Privacy Policy

Equal Opportunities and Diversity Policy

 

Policy Statement

 

It is the company’s policy not to discriminate against its workers on the basis of their gender, sexual orientation, marital or civil partner status, gender reassignment, race, religion or belief, colour, nationality, ethnic or national origin, disability or age, pregnancy or trade union membership or the fact that they are a part-time worker or a fixed-term employee. Our workers and applicants for employment shall not be disadvantaged by any policies or conditions of service which cannot be justified as necessary for operational purposes. The company shall, at all times, strive to work within legislative requirements as well as promoting best practice.

 

We are committed to a programme of action to make this policy effective and to bring it to the attention of all workers. The principle of non-discrimination and equality of opportunity applies equally to the treatment of visitors, clients, customers and suppliers by members of our workforce and also, in some circumstances, ex-employees.

 

The following paragraphs deal with the specific categories of workers and areas of work which we have identified as potentially giving rise to equal opportunities issues and provides more specific guidance on the parameters of our policy and approach to equal opportunities.

 

This policy is for guidance only and shall be provided to all workers, but does not form part of your contract of employment.

 

Who does this Policy Apply to?

This policy applies to all employees, whether permanent, temporary, casual, part-time or on fixed-term contracts, to ex-employees, to job applicants and to individuals such as agency staff and consultants and volunteers who are not our employees, but who work at the company (collectively workers).

 

All workers have a duty to act in accordance with this policy, and therefore to treat colleagues with dignity at all times, and not to discriminate against or harass other members of staff, whether junior or senior to them. In some situations, the company may be at risk of being held responsible for the acts of individual members of staff and will not therefore tolerate any discriminatory practices or behaviour.

 

The policy statement above applies equally to the treatment of our visitors, clients, customers and suppliers by our workers and the treatment of our workers by these third parties.

 

Personnel Responsible for Implementation of Policy

The MD has overall responsibility for the effective operation of this equal opportunities policy (EOP) and for ensuring compliance with the relevant statutory framework prohibiting discrimination. The MD has delegated day-to-day responsibility for operating the policy and ensuring its maintenance and review to the Managing Director.

 

Those working at a management level have a specific responsibility to set an appropriate standard of behaviour, to lead by example and to ensure that those they manage adhere to the policy and promote the aims and objectives of the company with regard to equal opportunities.

 

All members of staff are responsible for the success of this policy and must ensure that they familiarise themselves with the policy and act in accordance with its aims and objectives. If you have any questions about the content or application of this policy, you should contact the MD.

 

Scope and Purpose of Policy

The company will not unlawfully discriminate on grounds of gender, sexual orientation, marital or civil partner status, gender reassignment, race, religion or belief, colour, nationality, ethnic or national origin, disability or age, pregnancy, trade union membership, or part-time or fixed-term status.

 

This policy applies to the advertising of jobs and recruitment and selection, to training and development, opportunities for promotion, to conditions of service, benefits and facilities and pay; to health and safety and to conduct at work, to grievance and disciplinary procedures and to termination of employment, including redundancy.

The company will take appropriate steps to accommodate the requirements of workers’ religions, cultures, and domestic responsibilities. Our various family friendly policies in the Employee Handbook should be consulted for specific guidance on our approach to these issues and your entitlements.

 

Forms of Discrimination

Discrimination may be direct or indirect and it may occur intentionally or unintentionally. Direct discrimination occurs where someone is put at a disadvantage for a reason related to one or more of the grounds set out above, for example, rejecting an applicant of one race because it is considered they would not “fit in” on the grounds of their race could be direct discrimination. Indirect discrimination occurs where an individual is subject to an unjustified provision, criterion or practice which puts them at a particular disadvantage because of, for example, their sex or race. For example, a height requirement would be likely to eliminate proportionately more women than men. If the requirement cannot be objectively justified for a reason unconnected with sex, it would be indirectly discriminatory on the grounds of sex. Discrimination also includes victimisation (less favourable treatment because of action taken to assert legal rights against discrimination or to assist a colleague in that regard) and harassment (see the company’s anti-harassment policy in the Employee Handbook).

 

Recruitment and Selection

The company aims to ensure that no job applicant receives less favourable treatment on any of the unlawful grounds listed above. Recruitment procedures will be reviewed regularly to ensure that applicants are treated on the basis of their relevant merits and abilities.  Job selection criteria are regularly reviewed to ensure that they are justifiable on non-discriminatory grounds as being essential for the effective performance of the job.

 

The company may monitor applicants’ racial origins, gender, disability, sexual orientation and religion and age as part of the recruitment procedure.

 

Staff Training and Promotion and Conditions of Service

Staff training needs will be identified through regular staff reviews. All workers will be given appropriate access to training to enable them to progress within the organisation. All promotion decisions will be made on the basis of merit.

Data Protection Policy

 

Introduction

 

We aim to comply with the conditions introduced in May 2018.

 

We have published a Privacy Policy available through the Office and shortly via our website.  This details what personal data we hold, how it is stored, how long we store it for and how we destroy it.

 

We will carry out audits of employee and personal data, collect and process personal data in compliance with the General Data Protection Regulations 2016.

 

Subject Access requests (SAR)

Where employee request their personal data through a subject access request this may carry an admin fee at the time of the SAR request.

 

As individuals, we want to know that personal information about ourselves is handled properly, and we and others have specific rights in this regard. In the course of its activities the company will collect, store and process personal data, and it recognises that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.

 

The types of personal data that the company may be required to handle include information about current, past and prospective employees, suppliers, customers, and others with whom it communicates. The personal data, which may be held on paper or on a computer or other media, is subject to certain legal safeguards specified in the Data Protection Act 1998 (the Act) and other regulations. The Act imposes restrictions on how the company may process personal data, and a breach of the Act could give rise to criminal sanctions as well as bad publicity.

 

If your personal or bank details change please inform the company straight away so that accurate records may be maintained.

 

Status of this Policy

This policy sets out the company’s rules on data protection and the eight data protection principles contained in it. These principles specify the legal conditions that must be satisfied in relation to the obtaining, handling, processing, transportation and storage of personal data.

 

The company’s Data Protection Compliance Manager is responsible for ensuring compliance with the Act and with this policy. The Data Protection Compliance Manager is the MD. Any questions or concerns about the interpretation or operation of this policy should be taken up in the first instance with the Data Protection Compliance Manager.

 

This policy is not part of the contract of employment and the company may amend it at any time. However, it is a condition of employment that employees and others who obtain, handle, process, transport and store personal data will adhere to the rules of the policy. Any breach of the policy will be taken seriously and may result in disciplinary action.

 

Any employee who considers that the policy has not been followed in respect of personal data about themselves or others should raise the matter with their Line Manager and/or the company’s Data Protection Compliance Manager in the first instance.

 

Definition of Data Protection Terms

Data is recorded information whether stored electronically, on a computer, or in certain paper-based filing systems.

 

Data subjects for the purpose of this policy include all living individuals about whom [Company Name] holds personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information.

 

Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in possession of the company).Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal). It can even include a simple e-mail address. It is important that the information has the data subject as its focus and affects the individual’s privacy in some way. Mere mention of someone’s name in a document does not constitute personal data, but personal details such as someone’s contact details or salary would still fall within the scope of the Data Protection Act 1998.

 

Data controllers are the people or organisations who determine the purposes for which, and the manner in which, any personal data is processed. They have a responsibility to establish practices and policies in line with the Act. This company is the data controller of all personal data used in its business.

 

Data Users include employees whose work involves using personal data. Data users have a duty to protect the information they handle by following the company’s data protection and security policies at all times.

 

Data Processors include any person who processes personal data on behalf of a data controller. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on the company’s behalf.

 

Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.

 

Sensitive Personal data includes information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions, including a condition requiring the express permission of the person concerned.

 

Data Protection Principles

Anyone processing personal data must comply with the eight enforceable principles of good practice. These provide that personal data must be: –

 

• Processed fairly and lawfully
• Processed for limited purposes and in an appropriate way
• Adequate, relevant and not excessive for the purpose
• Accurate
• Not kept longer than necessary for the purpose
• Processed in line with data subjects’ rights
• Secure
• Not transferred to people or organisations situated in countries without adequate protection

 

Fair and Lawful Processing

The Act is intended not to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject. The data subject must be told who the data controller is (in this case this company), the purpose for which the data is to be processed by this company, and the identities of anyone to whom the data may be disclosed or transferred.

 

For personal data to be processed lawfully, certain specific conditions have to be met. These include, among other things, requirements that the data subject has consented to the processing, or that the processing is necessary for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive personal data is being processed, additional conditions must be met. In most cases the data subject’s explicit consent to the processing of such data will be required.

 

Processing for Limited Purposes

Personal data may only be processed for the specific purposes notified to the data subject when the data was first collected or for any other purposes specifically permitted by the Act. This means that personal data must not be collected for one purpose and then used for another. If it becomes necessary to change the purpose for which the data is processed, the data subject must be informed of the new purpose before any processing occurs.

 

Adequate Relevant and Non-Excessive Processing

Personal data should only be collected to the extent that it is required for the specific purpose notified to the data subject. Any data which is not necessary for that purpose should not be collected in the first place.

 

Accurate Data

Personal data must be accurate and kept up to date. Information which is incorrect or misleading is not accurate and steps should therefore be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out-of-date data should be destroyed.

 

Timely Processing

Personal data should not be kept longer than is necessary for the purpose. This means that data should be destroyed or erased from the company’s systems when it is no longer required.

Processing In Line With Data Subject’s Rights

Data must be processed in line with data subjects’ rights. Data subjects have a right to: –

• Request access to any data held about them by a data controller
• Prevent the processing of their data for direct-marketing purposes
• Ask to have inaccurate data amended
• Prevent processing that is likely to cause damage or distress to themselves or anyone else

 

Data Security

The company will ensure that appropriate security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. Data subjects may apply to the courts for compensation if they have suffered damage from such a loss.

 

The Act requires the company to put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data may only be transferred to a third-party data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.

 

Maintaining data security means guaranteeing the confidentiality, integrity and availability of the personal data, defined as follows: –

 

• Confidentiality means that only people who are authorised to use the data can access it
• Integrity means that personal data should be accurate and suitable for the purpose for which it is processed
• Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on the company’s central computer system instead of individual PCs

 

Security procedures include: –

• Entry controls. Any stranger seen in entry-controlled areas should be reported
• Secure lockable desks and cupboards. Desks and cupboards should be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential)
• Methods of disposal. Paper documents should be shredded. Floppy disks and CD-ROMs should be physically destroyed when they are no longer required
• Data users should ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended

 

Dealing With Subject Access Requests

A formal request from a data subject for information the company holds about them must be made in writing. Employees who receive a written request should forward it to the Data Protection Compliance Manager immediately.

 

When receiving telephone enquiries, employees should be careful about disclosing any personal information held on the company’s systems. In particular they should: –

 

• Check the caller’s identity to make sure that information is only given to a person who is entitled to it
• Suggest that the caller put their request in writing where the employee is not sure about the caller’s identity and where their identity cannot be checked.
• Refer to the Data Protection Compliance Manager for assistance in difficult situations. Employees should not be bullied into disclosing personal information

 

Our conditions of service, benefits and facilities will be reviewed regularly to ensure that they are available to all workers who should have access to them and that there are no unlawful obstacles to accessing them. This includes pay, bonus criteria, policies and all benefits offered.

 

Termination of Employment

We will monitor redundancy criteria and procedures to ensure that they are fair and objective and do not directly or indirectly discriminate against employees.

 

We will also ensure that disciplinary procedures are carried out fairly and uniformly for all workers, whether they result in the giving of disciplinary warnings, dismissal or other disciplinary action.

 

Disability Discrimination

If you are disabled, or become disabled in the course of your employment with us, you are encouraged to tell us about your condition. This is to enable us to support you as much as possible. You may also wish to advise your Line Manager of any reasonable adjustments to your working conditions or the duties of your job which you consider to be necessary, or which would assist you in the performance of your duties.

 

Your Line Manager may wish to consult with you and with your medical adviser(s) about possible reasonable adjustments. Careful consideration will be given to any such proposals and they will be accommodated where possible and proportionate to the needs of your job. Nevertheless, there may be circumstances where it will not be reasonable for us to accommodate the suggested adjustments and we will ensure that we provide you with information as to the basis of our decision not to make any adjustments.

 

Fixed-Term Employees and Agency and Temporary Workers

We will monitor our use of fixed-term employees and agency workers, and their conditions of service, to ensure that they are being offered appropriate access to benefits, training, promotion and permanent employment opportunities.

 

Part-Time Workers

We may monitor the conditions of service of part-time employees and their progression within the company to ensure that they are being offered appropriate access to benefits and training and promotion opportunities. We will also ensure requests to alter working hours are dealt with appropriately.

 

Breaches of the Policy

If you believe that you may have been disadvantaged on any of the unlawful grounds listed above, you may raise the matter through the company’s grievance procedure. If you believe that you may have been harassed on any of the unlawful grounds you are encouraged to raise the matter through our anti-harassment policy. Allegations regarding potential breaches of this policy will be treated in confidence and investigated in accordance with the relevant procedure. Workers who make such allegations in good faith will not be victimised or treated less favourably as a result. False allegations of a breach in this policy which are found to have been made in bad faith will, however, be dealt with under our disciplinary procedure.

 

If, after investigation, you are proven to have harassed any other worker on the grounds of sex, marital status, sexual orientation, religion or belief, race, disability or age or otherwise act in breach of this policy, you will be subject to disciplinary action. In serious cases, such behaviour may constitute gross misconduct and, as such, may result in summary dismissal. The company will take a strict approach to serious breaches of this policy.

 

As this policy applies equally to the company workers’ relations with visitors, clients, customers and suppliers, if, after investigation, you are proven to have discriminated against or harassed a client or supplier you will also be subject to disciplinary action.

 

Monitoring and Revision of Policy

This policy is reviewed regularly by the company.

 

The company will regularly monitor the effectiveness of this policy to ensure it is achieving the objectives stated in the EOP statement by monitoring the composition of job applicants and the benefits and career progression of its workers.

 

Environmental Policy

 

Why have a Policy?

There is a growing awareness of the need to protect the environment, a view supported by the company. Employees should make every effort within their sphere of control to minimise any adverse effect of the company on the environment. Some examples of how this can be done are listed below: –

• Trying to minimise the levels of waste paper
• Re-cycling toner cartridges as suggested on the toner cartridge packaging

 

The company is always willing to hear if systems can be improved.