Equality, diversity, inclusion
Equality, diversity, inclusion
Safeguarding means protecting people's health, well-being, and human rights, and enabling them to live free from harm, abuse and neglect. Equally Simple. acknowledges the duty of care to safeguard and promote the welfare of children, young people and ‘adults at risk’. We are committed to ensuring our safeguarding practice reflects statutory responsibilities, government guidance and complies with best practice and local safeguarding arrangements.
Equally Simple. will therefore;
§ Ensure everyone who undertakes work on behalf of the company understands their roles and responsibilities in respect of safeguarding and is provided with appropriate learning opportunities to recognise, identify, and respond to signs of abuse, neglect and other safeguarding concerns relating to children, young people and ‘adults at risk’.
§ Ensure appropriate action is taken in the event of incidents/concerns of abuse in line with legislative requirements and the procedures set out in local policies and guidance.
§ Ensure decisions about actions taken are reached in line with the Mental Capacity Act 2005 and the associated Code of Practice, where applicable.
§ Ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored.
§ Ensure, where appropriate, that those working on behalf of Equally Simple. have satisfactorily completed a DBS Check and other vetting procedures relevant to the nature of their role..
§ Ensure robust safeguarding arrangements and procedures are in operation.
All individuals representing or working on behalf of the company have a responsibility to follow the guidance laid out in this and related policies. In particular, they should familiarise themselves with, and work within, Cornwall and the Isles of Scilly multi-agency arrangements for safeguarding children, young people and adults at risk, which are available from the Cornwall Council www.cornwall.gov.uk
Concerns about a child or young person under the age of 18 years.
In the event that an individual working for, or representing, Equally Simple. has concerns about the welfare of a childor young person, they should, without delay, contactand seek advice from:
§ Multi-agency Referral Unit: 0300 123 1116 § Out of Hours Service: 01208 251300
If the concern is about a professional working with a child or young person, the Local Authority Designated Officer (LADO) should be contacted on:
Cornwall - 01872 326536
Any information concerning actual or potential abuse or neglect relating to a child or young person should also be discussed with one of the Directors of Equally Simple. as soon as possible and a record kept of the concern and any actions taken.
Concerns about an ‘adult at risk’
In deciding whether to raise a safeguarding concern, the following questions should be considered:
§ Is the person an ‘adult at risk’ as defined within the Care Act 2014?
§ Is the person experiencing, or at risk of, abuse and neglect? § What is the nature and seriousness of the risk?
§ What does the adult at risk want to happen now?
In all instances where there are concerns about an ‘adult at risk’, as defined above, the following principles will apply.
The adult at risk should experience the safeguarding process as empowering and supportive. Therefore, any individual working for, or representing, Equally Simple will seek to agree actions with the adult at risk, taking into consideration their desired outcomes of any support provided.
Consent should be sought where possible. However, there are occasions when a concern may need to be raised without without the person’s consent, for example:
· § It is in the public interest, for example,
· § There is a risk to other ‘adults at risk’, or
· § The concern is about organisational abuse, or
· § The concern or allegation of abuse relates to the conduct of an
employee or volunteer within an organisation providing
services to adults at risk, or
§ The abuse or neglect has occurred on property owned or
managed by an organisation with a responsibility to provide
care
§ A person is subject to coercion or undue influence, to the extent
that they are unable to give consent
§ A it is in the adult’s vital interests (to prevent serious harm or
distress or life- threatening situations)
§ The person lacks capacity to make specific decisions to consent
and a decision is made to raise a safeguarding concern in the person’s ‘best interests’ (Mental Capacity Act 2005)
However, notwithstanding the above, it is acknowledged that those working for, or on behalf of, Equally Simple. are most likely to hear about potential or actual abuse during a training session and will not have access to the individual to whom the concerns relate. This must not delay any appropriate action being taken and advice should be sought as soon as possible from the Adult Safeguarding Triage team on01872 326433.
Any information concerning actual or potential abuse or neglect relating to an adult at risk should also be discussed with Equally Simple, as soon as possible, and a record kept of the concern and any actions taken.
March 2022
Privacy Policy
Equally Simple is committed to safeguarding your privacy. Contact us at info@equallysimple.co.uk if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
By using this site or/and our services, you consent to the Processing of your Personal Data as described in this Privacy Policy.
This Privacy Policy is a part of our Terms and Conditions; by agreeing to Terms and Conditions you also agree to this Policy. In the event of collision of terms used in Terms and Conditions and Privacy Policy, the latter shall prevail.
Definitions
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed. Often this means delegates booking onto courses s and other contacts of the organisation.
We/us (either capitalized or not) – Equally Simple
Data Protection Principles
We promise to follow the following data protection principles:
Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
Processing is limited with a time period. We will not store your personal data for longer than needed.
We will do our best to ensure the accuracy of data.
We will do our best to ensure the integrity and confidentiality of data. Data Subject’s rights
The Data Subject has the following rights:
1. Right to information – meaning you have the right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
2. Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
3. Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
4. Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
5. Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
6. Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
7. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
8. Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
9. Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
10. Right for the help – meaning you have the right for the help and the right for other legal remedies such as claiming damages.
11. Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
Data we gather
Information you have provided us with
When you supply your personal details to Equally Simple they are stored and processed:
1. To provide you with the service you have purchased from us, sending you confirmation and reminders of your bookings.
2. On receiving a request from yourselves, and therefore we have your consent, share with regulatory / commissioning bodies what training you or your organisation have received from us.
3. Again, provided we have your consent, we may occasionally send you general in the form of what updates we have and any new courses we are providing.
4. Publicly available information. We might gather information about you that is publicly available. Such as Organisation purpose.
How we use your Personal Data
We use your Personal Data in order to:
Provide our service to you. This includes for example providing and monitoring training places and notifying you of changes to any courses.
Enhance your customer experience;
Fulfil our obligation under law as outlined above;
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of fulfilling our obligations, we Process your Personal Data for the following purposes:
To identify you.
To provide you with our service.
To communicate either for bookings, invoicing or other matters.
We will hold your information for a maximum of 3 years and you can ask us to delete your records if you wish prior to this date
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
To administer and analyse our customer base (behaviour and history) in order to improve the quality, variety, and availability of services offered/provided.
To conduct questionnaires concerning customer satisfaction;
As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
· to send you newsletters and articles regarding updates to law, policy.
· for other purposes we have asked your consent for;
We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law.
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
· the link between purposes, context and nature of Personal Data is suitable for further Processing;
We do not share your Personal Data with strangers. We share your data with:
Connected third parties:
We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data
to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented
to it or if there are other legal grounds for it.
How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.
Your records are stored:
On paper, in locked filing cabinets and the offices are always locked and alarmed out of working hours.
On our office computers. These are password protected, backed up regularly, and the offices are locked and alarmed out of working hours.
Even though we try our best we cannot guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
Children
We do not intend to collect or knowingly collect information from children, as we provide learning opportunities for Adults.
Cookies and other technologies we use
We use cookies and/or similar technologies to analyse customer behaviour, administer the website, track users’ movements, and to collect information about users, this also includes Eventbrite. This is done in order to personalise and enhance your experience with us.
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
We use cookies for the following purposes:
·Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e- mail in booking forms so you don’t have to re-enter this information next time when booking.
Analytics cookies – these cookies are used to track the use and performance of our website and services
Advertising cookies – if used (we currently do not do so), these cookies deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such
as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
Contact Information
Data Protection Officer (not required)
If you have any questions regarding Processing your Personal Data, your rights regarding your Personal Data or this Privacy Policy,
contact info@equallysimple.co.uk
Supervisory Authority
Email: international.team@ico.org.uk Phone: +44 1625 545 745
Changes to this Privacy Policy
We reserve the right to make change to this Privacy Policy. Last modification was made March 2022.
Equally Simple Fraud statement
Introduction
The purpose of this statement is to give the Equally Simple’s policy on fraud and set out our responsibilities for its prevention.
Equally Simple will act honestly and with integrity and to safeguard the resources for which they are responsible. Fraud is an ever-present threat to these resources and hence must be a concern of all.
What is Fraud?
The term fraud is used to describe a whole range of activities such as deception, bribery, forgery, extortion, corruption, theft, conspiracy, embezzlement, misappropriation, false representation, concealment of material facts and collusion. Generally, however, fraud involves the intention to deceive a person or organisation in order to obtain an advantage, avoid an obligation or cause loss.
The term also includes the use of information technology equipment to manipulate programs or data dishonestly, the theft of IT equipment and software, and the intentional misuse of computer time and resources.
Equally Simple’s Attitude to Fraud
Equally Simple takes the most serious view of any attempt to commit fraud by members of staff, contractors, their employees, and agents acting on behalf of the Equally Simple, and others. Equally Simple treats attempted fraud as seriously as accomplished fraud
As a result Equally Simple will strive to:
Identify and assess the risks involved in the operations for which they are responsible; develop and maintain effective controls to prevent and detect fraud; Ensure compliance with controls and ensure that agreed procedures are followed.
Equally Simple acknowledges it has a duty to ensure that public funds, and its own reputation are safeguarded.
Equally Simple will create an alert where they believe the opportunity for fraud exists. Equally Simple will report details of any suspected or actual fraud, or suspicious acts or events to the relevant party.
Fraud Policy March 2022
Equality, Diversity and Inclusion policy
Equally Simple is committed to encouraging equality, diversity and inclusion among our workforce, and eliminating unlawful discrimination.
The aim is for our workforce to be truly representative of all sections of society and our customers, and for employees to feel respected and able to give their best.
The organisation - in providing goods and/or services and/or facilities - is also committed against unlawful discrimination of customers or the public.
The policy’s purpose is to:
· provide equality, fairness and respect for all in our employment, whether temporary, part-time or full-time
· not unlawfully discriminate because of the Equality Act 2010 protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex and sexual orientation)
· oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for parents, requests for flexible working, and selection for employment, promotion, training or other developmental opportunities
The organisation commits to:
· Encourage equality, diversity and inclusion in the workplace as they are good practice and make business sense
· Create a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued.
This commitment includes training managers and all other employees about their rights and responsibilities under the equality, diversity and inclusion policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination.
All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public
· Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities.
Such acts will be dealt with as misconduct under the organisation’s grievance and/or disciplinary procedures, and appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice.
Further, sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence.
· Make opportunities for training, development and progress available to all staff, who will be helped and encouraged to develop their full potential, so their talents and resources can be fully utilised to maximise the efficiency of the organisation.
· Decisions concerning staff being based on merit (apart from in any necessary and limited exemptions and exceptions allowed under the Equality Act).
· Review employment practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law.
· Monitor the make-up of the workforce regarding information such as age, sex, ethnic background, sexual orientation, religion or belief, and disability in encouraging equality, diversity and inclusion, and in meeting the aims and commitments set out in the equality, diversity and inclusion policy.
· Monitoring will also include assessing how the equality, diversity and inclusion policy, and any supporting action plan, are working in practice, reviewing them annually, and considering and taking action to address any issues.
Judith Cook April 2021
Environmental Policy
Equally Simple are committed to providing a quality service in a manner that ensures a safe and healthy workplace for our employees and minimises our potential impact on the environment. We will operate in compliance with all relevant environmental legislation and we will strive to use pollution prevention and environmental best practices in all we do.
Our Policy therefore, is to :
· integrate the consideration of environmental concerns and impacts into our decision making and activities,
· minimise our waste and then reuse or recycle as much of it as is possible.
· minimise energy and water use within our buildings and processes in order to
conserve supplies and minimise the consumption of natural resources.
· As far as is possible, purchase products and services that do the least damage
to the environment.
· train, educate and inform our employees about environmental issues that may
affect their work,
· promote environmental awareness among our employees and encourage them
to work in an environmentally responsible manner,
· communicate our environmental commitment to clients, customers and the
public and encourage them to support it
Judith Cook April 2021.