equality, diversity & equal opportunities policy...work within the spirit and the practice of...

Policies & Proced- ures

Equality, Diversity & Equal Opportunities Policy

POLICY PAGEEquality, Diversity & Equal Opportunities Policy 2Privacy & Personal Data Policy 5Complaints Policy 9

ADDITIONAL POLICIES AVAILABLE UPON REQUESTCode of conductSafeguarding PolicyEquality, Diversity & Equal Opportunities PolicyHealth & Safety Policy Confidentiality PolicyWhistleblowing PolicyDisciplinary & Dismissal ProcedureGrievance Policy

Our Commitment Individuals with different cultures, perspectives and experiences are at the heart of the way that Spymonkey is run. We want to recruit, develop and retain the most talented people regardless of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (which includes colour, nationality and ethnic or national origins), religion or belief, sex or sexual orientation. At Spymonkey we recognise that be-ing a diverse and inclusive organisation helps us fulfil our responsibility to make a differ-ence for the people in the communities that we serve.

We are committed to the ongoing development of an environment where we treat all employees and workshop participants, as individuals, fairly and in a consistent way. We work within the spirit and the practice of the Equality Act 2010 by promoting a culture of respect and dignity and actively challenging discrimination, should it ever arise.

Equality and diversity at Spymonkey At Spymonkey, we consider that equality means breaking down barriers, eliminating dis-crimination and ensuring equal opportunities and access both in employment, and in the workshops we provide.

We consider diversity to mean celebrating difference and valuing everyone. Each person is an individual with visible and non-visible differences and by respecting this everyone can feel valued for their contributions which is beneficial not only for the individual but for Spymonkey.

Equality and diversity are not inter-changeable but inter-dependent. There can be no equality of opportunity if difference is not valued and harnessed.

Equal Opportunities Spymonkey is committed to achieving equal opportunities, respects and values diversity, and is committed to applying equality of opportunity in all its practices and objective/ser-vice delivery with regard to ethnic origin, age, gender, religion or belief, sexual orienta-tion, marital status and disability or any other criterion not relevant to the point at issue.

The Spymonkey senior management team have overall responsibility for the effective op-eration of this policy. However, all staff and service users have a duty as part of their in-volvement with the organisation to do everything they can to ensure that the policy works in practice.

The Spymonkey senior management team will bring to the attention of all staff the exist-ence of this policy, and will provide such training as is necessary to ensure that the policy is effective and that everyone is aware of it.

Reference to the policy should be included in the contract documents with outside agen-cies.

Policy Scope The rights and obligations set out in this policy apply equally to all employees, whether part time, full time, PAYE or freelance.

All individuals referred to above have responsibility for the application of this policy. You are expected to read and familiarise yourself with this policy and ensure that this policy is properly observed and fully complied with.

Definitions Direct Discrimination – is treating people less favourably than others on the grounds of a characteristic, such as age, race, religion or gender.

Indirect Discrimination – is applying a service, criteria or practice which disadvantages people of a particular group and which is not objectively justifiable.

Associative Discrimination – is discrimination against an individual based on their associ-ation with someone who has a protected characteristic as defined under the Equality Act

Harassment – is unwanted conduct that violates people’s dignity or is intimidating, hos-tile, degrading, humiliating or offensive.

Victimisation – is treating people less favourably because of an action they have taken in connection with equality legislation, for example making a formal complaint.

Employment Practices Spymonkey is an equal opportunities employer and will not unfairly discriminate against anyone or section of the community in its employment practices.

• Spymonkey encourages diversity of applicants in the local community and advert-ises in a range of publications to support this. Selection for employment at Spy-monkey is on the basis of aptitude and ability for the job applied for. Where pos-sible, Spymonkey will capture applicants’ diversity demographics as part of its re-cruitment processes to promote the elimination of unlawful discrimination.

• All promotion decisions will be made on the basis of merit, and will not be influ-enced by any of the protected characteristics as outlined in the Equality Act 2010.

• The benefits, terms and conditions of employment and facilities available to Spy-monkey employees will be reviewed on a regular basis to ensure that access is not restricted by unlawful means and to provide appropriate conditions to meet the special needs of disadvantaged or under-represented groups.

Services - Workshops At Spymonkey we are committed to including everyone in the community. Individual needs will be discussed and we will work within our means to ensure that any barriers to accessing our workshops are overcome.

•Everyone is included and made to feel valued and good about themselves.

•Everyone’s needs are treated individually and with equal concern and consistency.

•Learning and sharing about each other’s customs, beliefs, diet, dress and other spe-cific routines is encouraged.

Responsibilities All Spymonkey team members are responsible for:

•Being role models for each other and participants, working in a non-discriminatory way.

•Talking to other team members and participants in a respectful manner.

•Implementing this policy.

Governance This policy will be reviewed on an ongoing basis by Spymonkey senior management to assess its effectiveness and may be amended from time to time. Date of last review Au-gust 2020

Privacy & Personal Data Policy

Purpose

Spymonkey is committed to protecting your privacy according to GDPR guidelines. We will only use the data we collect from you to tell you about the work we are doing. This policy applies to users of our website, clients and customers.

The personal information that we collect about you is used only to provide effective communication with you. By providing us with your personal data, you consent to the col-lection and use of any information you provide in accordance with the above purposes and this privacy statement. Where we offer you services either directly or through a third party supplier, we will ask you for permission to use and/or share your information before we proceed.

Sharing personal information We will only share personal information about you with another organisation if:

• There is a safeguarding concern

• We are required to by government bodies or law enforcement

• To accept a booking or registration form online via a data support provider

• We have obtained your prior consent

We will not sell or rent your information to third parties.

We will never share your information with third parties for marketing purposes.

Security of personal data Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to pro-tect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

We will use all reasonable endeavours to ensure that you provide personal information in a secure and confidential environment and when the information is no longer needed it will be destroyed or permanently rendered anonymous.

Information that you provide to us is retained and processed in accordance with UK data protection legislation. This includes information you provide when you attend a class, course, event, workshop or training, sign up to our newsletter or submit a contact form or email to us.

Subscribe: We have a subscribing form on our website which is used to collect your name, email and marketing preferences. This option is available so that we can contact you and provide details of our services to you, make bookings, confirm bookings and deal with general enquiries. Data is held on the grounds of being legitimate to our busi-ness interests and in order to provide our services to you.

Emails: We retain copies of emails sent to us on our servers. Your personal information will be held by us in accordance with this Privacy Policy and will be on the basis of being legitimate to our business interests and in order to provide our services to you.

Email marketing: We will record your communication preferences when you sign up to our email alerts and may monitor whether you open our emails and which links you click on. We will also log your Internet Protocol (IP) address, and the type of web browser used. Data is held on the grounds of being legitimate to our business interests so that we can provide our services to you. Data is processed on the basis of valid consent obtained from you.

Email newsletter: We operates an email newsletter programme with email newsletter provider – Mailchimp, used to inform visitors about products and services supplied by Spymonkey . Users can subscribe through an online automated process. Subscriptions may also be manually processed through prior written agreement with the user. Data is only processed with your consent and you have the right to withdraw from further com-munications at any time.

Phone calls: We may make notes during phone calls recorded and any data relating to the call may be retained by us. The data will be held on the basis of being for our legitim-ate business needs or in order to fulfil our contractual obligations if you are a client of ours.

Social media: We use social media to engage with users using our pages on Facebook, Twitter, and Instagram. We do not keep any specific data that identifies you as an indi-vidual user, but hold details of our followers on these platforms. You should refer to the Privacy Policies of these channels to understand how they treat your data in relation to linking to our site.

Drop Box and Apple Contacts We keep class lists for workshops in files on Drop Box. These contacts are also imported into Apple Contacts for ease of communication. Com-puters are password protected.

Third party sites

Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

Your legal rights Spymonkey recognises a data subject’s rights and will uphold these in accordance with data protection laws. You are entitled to see the information held about you and you may ask us about any of the following:

Subject access requests Data subjects (i.e. individuals) have the right to access personal data that is held by sub-mitting a subject access request (SAR) to Spymonkey. We will endeavour to respond quickly to any such requests, which legally require us to respond within one month of re-ceiving the request and necessary information. A subject access request can be made by emailing us at [email protected].

Right to rectification Data subjects have the right to request that we amend or change personal information that is inaccurate or incorrect.

Right to erasure Data subjects have the right to ask us to delete personal information from our systems without giving any reason and at any time. We will act on any such request without delay.

Right to restrict processing Data subjects have the right to rectification or erasure of personal data in the following circumstances: • Personal data is not accurate; • The processing of data is unlawful – data subjects may request that processing is

restricted; • Data is required to exercise legal rights or defend legal claims; • Data is unlawful but there may be lawful grounds for processing, which override

this right. Right to object Data subjects have the right to object to the processing of data at any time based on their particular situation. This includes objecting to profiling unless it is in the ‘public in-

terest’ or exercised lawfully by an official authority. We will only process data under lawful grounds.

Right not to be subject to decisions based on automated processing We do not use any automated processing that results in any automated decision based on a data subject’s personal information.

Using your rights If you wish to invoke any of these rights, you should email us at: [email protected]. You also have the right to complain about any use of your information with the UK data protection regulator: https://ico.org.uk/.

Spymonkey Website With the exception of Google Analytics*, the Spymonkey website does not use cookies. Spymonkey may contain links to other websites, such as YouTube, but is not responsible for their privacy practices or content.

*Google Analytics uses cookies to collect information about how visitors use our site. Cookies are collected anonymously and do not identify individual visitors. Information that is collected includes the number of visitors to the site, the country the visitor is from, and the pages they have visited. For an overview of Google’s privacy policy, or to opt out of Google Analytics tracking, please visit the Google website.

Governance

This policy will be reviewed on an ongoing basis by Spymonkey senior management to assess its effectiveness and may be amended from time to time. Date of last review Au-gust 2020.

Complaints Policy Purpose

Whilst we hope that we provide a good service to all our customers, sometimes we may get it wrong and we would like to hear from you if you are not satisfied with any aspect of our work.

mailto:[email protected]

https://ico.org.uk/

This document explains our complaints procedure which is accessible to all our customers on an equal basis. Our approach will be to try to put things right quickly and politely. Making a complaint will not affect the level of service you receive from Spymonkey.

Do you need any specific requirements to enable you to make a complaint? Please let us know if you would like to receive this complaints procedure in an alternative format.

Making a complaint

If you would like to make a complaint, this is what you should do:

Stages in our complaints procedure:

Stage 1Contact the member of staff you first dealt with, giving details of what you wish to com-plain about. If the complaint is made in writing or through an answer message, we will in-form you that we have received it. The member of staff will investigate your complaint with the aim to settle the complaint as quickly as possible. Please tell us how you would like to be contacted to receive our response.

In most cases you will receive a full reply to your complaint within 10 working days of making the complaint. If we cannot give you a full reply in this time, we will tell you why and inform you of when you are likely to receive it.

Stage 2If you are dissatisfied with the response you receive from the member of staff you may ask us to review the complaint by emailing [email protected], with the word ‘Complaint’ in the email subject. You must request Stage 2 within 10 working days of receiving our re-sponse to Stage 1. Please put in writing:

• What happened

• When it happened (dates and times)

• Who dealt with you; and

• What you would like us to do to put it right

The decision will be given to you in writing up to 10 days after receiving your request for Stage 2.

Stage 3If you are still unhappy, your complaint will be put to a second member of the senior management team to review. We may ask you to attend a meeting with us to discuss your complaint in more detail. We would send you a written record of the meeting and a form-al reply to your complaint from the senior management team. This will take place up to 10 working days after Stage 3 was requested.


Your personal informationIf you use our complaints procedure, you are agreeing that we can use any personal in-formation you send us for purposes connected with your complaint. We will only give your personal information to other people and organisations if you have given us permis-sion to do so.

Equal opportunities We are committed to equal opportunities and take complaints about discrimination seri-ously.

Spymonkey may record information about the ethnic background, age, sex, religion, sexual orientation and disability of anyone who makes a complaint so that we promote and maintain our equal opportunities commitment. We will keep all information confiden-tial.

Comments and suggestionsWe hope that your concerns can always be resolved through the stages 1 – 3 of the pro-cedure above. However, we welcome comments and suggestions that can help us im-prove our services. The feedback we obtain from our customers will help us to continue to improve our service.

Contact informationSpymonkey, Unit 7b, Level 3N, New England House, New England Street, Brighton, BN1 4GH

Tel: 07766 712 757 (Toby Park) Email: [email protected]

Governance

This policy will be reviewed on an ongoing basis by Spymonkey senior management to assess its effectiveness and may be amended from time to time. Date of last review Au-gust 2020.


equality, diversity & equal opportunities policy...work within the spirit and the practice of...

Documents