Modern Day Slavery Policy

Introduction

Modern Day Slavery Statement

This statement is made pursuant to s54 of the Modern Slavery Act 2015 and sets out the steps that Global Training Centre Ltd has taken, and is continuing to take, to make sure that modern slavery or human trafficking is not taking place within our business or supply chain during the year ending 2019.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Global Training Centre Ltd has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

About the organisation

Global Training Centre Ltd provides trainings for all staff in the health and social care sector.
Our policies on slavery and human trafficking
Global Training Centre Ltd is aware of our responsibilities towards our learners, employees and the local community and expect all suppliers to the company to adhere to the same ethical principles. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our internal policies replicate our commitment to acting ethically and with integrity in all our business relationships.

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all directly employed staff, and agencies on approved frameworks are audited to provide assurance that pre-employment clearance has been obtained for agency staff, to safeguard against human trafficking or individuals being forced to work against their will

2. Equal Opportunities. We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities

3. Safeguarding policies. We adhere to the principles inherent within both our safeguarding children and adults policies. These are compliant with the Global multiagency agreements and provide clear guidance so that our employees are clear on how to raise safeguarding concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain.

4. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals

5. Standards of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.

We are zero tolerant to slavery and human trafficking and thereby expect all our direct and indirect suppliers/contractors to follow suit.

Where it is verified that a subcontractor has breached the child labour laws or human trafficking, then this subcontractor will be excluded in accordance with Regulation 57 of the Public Contracts Regulations 2015. The Trust will require that the main contractor substitute a new subcontractor.

Advice and training about modern slavery and human trafficking is available to staff through our mandatory safeguarding children and adults training programmes, our safeguarding policies and procedures, and our safeguarding leads. It is also discussed at our compulsory staff induction training.

We are looking at ways to continuously increase awareness within our organisation, and to ensure a high level of understanding of the risks involved with modern slavery and human trafficking in our supply chains and in our business.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

No reports are received from our staff, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

APPROVAL FOR THIS STATEMENT

This statement will be presented for approval at the Business and Strategy Executive on 01 May 2018

Name (Director) Adila Bashrit

Signature: a bashrit

Date 01/05/2018

Privacy/confidentiality policy

Confidentiality Policy

1. Confidentiality Policy Statement

The company’s business is to deliver training. Confidentiality is central and integral to protecting learners and offering safety and privacy. Information given is being held in strict confidence and in line with Data Protection Act(s). Global Training Centre Ltd will safeguard the Learner’s rights to confidentiality. Our employees will not disclose any personal information about Learners to a third party unless:

This has been agreed with the Learner concerned. The information required is subject to a court order
The information is required by the police as part of an investigation
The information will safeguard the learner from harm either from themselves or others This policy will be used in conjunction with the Data Protection Policy.

To support the human rights of the Learner.

To provide employees, and learners with clear guidelines regarding handling of confidential information, to prescribe limits of behaviour assign responsibilities.

All employees

Global Training Centre Ltd is responsible for ensuring that all employees involved in dealing with confidential information and data receive appropriate training, supervision and support regarding the policy and their legal responsibilities. All employees must sign a Confidentiality Agreement.

Manager’s Responsibility The operations manager is responsible for ensuring that a copy of this document is available to all employees and is available to learners. It is the responsibility of the administration supervisor to ensure all employees sign the Agreement and receive training as necessary.

It is the responsibility of managers to ensure that information is stored and handled in ways that limits access to those who have a need to know Managers should:

Provide lockable filing cabinets to hold Learners’ records and ensure those records are kept secure at all times.

Arrange for information held on computers to be accessed only by appropriate personnel.

Ensure that documents are not open to public view when sharing an office space

Ensure that telephone conversations that could breach confidentiality are not held in the hearing of others when sharing an office space.

Ensure that when the Learner’s personal information needs to be disposed of it is shredded or disposed of appropriately.

Individual’s Responsibility Individual employees are required to act in accordance with the policy, failure to do so will be considered as an act of gross misconduct and will result in disciplinary action.

5. Policy Implementation – Procedures

5.1 All Employees should:

Ask for identification in person. If being asked for information over the telephone, get the caller’s details and ring them back before handing over Learner information.

Only disclose information:

With the permission of the individual

In compliance with any statutory or legal obligations

For the legitimate interests of learners or a third party who has a legal right to such information

Where the courts have ordered such a disclosure

Be aware of risks to confidentiality

Can telephone conversations be overheard by others?

When discussing issues with Learners do you have privacy?

Do you mark “confidential” on anything, including outgoing mail and emails, which contain personal information?

Are filing cabinets that store confidential information kept locked? This includes learner, employee records and personnel files.

Are employee laptops securely locked away when in an employee home or car? Are they too easy to gain access to?

Are documents being taken home to work on being kept in a safe place? Employees should not leave confidential or sensitive documents in their cars where they can be easily read or stolen.

Are office computer / laptops logged in all of the time so that anyone could gain personal employee or Learner information?

5.2 Employees should not:

Discuss Learners with persons not employed by Global Training Centre Ltd including (list not exhaustive)

Friends or family of the learner, unless permission has been given by the learner

Your own family and friends

Other professionals that do not need that information to provide their role or to safeguard the learner.

Send emails or documents with information pertaining to Learners to anyone not directly involved in their support or employed by Global Training Centre Ltd.

Ask administration for, nor share colleague’s personal information including telephone numbers and addresses.

Share any computer passwords or phone lock passwords

5.3 Recording Information: Each learner with whom we work is issued with an Individual Learning Plan, this is stored in a file together with activity registers and all other relevant paperwork. These records hold confidential information and employees are required to store them appropriately. On each visit with the learner Assessors must record details of the work undertaken and any other relevant information. Any entries made can be commented on by the learner.

5.4 Gaining consent

If you feel that the information should be shared ask the Learner’s permission to do so.

When gaining consent be specific regarding the information/action to be shared and to whom.

Explain clearly why and accurately record.

If there are any concerns in these areas employees should seek advice from their supervisor.

5.5 Confidential Reporting: All employees are expected to report malpractice and wrong doing and may be liable to disciplinary action if they knowingly and deliberately withhold information relating to malpractice or wrong doing in any respect of the service provision. Malpractice or wrongdoing (for example plagiarism) may be about something which:

Is unlawful, or

Is not in accordance with established standards of practice,

Amounts to improper conduct by an employee or learner.

As a first step employees should normally raise concerns with their Supervisor/Line Manager. Concerns may be raised verbally but are better raised in writing. Employees should set out the background and history of the concern giving relevant names, dates and places where possible and the reason why you are particularly concerned about the situation and will be required to demonstrate to the supervisor/line manager that there are sufficient grounds for concern. Some concerns may be resolved by agreed action without the need for investigation. Within 14 calendar days of an issue being raised under this procedure a nominated officer of the company will write to the employee who raised the concern:

Acknowledging the concern

Indicating how it is being proposed to deal with the matter (please note if the concern results in disciplinary action of an employee this is confidential and details of the disciplinary action will not be given to you) and

Giving an estimate as to how long it will take to provide a final response

The amount of contact between management and the employee who raised the concern will depend on the nature of the matters raised, the potential difficulties involved and the clarity of the information provided, if necessary further information may be sought.

5.6 Working from home

It is each individual employee’s responsibility to follow this policy when working from home and ensure that information is not easily accessible to others that are not employed by Global Training Centre Ltd, this is true of both laptops, mobile phones (containing colleague/client information) and documents that are in an employee’s home.

GDPR statement

The General Data Protection Regulation (GDPR) has been described as a “game changer for everyone” by the Information Commissioner’s Office. This new piece of EU data protection law represented a major shake up in the way we collect, process and store personal data. It aims to standardise data protection law across the EU, giving individuals more control over how, when and by whom their data is processed.

Global Training Centre is committed to partnering with our customers on GDPR. Here we explain what we have done and what we will continue to do to achieve GDPR compliance both internally and for our customers.

How we prepared for GDPR: We adopted a company wide approach to become GDPR ready and our working group prepared the business for the significant changes involved. These include:

Updating and amending our terms and conditions, customer agreements and privacy policies and statements to bring them in line with the GDPR.

Ensuring that correct and appropriate contractual terms are in place with data processors including data security and international data transfers.
Updating our internal policies and practices to reflect GDPR requirements.
Continuing to invest in our products, services and staff training.
We continue to work closely with our legal team and Data Protection Officer so we can monitor GDPR compliance across the organisation.
Security Standards and Certifications: Protecting our customers privacy and securely managing your data is a high priority for us. All our web properties use SSL (secure sockets layer) to encrypt data you transmit to us across the Internet. Our Development Team manages our servers and data transfer processes for the purposes of maintenance, support and development. Access to our servers is tightly controlled; only authorised company administrators employed directly by Global Training Centre are granted access. Staff training is an important ethos that we hold as a company. As such, we ensure all our staff have an up-to-date working knowledge of data protection law inclusive of GDPR.

International Data Transfers: Data is stored with ICanQualify.Net This service meets the EU-US Privacy Shield framework adopted by the European Commission. This complies with data protection requirements when transferring data outside of the EU. We keep this under review to ensure that data is stored, at all times, with appropriate safeguards.

Data Processors: To help us deliver the best possible service, we use a number of tools to process data. A data processor can be an organisation or third party provider who manages and processes personal data on behalf of a business. We are working with our providers to ensure compliance with the new regulations, including introducing data processing contracts where appropriate.

Upholding our customers rights: We have embedded, across the organisation, policies and procedures which for example allow customers to access their data in ways that are accessible to them and we have introduced an updated Data Privacy Notice which is regularly updated so that our customers are always aware of all of our data privacy arrangements.

Stay Updated: If you have any specific questions about our GDPR and data privacy arrangements, we hope that you contact us directly.

Equality, diversity and inclusion statement.

Equality, Diversity and Inclusion Policy

Policy Statement

Global Training Centre Ltd recognises that providing equality of opportunity, valuing diversity and promoting a culture of inclusion are vital to our success.

We want our staff and learners to reflect the diversity of the regional, national, and international communities that we serve and influence. We aim to be a place where people can be free to be themselves no matter what their identity or background.

By creating a working, learning and social environment in which individuals can utilise their skills and talents to the full without fear of prejudice or harassment, we aim to create a culture where everyone can reach their fullest potential.

We will ensure that equality is embedded in all of our activities, policies and decisions and will work with our partners to share good practice. Key to this is our commitment to implementing a programme of activity to progress our equality aims and objectives.

Scope

This policy applies to all current and potential learners and staff working at Global Training Centre on a paid or voluntary basis, external examiners, consultants, and visitors or contractors who visit our premises. It covers discrimination on the basis of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and/or belief, sex or sexual orientation as set out in the Equality Act (2010).

Commitment

Equality is at the heart of our Company Strategy which sets out our values and goals. Our aim is to make full use of people’s talents and skills by creating an open and inclusive workplace culture where people from all backgrounds can work together with dignity and respect.

We will take active steps to fulfill our responsibilities and promote good practice by:

• Complying with legal obligations in a transparent manner

• Developing and publishing Company Wide diversity objectives as well as mainstreaming equality, diversity and inclusion (EDI) in to the Companies planning process for all departments and colleges

• Publishing this policy widely amongst staff and leaners, together with policy assessments, equality analysis and results of monitoring

• Assessing the impact of policies and practices to identify, remove or mitigate any disadvantage to underrepresented groups

• Taking measures to eliminate discrimination

• Taking action to redress any gender, racial or other imbalance including monitoring the recruitment and progress of all students and staff, collecting and collating equalities information and data and publishing this as required, and acting on any inequality revealed by the data.

• Fostering good relations between persons who share a protected characteristic and persons who do not

• Promoting awareness and understanding of EDI matters among staff and learners through policies, training, guidance and campaigns

• Engaging with staff and students in respect of changes which may affect their employment or study

• Ensuring that existing staff and students, as well as applicants to work or study, are treated fairly and judged solely on merit and by reference to their skills and abilities

• Raising awareness of our policies and commitment to EDI with external suppliers, contractors and partners and encouraging them to follow similar good practice

• Making sure reasonable adjustments are made, as appropriate, to enable disabled staff and students to overcome barriers in the working, learning and social environment

• Requiring that learning and teaching material, where practical, includes positive, diverse, non-stereotypical content

• Ensuring staff and students are provided with appropriate tools so that they feel confident to discuss EDI issues and raise any concerns

• Dealing with potential and actual acts of discrimination, harassment and bullying appropriately under relevant company policy and taking appropriate action where necessary

• Consulting with staff, leaners, on EDI issues through existing mechanisms

Responsibilities

• All members of the Company community have a responsibility to promote EDI.

• The Equality, Diversity and Inclusion Team has responsibility for the co-ordination, support and delivery of this work.

Implementation, Monitoring and Review

This Policy will be reviewed on annual basis to ensure that it reflects best practice and current legislation. We will consult widely with the Companies Diversity and Equality Advisory Group, diversity networks.

Training

All staff are required to take part in EDI training appropriate to their role with new staff required to take EDI training as part of their induction. Information on all related training will be available our website.

Complaints Procedures related to Equality, Diversity and Inclusion
The company expects all members of its community to treat others equitably, with dignity and respect. Any members of our compnay community who believe they have been discriminated against, harassed or bullied have the right to make a complaint free from victimisation or fear of retaliation.
When making a complaint, normally the matter should be raised informally in the first instance with the immediate supervisor, of the person being complained of using the following procedures.
Making a complaint does not prejudice an individual’s right to make use of other procedures, including the Respect at Work or Study policies or Grievance procedures.
We aim to support and protect anyone who makes a complaint, or who acts as a witness, under these procedures from victimisation or retaliation.
Members of the public should address complaints to the Company service in question in the first instance.
Approved: April 2019