations in question so as to allow these organisations to participate in learning and volunteer events on Ilkley Moor.

Supplier data

The following data is held in relation to suppliers or prospective suppliers of goods and services to FOIM (which will not comprise personal data, save for the first two items, in relation to corporate suppliers):

• contact name and address
• telephone and email addresses
• their bank account details
• orders placed with them
• sums due to and paid to them
• email traffic with them re the supply being/to be made which may occasionally contain personal data within the body of the email.

Such data is only used for the following purposes:

• sourcing of supplies
• the management of the supply
• payment for those supplies where made
• issues (if any) arising from the supply.

All such use of the data in question is as any supplier of data would expect. Details are held for a number of years (unless an individual supplier properly requests otherwise) given the repeat nature of the purchases FOIM may make (e.g. dog bags, printing and signage) and the prospective defect liability period (up to 6 years) for the supply should defects subsequently arise.

Conclusion

On the basis of the above analysis FOIM considers that its use of personal data in the above manner will fall within Article 6(1)(f) of the GDPR, and the ICO’s three tests.

For the record the following security arrangements are in place to protect data:

• The member data (other than bank account information) is held on a single password protected laptop held and used solely by the membership secretary. The only other person to have occasional use of this laptop is Norman Blackburn. He is the member who developed the database and used to operate it. He will include software updates/fixes at the request of the membership secretary when required to do so.
• The members’ bank account data is password protected and held by Unity Trust Bank on their password protected secure systems. Only the FOIM Treasurer may input this data or request changes.
• The employee payroll data is processed and held on the Government recommended Enrol Pay system and her pension data will, once payments start, be held on the Government mandated NEST system. Only the FOIM Treasurer has access to these systems for FOIM.
• The data held by the Tracey is held on the FOIM laptop provided to her which is password protected. Tracey has sole use of this laptop and controls the password.