A. DEFINITION

Corporate Social Responsibility (CSR) is a concept whereby an organisation recognises that its business operations and processes may have an impact on social, economic and environmental issues outside of the workplace. It also represents a commitment to ensuring and maintaining socially responsible behaviour in an organisation.

B. OBJECTIVE

Corporate Social Responsibility (CSR) is a concept whereby an organisation recognises that its business operations and processes may have an impact on social, economic and environmental issues outside of the workplace. It also represents a commitment to ensuring and maintaining socially responsible behaviour in an organisation.

C. POLICY

We are aware that the running of our business will, in many ways, affect our place of work, the community and the wider environment in which we operate. We believe that the way we run our business can and should make a positive difference in these areas and we aim to ensure that continued efforts are made to achieve that.

Our corporate social responsibilities are identifiable in the following areas:

1. Environment

Corporate Social Responsibility (CSR) is a concept whereby an organisation recognises that its business operations and processes may have an impact on social, economic and environmental issues outside of the workplace. It also represents a commitment to ensuring and maintaining socially responsible behaviour in an organisation.

• Efficient printing, including only printing when absolutely necessary, using recycled materials where possible and turning off printers when not in use;
• Reducing the amount of waste produced by the business;
• Ensuring that water/electricity is used responsibly by our staff;
• Recycling materials as extensively as possible;
• Using technology to lessen the need for travel;
• Using public transport or electric vehicles wherever possible when travelling is unavoidable;
• Appointing an Energy Champion to promote and encourage energy saving measures throughout the business and provide regular updates on pro
• Ensuring that water/electricity is used responsibly by our staff;

2. Charitable/community work

Our organisation is keen to support and become involved in community initiatives and charitable work. We do this in the form of sponsorship, donations to national and local charities which may be suggested by our staff, and the funding of community projects. Every suggestion is given due consideration.

3. Education

We recognise the importance of education in our community, and supporting individuals during this process is key to advancement. We actively encourage our employees to take up training courses, often funded by ourselves, and we offer a number of work experience placements in partnership with local schools.

4. Our employees

Involvement: We keep our staff fully informed of our policies and procedures and we encourage them to share their ideas with us on both internal processes affecting them, and the way our service is provided to customers/clients. We maintain an open and honest approach to all of our communications.

5. Equal Opportunities

We are committed to providing an environment of equal opportunities for all members of our workforce. No account of any of the protected characteristics set out in the Equality Act 2010 shall be taken to a detrimental effect in any decision involving recruitment, promotion, provision of facilities etc. See our Equality, Inclusion and Diversity Policy or Equal Opportunities policy* delete as applicable for more detail in this regard.

6. Business partnerships

We will strive to engage with local suppliers and businesses where possible to meet the business’ operational needs, in order to support businesses within our area and decrease our carbon footprint.
In respect of our entire CSR initiative, we expect no lesser standards from our suppliers and business partners.

D. ONGOING COMMITMENT

We are fully committed to the principle of CSR and aim to ensure that no relevant policy decisions are made within the business, without first evaluating the potential CSR impact.

STRATEGIC CSR FOCUS AREAS

At Best Training London, a strong sense of social responsibility is therefore an integral part of our value system. We embrace our responsibility to create a positive impact in the communities in which we work and live. Our key programs are driven by the valuable CSR (Corporate Social Responsibility) platforms we have built.

• Working with Community groups and Charity organisations.
• Getting into spirit of earth (Green Spaces).
• Health and Hygiene campaign for students.
• Anti-drug Awareness for students.

INTRODUCTION.

The risk of data theft, scams, and security breaches can have a detrimental impact on a company’s systems, technology infrastructure, and reputation. As a result, Best Training London has created this policy to help outline the security measures put in place to ensure information remains secure and protected.

PURPOSE.

The purpose of this policy is to (a) protect Best Training London data and infrastructure, (b) outline the protocols and guidelines that govern cyber security measures, (c) define the rules for company and personal use, and (d) list the company’s disciplinary process for policy violations.

SCOPE

This policy applies to all Best Training London remote workers, permanent, and part-time employees, contractors, volunteers, suppliers, interns, and/or any individuals with access to the company’s electronic systems, information, software, and/or hardware.

1. Environment

Corporate Social Responsibility (CSR) is a concept whereby an organisation recognises that its business operations and processes may have an impact on social, economic and environmental issues outside of the workplace. It also represents a commitment to ensuring and maintaining socially responsible behaviour in an organisation.

Confidential Data.
Best Training London defines “confidential data” as:

• Unreleased and classified financial information.
• Customer, supplier, and shareholder information.
• Customer leads and sales-related data.
• Patents, business processes, and/or new technologies.
• Employees’ passwords, assignments, and personal information.
• Company contracts and legal records.
  Device Security:
  Company Use.
  To ensure the security of all company-issued devices and information, Best Training London employees are required to:
• Keep all company-issued devices password-protected (minimum of 8 characters). This includes tablets, computers, and mobile devices.
• Secure all relevant devices before leaving their desk
• Obtain authorization from the Office Manager and/or Inventory Manager before removing devices from company premises.
• Refrain from sharing private passwords with co-workers, personal acquaintances, senior personnel, and/or shareholders.
• Regularly update devices with the latest security software.

INTRODUCTION.

We aim to be an environmentally friendly Company and it is our intention to promote a policy that is focused on being green aware. A culture will be fostered within the company that ensures all employees understand they can make a significant contribution to the Company being an environmentally friendly and green aware company.
The Company’s policy is to comply or exceed the requirements of environmental legislation and regulation.

POLICY

The specifics of the company environmental policy are as follows

• The Company will review and explore measures for the reduction of volumes of all waste materials generated by the Company;
• The Company will explore opportunities for recycling all possible waste materials. Our ultimate aim will be to recycle any waste material that can be recycled;
• The Company will aim to reduce levels of energy consumption. The Company will introduce working practices that requires computers, lights, photocopiers, printers to be “switched off” when not in use. The Company will also ensure that heating, lighting and ventilation are used efficiently and effectively;
• The Company will aim to purchase energy efficient products where possible and appropriate;
• Additionally, the Company will explore whether environmentally friendly products can be purchased when buying any equipment for use within the company;
• The Company will review opportunities and consider implementing measures for the reduction of the use of water;
• The Company will aim to reduce levels of pollution emissions wherever possible;
• The Company will ensure that all employees are made aware and have access to a copy of this environmental policy. The Company will regularly review the policy to ensure that we are a green aware and environmentally friendly organisation.

FORM EO 

Equal Opportunity Monitoring

INTRODUCTION

• We are an equal opportunities employer. 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 favorable 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 victimized or subjected to any form of bullying or harassment.
• We value people as individuals with diverse opinions, cultures, lifestyles and circumstances. All employees are covered by this policy and it applies to all areas of employment 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 management has particular responsibility for implementing and monitoring the Equality and Diversity 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 utilized to maximize 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.
• The Company will review opportunities and consider implementing measures for the reduction of the use of water;
• The Company will aim to reduce levels of pollution emissions wherever possible;
• The Company will ensure that all employees are made aware and have access to a copy of this environmental policy. The Company will regularly review the policy to ensure that we are a green aware and environmentally friendly organisation.

OUR COMMITMENT AS AN EMPLOYER

• To create an environment in which individual differences and the contributions of our staff are recognized and valued.
• Every employee, worker or self-employed contractor 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 staff.
• 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.

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.

Policy statement

Age

We will :

• ensure that people of all ages are treated with respect and dignity;
• ensure that people 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 gender;
• take positive action to redress the negative effects of discrimination against everyone;
• offer equal access for everyone to representation, services, employment, training and pay and encourage other organisations to do the same; and
• provide support to prevent discrimination against transgender people who have or who are about to undergo gender reassignment.

Sexual Orientation

We will :

• ensure that we take account of the needs of everyone, including the LGBTQ+ communities; and
• promote positive images of the LGBTQ+ communities.

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.
• offer equal access for everyone to representation, services, employment, training and pay and encourage other organisations to do the same; and
• provide support to prevent discrimination against transgender people who have or who are about to undergo gender reassignment.

Pregnancy Or Maternity

We will :

• Ensure that people are treated with respect and dignity during pregnancy and during maternity leave;
• 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 during pregnancy and during maternity leave

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 as a result of their marriage or civil partnership status.

Equal Pay

We will :

• ensure that all employees 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.

INTRODUCTION

In this course, we will cover:

• what equality and diversity mean and how they affect you
• barriers that can prevent equality from being realised
• key legislation and both employers’ and employees’ responsibilities in relation to it.

RIDDLE

The term ‘equality’ means that everyone should be treated equally. It recognises that everyone has individual needs and that they have the right to have their needs respected. Equality also means that everyone’s voice and opinion should carry equal weight, regardless of background, age, sex, and other protected characteristics.

Equality is not quite the same as equity; an equitable solution for fairness goes further than the even distribution of tools and resources. Instead, it allocates the exact resources and support that each individual needs for them to access opportunity. Equity exists to address the imbalances of society to make it more equal.

For example, children from low-income backgrounds may require more support and funding to attend the same university as their friends. To meet the needs of those without sufficient home internet access, a library or community centre in one area may have longer opening hours, more computers and printers, or more frequent support sessions than a community centre in another area.

EQUALITY

The term ‘equality’ means that everyone should be treated equally. It recognises that everyone has individual needs and that they have the right to have their needs respected. Equality also means that everyone’s voice and opinion should carry equal weight, regardless of background, age, sex, and other protected characteristics.

Equality is not quite the same as equity; an equitable solution for fairness goes further than the even distribution of tools and resources. Instead, it allocates the exact resources and support that each individual needs for them to access opportunity. Equity exists to address the imbalances of society to make it more equal.

For example, children from low-income backgrounds may require more support and funding to attend the same university as their friends. To meet the needs of those without sufficient home internet access, a library or community centre in one area may have longer opening hours, more computers and printers, or more frequent support sessions than a community centre in another area.

DIVERSITY

The term ‘diversity’ means that our background, knowledge, skills, aptitudes, and experiences are all different and that our differences should be valued and appreciated through inclusion, discussion, and shared space.

Employers and services have ignored certain differences such as background, personality, and work style. However, individual and group diversity needs to be considered to ensure that everybody’s needs, and requirements are understood and responded to. This is particularly true within employment practice and service design and delivery. These approaches recognise that to provide accessible services, and to ensure we promote inclusive working environments, organisations need to respond differently to both individuals and to groups.

WHY DO EQUALITY AND DIVERSITY MATTER?

According to government figures, the facts are that:

• ethnic minorities made up 13 per cent of the UK population at the last census.
• in 2019/20, around 14.1 million people in the UK reported a disability, which represents approximately 22 per cent of the population.
• in 2019 in the UK, around one in five people were aged 65 and over, but by 2039 this figure is projected to increase to around one in four.
  But inequalities still persist
• The gender pay gap among all employees in the UK in 2019 was 17.3 per cent. This means that on average, women were paid approximately 83p for every £1 that men were paid.
• Children growing up in poorer families emerge from school with substantially lower levels of educational attainment. Disabled people are still more than twice as likely to be out of work than non-disabled people.
• 78% of white people were in employment in 2019, compared with 66% of people from all other ethnic groups combined.

GENDER BIAS

In the 1970s, the top five orchestras in the US employed fewer than five percent women. But over the next few decades this number steadily rose.
How do you think they achieved this?

HOW DID THEY DO IT?

In the 1980s and 90s, many orchestras began to hold blind auditions, in which the musicians would play behind a screen. Those on the jury did not know the sex of whoever was playing and as a result many more women were hired. Those on the jury were not necessarily conscious of any gender bias but they still applied different standards to men and women.

This sort of scenario applies to us in everyday life. Imagine you were hiring; you probably would like to be fair in your selection, but as much research has shown, men still have a better chance of success.

The situation is getting better; in the year 2000 employment rates for women were 65.9% and for men 79.2%. In 2019, there were 72% of women employed compared to 80.3% of men.

By being aware of bias, we can challenge the motivations for the actions and decisions we make.

UNCONSCIOUS BIAS

Unconscious bias describes how we are all shaped by our prior experiences and the social and cultural values that we assimilate throughout our lives. We develop assumptions about people and create our own personal stereotypes. People often feel more comfortable around those that are like them.

For example, we usually prefer to spend time with people of a similar age or familiar background. Unconscious bias is a natural result of this, but it can cause unintentional prejudice. It often contradicts what we believe about ourselves, as most people would not describe themselves as ‘biased’ against certain types of people.

Example

Jack returns to the office car park after work, but his car won’t start. He looks for a male colleague to help him.

In this situation, Jack feels much more comfortable asking a man to help, and his cultural norm backs up this instinct.

Unconscious bias can affect our behaviour in many ways, but if the bias is against a protected characteristic it could lead to illegal discrimination. In the workplace, this can affect recruitment, progression, recognition and much more.

Example

Nadia is recruiting for a vacant position in her team, currently made up of nine women and one man. She invites three candidates for interview, all of them female, despite the applications being from an equal mix of men and women.

Nadia’s unconscious bias leads her to select three women for interview. The team has always been predominantly female, and she instinctively feels that a woman will fit into the team more easily and quickly.
There are many forms of bias. See how these common types affect Nadia’s decision-making:

AFFINITY BIAS

This leads us to prefer people with whom we feel a connection.

Example

Nadia discovers in the interview that she and Candidate A grew up in the same town. They reminisce for a while, and following this pleasant chat Nadia’s unconscious affinity bias leads her to believe that this candidate would be best for the job.

HALO BIAS

A person might have one single characteristic or achievement which makes us rate them more highly overall.

Example

Candidate B has previously held a similar senior post at a highly regarded competitor. Nadia’s unconscious halo bias leads her to believe that this means that the candidate would be best for the job and does not ask many questions about her other previous employment.

HORNS BIAS

The opposite of halo bias, where one quality that we dislike in a person makes us dismiss them more easily overall.

Example

Candidate C arrives late to her interview. Nadia’s unconscious bias means that she finds it hard to overcome her irritation. Her belief that the candidate must be generally disorganised means that she does not make as much effort to get to know her in the interview.

BARRIERS TO EQUALITY

We may feel that we treat everyone fairly and value their differences but ask yourself if you have ever been guilty of any of the following:

Example

Candidate C arrives late to her interview. Nadia’s unconscious bias means that she finds it hard to overcome her irritation. Her belief that the candidate must be generally disorganised means that she does not make as much effort to get to know her in the interview.
Prejudice – where you pre-judge a person or group of people without prior knowledge of them.
Stereotyping – where you assume people have certain behaviours or attitudes that a ‘type’ of person is expected to exhibit.
Unfair discrimination – where a person or a group of people is treated less favourably than another based on their colour, ethnic origin or nationality, gender, age, disability, sexual orientation, religion or belief or marital status.

BUT WHAT ABOUT POSITIVE STEREOTYPES?

Sometimes stereotypes exist that may not be negative, but all stereotypes are damaging. ‘Positive’ stereotypes can put pressure on those who do not possess certain traits but ‘should’ and can sometimes set high expectations for certain people. This can cause feelings of alienation.
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The celebration of difference makes for a strong and well-rounded society, but it is important to remember that people are individuals, not just representatives of an ethnicity, disability, faith, gender, sexuality, or other characteristic.
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The concept of the high achieving ‘model minority’ is sometimes projected onto members of a minority group, most often in relation to their race. This means that certain people are perceived to be more intelligent and productive than those belonging to other racial groups.

You should recognise people’s differences, but you should always remember that single characteristics do not necessarily relate to a person’s interests, abilities, or wider identity.

True inclusivity is about accepting people for who they are, not who you expect them to be.

THE EQUALITY ACT 2010

The Equality Act 2010 came into effect in October 2010 and in doing so consolidated and streamlined a huge amount of existing legislation, much of which had been developed over the last 40 years.

As well as reforming discrimination law into a single Act, it also strengthened the law to support the country’s progress on equality.

The Equality Act 2010 details a list of ‘protected characteristics’; these are the grounds upon which it is unlawful to discriminate against people.

Protected characteristics are:

• Age
• marriage and civil
• partnership
• marriage and civil
• partnership
• disability
• race
• sexual orientation
• gender reassignment
• religion or belief (or lack thereof)
• pregnancy and maternity.
  These protected characteristics are very important when issues of discrimination arise.

THE MAIN TYPES OF DISCRIMINATION

The main types of discrimination are:

• direct discrimination (including perceptive and associative discrimination)
• indirect discrimination
• victimisation
• harassment.

DIRECT DISCRIMINATION

Direct discrimination is where someone is treated less favourably than another person because of a protected characteristic they have or are thought to have (perceptive discrimination), or because they associate with someone who has a protected characteristic (associative discrimination).

Perceptive discrimination is direct discrimination against an individual because others think they possess a particular protected characteristic. It applies even if the person does not actually possess that characteristic.

Associative discrimination is direct discrimination against someone because they associate with another person who possesses any one or more of the protected characteristics.

Indirect discrimination can happen when there’s a condition, rule, policy or even a practice in your organisation that applies to everyone but particularly disadvantages people who share a protected characteristic.

An example of indirect discrimination could be a fitness centre requiring all staff to wear shorts as part of their uniforms. This would discriminate against people whose religion and beliefs state that they should dress modestly.

Another example could be imposing a minimum height restriction on a job. This would indirectly discriminate against people from some ethnic origins as they tend to be smaller in stature.

INDIRECT DISCRIMINATION

Like direct discrimination, indirect discrimination is unlawful whether it is intentional or not, unless it can be fully justified.

Employers can only justify indirect discrimination if they can show that they acted fairly and reasonably in managing their business (eg in order to achieve a legitimate aim) and they would need to show that they had considered other, less discriminatory alternatives.

VICTIMISATION

Most of us will understand the word victimisation to mean singling someone out for exploitation or unfair treatment.
For the purposes of this course, in this context, it is when an employee is treated badly because they have made or supported a complaint or raised a grievance under the Equality Act; or because they are suspected of doing so.

An employee is not protected if they have maliciously made or supported an untrue complaint.

HARASSMENT

The law defines harassment as:

“unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual.”

POSITIVE ACTION

Organisations can take positive action to target their goods, facilities and services to a particular group or groups, where they have the relevant protected characteristics and the organisation believes they are under-represented or disadvantaged amongst their customers.

This would involve doing some research to find out about the needs of their existing or potential customers and then taking steps to promote or design goods or services that cater for this group. However it is the organisation’s own choice about whether they do this.

Example

Having identified that its white male pupils are underperforming at maths, a school could run supplementary maths classes exclusively for them. In relation to a company’s recruitment and employment practice if both a male and female candidate apply for a role within an organisation where women are under-represented, the employer can appoint the female as long as she is more or equally qualified as a male candidate. It would be unlawful to appoint the female if the male was more qualified.

BUT WHAT ABOUT SO-CALLED ‘REVERSE’ DISCRIMINATION?

Some individuals may identify actions or opinions as ‘reverse’ discrimination, which means that a member of a majority or historically dominant group may feel that they are being discriminated against because of this. The term ‘reverse discrimination’ itself implies that ‘normal’ discrimination only goes in one direction, with a majority group dominating or maltreating a minority group.

Contrary to this traditional understanding of discrimination, some people belonging to the majority may claim that they were discriminated against in favour of a minority or disadvantaged group based on their race, sex, or other protected characteristic.

Examples may include

• recruitment practices that favour women over men despite the men being more qualified
• rejecting a white job applicant in favour of a black applicant where the former has skills better suited to the job.
  ‘Reverse’ discrimination and so-called positive discrimination are illegal in the UK.
  Historically, the negative effects of a majority group discriminating against a minority group far outweigh the negative effects of a minority group being favoured over a majority group. Positive action is not the same as discrimination, and describes measures targeted at a particular group to put right past discrimination or increase the participation of under-represented groups. Positive action is legal in the UK.

THE PUBLIC SECTOR EQUALITY DUTY

Since 2011, public sector organisations (local authorities, hospitals, educational settings, the police etc) are required to:

• Eliminate unlawful discrimination, harassment, victimisation or any other behaviour that is unlawful.
• Advance equality of opportunity between people who share a relevant protected characteristic, as well as those who do not share one.
  Regarding the last point on equality of opportunity, organisations need to:
• Remove or minimise any disadvantages suffered by people who share a protected characteristic.
• Take steps to meet any differing needs of people with a protected characteristic.
• Encourage people who share a protected characteristic to take part in public life or in any other activity where their participation is low.

WHAT MUST EMPLOYERS DO?

It makes good sense for every organisation to have an equality and diversity policy. If an employer had to defend themselves at an employment tribunal, they would need to demonstrate that they take equality and diversity seriously and without a written policy, providing evidence would be very difficult. But having a policy also demonstrates to employees, potential employees and customers and suppliers alike that the organisation respects people’s rights and values their differences.

What should an equality and diversity policy look like?

A policy should state the organisation’s commitment to:

• complying with all employment and equality legislation
• treating all employees fairly and with dignity and respect regardless of their employment status
• valuing the contribution that all employees make to the organisation’s work
• appreciating people’s diversity and valuing their differences
• paying due regard to selection, recruitment, training and development processes to ensure that candidates are selected for their aptitude and ability
• giving all employees equal opportunities in the workplace in accordance with all protected characteristics
• creating a culture where discrimination, harassment, bullying and victimisation is totally unacceptable
• dealing with problems quickly, thoroughly and confidentially
• mitigating unconscious bias; for example, through training and awareness programmes.
  The policy should then describe what the organisation is doing in each area; for example, it could deal with problems by operating a whistle-blowing policy or putting a confidential telephone line in place.

All staff must be made aware of the policy and receive training on it. They should know that a breach of it will be regarded as misconduct that could lead to disciplinary action.

Finally, the policy should be a ‘living’ document that is monitored, regularly reviewed and reported on. A senior, named person should be responsible for making sure that it is adhered to.

WHAT MUST EMPLOYEES DO?

• Comply with the law and with the organisation’s employment and equality and diversity policies and treat everyone with respect and dignity.
• Not make derogatory comments, unfairly discriminate or act in a way that might cause distress or embarrassment to co-workers or customers, whether intentionally or not.
• Not engage in harassment or bullying behaviour.
• Respect people’s beliefs.
• Report inappropriate behaviour immediately.

SUMMARY

In this module, we have covered:

• what equality and diversity mean and how they affect you
• barriers that can prevent equality from being realised
• key legislation and both employers’ and employees’ responsibilities in relation to it.
  This concludes your course on Equality & Diversity and we trust you have found it informative.

Please visit the ‘Resources’ section of the course which contains much more information and guidance to extend your knowledge. You are now ready to complete the corresponding questionnaire. Click ‘Questionnaire’ to begin the questions.

EQUALITY IMPACT ASSESSMENT FORM

Step 1 – Identify The Policy/Procedure

The terms policy/procedure is interpreted broadly in equality legislation, andrefers to anything that describes what we do and how we expect to do it. It canrange from published University policies and procedures to the everydaycustoms and practices – sometimes unwritten – that contribute to the way ourpolicies are implemented and how our services are delivered.

Published statements of policy are a useful starting point for equality impactassessments, as they establish the overall purpose of particular activities.Please use this form to document your assessment.

Step 2 – Further Information

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Step 3 – Assess The Impact On Different Groups Of People

In the table below, please tick whether the policy affects particulargroups of people – the Equality Target Groups below — in different ways,compared to other groups.
Here are some examples:
Positive impact: a policy or practice where the impact on a particular group ofpeople is more positive than for other groups, e.g., accessible website design. Itcan also include legally permitted positive action initiatives designed to remedy workforce imbalance, such as job interview guarantee schemes for disabledpeople.
Negative impact: a policy or practice where the impact on a particular groupof people is more negative than for other groups (e.g., where the choice ofvenue for a staff social occasion precludes members of a particular faith orbelief group from participating).
Neutral impact: a policy or practice with neither a positive nor a negativeimpact on any group or groups of people, compared to others.

Note: The above assessment will be given once data is compared over aperiod of time.

• Data for the EIA is captured on Sex (meaning gender), Disability, Race(including ethnicity and nationality), Age, and part / full time hours.
• Information on Gender Reassignment and Sexual Orientation is notcurrently monitored by the University. However, the University’sIndividual Circumstances Form (ICF) attached in Appendix 1, requestscircumstances explicitly involving these characteristics
• Information on Pregnancy & Maternity leave will also have an impactupon the procedure
• Information on Religion or Belief (not monitored by the University)and Marriage & Civil Partnership (monitored) was not explicitlyrequested but could also be given on the ICF in describing individualcircumstances.
• The number of staff “at risk” in this data is13

Step 4 – Promoting Equality

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Step 5 – Monitoring Effectiveness

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Step 6 – Recommendation

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INTRODUCTION

We may have to collect and use information about people with whom we work. This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.

We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business. We will ensure that we treat personal information lawfully and correctly.

To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).

This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our human resources function as described below. It also covers our response to any data breach and other rights under the GDPR.

This policy applies to the personal data of job applicants, existing and former employees, apprentices, volunteers, placement students, workers and self-employed contractors. These are referred to in this policy as relevant individuals.

DEFINITIONS

“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.

“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).

“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.

“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

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:

• processing will be fair, lawful and transparent
• data be collected for specific, explicit, and legitimate purposes
• This policy is fully supported by senior management and has been agreed with employee representatives
• data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
• data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
• data is not kept for longer than is necessary for its given purpose
• data is not kept for longer than is necessary for its given purpose
• we will comply with the relevant GDPR procedures for international transferring of personal data

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:

• personal details such as name, address, phone numbers
• information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter, references from former employers, details on your education and employment history etc
• details relating to pay administration such as National Insurance numbers, bank account details and tax codes
• medical or health information
• information relating to your employment with us, including:

1. job title and job descriptions
2. your salary
3. your wider terms and conditions of employment
4. 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.
5. internal and external training modules undertaken
All of the above information is required for our processing activities. More information on those processing activities are included in our privacy notice for employees, which is available from your manager.

Employee Rights

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

• the right to be informed about the data we hold on you and what we do with it;
• 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”;
• 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’;
• the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
• the right to restrict the processing of the data;
• the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
• the right to object to the inclusion of any information;
• 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.

RESPONSIBILITIES

In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection. We have also appointed employees with responsibility for reviewing and auditing our data protection systems.

Lawful Bases Of Processing

We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.
Where no other lawful basis applies, we may seek to rely on the employee’s consent in order to process data.

However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. Employees will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.

Access To Data

As stated above, employees have a right to access the personal data that we hold on them. To exercise this right, employees should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.

No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.

Further information on making a subject access request is contained in our Subject Access Request policy.

Data Disclosures

The Company may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:

• any employee benefits operated by third parties;
• disabled individuals – whether any reasonable adjustments are required to assist them at work;
• individuals’ health data – to comply with health and safety or occupational health obligations towards the employee;
• for Statutory Sick Pay purposes;
• HR management and administration – to consider how an individual’s health affects his or her ability to do their job;
• the smooth operation of any employee insurance policies or pension plans;
• to assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders or to assess or collect any tax or duty.

These kinds of disclosures will only be made when strictly necessary for the purpose.

Data Security

These kinds of disclosures will only be made when strictly necessary for the purpose.

Employees are aware of their roles and responsibilities when their role involves the processing of data. All employees are instructed to store files or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops etc when unattended. No files or written information of a confidential nature are to be left where they can be read by unauthorised people.

Where data is computerised, it should be coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must itself be kept in a locked filing cabinet, drawer, or safe.

Employees must always use the passwords provided to access the computer system and not abuse them by passing them on to people who should not have them. Personal data relating to employees should not be kept or transported on laptops, USB sticks, or similar devices, unless prior authorisation has been received. Where personal data is recorded on any such device it should be protected by:

• ensuring that data is recorded on such devices only where absolutely necessary.
• using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted.
• ensure that no individual is disadvantaged as a result of their marriage or civil partnership status.

Failure to follow the Company’s rules on data security may be dealt with via the Company’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.

Third Party Processing

Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.

International Data Transfer

Delete as appropriate
The Company does not transfer personal data to any recipients outside of the EEA.
OR
The Company may be required to transfer personal data to a country/countries outside of the EEA. Transfers may take place because (provide details on why transfer may have to take place). Where this occurs, the following safeguards are adopted (insert details eg binding corporate rules/standard data protection clauses/compliance with an approved code of practice etc).

Requirement To Notify Breaches

All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.

More information on breach notification is available in our Breach Notification policy.

Training

New employees must read and understand the policies on data protection as part of their induction.
All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.

The nominated data controller/auditors/protection officers for the Company are trained appropriately in their roles under the GDPR.
All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.

Records

The Company keeps records of its processing activities including the purpose for the processing and retention periods in its HR Data Record. These records will be kept up to date so that they reflect current processing activities.

Data Protection Compliance

Delete as appropriate

To learn more about how we use these and your choices in relation to these tracking technologies, please refer to our Cookie Policy.

GENERAL POLICY

A declaration of our intent to provide and maintain, so far as is reasonably practicable, a safe and healthy working environment and to enlist the support of our employees in achieving these goals.

ORGANISATION AND RESPONSIBILITIES

This section sets out the health and safety responsibilities of key personnel within the organisation.

ORGANISATION AND RESPONSIBILITIES

This section explains the systems and procedures that will be used to form the basis of our health and safety regime.

SAFETY RECORDS (THIS SECTION MAY BE IN A SEPARATE FOLDER)

This section contains;

• processing will be fair, lawful and transparent
• data be collected for specific, explicit, and legitimate purposes
• This policy is fully supported by senior management and has been agreed with employee representatives
• data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
• data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
• data is not kept for longer than is necessary for its given purpose
• data is not kept for longer than is necessary for its given purpose
• we will comply with the relevant GDPR procedures for international transferring of personal data

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:

• personal details such as name, address, phone numbers
• information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter, references from former employers, details on your education and employment history etc
• details relating to pay administration such as National Insurance numbers, bank account details and tax codes
• medical or health information
• information relating to your employment with us, including:

1. job title and job descriptions
2. your salary
3. your wider terms and conditions of employment
4. 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.
5. internal and external training modules undertaken
All of the above information is required for our processing activities. More information on those processing activities are included in our privacy notice for employees, which is available from your manager.

Employee Rights

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

• the right to be informed about the data we hold on you and what we do with it;
• 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”;
• 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’;
• the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
• the right to restrict the processing of the data;
• the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
• the right to object to the inclusion of any information;
• 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.

RESPONSIBILITIES

In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection. We have also appointed employees with responsibility for reviewing and auditing our data protection systems.

Lawful Bases Of Processing

We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.
Where no other lawful basis applies, we may seek to rely on the employee’s consent in order to process data.

However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. Employees will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.

Access To Data

As stated above, employees have a right to access the personal data that we hold on them. To exercise this right, employees should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.

No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.

Further information on making a subject access request is contained in our Subject Access Request policy.

Data Disclosures

The Company may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:

• any employee benefits operated by third parties;
• disabled individuals – whether any reasonable adjustments are required to assist them at work;
• individuals’ health data – to comply with health and safety or occupational health obligations towards the employee;
• for Statutory Sick Pay purposes;
• HR management and administration – to consider how an individual’s health affects his or her ability to do their job;
• the smooth operation of any employee insurance policies or pension plans;
• to assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders or to assess or collect any tax or duty.

These kinds of disclosures will only be made when strictly necessary for the purpose.

Data Security

These kinds of disclosures will only be made when strictly necessary for the purpose.

Employees are aware of their roles and responsibilities when their role involves the processing of data. All employees are instructed to store files or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops etc when unattended. No files or written information of a confidential nature are to be left where they can be read by unauthorised people.

Where data is computerised, it should be coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must itself be kept in a locked filing cabinet, drawer, or safe.

Employees must always use the passwords provided to access the computer system and not abuse them by passing them on to people who should not have them. Personal data relating to employees should not be kept or transported on laptops, USB sticks, or similar devices, unless prior authorisation has been received. Where personal data is recorded on any such device it should be protected by:

• ensuring that data is recorded on such devices only where absolutely necessary.
• using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted.
• ensure that no individual is disadvantaged as a result of their marriage or civil partnership status.

Failure to follow the Company’s rules on data security may be dealt with via the Company’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.

Third Party Processing

Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.

International Data Transfer

Delete as appropriate
The Company does not transfer personal data to any recipients outside of the EEA.
OR
The Company may be required to transfer personal data to a country/countries outside of the EEA. Transfers may take place because (provide details on why transfer may have to take place). Where this occurs, the following safeguards are adopted (insert details eg binding corporate rules/standard data protection clauses/compliance with an approved code of practice etc).

Requirement To Notify Breaches

All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.

More information on breach notification is available in our Breach Notification policy.

Training

New employees must read and understand the policies on data protection as part of their induction.
All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.

The nominated data controller/auditors/protection officers for the Company are trained appropriately in their roles under the GDPR.
All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.

Records

The Company keeps records of its processing activities including the purpose for the processing and retention periods in its HR Data Record. These records will be kept up to date so that they reflect current processing activities.

Data Protection Compliance

Delete as appropriate

SAFEGUARDING & PREVENT RISK REGISTER AND ACTION PLAN – BTL

ASSESSMENT UNDERTAKEN BY COLLEGE PREVENT LEADS

Sara Hanif – Designated Safeguarding
LeadNoaman Islam – Designated Safeguarding
LeadJosh Brown – Deputy Designated Safeguarding Lead
Niharika Barua – Deputy Designated Safeguarding Lead

Internal/External Verification/Approval

Internal:

• SLT
• Safeguarding Committee

External:

London PREVENT Coordinator – Jennie Fisher and local authorities for safeguarding concerns and advise

Date Undertaken: August 2021
Next Annual review:

Who Is This Document For?

This document is intended for leaders, managers and governors; the intention of this document is to give advice, reassurance and guidance on how Prevent is being implemented within Best Training London. It will provide a framework on how to assess and deal with Prevent vulnerabilities at the institution and to have due regard to the need to prevent people being drawn into terrorism.