01708 776 050 info@harrietellis.com

EQUALITY & DIVERSITY POLICY

  1. INTRODUCTION
    • We are an equal opportunities employers and learners. We are committed to equality of opportunity and to providing a service and following practices which are free from unfair and unlawful discrimination. The aim of this policy is to ensure that no applicant or member of staff receives less favourable treatment on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation, or is disadvantaged by conditions or requirements which cannot be shown to be relevant to performance. It seeks also to ensure that no person is victimised or subjected to any form of bullying or harassment.
  • We value people as individuals with diverse opinions, cultures, lifestyles and circumstances. All employees and learners are covered by this policy and it applies to all areas of employment and training including recruitment, selection, training, deployment, career development, and promotion. These areas are monitored and policies and practices are amended if necessary to ensure that no unfair or unlawful discrimination, intentional, unintentional, direct or indirect, overt or latent exists.
  • The Lead IQA has particular responsibility for implementing and monitoring the Equality and Diversity in Employment Policy and, as part of this process, all personnel policies and procedures are administered with the objective of promoting equality of opportunity and eliminating unfair or unlawful discrimination.
  • All employees, workers or self-employed contractors whether part time, full time or temporary, will be treated fairly and with respect. Selection for employment, promotion, training, or any other benefit will be on the basis of aptitude and ability. All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the Company.
  • Equality of opportunity, valuing diversity and compliance with the law is to the benefit of all individuals in our Company as it seeks to develop the skills and abilities of its people. While specific responsibility for eliminating discrimination and providing equality of opportunity lies with managers and supervisors, individuals at all levels have a responsibility to treat others with dignity and respect. The personal commitment of every employee to this policy and application of its principles are essential to eliminate discrimination and provide equality throughout the Company.

 

  1. OUR COMMITMENT
    • To create an environment in which individual differences and the contributions of individuals are recognised and valued.
  • Every employee, worker or self-employed contractor and learner is entitled to a working environment that promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated.
  • Training, development and progression opportunities are available to all.
  • Equality in the workplace is good management practice and makes sound business sense.
  • We will review all our employment practices and procedures to ensure fairness.
  1. OUR COMMITMENT AS A SERVICE PROVIDER
    • We aim to provide services to which all clients are entitled regardless of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation, offending past, caring responsibilities or social class.
  • We will make sure that our services are delivered equally and meet the diverse needs of our service users and clients by assessing and meeting the diverse needs of our clients.
  • This policy is fully supported by senior management and has been agreed with employee representatives
  • This policy will be monitored and reviewed annually.
  • We have clear procedures that enable our clients, candidates for jobs and employees to raise a grievance or make a complaint if they feel they have been unfairly treated.
  • Breaches of our equality and diversity policy will be regarded as misconduct and could lead to disciplinary proceedings.
  1. POLICY STATEMENTS

AGE

We will:

  • ensure that people of all ages are treated with respect and dignity;
  • ensure that people of working age are given equal access to our employment, training, development and promotion opportunities; and
  • challenge discriminatory assumptions about younger and older people.

 

DISABILITY

We will:

  • provide any reasonable adjustments to ensure disabled people have access to our services and employment opportunities;
  • challenge discriminatory assumptions about disabled people; and
  • seek to continue to improve access to information by ensuring availability of loop systems, braille facilities, alternative formatting and sign language interpretation.

RACE

We will:

  • challenge racism wherever it occurs;
  • respond swiftly and sensitively to racists incidents; and
  • actively promote race equality in the Company.

GENDER

We will:

  • challenge discriminatory assumptions about women and men;
  • take positive action to redress the negative effects of discrimination against women and men;
  • offer equal access for women and men to representation, services, employment, training and pay and encourage other organisations to do the same; and
  • provide support to prevent discrimination against transsexual people who have or who are about to undergo gender reassignment.

 

SEXUAL ORIENTATION

We will:

  • ensure that we take account of the needs of lesbians, gay men and bisexuals; and
  • promote positive images of lesbians, gay men and bisexuals.

 

RELIGION OR BELIEF

We will:

  • ensure that employees’ religion or beliefs and related observances are respected and accommodated wherever possible; and
  • respect people’s beliefs where the expression of those beliefs does not impinge on the legitimate rights of others.

 

PREGNANCY OR MATERNITY

We will:

  • Ensure that people are treated with respect and dignity and that a positive image is promoted regardless of pregnancy or maternity;
  • challenge discriminatory assumptions about the pregnancy or maternity of our employees; and
  • ensure that no individual is disadvantaged and that we take account of the needs of our employees’ pregnancy or maternity.

MARRIAGE OR CIVIL PARTNERSHIP

We will:

  • Ensure that people are treated with respect and dignity and that a positive image is promoted regardless of marriage or civil partnership;
  • challenge discriminatory assumptions about the marriage or civil partnership of our employees; and
  • ensure that no individual is disadvantaged and that we take account the needs of our employees’ marriage or civil partnership.

 

EX-OFFENDERS

We will:

  • prevent discrimination against our employees regardless of their offending background (except where there is a known risk to children or vulnerable adults).

 

EQUAL PAY                                                       

We will:

  • ensure that all employees, male or female, have the right to the same contractual pay and benefits for carrying out the same work, work rated as equivalent work or work of equal value.

 

BULLYING & HARASSMENT POLICY (BDA)

All members of staff and learners are entitled to be treated with dignity and respect in their place of work and / or study. This means freedom from behaviour by colleagues/staff that can be interpreted as bullying or harassment or that causes offense, and access to redress if such behaviour does arise. It also means standards of everyday behaviour that contribute to a working/ studying environment in which mutual respect and individual dignity are maintained.

  1. BULLYING AND HARASSMENT

Behaviour can constitute bullying or harassment where: it violates the dignity of a person on the grounds of their age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation (the protected characteristics); or where it creates an intimidating, hostile and degrading, humiliating or offensive environment. Individual or accumulative acts can seriously undermine the dignity, confidence, and work satisfaction to such an extent that it has an effect on job performance, and general happiness both inside and outside work.

Conduct becomes harassment if it persists and it has been made clear that it is regarded as offensive by the recipient or a witness to the conduct, although a single offensive act can amount to harassment if it is sufficiently serious.

Bullying and harassment can be further defined in the following ways:

  1. HARASSMENT BASED ON RACE, COLOUR OR ETHNIC ORIGIN

Harassment based on race, colour or ethnic origin that is directed towards an individual by another person or group of people which is racist in nature, and which is regarded as unwelcome or offensive by the recipient or a witness.

  • The following are examples that illustrate such conduct, though this is not an exhaustive list:
  • Jokes about race, colour or ethnic origin
  • Use of offensive names.
  • References to colleagues by offensive racist descriptions.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on race, colour or ethnic origin.
  • Circulation, or display, of offensive material based on race, colour or ethnic origin.
  • Detrimental behaviour because of a colleague’s race, colour or ethnic origin.
  1. HARASSMENT BASED ON PREGNANCY OR MATERNITY

Harassment based on pregnancy or maternity that is directed towards an individual by another person or group of people which is regarded as unwelcome or offensive by the recipient or a witness.

The following are examples that illustrate such conduct, though this is not an exhaustive list:

  • Jokes about pregnancy or maternity.
  • Use of offensive names.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on pregnancy or maternity.
  • Circulation, or display, of offensive material based on pregnancy or maternity.
  • Detrimental behaviour because of a colleague’s pregnancy or maternity.
  1. SEXUAL HARASSMENT

Sexual harassment is conduct that is directed towards an individual by another person or group of people which is regarded as unwelcome or offensive by the recipient or a witness.

  • The following are examples which illustrate such conduct, though this is not an exhaustive list:
  • Unwanted physical contact.
  • Contact which is intimidating, or physically or verbally abusive.
  • Jokes that are based on sexual or gender issues.
  • Non-verbal conduct, such as staring or gestures.
  • Suggestions that sexual favours may further a persons career, or that refusal may hinder it.
  • Sexual advances, propositions, suggestions or pressure for sexual activity at or outside work.
  1. HARASSMENT BASED ON DISABILITY

Harassment based on disability is conduct directed towards that is directed towards an individual by another person or group of people which is based on the persons disability or association with someone who has a disability and which is unwelcome to the recipient or a witness.

The following are examples which illustrate such behaviour, though this is not an exhaustive list:

  • Jokes about disability.
  • Use of offensive names.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on disability.
  • Circulation, or display, of offensive material based on disability.
  • Deliberate actions designed to hinder a colleague’s ability to undertake his/her duties because of their disability.
  1. HARASSMENT BASED ON SEXUAL ORIENTATION OR GENDER REASSIGNMENT

Harassment based on sexual orientation or gender reassignment is conduct that is directed towards an individual by another person or group of people which is regarded as unwelcome or offensive by the recipient or a witness.

The following are examples which illustrate such behaviour, though this is not an exhaustive list:

  • Jokes about sexuality or gender reassignment.
  • Use of offensive names.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on sexuality or gender reassignment.
  • Circulation, or display, of offensive material based on sexuality or gender reassignment.
  1. HARASSMENT BASED ON MARRIAGE OR CIVIL PARTNERSHIP

Harassment based on marriage or civil partnership is conduct that is directed towards an individual by another person or group of people which is regarded as unwelcome or offensive by the recipient or a witness.

The following are examples which illustrate such behaviour, though this is not an exhaustive list:

  • Jokes about marriage or civil partnership.
  • Use of offensive names.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on marriage or civil partnership.
  • Circulation, or display, of offensive material based on marriage or civil partnership.
  1. HARASSMENT BASED ON RELIGION OR BELIEF

Harassment based on religion or belief that is directed towards an individual by another person or group of people which is regarded as unwelcome or offensive by the recipient or a witness.

The following are examples which illustrate such behaviour, though this is not an exhaustive list:

  • Jokes about religions or beliefs.
  • Use of offensive names.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on religion or belief.
  • Circulation or display, of offensive material based on religion or belief.
  1. HARASSMENT BASED ON AGE

Harassment based on age is conduct directed towards a person or group of peoples which is based on the age of the person and which is unwelcome by the recipient or a witness.

  • Jokes about age.
  • Use of offensive names.
  • Use of offensive or insensitive stereotypes.
  • Verbal abuse based on age.
  • Circulation, or display, of offensive material based on age.
  1. DETRIMENTAL BEHAVIOUR BECAUSE OF AN ASSOCIATION WITH A PROTECTED CHARACTERISTIC

Bullying and harassment may not be based on the fact that an individual belongs to a particular group, but simply because the individual has been singled out for such treatment or associates with someone of a protected characteristic. For example, this would include claiming someone is gay when they are not or making fun of someone who has a disabled relative. The bullying and harassment may take the following forms, though again this is not intended as an exhaustive list:

  • Limiting or withdrawing verbal communication.
  • Isolating a colleague by unfriendly behaviour.
  • Behaviour designed to belittle or produce anxiety in a colleague.
  • Unreasonable scrutiny of work.
  • Unreasonable criticism of work, and adopting double standards in expectations of work performance.
  • Unreasonable denial of leave and/or special leave requests.
  • Unreasonable denial of requests for flexible working.
  • Work or staff social activities that deliberately exclude a colleague.
  • Jokes or inappropriate humour at the expense of a colleague.
  1. STANDARDS OF BEHAVIOUR
  • Courtesy towards others.
  • Consideration and understanding of the work demands of individuals
  • Maintaining a temperate tone, and temperate language, in all verbal and written communication with all.
  • Avoidance of the use of foul language.
  • Awareness of language and conduct which have the potential to offend someone.
  • Obtaining the express or implied permission of an individual; before adopting familiarity in conduct or language.
  1. WHAT TO DO IF YOU OR A COLLEAGUE / LEARNER IS SUBJECT TO BULLYING OR HARASSMENT

The company is committed to ensuring that there is no harassment or bullying in the workplace or in training. Allegations of harassment will be treated as a disciplinary matter, although every situation will be considered on an individual basis and in accordance with the principles of the grievance and disciplinary procedures.

  • Informal Complaint

The first step you are encouraged to take is to raise such issues with a senior colleague of your choice (whether or not that person has a direct supervisory responsibility for you) as a confidential helper. However this person cannot be David Martin, who will be responsible for investigating the matter if it becomes a formal complaint.

If you decide you can deal with the inappropriate behaviour informally, for example, if the act concerned is relatively minor, isolated or clearly unintentional. In these situations it is possible that the matter can be resolved immediately by letting your colleague know that the behaviour in question is unacceptable to you and should be avoided in future. If you feel unable to do this verbally, you should hand a written request to your harasser; this is something your confidential helper can assist you with. 

  • Formal Complaint

If you feel uncomfortable about raising the issue directly with your harasser or if you consider the behaviour is more serious because it was deliberate, part of a persistent pattern, or serious in nature, or has been repeated despite having discussed a previous incident informally, then you should bring the matter to the attention of David Martin as a formal written complaint and again this is something that your confidential helper can assist you with.

If possible, you should keep notes of the harassment so that the written complaint can include:

  1. the name of the alleged harasser;

 

  1. the nature of the alleged harassment;

 

  1. the dates and times when the alleged harassment occurred;

 

  1. the names of any witnesses; and

 

  1. any action already taken by you to stop the alleged harassment.

 

On receipt of a formal complaint we will take action to separate you from the alleged harasser to enable an uninterrupted investigation to take place.  This may involve a temporary transfer of the alleged harasser to another work area or suspension with contractual pay until the matter has been resolved.

The person dealing with the complaint will invite you to attend a meeting, at a reasonable time and location, to discuss the matter and carry out a thorough investigation. You have the right to be accompanied at such a meeting by your confidential helper or another work colleague of your choice and you must take all reasonable steps to attend. Those involved in the investigation will be expected to act in confidence and any breach of confidence will be a disciplinary matter.

On conclusion of the investigation which will normally be within ten working days of the meeting with you, the decision of the investigator detailing the findings will be sent, in writing, to you.

You have the right to appeal against the findings of the investigator in accordance with the appeal provisions of the complaints procedure.

  1. NOTES
  • If the decision is that the allegation is well founded, the harasser will be liable to disciplinary action in accordance with our disciplinary procedure. An employee who receives a formal warning or who is dismissed for harassment may appeal by using our capability/disciplinary appeal procedure.
  • If you bring a complaint of harassment you will not be victimised for having brought the complaint. However if it is concluded that the complaint is both untrue and has been brought with malicious intent, disciplinary action and /or action will be taken against you.

 

Safeguarding Policy

Introduction 

Harriet Ellis Training Solutions makes a positive contribution to a strong and safe community and recognises the right of every individual to stay safe.

Harriet Ellis comes into contact with adults through their training courses, in the provision of the Level 3 National Diploma Apprenticeship programme, this is via distance learning, however will require assessor visits.  The contact will include, email, Skype, telephone & face to face contact.  The face to face contact will be with the trained Dental Educationalists and Exam Invigilators only, who will hold relevant DBS checks.

This policy seeks to ensure that Harriet Ellis undertakes its responsibilities with regards to protection of adults and will respond to concerns appropriately. The policy establishes a framework to support paid and unpaid staff in their practices and clarifies the organisation’s expectations. All staff can confirm that they have been made fully aware of, and understand the contents of, the Safeguarding Policy and Procedures for Harriet Ellis Training Solutions.

Safeguarding is about embedding practices throughout the organisation to ensure the protection of vulnerable adults wherever possible. In contrast adult protection is about responding to circumstances that arise.

Abuse is a selfish act of oppression and injustice, exploitation and manipulation of power by those in a position of authority. This can be caused by those inflicting harm or those who fail to act to prevent harm. Abuse is not restricted to any socio-economic group, gender or culture.

It can take a number of forms, including the following:

  • Physical abuse
  • Sexual abuse
  • Emotional abuse
  • Bullying
  • Neglect
  • Financial (or material) abuse

Prevent & Protect

Harriet Ellis is committed to helping & identifying the needs & vulnerabilities of individuals.  As an organisation we are committed to promoting the welfare of individuals & keeping people safe.  All staff must be vigilant at all times & are trained to be able to recognise & respond to neglect & signs of abuse.  All staff know that they must act quickly if they suspect an individual is suffering or likely to suffer from harm. 

Standards of Good Practice

To ensure that we meet our responsibilities to individuals, all staff will:

  • treat all individuals with respect
  • treat young people and adults as individuals
  • put the person’s welfare first
  • set a good example by conducting ourselves appropriately
  • involve people in decisions that affect them
  • encourage positive and safe behaviour among all
  • be a good listener
  • be alert to changes in people’s behaviour
  • recognise that challenging behaviour may be an indicator of abuse
  • maintain appropriate standards of conversation and interaction with and between young people and avoid the use of sexualised or derogatory language
  • be aware and sensitive of different cultures and different communities
  • share concerns immediately with the DO; and in their absence make an immediate referral to children’s services
  • always act in the best interests of an individual

Abuse of Trust

All staff understand that inappropriate behaviour is completely unacceptable.  In addition, staff must understand that, under the Sexual Offences Act 2003, it is an offence for a person over the age of 18 to have a sexual relationship with a person under the age of 18, where that person is in a position of trust, even if the relationship is consensual. This means that any sexual activity between a member of staff and a learner under 18 may be a criminal offence, even if that young person is over the age of consent.

Whistleblowing

Staff that are concerned about the conduct of a colleague or professional towards a learner have a duty to protect the welfare of an individual and report the behaviour immediately.  We appreciate that staff will be placed into an unsettling & difficult position, however must Remember their duty to respond and inform.

All concerns of poor practice or possible abuse by colleagues should be reported to the DO immediately.

Definition of Vulnerable Adults

A vulnerable adult is a person aged 18 years or over who may be unable to take care of themselves or protect themselves from harm or from being exploited.

This may include a person who:

  • Is elderly and frail
  • Has a mental illness including dementia
  • Has a physical or sensory disability
  • Has a learning disability
  • Has a severe physical illness
  • Is a substance misuser
  • Is homeless

 

All staff, including freelanced staff (paid or unpaid) have a responsibility to follow the guidance laid out in this policy and related policies, and to pass on any welfare concerns using the required procedures.

We expect all staff (paid or unpaid) to promote good practice by being an excellent role model, contribute to discussions about safeguarding and to positively involve people in developing safe practices.

The scope of this Safeguarding Policy is broad ranging and in practice, it will be implemented via a range of policies and procedures within the organisation. These policies include:

  • Health & Safety Policy
  • Equal & Diversity Policy
  • Bullying & Harassment Policy
  • Data Protection Policy

Role of Staff and Volunteers

All staff and volunteers working on behalf of the organisation have a duty to promote the welfare and safety of adults at risk. Staff and volunteers may receive disclosures of abuse and observe adults who are at risk. This policy will enable staff/volunteers to make informed and confident responses to specific adult protection issues.

It is important that adults at risk are protected from abuse. All complaints, allegations or suspicions must be taken seriously.  This procedure must be followed whenever an allegation of abuse is made or when there is a suspicion that an adult at risk has been abused.

Promises of confidentiality must not be given as this may conflict with the need to ensure the safety and welfare of the individual.

A full record shall be made as soon as possible of the nature of the allegation and any other relevant information.  This must include information in relation to the date, the time, the place where the alleged abuse happened, your name and the names of others present, the name of the complainant and, where different, the name of the adult who it is alleged has been abused, the nature of the alleged abuse, a description of any injuries observed, the account which has been given of the allegation.

Any suspicion, allegation or incident of abuse must be reported to the Designated Adult Protection Lead or Senior Manager on that working day where possible.

The nominated member of staff shall telephone and report the matter to the appropriate body/agency. A written record of the date and time of the report shall be made and the report must include the name and position of the person to whom the matter is reported. The telephone report must be confirmed in writing to the relevant local authority adult social services department within 24 hours.

The Role of the Designated Officer

The role of the designated officer is to deal with all instances involving adult protection that arise within the organisation. They will respond to all adult at risk protection concerns and enquiries.

The designated Vulnerable Adult Protection Lead for the organisation is Hadley Silver. Should you have any suspicions or concerns relating to Adult Protection, contact hadley@harrietellis.com.

Training will be provided, as appropriate, to ensure that staff are aware of these procedures. Specialist training will be provided for the member of staff with vulnerable adult protection responsibilities.

 

HEALTH & SAFETY POLICY

  1. General Statement
    • Harriet Ellis fully recognises the duties placed upon it under the Health and Safety at Work Act 1974 and all other relevant legislation. The company is committed to ensuring it at least complies with the minimum requirement and wherever reasonably practicable shall exceed them. It also recognises the obligation it has to others with regard to its activities including the funding bodies in UK responsible for provision of youth training as well as other partners in relation to delivery of training.
  • The company is committed to working with these partners to ensure a safe and healthy working environment. The company recognises the duties it has to not only its staff, but also to trainees, contractors, apprentices, visitors and any others who may be affected by its activities and shall adopt the principle of zero tolerance with regard to accident prevention. This principle is underpinned by the acceptance of the company that no accident at work is acceptable.

 

  • Harriet Ellis also recognises the position it holds within the Recruitment and Training Industry and as such is committed to the production of high quality Health and Safety training materials. The company will also work toward attaining a position of Standard in Health & Safety.
  1. Policy Objectives
  • The company will ensure that:
  • Provide and maintain a safe, healthy working environment with safe access and outlets;
  • Ensure the safety of staff who are mobile workers or those who work from work.
  • Ensure that trainees and Apprentices under its Training Agency are placed in a safe and healthy working environment;
  • Provide all necessary safety devices, protective equipment and supervise their use.
  • Maintain a constant and continuing improvement in all aspects of safety, in particular by introducing and monitoring safety procedures.
  • Consult employees on matters relating to workplace health, safety and welfare, development and review of policy and procedures through safety management established within the company.
  • Communicate relevant Health and Safety information through Notice boards in the workplace and the internal e-mail.
  • all processes and systems of work are designed to take account of health and safety and are properly supervised at all times.
  • competent people are appointed to assist us in meeting our statutory duties including, where appropriate, specialists from outside of the company
  • all employees are consulted on matters relating to health, safety and welfare
  • adequate facilities and arrangements will be maintained to enable employees to raise issues of health and safety
  • each employee will be given such information, instruction and training as is necessary to enable the safe performance of work activities
  • all arrangements are brought to employees’ attention and are monitored and reviewed to ensure that they are effective.

2.2 Staff, contractors & freelance workers also have a duty to co-operate fully in the operation of this Policy by:

  • co-operate with management to enable all statutory duties to be complied with
  • Work safely and efficiently, complying with any instruction, information & training in accordance with all procedures and statutory obligations.
  • take reasonable care of their own health and safety and the health and safety of others who may be affected by their acts or omissions
  • Familiarise themselves with the health and safety arrangements that apply to them and their work functions.
  • Immediately reporting incidents (including accidents, near misses, which have results in, or may lead to injury) to their line Manager.
  • Immediately reporting any incidents within the Dental Practice directly to the GDC.
  • Assisting with the investigation of accidents and aiding the introduction of measures to prevent a recurrence.
  1. Policy Implementation

3.1 The company has appointed a Manager responsible for Health & Safety who will ensure continual strategic direction with regard to health, safety and welfare in Harriet Ellis.

3.2 Harriet Ellis shall appoint local advisors competent in Health and Safety who will provide general advice on policy implementation.

3.3 The Health and Safety Officer shall maintain the all safety records and ensure policies & processes are in place for its continual improvement.

3.4 Department Managers are responsible for implementation and operation of the safety management system in their departments and will be accountable to the Director responsible for Health and Safety.  Managers will be supported in this function by the Health and Safety Officer.

3.5 The Operational staff handbook which contains health and Safety information will give further guidance on arrangements for putting into effect this policy.

3.6 This policy shall be reviewed whenever circumstances require it such as changes to legislation or activities and at least annually.

3.7 This policy shall be issued to all new members of staff and be made available to all other interested parties.

This policy will be included in the induction of new staff.

  1. Fire and Evacuation Procedures

4.1 Harriet Ellis understands how dangerous a fire can be and will therefore take all reasonable action to ensure that fire is prevented and that in the event of such an event, staff, service users and visitors can be safely evacuated following the Evacuation Policy.

4.2 Harriet Ellis has trained Fire Marshalls throughout the company.

  1. Accidents and First Aid

5.1 Harriet Ellis understands the need of all accidents and incidents to be reported and adequate records kept to review and resolve any patterns that may be identified.

All accidents and incidents are to be reported to be logged on the Accident & Incident log on the Company T Drive and the Operations Manager must be informed of these.  The Operations Manager will then decide whether any actions are to be taken to prevent further repeat incidents.

5.2 Harriet Ellis has trained First Aider’s throughout the company.

Safe Recruitment

Harriet Ellis ensures safe recruitment through the following processes: 

Job or role descriptions for all roles involving contact with children and / or vulnerable adults will contain reference to safeguarding responsibilities.

There are person specifications for roles which contain a statement on core competency with regard to child/ vulnerable adult protection/ safeguarding are included within all contracts offered.

Interviews are conducted according to equal opportunity principles and interview questions are based on the relevant job description and person specification.

Criminal Bureau Records Gap Management

The organisation commits resources to providing a Disclosure and Barring Service check on all staff whose roles involve contact with children and /or vulnerable adults. DBS checks will be conducted for specific roles for all staff working with children and vulnerable adults. Portable/ carry over DBS checks from another employer will not be deemed to be sufficient unless the update service is current and can be verified. It is a criminal offence for individuals barred by the ISA to work or apply to work with children or vulnerable adults in a wide range of posts.

Harriet Ellis Training Solutions will ensure that their established staff and roles are regularly reviewed through the following:

A 3 year rolling programme of re-checking DBS’s is in place for holders of all identified posts. Existing staff who transfer from a role which does not require a DBS check to one which involves contact with children / vulnerable adults will be subject to a DBS check.

No formal job offers are made until after checks for suitability are completed (including DBS )

Harriet Ellis Training Solutions commits resources for induction, training of staff, effective communications and support mechanisms in relation to Safeguarding

Induction will include the following:

Training

All staff who, through their role, are in contact with children and /or vulnerable adults will have access to safeguarding training at an appropriate level.

We recognise that involvement in situations where there is risk or actual harm can be stressful for staff concerned. The mechanisms in place to support staff include:

Debriefing support for paid and unpaid staff so that they can reflect on the issues they have dealt with, this can be provided by the Lead IQA

Seeking further support as appropriate e.g. access to counselling.

Staff who have initiated protection concerns will be contacted by line manager /DSM within a timescale of one week.

Communications

Harriet Ellis use the following mechanisms for enabling effective discussion of safeguarding issues between staff:

  • Team/Tutor meetings
  • SMT meetings
  • Board meetings
  • One to one meetings (formal or informal),
  • Clinical supervision

Monitoring

The safeguarding aspects that Harriet Ellis Monitor include:

Safe recruitment practices

  • DBS checks undertaken
  • References applied for new staff
  • Records made and kept of supervision sessions
  • Training – register and record of all staff training
  • Monitoring whether concerns are being reported and acted upon
  • Checking that policies are up to date and relevant
  • Reviewing the current reporting procedure in place
  • Presence and action of Designated Senior Manager responsible for Safeguarding is in post

Safeguarding Apprentices / Students / Pupils who are vulnerable to Extremism

Since 2010, when the Government published the Prevent Strategy, there has been an awareness of the specific need to safeguard children, young people and families from violent extremism.  There have been several occasions both locally and nationally in which extremist groups have attempted to radicalise vulnerable children and young people to hold extreme views including views justifying political, religious, sexist or racist violence, or to steer them into a rigid and narrow ideology that is intolerant of diversity and leaves them vulnerable to future radicalisation.

Harriet Ellis values freedom of speech and the expression of beliefs / ideology as fundamental rights underpinning our society’s values.  Both Apprentices / Students and teachers / Assessors / Dental Educationalists have the right to speak freely and voice their opinions.  However, freedom comes with responsibility and free speech that is designed to manipulate the vulnerable or that leads to violence and harm of others goes against the moral principles in which freedom of speech is valued.  Free speech is not an unqualified privilege; it is subject to laws and policies governing equality, human rights, community safety and community cohesion. 

The current threat from terrorism in the United Kingdom may include the exploitation of vulnerable people, to involve them in terrorism or in activity in support of terrorism.  The normalisation of extreme views may also make children and young people vulnerable to future manipulation and exploitation. Harriet Ellis is clear that this exploitation and radicalisation should be viewed as a safeguarding concern.

Definitions of radicalisation and extremism, and indicators of vulnerability to radicalisation are in Appendix A.

Harriet Ellis seeks to protect its apprentices / students against the messages of all violent extremism including, but not restricted to, those linked to Islamist ideology, or to Far Right / Neo Nazi / White Supremacist ideology, Irish Nationalist and Loyalist paramilitary groups, and extremist Animal Rights movements.

Response

Harriet Ellis, like all other organisations, is required to identify a Prevent Single Point of Contact (SPOC) who will be the lead within the organisation for safeguarding in relation to protecting individuals from radicalisation and involvement in terrorism: this will normally be the Designated Safeguarding Lead.  The SPOC for Harriet Ellis is Hadley Silver.

When any member of staff has concerns that a Student / Apprentice may be at risk of radicalisation or involvement in terrorism, they should speak with the SPOC and to the Designated Safeguarding Lead if this is not the same person. 

Numerous factors can contribute to and influence the range of behaviours that are defined as violent extremism, but most young people do not become involved in extremist action.  For this reason the appropriate interventions in any particular case may not have any specific connection to the threat of radicalisation, for example they may address mental health, relationship or drug/alcohol issues.

Safeguarding Apprentices / Students who are vulnerable to Exploitation, Forced Marriage, Female Genital Mutilation or Trafficking

Our safeguarding policy above through the organisation’s values, ethos and behaviour policies provides the basic platform to ensure children and young people are given the support to respect themselves and others, stand up for themselves and protect each other.

Our organisation keeps itself up to date on the latest advice and guidance provided to assist in addressing specific vulnerabilities and forms of exploitation.

Our staff are supported to recognise warning signs and symptoms in relation to specific issues, include such issues in an age appropriate way in their curriculum,

Our Designated Safeguarding Lead knows where to seek and get advice as necessary.

What to do when we are concerned

Where risk factors are present but there is no evidence of a particular risk then our DSL /SPOC advises us on preventative work that can be done within school to engage the pupil into mainstream activities and social groups.  The DSL may well be the person who talks to and has conversations with the  pupil/student’s family, sharing the school’s concern about the young person’s vulnerability and how the family and school can work together to reduce the risk. 

In this situation, depending on how worried we are and what we agree with the parent and the young person (as far as possible) –

The DSL/SPOC can decide to notify the Multi-Agency Safeguarding Hub (MASH) of the decision so that a strategic overview can be maintained and any themes or common factors can be recognised; and

The school will review the situation after taking appropriate action to address the concerns.

If the concerns about the pupil/student are significant and meet the additional needs/complex need criteria, they will be referred to the MASH.  This includes concerns about a child/young person who is affected by the behavior of a parent or other adult in their household.

Appendix A

INDICATORS OF VULNERABILITY TO RADICALISATION

  1. Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism leading to terrorism.

 

  1. Extremism is defined by the Government in the Prevent Strategy as:

Vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.  We also include in our definition of extremism calls for the death of members of our armed forces, whether in this country or overseas. 

  1. Extremism is defined by the Crown Prosecution Service as:

The demonstration of unacceptable behaviour by using any means or medium to express views which:

  • Encourage, justify or glorify terrorist violence in furtherance of particular beliefs;
  • Seek to provoke others to terrorist acts;
  • Encourage other serious criminal activity or seek to provoke others to serious criminal acts; or
  • Foster hatred which might lead to inter-community violence in the UK.
  1. There is no such thing as a “typical extremist”: those who become involved in extremist actions come from a range of backgrounds and experiences, and most individuals, even those who hold radical views, do not become involved in violent extremist activity.
  2. Pupils may become susceptible to radicalisation through a range of social, personal and environmental factors – it is known that violent extremists exploit vulnerabilities in individuals to drive a wedge between them and their families and communities. It is vital that school staff are able to recognise those vulnerabilities. 
  3. Indicators of vulnerability include:
  • Identity Crisis – the student / pupil is distanced from their cultural / religious heritage and experiences discomfort about their place in society;
  • Personal Crisis – the student / pupil may be experiencing family tensions; a sense of isolation; and low self-esteem; they may have dissociated from their existing friendship group and become involved with a new and different group of friends; they may be searching for answers to questions about identity, faith and belonging;
  • Personal Circumstances – migration; local community tensions; and events affecting the student / pupil’s country or region of origin may contribute to a sense of grievance that is triggered by personal experience of racism or discrimination or aspects of Government policy;
  • Unmet Aspirations – the student / pupil may have perceptions of injustice; a feeling of failure; rejection of civic life;
  • Experiences of Criminality – which may include involvement with criminal groups, imprisonment, and poor resettlement / reintegration;
  • Special Educational Need – students / pupils may experience difficulties with social interaction, empathy with others, understanding the consequences of their actions and awareness of the motivations of others.
  1. However, this list is not exhaustive, nor does it mean that all young people experiencing the above are at risk of radicalisation for the purposes of violent extremism.
  2. More critical risk factors could include:
  • Being in contact with extremist recruiters;
  • Accessing violent extremist websites, especially those with a social networking element;
  • Possessing or accessing violent extremist literature;
  • Using extremist narratives and a global ideology to explain personal disadvantage;
  • Justifying the use of violence to solve societal issues;
  • Joining or seeking to join extremist organisations; and
  • Significant changes to appearance and / or behaviour;
  • Experiencing a high level of social isolation resulting in issues of identity crisis and / or personal crisis.

Complaints Procedure

If a student is dissatisfied with either the course’s educational provision (other than the award of credit, a mark, or grade) or its support services, the following procedure must be followed.

Step 1 Speak to your Customer Service Officer to discuss your views.

Step 2: Contact the Operations Manager David Martin in writing at david@harrietellis.com. You will receive a response within seven working days.

Step 3 if you are still not satisfied then please put your complaint in writing to Hadley Silver, Managing Director. You will receive a response inside seven working days.

The student should contact the Company Director concerned in writing and explain the nature and grounds of the complaint.

The Director of the Division will acknowledge the complaint when received and resolve the complaint informally where possible, and record its outcome, where the issues raised by the student appear capable of effective and fair resolution by informal discussion with the student.

If it appears to the Director of the Division that the complaint appears on the face of it to be unjustified, misconceived or vexatious the Director may write to the student and invite withdrawal of the complaint on such basis with an indication that the complaint will only proceed to an investigation if the student responds in writing and requires the complaint to proceed.

In the event of a complaint proceeding formally, the Director of the Division will consider the complaint in consultation with those concerned in the provision of the service e.g. the course tutor, internal assessor, programme manager or other service manager.

Where a complaint puts in question a matter of academic performance and/or professional judgment/reputation of the person who is the subject of the complaint he/she shall have a right to put their case to the Director of the Division.

The Director of the Division will provide the student with a provisional response in writing as soon as reasonable practicable, and in any case within four weeks of receiving the complaint. The student will be invited to comment in writing within seven days. The Director of the Division will review the provisional response in the light of any observations communicated by the student and then finalize and provide the student with the written response itself within seven days of receiving any observations on the provisional response.

If the Director of the Division decides that there is a basis for the complaint, the Director of the Division will seek an equitable resolution of the issue.

If a student is expelled, a letter detailing the reasons will be sent to the student. The student will not be entitled to a refund of course fees paid. Harriet Ellis reserves the right to expel instantly any student contravening our gross misconduct policy.

 

Privacy Notice for Students / Apprentices Applications

In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, as prospective Students / Apprentices of our Company, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

  1. DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

  1. processing is fair, lawful and transparent
  2. data is collected for specific, explicit, and legitimate purposes
  3. data collected is adequate, relevant and limited to what is necessary for the purposes of processing
  4. data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
  5. data is not kept for longer than is necessary for its given purpose
  6. data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  7. we comply with the relevant GDPR procedures for international transferring of personal data

 

  1. TYPES OF DATA HELD

We keep several categories of personal data on our prospective Students / Apprentices in order to carry out effective and efficient processes. We keep this data in recruitment files relating to each vacancy and we also hold the data within our computer systems, for example, recruitment logs.

Specifically, we hold the following types of data:

  1. personal details such as name, address, phone numbers;
  2. name and contact details of your next of kin;
  3. your photograph;
  4. your gender, marital status, information of any disability you have or other medical information;
  5. right to work documentation;
  6. information on your race and religion for equality monitoring purposes;
  7. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter;
  8. references from former employers;
  9. details on your education and employment history etc;
  10. driving licence;
  11. criminal convictions.

 

  1. COLLECTING YOUR DATA

You provide several pieces of data to us directly during the recruitment / enrolment exercise.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.

Should you be successful in your application, we will gather further information from you, for example, your bank details and next of kin details, once your enrolment begins.

  1. LAWFUL BASIS FOR PROCESSING

The law on data protection allows us to process your data for certain reasons only.

The information below categorises the types of data processing we undertake and the lawful basis we rely on.

Activity requiring your data

Lawful basis

Carrying out checks in relation to your right to work in the UK

Legal obligation

Making reasonable adjustments for disabled employees

Legal obligation

Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion

Our legitimate interests

Making decisions about salary and other benefits

Our legitimate interests

Making decisions about contractual benefits to provide to you

Our legitimate interests

Assessing training needs

Our legitimate interests

Dealing with legal claims made against us

Our legitimate interests

Preventing fraud

Our legitimate interests

 

  1. SPECIAL CATEGORIES OF DATA

Special categories of data are data relating to your:

  1. health
  2. sex life
  3. sexual orientation
  4. race
  5. ethnic origin
  6. political opinion
  7. religion
  8. trade union membership
  9. genetic and biometric data.

We carry out processing activities using special category data:

  1. for the purposes of equal opportunities monitoring
  2. to determine reasonable adjustments

Most commonly, we will process special categories of data when the following applies:

  1. you have given explicit consent to the processing
  2. we must process the data in order to carry out our legal obligations
  3. we must process data for reasons of substantial public interest
  4. you have already made the data public.
  1. FAILURE TO PROVIDE DATA

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment, or administer contractual benefits.

  1. CRIMINAL CONVICTION DATA

We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to determine your suitability, or your continued suitability for the role. We rely on the lawful basis of our legitimate interests to process this data.

  1. WHO WE SHARE YOUR DATA WITH

Employees within our company who have responsibility for recruitment will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR. 

Data is shared with third parties for the following reasons:

N/A

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

We do not share your data with bodies outside of the European Economic Area.

  1. PROTECTING YOUR DATA

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

  1. RETENTION PERIODS

We only keep your data for as long as we need it for, which, in relation to unsuccessful candidates, is six months to a year.

If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job or training vacancies, we will keep your data for six months once the recruitment exercise ends.

If we have sought your consent to keep your data on file for future job or training vacancies, and you have provided consent, we will keep your data for a suitable period once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data and there will be no consequences of withdrawing consent.

If your application is successful, your data will be kept and transferred to the systems we administer for Students / Apprentices. We have a separate privacy notice for Students / Apprentices, which will be provided to you.

  1. AUTOMATED DECISION MAKING

Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

  1. YOUR RIGHTS

You have the following rights in relation to the personal data we hold on you:

  1. the right to be informed about the data we hold on you and what we do with it;
  2. the right of access to the data we hold on you. We operate a separate Subject Access Request policy and all such requests will be dealt with accordingly;
  3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
  4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
  5. the right to restrict the processing of the data;
  6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
  7. the right to object to the inclusion of any information;
  8. the right to regulate any automated decision-making and profiling of personal data.

 

In addition to the above rights, you also have the unrestricted right to withdraw consent, that you have previously provided, to our processing of your data at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any of the rights explained above, please contact Hadley Silver, Managing Director.

  1. MAKING A COMPLAINT

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.

  1. DATA PROTECTION COMPLIANCE

Karen Pursern – karenp@harrietellis.com

 

PRIVACY NOTICE FOR STUDENTS / APPRENTICES

 

In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our Students / Apprentices, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

This notice applies to current and former Students / Apprentices.

  1. DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

  1. processing is fair, lawful and transparent
  2. data is collected for specific, explicit, and legitimate purposes
  3. data collected is adequate, relevant and limited to what is necessary for the purposes of processing
  4. data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
  5. data is not kept for longer than is necessary for its given purpose
  6. data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  7. we comply with the relevant GDPR procedures for international transferring of personal data

 

  1. TYPES OF DATA HELD

We keep several categories of personal data on our Students / Apprentices in order to carry out effective and efficient processes. We keep this data in a personnel file relating to each Student / Apprentice and we also hold the data within our computer systems, for example, our data management system.

Specifically, we hold the following types of data:

  1. personal details such as name, address, phone numbers
  2. name and contact details of your next of kin
  3. your photograph / ID
  4. your gender, marital status, information of any disability you have or other medical information
  5. right to work documentation
  6. information on your race and religion for equality monitoring purposes
  7. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter
  8. references from former employers
  9. details on your education and employment history etc
  10. National Insurance numbers
  11. bank account details
  12. tax codes
  13. driving licence
  14. criminal convictions
  15. information relating to your employment with us, including:

 

  1. job title and job descriptions
  2. your salary
  • your wider terms and conditions of employment
  1. details of formal and informal proceedings involving you such as letters of concern, disciplinary and grievance proceedings, your annual leave records, appraisal and performance information
  2. internal and external training modules undertaken
  3. information on time off from work including sickness absence, family related leave etc
  4. IT equipment use including telephones and internet access.

 

  1. COLLECTING YOUR DATA

You provide several pieces of data to us directly during the recruitment period and subsequently upon the start of your course.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.

Personal data is kept in files or within the Company’s IT systems.

  1. LAWFUL BASIS FOR PROCESSING

The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the training agreement we have with you, including ensuring you are paid correctly.

The information below categorises the types of data processing we undertake and the lawful basis we rely on.

Activity requiring your data

Lawful basis

Carry out the training agreement that we have entered into with you e.g. using your name, contact details, education history, information on any disciplinary, grievance procedures involving you

Performance of the agreement

Carrying out checks in relation to your right to work in the UK

Legal obligation

Making reasonable adjustments for disabled students

Legal obligation

Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion

Our legitimate interests

Ensuring efficient administration of contractual benefits to you

Our legitimate interests

Effectively monitoring both your conduct, including timekeeping and attendance, and your performance and to undertake procedures where necessary

Our legitimate interests

Maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained

Our legitimate interests

Implementing grievance procedures

Our legitimate interests

Assessing training needs

Our legitimate interests

Implementing an effective sickness absence management system including monitoring the amount of leave and subsequent actions to be taken including the making of reasonable adjustments

Our legitimate interests

Gaining expert medical opinion when making decisions about your fitness for study

Our legitimate interests

Dealing with legal claims made against us

Our legitimate interests

Preventing fraud

Our legitimate interests

Ensuring our administrative and IT systems are secure and robust against unauthorised access

Our legitimate interests

 

  1. SPECIAL CATEGORIES OF DATA

Special categories of data are data relating to your:

  1. health
  2. sex life
  3. sexual orientation
  4. race
  5. ethnic origin
  6. political opinion
  7. religion
  8. trade union membership
  9. genetic and biometric data

We carry out processing activities using special category data:

  1. for the purposes of equal opportunities monitoring
  2. to determine reasonable adjustments

Most commonly, we will process special categories of data when the following applies:

  1. you have given explicit consent to the processing
  2. we must process the data in order to carry out our legal obligations
  3. we must process data for reasons of substantial public interest
  4. you have already made the data public.

 

  1. FAILURE TO PROVIDE DATA

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a training agreement with you. This could include being unable to offer you training.

  1. CRIMINAL CONVICTION DATA

We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to determine your suitability, or your continued suitability for the role. We rely on the lawful basis of our legitimate interests to process this data.

  1. WHO WE SHARE YOUR DATA WITH

Employees within our company who have responsibility for training, collection of payment and agreement benefits and the carrying out performance related procedures will have access to your data which is relevant to their function. All Apprentices / Students with such responsibility have been trained in ensuring data is processing in line with GDPR. 

Data is shared with third parties for the following reasons:

  • For collection of payment.
  • For studying purposes & qualification purposes.
  • For employment purposes.

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

We do not share your data with bodies outside of the European Economic Area

  1. PROTECTING YOUR DATA

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

  1. RETENTION PERIODS

We only keep your data for as long as we need it for, which will be at least for the duration of your employment with us though in some cases we will keep your data for a period after your employment has ended. Some data retention periods are set by the law. Retention periods can vary depending on why we need your data, as set out below:

Record

Recommended Retention Period

Application forms and interview notes

Permanently

Assessments under health and safety regulations and records of consultations with safety representatives and committees

Permanently

Money purchase details

6 years after transfer or value taken

Personnel files, training records (disciplinary records, working time records)

Permanently

 

  1. AUTOMATED DECISION MAKING

Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

  1. EMPLOYEE RIGHTS

You have the following rights in relation to the personal data we hold on you:

  1. the right to be informed about the data we hold on you and what we do with it;
  2. the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
  3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
  4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
  5. the right to restrict the processing of the data;
  6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
  7. the right to object to the inclusion of any information;
  8. the right to regulate any automated decision-making and profiling of personal data.

More information can be found on each of these rights in our separate policy on employee rights under GDPR.

  1. CONSENT

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.

  1. MAKING A COMPLAINT

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.

  1. DATA PROTECTION COMPLIANCE

Our appointed compliance officer in respect of our data protection activities is:

Karen Purser – karenp@harrietellis.com

 

PRIVACY NOTICE FOR EMPLOYEES

In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our employees, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

This notice applies to current and former employees, workers and contractors.

  1. DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

  1. processing is fair, lawful and transparent
  2. data is collected for specific, explicit, and legitimate purposes
  3. data collected is adequate, relevant and limited to what is necessary for the purposes of processing
  4. data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
  5. data is not kept for longer than is necessary for its given purpose
  6. data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  7. we comply with the relevant GDPR procedures for international transferring of personal data

 

  1. TYPES OF DATA HELD

We keep several categories of personal data on our employees in order to carry out effective and efficient processes. We keep this data in a personnel file relating to each employee and we also hold the data within our computer systems, for example, our holiday booking system.

Specifically, we hold the following types of data:

  1. personal details such as name, address, phone numbers
  2. name and contact details of your next of kin
  3. your photograph / ID
  4. your gender, marital status, information of any disability you have or other medical information
  5. right to work documentation
  6. information on your race and religion for equality monitoring purposes
  7. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter
  8. references from former employers
  9. details on your education and employment history etc
  10. National Insurance numbers
  11. bank account details
  12. tax codes
  13. driving licence
  14. criminal convictions
  15. information relating to your employment with us, including:

 

  1. job title and job descriptions
  2. your salary
  • your wider terms and conditions of employment
  1. details of formal and informal proceedings involving you such as letters of concern, disciplinary and grievance proceedings, your annual leave records, appraisal and performance information
  2. internal and external training modules undertaken
  3. information on time off from work including sickness absence, family related leave etc
  4. IT equipment use including telephones and internet access.

 

  1. COLLECTING YOUR DATA

You provide several pieces of data to us directly during the recruitment period and subsequently upon the start of your employment.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.

Personal data is kept in files or within the Company’s HR and IT systems.

  1. LAWFUL BASIS FOR PROCESSING

The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the employment contract we have with you, including ensuring you are paid correctly.

The information below categorises the types of data processing we undertake and the lawful basis we rely on.

Activity requiring your data

Lawful basis

Carry out the employment contract that we have entered into with you e.g. using your name, contact details, education history, information on any disciplinary, grievance procedures involving you

Performance of the contract

Ensuring you are paid

Performance of the contract

Ensuring tax and National Insurance is paid

Legal obligation

Carrying out checks in relation to your right to work in the UK

Legal obligation

Making reasonable adjustments for disabled employees

Legal obligation

Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion

Our legitimate interests

Making decisions about salary and other benefits

Our legitimate interests

Ensuring efficient administration of contractual benefits to you

Our legitimate interests

Effectively monitoring both your conduct, including timekeeping and attendance, and your performance and to undertake procedures where necessary

Our legitimate interests

Maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained

Our legitimate interests

Implementing grievance procedures

Our legitimate interests

Assessing training needs

Our legitimate interests

Implementing an effective sickness absence management system including monitoring the amount of leave and subsequent actions to be taken including the making of reasonable adjustments

Our legitimate interests

Gaining expert medical opinion when making decisions about your fitness for work

Our legitimate interests

Managing statutory leave and pay systems such as maternity leave and pay etc

Our legitimate interests

Business planning and restructuring exercises

Our legitimate interests

Dealing with legal claims made against us

Our legitimate interests

Preventing fraud

Our legitimate interests

Ensuring our administrative and IT systems are secure and robust against unauthorised access

Our legitimate interests

 

  1. SPECIAL CATEGORIES OF DATA

Special categories of data are data relating to your:

  1. health
  2. sex life
  3. sexual orientation
  4. race
  5. ethnic origin
  6. political opinion
  7. religion
  8. trade union membership
  9. genetic and biometric data

We carry out processing activities using special category data:

  1. for the purposes of equal opportunities monitoring
  2. in our sickness absence management procedures
  3. to determine reasonable adjustments

Most commonly, we will process special categories of data when the following applies:

  1. you have given explicit consent to the processing
  2. we must process the data in order to carry out our legal obligations
  3. we must process data for reasons of substantial public interest
  4. you have already made the data public.

 

  1. FAILURE TO PROVIDE DATA

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment, or administer contractual benefits.

  1. CRIMINAL CONVICTION DATA

We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to determine your suitability, or your continued suitability for the role. We rely on the lawful basis of our legitimate interests to process this data.

  1. WHO WE SHARE YOUR DATA WITH

Employees within our company who have responsibility for recruitment, administration of payment and contractual benefits and the carrying out performance related procedures will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR. 

Data is shared with third parties for the following reasons:

  • For your Pension Contribution.
  • For Tax & National Insurance Collections.
  • For processing payments of wages.

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

We do not share your data with bodies outside of the European Economic Area.

  1. PROTECTING YOUR DATA

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

  1. RETENTION PERIODS

We only keep your data for as long as we need it for, which will be at least for the duration of your employment with us though in some cases we will keep your data for a period after your employment has ended. Some data retention periods are set by the law. Retention periods can vary depending on why we need your data, as set out below:

Record

Statutory Retention Period

Children/young adults

Until the child reaches 21

Retirement Benefits Schemes

6 years from the end of the scheme year

Statutory Maternity Pay (calculations, certificates, medical evidence)

3 years after the end on the tax year in which the period ends

Wage/salary (overtime, bonuses, expenses)

6 years

National Minimum Wage

3 years after the end of the consequent pay reference period

Working hours

2 years after they are made

 

Record

Recommended Retention Period

Application forms and interview notes

6 months to a year

Assessments under health and safety regulations and records of consultations with safety representatives and committees

Permanently

HMRC approvals

Permanently

Money purchase details

6 years after transfer or value taken

Parental leave

Until child is 18 (birth/adoption)

Pension scheme investment policies

12 years from the ending of any benefit payable under the policy

Pensioners’ records

12 years after end of benefit

Personnel files, training records (disciplinary records, working time records)

6 years after end of employment

Redundancy details, calculations of payments, refunds, notification to the Secretary of State

6 years after date of redundancy

Statutory Sick Pay records, calculations, certificates, self-certificates

at least 3 months after the end of the period of sick leave, but 6 years after the employment ceases advisable

Time cards

2 years after audit

Trade Union agreements

10 years after end

Works Council minutes

Permanently

 

  1. AUTOMATED DECISION MAKING

Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

  1. EMPLOYEE RIGHTS

You have the following rights in relation to the personal data we hold on you:

  1. the right to be informed about the data we hold on you and what we do with it;
  2. the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
  3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
  4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
  5. the right to restrict the processing of the data;
  6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
  7. the right to object to the inclusion of any information;
  8. the right to regulate any automated decision-making and profiling of personal data.

More information can be found on each of these rights in our separate policy on employee rights under GDPR.

  1. CONSENT

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.

  1. MAKING A COMPLAINT

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.

  1. DATA PROTECTION COMPLIANCE

Our appointed compliance officer in respect of our data protection activities is:

Karen Purser – karenp@harrietellis.com

 

Privacy Notice for Job Applicants

In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, as prospective employees of our Company, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

  1. DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

  1. processing is fair, lawful and transparent
  2. data is collected for specific, explicit, and legitimate purposes
  3. data collected is adequate, relevant and limited to what is necessary for the purposes of processing
  4. data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
  5. data is not kept for longer than is necessary for its given purpose
  6. data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  7. we comply with the relevant GDPR procedures for international transferring of personal data

 

  1. TYPES OF DATA HELD

We keep several categories of personal data on our prospective employees in order to carry out effective and efficient processes. We keep this data in recruitment files relating to each vacancy and we also hold the data within our computer systems, for example, recruitment logs.

Specifically, we hold the following types of data:

  1. personal details such as name, address, phone numbers;
  2. name and contact details of your next of kin;
  3. your photograph;
  4. your gender, marital status, information of any disability you have or other medical information;
  5. right to work documentation;
  6. information on your race and religion for equality monitoring purposes;
  7. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter;
  8. references from former employers;
  9. details on your education and employment history etc;
  10. driving licence;
  11. criminal convictions.

 

  1. COLLECTING YOUR DATA

You provide several pieces of data to us directly during the recruitment exercise.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.

Should you be successful in your job application, we will gather further information from you, for example, your bank details and next of kin details, once your employment begins.

  1. LAWFUL BASIS FOR PROCESSING

The law on data protection allows us to process your data for certain reasons only.

The information below categorises the types of data processing we undertake and the lawful basis we rely on.

Activity requiring your data

Lawful basis

Carrying out checks in relation to your right to work in the UK

Legal obligation

Making reasonable adjustments for disabled employees

Legal obligation

Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion

Our legitimate interests

Making decisions about salary and other benefits

Our legitimate interests

Making decisions about contractual benefits to provide to you

Our legitimate interests

Assessing training needs

Our legitimate interests

Dealing with legal claims made against us

Our legitimate interests

Preventing fraud

Our legitimate interests

  1. SPECIAL CATEGORIES OF DATA

Special categories of data are data relating to your:

  1. health
  2. sex life
  3. sexual orientation
  4. race
  5. ethnic origin
  6. political opinion
  7. religion
  8. trade union membership
  9. genetic and biometric data.

We carry out processing activities using special category data:

  1. for the purposes of equal opportunities monitoring
  2. to determine reasonable adjustments

Most commonly, we will process special categories of data when the following applies:

  1. you have given explicit consent to the processing
  2. we must process the data in order to carry out our legal obligations
  3. we must process data for reasons of substantial public interest
  4. you have already made the data public.
  1. FAILURE TO PROVIDE DATA

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment, or administer contractual benefits.

  1. CRIMINAL CONVICTION DATA

We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to determine your suitability, or your continued suitability for the role. We rely on the lawful basis of our legitimate interests to process this data.

  1. WHO WE SHARE YOUR DATA WITH

Employees within our company who have responsibility for recruitment will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR. 

Data is shared with third parties for the following reasons:

  • For your Pension Contribution.
  • For Tax & National Insurance Collections.
  • For processing payments of wages.

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

We do not share your data with bodies outside of the European Economic Area.

  1. PROTECTING YOUR DATA

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

  1. RETENTION PERIODS

We only keep your data for as long as we need it for, which, in relation to unsuccessful candidates, is six months to a year.

If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for six months once the recruitment exercise ends.

If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for nine months once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data and there will be no consequences of withdrawing consent.

If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.

  1. AUTOMATED DECISION MAKING

Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

  1. YOUR RIGHTS

You have the following rights in relation to the personal data we hold on you:

  1. the right to be informed about the data we hold on you and what we do with it;
  2. the right of access to the data we hold on you. We operate a separate Subject Access Request policy and all such requests will be dealt with accordingly;
  3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
  4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
  5. the right to restrict the processing of the data;
  6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
  7. the right to object to the inclusion of any information;
  8. the right to regulate any automated decision-making and profiling of personal data.

In addition to the above rights, you also have the unrestricted right to withdraw consent, that you have previously provided, to our processing of your data at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any of the rights explained above, please contact Hadley Silver, Managing Director.

  1. MAKING A COMPLAINT

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.

  1. DATA PROTECTION COMPLIANCE

Karen Purser – karenp@harrietellis.com

 

 

 

 

 

 

 

 

 

 

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