Safeguarding Policy

Policy statement

DTS is committed to adopting the highest standards and taking all reasonable steps in relation to the safety and welfare of children, young people and adults in respect of its learning services. We will meet our social and moral responsibilities to protect such individuals fully in accordance with the law and where appropriate, with the support of relevant external agencies.

All children, young people and adults, without exception, have the right to protection from abuse regardless of age, disability, gender, marriage and civil partnership, pregnancy and maternity, race, religion and belief, gender, sexual orientation or socio-economic background.

We aim to create a positive learning and working environment where every individual can be true to themselves and is able to learn and work without fear of harm. We will ensure that our employees are carefully selected, trained, supervised and have an appropriate level of DBS check in place where required. We will ensure that all employees adopt and abide by the Company’s Safeguarding Code of Conduct, are proactive and respond to any allegations appropriately in accordance with the reporting procedure.

Scope and purpose

This policy applies to:

• DTS learners and customers.
• employees (individuals who work – or have applied to work for the company either on a permanent, temporary, contractual or voluntary basis);
• employers (organisations that work in partnership with us)
• suppliers (external partners who are in receipt of and/or provide DTS training or employability services on our behalf)
• external stakeholders and visitors

The purpose of this policy is to set out our approach to safeguarding children, young people and adults and protecting them from a range of potential harm.

General principles

The Company’s Safeguarding Policy and associated policies are based on the following principle:

• The welfare of children, young people and vulnerable adults are the primary concern
• All children, young people and vulnerable adults have the right to protection from abuse
• It is the responsibility of experts to determine whether abuse has taken place, but it is everyone’s responsibility to report any concerns using the appropriate procedures outlined in this policy
• All incidents of suspicious practice and allegations must be taken seriously and responded to swiftly and appropriately
• Confidentiality must be upheld in line with the General Data Protection Regulation (GDPR) 2018, Data Protection Act 1998 and the Human Rights Act 1998.

Definitions and terms of abuse

Child - A child is defined as someone who has not reached 18 years of age.

Young Person - A young person is defined as someone normally between the age of 14 – 17 years of age.

Vulnerable Adult - Following the Protection of Freedoms Act 2012 the definition of regulated activity relating to adults no longer labels adults as ‘vulnerable’. Instead, the definition identifies the activities which, if any adult requires them, lead to that adult being considered vulnerable at that particular time. This means that the focus is on the activities required by the adult and not on the setting in which the activity is received; or the personal characteristics or circumstances of the adult receiving the activities or the frequency in which they receive the service. An adult is defined as vulnerable when they are in receipt of a ‘regulated activity’ in relation to vulnerable adults. Regulated activity is therefore defined by the following 6 broad categories:

1. Providing health care
2. Providing personal care
3. Providing social work
4. Assistance with cash, bills and/or shopping
5. Assistance in the conduct of a person’s own affairs
6. Providing transportation of individuals where that transport is provided because of age, health or disability

For more information please see the Safeguarding Vulnerable Groups Act 2006, as amended by the Protection of Freedoms Act 2012.

Discriminatory Abuse

Discriminatory abuse includes psychological abuse, harassment and discrimination which is motivated by a person’s age, gender, disability, sexual orientation, race, cultural background or religion. Discrimination may be a motivating factor in other forms of abuse such as domestic violence or hate crime.

Where the abuse or neglect is motivated by age, gender, sexual orientation, immigration status, racial, religion or disability; or occurs in a domestic violence situation; or perceived as a Hate Crime: the abuse will be considered to be aggravated by these factors.

Discriminatory abuse can be in the form of personal or institutional discrimination. Personal discrimination is the prejudice of the individual, whereas, Institutional discrimination is where systems and structures directly discriminate against potential or actual users of a service.

Signs and symptoms of Discriminatory Abuse can include:

• fearfulness expressed in the eyes, person avoids looking at the potential abuser, flinching on approach
• emotional withdrawal
• sleep disturbance
• low self-esteem
• unexplained fear or defensiveness
• isolation / shunning by others
• threats or intimidation, bullying or shouting
• unexplained attacks on property or possessions
• continual favouritism to other people in preference to the individual
• internalising the discrimination to the extent that they express similar discriminatory views about others

Other types of Abuse which could be considered Discriminatory:

Hate Crimes: any incident which constitutes a criminal offence which is perceived by the victim or any other person as being motivated by prejudice and hate.

Ageism: discrimination based on age, especially against the elderly.

Gender Discrimination: is a belief that one sex is superior to the other and that the superior sex has endowments, rights, prerogatives and status greater than those of the inferior sex.

Homophobia: discrimination against (fear or dislike of) homosexual people and homosexuality

Transgender Discrimination: discrimination against people who are transgender

Religious Intolerance: is either intolerance motivated by one's own religious beliefs or intolerance against another's religious beliefs or practices.

Racism: the belief that all members of each race possess characteristics or abilities specific to that race, especially so as to distinguish it as inferior or superior to another race or races.

Disablism: discriminatory, oppressive or abusive behaviour arising from the belief that disabled people are inferior to others.

Physical Abuse

Physical Abuse is the physical mistreatment of one person by another which may or may not result in physical injury. Physical abuse includes assault, hitting, slapping, scratching, pushing, kicking, pinching, burning, force-feeding, misuse of medication or the withholding of medication or treatment, unwarranted or inappropriate restraint, forced isolation or inappropriate sanctions, unwarranted or unauthorised deprivation of liberty, false imprisonment or abduction, rough handling causing injury or any injury not fully explained by the history given.

Signs and symptoms of Physical Abuse can include:

• unexplained bruises or welts on body, including face, lips, mouth, body, arms, back, buttocks, thighs
• bruises in various stages of healing, clusters forming regular patterns, reflecting the shape of an article or finger marks
• unexplained burns, especially on soles, palms and back, immersion burns, rope burns, electric appliance or carpet burns
• unexplained fractures to any part of the body, especially if in various stages of healing, multiple or spinal injuries
• unexplained lacerations or abrasions to the mouth, lips, gums, eyes, external genitalia
• recoiling from physical contact or flinching
• malnutrition – rapid or continuous weight loss, insufficient supply of food on premises, dehydration, complaints of hunger
• lack of personal care, inadequate or inappropriate clothing, inadequate heating
• untreated medical problems
• unmanaged urinary / faecal incontinence
• signs of medication misuse such as drowsiness
• use of furniture and other equipment to restrict movement

Other types of Abuse which could be considered Physical:

Domestic Violence: any incident, or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are, or have been intimate partners, or family members regardless of gender or sexuality;

Forced Marriage: is a marriage conducted without the valid consent of one or both parties where duress is a factor. Forced Marriage is a violation of internationally recognised human rights and contrary to the Matrimonial Causes Act 1973;

‘Honour’ Based Violence: is an incident or crime carried out to protect or defend the honour or ‘izzat’ of the family or community. This type of violence can be distinguished from other forms of violence as it is often committed with some degree and / or collusion from the family and / or community. Honour based violence includes acts of harassment, assault, imprisonment, unexplained death (suicide), forced pregnancy / abortion and in some cases murder. The family may perceive that the person has acted inappropriately and dishonoured the family and community. Consequently, the violence carried out is to punish them for this. For more information about honour based violence visit Karma Nirvana’s website www.karmanirvana.org.uk

Environmental Abuse: includes depriving someone of their liberty, sustained restrictions on a person’s freedom of movement as a result of the physical environment the person is in, culture of the environment or institution. It can also mean a child living without expressions of love, living in unsuitable / unclean accommodation.

Sexual Abuse

Sexual abuse is the involvement of individuals in sexual activities to which they have not had the freedom and capacity to give their informed consent to, before and during the act, and/or may not fully comprehend. These acts include rape and attempted rape, sexual assault by penetration, sexual assault, abuser touching the victim’s body for their own gratification, indecent exposure, non-contact abuse (pornography), and sexual harassment, causing or inciting a person to engage in sexual activity without their consent. The use of social media and the internet has introduced ‘cyber’ sexual abuse such as ‘sexting’ and un-authorised sharing of sexual images.

Signs and symptoms of sexual abuse can include:

• full or partial disclosure or hints of sexual abuse
• signs of depression, stress
• recoiling from physical contact
• unusual difficulty in walking and sitting
• sexually-transmitted disease, urinary tract / vaginal infections
• love bites, bruises or finger marks on thighs or arms
• significant change in sexual behaviour, language or outlook
• fear of males or females
• pregnancy in a person who is not able to consent
• Worries over social media content and sharing of personal content (see Cyber Abuse)

Other types of Abuse which could be considered Sexual:

Female Genital Mutilation: (FGM) is a collective term for procedures which include the removal of part or all of the external female genitalia for cultural or other non-therapeutic reasons.

Sexual Exploitation: Sexual exploitation of young people and vulnerable adults involves exploitative situations, contexts and relationships where the vulnerable person receives ‘something’ (e.g. food, accommodation, drugs, alcohol, SIM cards and mobile phones, cigarettes, affection, gifts, money) or perceived friendship/boyfriend as a result of them performing, and/or others performing on them, sexual activities.

Psychological / Emotional Abuse

Psychological or emotional abuse is action or neglect by a person which impairs the psychological wellbeing of another person. This results from being repeatedly made to feel unhappy anxious afraid humiliated or devalued by the actions or inactions and/or attitudes of others and includes emotional abuse, threats of harm or abandonment, deprivation of contact, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation or withdrawal from services or supportive networks. People who use social media can be at risk from being humiliated or abused ‘on-line’

Signs and symptoms of Psychological/Emotional abuse can include:

• fearfulness expressed in the eyes, avoids looking at the caregiver, flinching on approach
• ambivalence to carer
• emotional withdrawal
• sleep disturbance
• low self-esteem
• unexplained fear or defensiveness
• threats or intimidation, bullying or shouting
• significant pressure on a person to commit criminal acts
• threat to abandon person or put them “away”
• promises which are not kept
• few visitors, phone calls or outings
• locking the person in at home, or in a car
• significant community pressure for example anti-social behaviour
• Withdrawing from on-line or reality social groups (see Cyber Abuse)

Other types of Abuse which could be considered Psychological:

Anti-Social Behaviour: acting in a manner that caused or was likely to cause harassment alarm or distress to one or more persons not of the same household as the defendant.

Discriminatory Abuse: as described above

Cyber Abuse: the use of technology and social networking sites to threaten, bully, harass, groom for exploitation, stalk, pose risks to personal safety and wellbeing or discriminate against an adult at risk. This could be through the use of a PC, laptop, tablet, mobile phone, gaming console or television with internet access. Threats can come through content, contact and conduct. This includes text messages, phone calls, pictures, video clips, emails, chat room messages, instant messaging and websites. Signs and symptoms can include spending long periods of time online, secrecy about a mobile phone and/or computer, withdrawal from social contact, depression, mood swings, unexplained gifts, sleep disturbance and self-harming. For more information see www.digital- stalking.com

Financial or Material Abuse

Financial abuse is the misappropriation of an individual’s funds, benefits, savings, assets etc. or any other action that is against the person’s best financial interests. This includes theft, fraud, exploitation, pressure in connection with wills, property or inheritance or financial transactions, denying access to money, or the misuse or misappropriation of property, possessions or benefits.

Signs and symptoms of Financial/Material Abuse can include:

• unusual or inappropriate bank activity
• a Power of Attorney obtained when a person is unable to comprehend
• recent change of deeds or title of house
• person lacks belongings or services which they can clearly afford
• recent acquaintances expressing sudden or disproportionate affection for a person with money or property
• carer asks only financial questions of the worker, does not ask questions about care
• withholding money
• person managing financial affairs is evasive or uncooperative.

Neglect and Acts of Omission

Neglect is the deliberate withholding OR unintentional failure to provide appropriate and adequate care and support. Section 44 Mental Capacity Act 2005 states “Anyone who has a duty of care to a person who lacks capacity is guilty of an offence if they deliberately or recklessly ill-treat that person or if they willfully neglect that person.”

It does not matter whether the behaviour was likely to cause, or actually caused, harm or danger to the victim's health. Willful neglect usually means that a person has deliberately failed to carry out an act they knew they had a duty to do.

Signs and Symptoms of Neglect and Acts of Omission can include:

• physical condition of the person is poor
• unexplained or untreated deterioration in health and wellbeing, including not seeking appropriate medical attention
• inadequate heating or lighting
• poor personal hygiene
• malnutrition – loss of weight
• dehydration
• demanding food or drink
• pressure sores
• inconsistent or reluctant contact with health or social agencies
• lack of social support and/or refusal to arrange access to callers / visitors
• inappropriate, old or shabby clothing, or being kept in night clothes during the day
• sensory deprivation, not allowed to have hearing aid, glasses or other aids to daily living
• accumulation of medication, or prescriptions not being collected from pharmacy
• increased number of incidents or accidents e.g. falls or physical altercations with others, which appear to have resulted from a lack of supervision both inside and outside of the home environment

Extremism and Radicalisation

Since 2010, when the Government published the Prevent Strategy, there has been an awareness of the specific need to safeguard children, young people and families from violent extremism. There have been several occasions both locally and nationally in which extremist groups have attempted to radicalise vulnerable children and young people to hold extreme views including views justifying political, religious, sexist or racist violence, or to steer them into a rigid and narrow ideology that is intolerant of diversity and leaves them vulnerable to future radicalisation.

DTS values freedom of speech and the expression of beliefs / ideology as fundamental rights underpinning our society’s values. Individuals have the right to speak freely and voice their opinions. However, freedom comes with responsibility and free speech that is designed to manipulate the vulnerable or that leads to violence and harm of others goes against the moral principles in which freedom of speech is valued. Free speech is not an unqualified privilege; it is subject to laws and policies governing equality, human rights, community safety and community cohesion.

The normalisation of extreme views may also make children and young people vulnerable to future manipulation and exploitation. DTS is clear on its legislative and moral duty to view exploitation and radicalisation as a safeguarding concern and act accordingly.

Signs and Symptoms of Extremism or Radicalisation can include:

• being in contact with extremist recruiters;
• accessing violent extremist websites, especially those with a social networking element;
• possessing or accessing violent extremist literature;
• using extremist narratives and a global ideology to explain personal disadvantage;
• justifying the use of violence to solve societal issues;
• joining or seeking to join extremist organisations; and
• significant changes to appearance and/or behaviour;
• experiencing a high level of social isolation, resulting in issues of identity crisis and/or personal crisis

DTS has a separate policy to ensure we comply with and support CONTEST, the Government’s Counter Terrorism Strategy and in particular the PREVENT strategy to stop people from becoming terrorists or supporting terrorism.

Procedure for reporting

DTS Safeguarding – PREVENT reporting procedure which details the procedure to be followed when dealing with child protection, safeguarding and PREVENT reporting. In order to ensure appropriate action is taken in such circumstances DTS has adopted and utilised the principles of the 5 R’s model below:

Recognition

• Recognition covers both disclosures of abuse and your personal concerns about a learners welfare
• Disclosure of abuse is likely to be direct
• A concern that you have may arise from either a conversation or a change in a learners behaviour

Response

• Do not interview - just listen and clarify if necessary
• Remain calm and listen
• Inform the person that the concerns must be recorded and passed on so that the issue can be dealt with
• Reassure the person that they have done the right thing in reporting their concerns and that you will do everything you possibly can to help
• Do not make unrealistic promises around confidentiality

Reporting

• All disclosures of abuse must be urgently reported to the Designated Safeguarding Lead at wellbeing@dimensionstrainingsolutions.co.uk
• DO NOT DISCUSS THE DISCLOSURE WITH ANYONE ELSE

Recording

Record precisely what has been alleged/happened - use the words of the learner

• This should be scanned and emailed to the Designated Safeguarding Lead. The original should also be sent in a sealed envelope and marked as confidential. It should not automatically be added to a learner/employer file and copies should not be made
• Your record should use accurate quotation
• If appropriate, include factual observations
• Once you have reported concerns using this process it is the responsibility of the Designated Safeguarding Lead to take any further decisions as to the actions which would follow. This may or may not directly involve you

Referral

• Only a Designated Safeguarding Lead can make the decision to refer a complaint or allegation having gathered and examined all relevant information
• Only a Designated Safeguarding Lead should look into a complaint, allegation or suspicion of abuse. Actions carried out by others could be construed as unjustified interference which could jeopardise an investigation and any possible subsequent court case
• No employee is in a position to decide whether abuse has taken place

Contact points for advice and support

The following members of staff have been identified as Safeguarding contacts.

Safeguarding, PREVENT & H&S Leads – DTS / In10tion
	DTS						In10tion
	Government Funded			Commercial
	APPS	ESF (SSW)	DWP	Blended Loans	Online Loans	A2HE Loans	ESF (SSU / SSR)
Safeguarding, PREVENT & H&S Lead	Saskia Jamieson	Kymm Bailey	Rachael Trafford	Helen Spilsbury	Diane Sharp	Wendy Lomas	Saskia Jamieson
Group Safeguarding, PREVENT & H&S Lead	Saskia Jamieson

Support

DTS is committed to providing timely and effective support to all learners, customers and employees to achieve and maintain a safe and secure environment for all. To support this, staff receive training to support the 5 R’s model. Details of useful contacts and support agencies such the local Safeguarding Board; Local Children’s’ Services, Local Adult Services; Local Police Station and other specialist agencies are also available locally and centrally.

This document reflects the following key pieces of legislation

• Keeping Children safe in Education (2018)
• Working Together to Safeguard Children (2015)
• Education Act (2002)
• Children Act (2004)
• Safeguarding Children (2006)
• Information Sharing (2015)

Monitoring and review

This policy will be monitored annually to review its effectiveness and will be updated in accordance with necessary changes.

PREVENT Policy Supporting the Prevention of Extremism and Radicalisation

1. Policy Statement

The current threat from Terrorism and Extremism in the United Kingdom is real and severe and can involve the exploitation of vulnerable people, including children and young people.

This policy is designed to provide a clear framework to structure and inform our response to safeguarding concerns for those people who may be vulnerable to the messages of extremism. In addition, it provides details of the local inter agency process and expectations in identifying appropriate interventions based on the threshold of need and intervention model and the Channel process.

2. Scope and Purpose

This policy is non-contractual and may be amended from time to time to reflect best practice and any changes in legislation.

The Policy applies to all employees and third parties including (this list is not exhaustive):

• learners and customers
• DTS colleagues
• All employers with whom we partner for the provision of work placements and / or training
• All persons coming onto our premises
• Business partners and suppliers who provide services on behalf of DTS

It is the responsibility of all to comply with this Policy. Any learner or colleague who has any concerns regarding the issues identified within this policy should report those concerns immediately.

3. Definition

Radicalisation is defined as the process by which people come to support terrorism and extremism and, in some cases, to then participate in terrorist groups.

Extremism is vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. We also include in our definition of extremism calls for the death of members of our armed forces, whether in this country or overseas (HM Government Prevent Strategy, 2011).

4. National Guidance and Strategies

Prevent is a key part of the Government’s strategy to stop people becoming terrorists or supporting terrorism. Early intervention is at the heart of Prevent in diverting people away from being drawn into terrorist activity. Prevent is relevant before any criminal activity takes place. It is about recognising, supporting and protecting people who might be susceptible to radicalisation.

The Prevent strategy objectives are:

• Ideology: respond to the ideological challenge of terrorism and the threat we face from those who promote it
• Individuals: prevent people from being drawn into terrorism and ensure that they are given appropriate advice and support
• Institutions: work with sectors and institutions where there are risks of radicalisation which we need to address.

DTS is committed to supporting the Prevent duty and expect all colleagues to understand and comply with it. It is imperative that employees understand the various forms of radicalisation, being able to recognise signs and indicators and respond appropriately. Furthermore, it is vital that this understanding is shared with learners and that they are supported in their understanding of how to keep themselves safe in society with regard to terrorism and extremism.

5. Procedure

Any identified concerns as the result of observed behaviour or reports of conversations to suggest that an individual maybe vulnerable to or supports terrorism and/or extremism, must be addressed, reported and where appropriate escalated following the DTS Safeguarding Procedure. Escalating concerns to wellbeing@dimensionstrainingsolutions.co.uk will ensure that these are addressed timely by a safeguarding professional, responsible for determining an appropriate resolution and contacting outside agencies where appropriate.

6. Vulnerability/Risk Indicators

The following lists are not exhaustive and all or none may be present in individual cases of concern. Nor does it mean that vulnerable young people experiencing these factors are automatically at risk of exploitation for the purposes of extremism. The accepted view is that a complex relationship between the various aspects of an individual’s identity determines their vulnerability to extremism.

There is no such thing as a ‘typical extremist’ and those involved in extremism come from a range of backgrounds and experiences. The following indicators may help to identify factors that suggest an individual or their family may be vulnerable or involved with extremism:

Vulnerability

• Identity crisis: Distance from cultural/religious heritage and uncomfortable with their place in the society around them.
• Personal crisis: Family tensions; sense of isolation; adolescence; low self-esteem; disassociating from existing friendship group and becoming involved with a new and different group of friends; searching for answers to questions about identity, faith and belonging.
• Personal circumstances: Migration; local community tensions; events affecting country or region of origin; alienation from UK values; having a sense of grievance that is triggered by personal experience of racism or discrimination or aspects of Government policy.
• Unmet aspirations: Perceptions of injustice; feeling of failure; rejection of civic life.
• Criminality: Experiences of imprisonment; poor resettlement/reintegration, previous involvement with criminal groups.

Access to extremist influences

• Reason to believe that the young person associates with those known to be involved in extremism
• Possession or distribution of extremist literature/other media material likely to incite racial/religious hatred or acts of violence
• Use of closed network groups via electronic media for the purpose of extremist activity

Experiences, behaviours and influences

• Experience of peer, social, family or faith group rejection
• International events in areas of conflict and civil unrest had a personal impact on the young person resulting in a noticeable change in behaviour
• Verbal or written support of terrorist attacks
• First-hand experience of racial or religious hate crime
• Extended periods of travel to international locations known to be associated with extremism
• Evidence of fraudulent identity/use of documents to support this
• Experience of disadvantage, discrimination or social exclusion
• History of criminal activity
• Pending a decision on their immigration/national status

More critical risk factors include:

• Being in contact with extremist recruiters
• Articulating support for extremist causes or leaders
• Accessing extremist websites, especially those with a social networking element
• Possessing extremist literature
• Justifying the use of violence to solve societal issues
• Joining extremist organisations
• Significant changes to appearance/behaviour

6. Channel Referral Process

What is Channel?

Channel is a key part of the Prevent strategy that may be appropriate for anyone who is vulnerable to being drawn into any form of terrorism. It is about ensuring that individuals of any faith, ethnicity or background receive support before their vulnerabilities are exploited by those that would want them to embrace terrorism, and before they become involved in criminal terrorist related activity.

Channel is a multi-agency safeguarding programme available in every local authority in England and Wales. It provides a range of support including: mentoring; counselling; and assistance with training or employment.

Channel is a voluntary programme. It is up to an individual, (or their parents/carer if the individual is under 18 and where it is appropriate), to decide whether to take advantage of the support it offers. It is not any form of criminal or civil sanction.

Channel is confidential. Participation will not show up on any checks or negatively affect an individual’s future in any way. No one will get a criminal record and all channel information is held separately to all other police business so it can’t be searched for other purposes such as DBS (Disclosure and Barring Service) checks. Channel works best when the individuals and their families fully engage with the programme and are supported in a consistent manner. The vast majority of those who choose to receive support go on to leave the programme with no further terrorism-related concerns.

Concern identified – raise concerns

• If someone identifies a possible risk of radicalisation or a concern that an individual may be vulnerable, the concern should be raised to a Safeguarding representative.

DTS review - potential to refer to Prevent officer

• DTS will gather the information and review it. If there is an immediate risk then we will contact the emergency services. If there are concerns that the individual may be vulnerable to terrorist ideologies, then we will seek advice from Prevent, police or the local authority officer. If there is no evidence of vulnerability to radicalisation then an individual may be referred to other relevant services such as mental health or social services.

Police screening and routes to support, including Channel referrals

• Whether the initial referral went to Prevent police or to a local authority officer, the referral will be passed to the local Prevent police team, who will open it as a case on their Prevent Case Management (PCM) systems. This team operates from within the police, but Prevent systems are separated from other police business and cannot be used in the same way, for example they cannot be searched for DBS checks.
• All referrals are screened by the police to ensure taking any further action on the referral will not interfere with any live investigations.
• The police then make a further assessment of the referral to check that it isn’t Malicious, Misinformed or Misguided (the ‘3M’ check). Many referrals are screened out at this stage. The police ask other safeguarding agencies (panel partners) to provide information.
• The police will complete a Vulnerability Assessment Framework (VAF). If there is a genuine vulnerability to radicalisation the police will refer the individual to Channel.
• There are some cases where Channel is not appropriate, for example if the individual is linked to an ongoing investigation. The police may offer support to the individual in a way that does not interfere with other interests. These are handled separately to Channel.

Review by multi-agency Channel Panel

• The Channel referrals are reviewed by a local multi-agency Channel Panel, which is made up of local safeguarding partners, such as health, mental health, youth services, housing and education, and is chaired by the local authority Channel Panel Chair (CPC). These panels meet approximately every 4 weeks. The referrals are reviewed using the VAF and each case is discussed to assess the risks and identify the necessary support.

Delivery of support package

• If the Channel Panel concludes that support is necessary, a support plan will be put in place. All support plans are tailored to the individual and can include: life skills; careers/educational support; mental health support; and theological mentoring from Home Office approved Channel intervention providers. The Panel monitors the progress with the provider and other safeguarding professionals. All cases are reviewed at 6 and 12 months.
• Some cases may not be suitable for the Channel programme, or they may reject support. Refusal of support does not affect the way the individual is dealt with. Those that refuse support may be referred back to wider Prevent case management who will look for alternative options to support and safeguard the individual.
• In some cases, the Channel Panel may decide that the person in question does have vulnerabilities, but that these are not related to radicalisation. In these circumstances the panel will pass the case to other services - such as mental health - for support. Each case will be reviewed at 6 and 12 months after exiting the Channel programme to ensure no further concerns have been raised.

7. Monitoring and Review

This policy will be monitored annually to review its effectiveness and will be updated in accordance with necessary changes.

Anti-Slavery and Human Trafficking

1. Policy Statement

Dimensions Training Solutions (DTS) maintains relationships with many different organisations in its supply chain, as well as employing large numbers of people. In the light of the general law on employment and human rights, and, more specifically, the Modern Slavery Act 2015, we have reviewed our existing compliance and risk management processes to determine which existing measures are in place, and the further measures that may be required to prevent slavery and human trafficking taking place in any part of our business or in our supply chain.

The policy below underpins our approach, and will be used to inform our Statement on Slavery and Human Trafficking.

DTS expect all who have, or seek to have, a business relationship with DTS to familiarise themselves with our anti-slavery statement and to act in accordance with its contents at all times.

DTS are committed to opposing modern slavery in all its forms and preventing its occurrence by whatever means we can. We demand the same attitude of all who work for us and expect it of all with whom we have business dealings. Our attitude to modern slavery is that of zero tolerance.

2. Aims of the Policy

Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”). Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. This document sets out the policy of DTS (the “Company”) with the aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act.

DTS have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or those of our suppliers.

3. Scope of the Policy

DTS are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and our contracting processes will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. DTS expect our suppliers to hold their own suppliers to the same high standards.

All employees have an obligation to familiarise themselves with our procedures to help in the identification and prevention of modern slavery and to conduct business in a manner such that the opportunity for and incidence of modern slavery is prevented. Adherence to this policy forms part of all employee’s obligations under their contract of employment.

Whilst recognising our statutory obligation to set out the steps we have taken to ensure that modern slavery and human trafficking is not taking place in our supply chains, we acknowledge that we do not control the conduct of individuals and organisations in our supply chains. To underpin our compliance with practical steps, we intend to implement the following measures:

4. Responsibility for the Policy

Ultimate responsibility for the prevention of modern slavery rests with DTS’s Executive Board. The Executive Board of directors have overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations.

Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it’s contents and the issue of modern slavery.

5. Types of Concerns

'Whistleblowing' refers to the disclosure by individuals of suspected malpractice, illegal acts or omissions at work. Examples of the types of concerns that may be raised include:

• You suspect a person acting on behalf of DTS is seeking to exploit another in a way which could amount to modern slavery;
• You suspect that a person acting on behalf of one of our suppliers is seeking to exploit another in a way which could amount to modern slavery;
• You have received an approach from a person acting on behalf of DTS or one of our supply chain partners who has invited you to participate in acts which could result in offences under the Modern Slavery Act 2015 being committed;
• You have information which leads to the rational conclusion that a person acting on behalf of DTS or one of our suppliers is preparing to commit, is committing or has committed an act in contravention of the Modern Slavery Act 2015.

The list is not exhaustive and simply representative of the types of concerns which may be raised.

6. Protection for those raising a concern

DTS aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery, of whatever form, is, or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. The Company will accept and take seriously concerns communicated anonymously.

However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations.

Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against the individual.

7. Raising a concern

7.1. Internal Reporting

As a first step employees should normally raise concerns with their immediate line manager, or contract manager where applicable. However, depending on the seriousness and sensitivity of the issue and the nature of the concern, employees may feel unable to raise the matter with their line manager and in this instance should approach the next level of management. The guiding rule is that employees should address their complaint to the level of management who they believe has no involvement in the matter.

If employees feel unable to raise the matter with their line manager, or their superior, the matter should be raised with one of the designated officers who have responsibility and training in dealing with whistleblowing concerns, namely: the Head of Risk and Assurance or the Head of Investigations using the dedicated and confidential email: wellbeing@dimensionstrainingsolutions.co.uk.

A line manager in receipt of an allegation should refer it to the Head of Risk and Assurance or the Head of Investigations as outlined above.

7.2. External Reporting

This policy has been developed in order to provide employees with the guidance and reassurance they need to raise a concern internally. However, it is recognised that there may be circumstances where employees feel it necessary to raise their concerns outside the business and in these circumstances employees have a number of external avenues open to them.

Public Concern at Work is an independent charity and leading authority on public interest whistleblowing and can provide advice on how to raise a concern.

Public Concern at Work

T: 0207 404 6609
E: whistle@pcaw.co.uk www.pcaw.co.uk

Employees can also raise their concerns with the proper authority (guidance is available from GOV.UK - Blowing the whistle: list of prescribed people and bodies).

Investigating Procedure

Action taken by DTS will depend upon the nature of the concern. Disclosures will be assessed to:

• Determine whether a further investigation should be conducted.
• Determine the form the investigation should take.
• Appoint an investigating officer to undertake the investigation.

If it is decided that an investigation is required, an investigating officer will be appointed who will aim to abide by the following steps:

• Obtain full details and clarifications of the concern.
• Investigate the concern with third parties / witnesses where possible and obtain objective statements.
• Secure all evidence in an admissible format.
• The discloser will, as far as possible, be kept informed of progress and, if appropriate, the final outcome of the investigation.
• Reporting of the findings will depend on the nature of the disclosure.
• If appropriate, a copy of the outcomes will be reported to the Executive Board.
• Confidential records will be maintained for monitoring purposes.

8. Timescales

Investigations will be conducted as speedily as possible whilst having regard to the nature and complexity of the disclosure.

9. Outcomes

Depending on the findings of the investigation, outcomes may vary from no further action to sanctions against perpetrators. Anti-Slavery and Human Trafficking Policy v1 Page 5 of 5

10. Communication and awareness of this policy

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

11. Review

Following its initial adoption, this Anti-Slavery and Human Trafficking Policy will be reviewed by the Company’s Executive Board of Directors on a regular basis (at least annually) and may be amended from time to time. This policy will be used to inform our Statement on Slavery and Human Trafficking which will be published no later than the publication of our 2016 financial results.

Safeguarding and E-Safety/Safe use of IT

Statement of Intent

This policy outlines the general responsibilities and requirements that Dimensions Training Solutions (DTS) expects from members of staff, learners and employees in relation to their online activity and use of technologies during the course of their day-to-day activities on premises (or any premises by its nature associated with DTS) or whilst representing the organisation. This policy is in addition to our Safeguarding and Prevent Policy.

Scope

The policy applies to all members of DTS (including staff, learners, volunteers, community users) who have access to our ICT systems, both on site and off. We will aim to educate all members about e-safety issues and appropriate behaviours so that they can remain safe and legal online.

We understand that the use of technology has become a prominent feature in many safeguarding issues. Child sexual exploitation and radicalisation (amongst others) are often given the platform to manifest, and subsequently inflict harm, through technology. It is our obligation as an effective education provider to educate members in their use of technology and to establish mechanisms to identify, intervene and escalate incidents where appropriate.

Terms

• To provide protection for all learners who come into contact with DTS and make use of technology (such as mobile phones, hand held devices, computers)
• To provide staff, learners and volunteers with guidance on the procedures they must follow in the event that they suspect a learner may be in breach of policy

1. Introduction:

E-safety is defined as being safe from risks to personal safety and wellbeing when using all fixed and mobile devices that allow access to the internet, as well as those that are used to communicate electronically. This includes personal computers, laptops, mobile phones and gaming consoles such as Xbox, PlayStation and Wii. Safeguarding against these risks is not just an ICT responsibility, it is everyone's responsibility and needs to be considered as part of the overall arrangements in place that safeguard and promote the welfare of all members of DTS, learners, staff and stakeholders, particularly those that are vulnerable. Our E-safety Policy has been written by DTS, involving all stakeholders and builds on best practice and government guidance. It relates to the latest version of DfE statutory guidance: "Keeping Children Safe in Education", and E-safety Guidance and Procedures. Cyber-bullying by learners will be treated as seriously as any other type of bullying and will be managed through our Anti-bullying Policy and Behaviour Policy.

2. Understanding the risks of using the Internet and associated devices:

The internet is an essential element in 21st century life and ICT knowledge, now seen as an important life-skill, is vital to access life-long learning and employment. It is also important to recognise that the internet provides many benefits, not just to young people and vulnerable adults, but also to the professional work of staff. E-safety covers the Internet, but it also covers mobile phones and other electronic communications technologies. We know that some adults and young people will use these technologies to harm young people. The harm might range from sending hurtful or abusive texts and emails, to enticing children to engage in sexually harmful conversations or actions online, webcam filming, photography or face-to-face meetings.

There is a "duty of care" for any persons working with young people and educating all members of DTS's staff, learners and stakeholders on the risks and responsibilities and E-safety falls under this duty. It is important that there is a balance between controlling access to the internet and technology and allowing freedom to explore and use these tools to their full potential. This policy aims to be an aid in regulating ICT activity in DTS and provide a good understanding of appropriate ICT use that members of DTS can use as a reference for their conduct online outside of DTS hours. E-safety is a company-wide issue and responsibility. While acknowledging the benefits, it is also important to recognise that the risk to safety and well-being of users is everchanging as technologies develop.

These can be summarised into three key areas as follows:

Content

Exposure to illegal, inappropriate or harmful material. This includes but is not limited to online pornography, violence and hate sites, substance abuse, websites that are pro anorexia/self-harm/suicide.

• Commercial - adverts, spam, sponsorship, personal information
• Aggressive - violent/hateful content
• Sexual - pornographic or unwelcome sexual content
• Values - bias, racism, misleading information or advice

Contact

Being subjected to harmful online interaction with others. This includes but is not limited to grooming, cyber-bullying, identity theft and sharing of passwords.

• Commercial - tracking, harvesting personal information
• Aggressive - being bullied, harassed or stalked
• Sexual - meeting strangers, being groomed
• Values - self-harm, unwelcome persuasions

Conduct

Personal online behaviour that increases the likelihood of, or causes, harm. This covers the disclosure of personal information, health and wellbeing and sexting.

• Commercial - illegal downloading, hacking, gambling, financial scams, terrorism
• Aggressive - bullying or harassing another
• Sexual - creating and uploading inappropriate material, including sexting
• Values - providing misleading information or advice

Much of the material on the internet is published for an adult audience and some is unsuitable for young people. In addition, there is information on weapons, crime, racism and extremism that would be considered inappropriate and restricted elsewhere. It is also known that adults who wish to abuse others may pose as a child/young person/peer to engage with them and then attempt to meet up with them. This process is known as "grooming" and may take place over a period of months using chat rooms, social networking sites, tablets and mobile phones.

Cyberbullying:

Cyberbullying is bullying through the use of communication technology and can take many forms e.g. sending threatening or abusive text messages, e-mails or through messaging within social media websites. This bullying can be either personally or anonymously directed at individuals, making insulting comments about someone on a social networking site or blog or making/sharing derogatory or embarrassing videos of someone via mobile phone or email.

Sexting:

This involves users sending sexually explicit texts in the form of images or video to other young people or adults. These images are often then distributed further without permission, which poses a significant safeguarding risk and places them at risk of further harm.

3. General Principles

DTS recognises that staff and learners have lives outside and can and will make decisions about their own use of social networking sites. To inform these decisions, and for the protection of both staff and learners, this policy is designed to be clear and explicit about appropriate behaviour in the use of social media and electronic communication and DTS's responsibility to its staff and learners to promote E-safety.

Staff/employers obligations:

• Staff should be aware of this policy, as well as the safeguarding policy
• Staff should not "friend" learners on social media platforms, nor should they communicate with those learners outside the realms of their working duty
• Staff should seek the advice of the designated safeguarding lead if they have any concerns about the use of the internet or technology
• Staff should follow the safeguarding reporting process if they have concerns that a learner is a risk of harm (immediate, imminent or future) and follow the Prevent reporting process if they suspect a learner is at risk of radicalisation or extremism (definitions of which can be found in the safeguarding policy document)

Learners' obligations:

• Learners should be aware of this policy and agree to its terms for acceptable use
• Learners should behave online in a manner that is consistent with the following guidelines:
  • Learners are responsible for their behaviour when using the internet/social media/mobile-phones/technology at DTS and their associated premises, including the content they access and the way they conduct themselves
  • Learners will not create or access material that could be considered illegal or offensive. If this happens accidentally, they will report this to a member of staff
  • Learners will not distribute material to other persons via technology that could be considered threatening, offensive, bullying or illegal
  • Learners should not give our their personal information online, or that of anyone else
  • Learners should avoid using their mobile phone during activities

We take the view that all Information posted on websites should be considered as published, permanent and potentially public - even if it is "protected" in some way. Just because something is personal in nature or an individual doesn't want people to know about it does not make it private. Social networks by their nature blur the divide between public and private simply by being networks. Their purpose is to provide simple ways of sharing information as widely as possible and some will make information available to a far wider audience than might be expected or desired.

Seemingly innocent information, photographs, videos, opinions or comments are vulnerable to misrepresentation and unauthorised distribution via the internet.

Therefore DO

1. Assume everything online is permanent and effectively public
2. Make sure you consider who might see anything you post.
3. Write appropriately for your expected audience.
4. Make all staff / learner online interactions meaningful and professional.
5. Consider specifically safety and reputation before posting online.
6. Take responsibility for what you post / distribute online.
7. Use the internet positively for communication, collaboration and learning.
8. Use and maintain privacy settings to protect personal information but do not rely on them.

DON'T

1. Post anything which might damage your own or DTS's reputation
2. Redistribute any material which may harm others in any way.
3. Use the internet to form, or attempt to form, any relationship which would be otherwise inappropriate.
4. Create an online environment which invites others to post harmful content.
5. Post without thinking
6. Post without considering the safeguarding risks.

Education

All learners will receive education regarding the use and potential dangers of social media.

Staff are encouraged to use the resource to update their understanding and ensure they are using best practice. Staff development will be arranged to ensure staff use social media in a professional way. Learners will be advised of the how to use the internet and social media safely through both tutorials.

4. Code of Practice

Staff Conduct

Staff are reminded that their professional responsibilities at DTS require them to act professionally in their social networking and internet activities, and to create a clear distinction between their social and their professional lives. Contact with learners must remain within the boundaries of their professional lives. The guiding principle here is “think before you post” Where staff make use of web-publishing and social networks for professional purposes they are expected to:

• Behave professionally and with integrity
• Adhere to DTS policy guidelines
• Respect their audience
• Promote productive conversations
• Protect and enhance the value of DTS's reputation
• Protect confidential and business sensitive information
• Be personable, add value and encourage responses
• Be proactive in correcting any errors made

Staff must not post comments or any other information on any public forum, website, social networking site or blog:

• that are unsubstantiated and/or negative about DTS, their colleagues, our learners, parents, or customers
• that run counter to DTS's Equality and Diversity, and Safeguarding Policies.
• that recommend or appear to endorse law breaking of any kind
• that give an account of any inappropriate behaviour

Nor should such comments be made in emails sent in an official or professional capacity.

Communications between staff and current or prospective learners should only take place for legitimate, professional reasons. In some cases, there may be a nonprofessional reason for a relationship to exist beyond DTS (e.g. common academic interest / common membership of a club, society or team / family members). In such circumstances social communication may occur. Staff should, however, be aware of the risks involved and use their professional judgment to ensure that this communication is limited appropriately.

A member of staff inviting a current or prospective learner to join a network without any professional purpose or inviting them to "follow" a purely personal profile will be regarded as inappropriate. The risks in this situation are clear and there can be no justification. Where such a situation arises DTS reserves the right to demand an explanation for this action and act accordingly.

Accepting any invitation to "friend", follow or become part of a current or prospective learner's personal network is also considered inappropriate.

We recognise staff may wish to take part in online communities also used by learners. In such cases staff should ensure that personal information is secured. Any staff member contributing under a personal profile is obliged to ensure that minimal personal information is visible under that profile.

If a member of staff is unable to access a social media site due to it being blocked by DTS's network, a request to access this site should be made to the IT Helpdesk who will review access to the site.

Official usage

As a general principle staff should use their DTS contact details or a "professional" profile for communication with current and prospective learners, and ensure that any communication is both professional and necessary.

Email contact with learners, parents and other stakeholders should be channeled through DTS's email system. Staff should use the facility to set up a forwarding email address where access to DTS webmail may present a problem.

Staff should pay particular attention when replying to emails forwarded to a personal account as these will appear to the recipient as having been sent from the personal account.

DTS will continue to develop the use of social media for marketing, communications and curriculum purposes.

Authorised DTS networks (group/page/blog) which exist for a clear professional purpose should be discussed with the Operations Director who will offer advice and guidance on what is acceptable.

Staff creating or participating in authorised networks should do so either anonymously, where this is possible, or under a professional profile.

A professional profile is where a member of staff maintains an online presence explicitly for professional purposes. This profile should minimise any information which could be used to compromise the individual and should not be used to record social activity or personal opinion but may be used to record professional information or opinion. It is important that a professional profile is not added to non-professional networks or linked to the profiles of others except where the connection is professional. This might legitimately include links to learner groups but would be unlikely to include groups of friends / family.

Monitoring

Under certain circumstances DTS may need to monitor staff and learner email communication and use of the internet via DTS internet link. Staff and learners should be aware that all use of the DTS internet link is governed by the Acceptable Use Policy.

We recommend that staff monitor their own online presence, in particular, any material posted by others about them.

If staff become aware of, and / or are concerned about, any critical or unprofessional comments that are posted by colleagues they should draw these initially to the attention of the senior line manager and if necessary the Senior Leadership Team in order that an official response may be posted if appropriate.

It is the responsibility of line managers to monitor staff use of social networks in the workplace. In general, personal use is discouraged particularly where an alert service or other desktop "widget" may interrupt workflow. Professional use should be transparent and any request to view interactions respected.

It is acknowledged that existing and new staff members may already have a significant online presence with membership of complex social-networks. It is the responsibility of staff to consider their existing and ongoing online activity in line with this code of practice. We anticipate that restrictions within this policy may mean that existing members of staff need to change their current practice and recognise that this will take time. For existing staff, it is expected that these adjustments will be concluded within 6 months of the publication of this policy.

Fan Sites Where staff or learners are the subject of groups, pages, sites or "posts" over which they have no control, DTS commits to taking whatever reasonable steps it can to safeguard individuals and to help protect individual reputations along with the reputation of DTS.

5. Learner Conduct

As members of the DTS community, learners must abide by the terms of the Learner Code of Conduct, respecting the rights of fellow learners and staff, as well as the reputation of DTS. They should think carefully about how they express themselves, and bear in mind the need to safeguard themselves. Material posted on the internet can be hard to delete and should, therefore, be considered permanent.

Learners must not post comments on a social networking site or blog, or send text messages:

• that could be viewed as bullying or harassing another member of DTS community
• that are counter to DTS's Equality and Diversity policy or the Learner Code of Conduct
• that explicitly encourages other members of DTS community to break the law
• that are likely to bring DTS into disrepute

Learners should not post photos that they might not wish others to see.

Learners should not invite staff to join social networks or follow purely personal profiles.

Learners will be given guidance on appropriate use of the internet and e-safety through tutorial.

If a learner has cause for concern regarding use of the internet or social networking, they must report the incident immediately to a member of staff. There may be occasions where this will be treated as a safeguarding issue.

6. Associated policies:

This policy must be read in conjunction with the associated policies below:

• Safeguarding
• Data Protection Policy
• Staff Disciplinary Procedures

Any breach of any aspect of this social media policy by staff or learners may result in action being considered under the appropriate disciplinary policy as considered necessary after appropriate investigation. Please see DTS disciplinary policy for more details.

7. Notes / Definitions

Open communication takes place in a public forum which can be viewed by unknown internet users i.e. the general public

Closed communication is where the participants are all known to each other. Most closed communication will be between two individuals (e.g. email exchange) but would also include "friends only" groups or sites with registered members etc.

Public information is that which can be accessed anonymously by internet users who are unknown to the originator.

Private information is that which is only available to a limited, known sub-set of internet users or solely by the owner of the information themselves.

The originator of online content is the individual who first uploads or creates the content using online tools.

Distribution – posting, uploading, adding, or forwarding digital content via electronic, web-based systems (including email) constitutes distribution of that content. A choice to publicly distribute private information is the responsibility of the distributor NOT the originator or the maintainer of the system used to distribute. It is the responsibility of content originators to understand the system they are using and, where control cannot be guaranteed, to amend use of the system accordingly.

Adding content to online systems, other than those designed solely for storage purposes, will be seen as distribution of that content.

Content which is "personal" in nature but made available to a public audience either deliberately or by carelessness will be considered the responsibility of the originator/ distributor of the content (e.g. the photographer NOT the subject of the photograph)

Whilst an initial interaction may be "private", the content of any e-communication with a learner or parent must be considered permanent and de-facto public because there can be no guarantee sought or given that the learner/parent will not redistribute content publicly.

If private information is re-distributed without the consent of the originator this is the responsibility of the distributor. However, where such information is inappropriate it may be necessary for the originator to defend the initial process of distribution which placed it in a vulnerable position.

8. Equality and Diversity

As with all DTS Policies and Procedures due care has been taken to ensure that this policy is appropriate to all employees regardless of gender, race, ethnicity, disability, sexual orientation, marital status, gender identity, religion or age.

The policy will be applied fairly and consistently whilst upholding DTS's commitment to providing equality to all.

If any employee feels that this or any other policy does not meet this aim, please contact the DTS Director of Quality.

Whistleblowing Policy

Policy Statement

Dimensions Training Solutions (DTS) is committed to conducting its business with the highest standards of honesty and integrity and in a responsible and transparent way. However, all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations occurring or to address them when they occur. In line with this commitment, DTS encourages employees and those within the scope of this policy with reasonable suspicions to voice those concerns without fear of reprisal or subsequent discrimination, victimisation, or detriment.

Raising a concern is sometimes referred to as ‘blowing the whistle’, ‘making a disclosure’ or ‘speaking up’ about serious wrongdoing, malpractice, or impropriety including irregularities in the running of the Company, or of the activities of colleagues working within the company.

Aims

The policy is designed to:

• Encourage employees to report suspected wrongdoings as soon as possible, in the knowledge that their concerns will be taken seriously and investigated appropriately, and that their confidentiality will be respected.
• Provide a process for concerns to be raised, investigated and, where appropriate, acted upon.
• Ensure those raising concerns receive a response to their concerns and how to pursue them if they are not satisfied.
• Reassure employees that they can raise genuine concerns in good faith without fear of reprisal.
• Demonstrate the company’s commitment to combating fraud, corruption and malpractice.
• Act as a deterrent to potential perpetrators of misconduct.

Scope

This policy applies to all employees and those working on behalf of DTS including consultants, contractors, and certain agency staff, referred to collectively as ‘employees’ in this policy.

The whistleblowing process does not apply to raising grievances about employees’ terms of employment concerns. The company’s Grievance Policy should be followed in such cases.

Types of Concerns

'Whistleblowing' refers to the disclosure by individuals of suspected malpractice, illegal acts or omissions at work. Examples of the types of concerns that may be raised include:

• Possible criminal activity
• Failure to comply with legal obligations or regulatory requirements
• Possible fraud or irregularities
• Unauthorised use of public funds or other assets
• Improper accounting practices
• Offering, taking or soliciting bribes
• Theft or misuse of property or assets
• Racial, sexual, disability or other discrimination
• Suspicion of radicalisation (*)
• Health and Safety concerns
• Damage or potential damage to the environment
• Data protection or information security breaches
• Unauthorised disclosure of confidential information
• Conduct likely to damage the company’s reputation
• Unethical conduct
• Actions which are intended to conceal any of the above

This list is not exhaustive and simply representative of the types of concerns which may be raised.

(*) As an education provider, DTS has a legal requirement to comply with the Government’s ‘Prevent Strategy’ aimed at preventing radicalisation. We will do this by escalating incidences and concerns using our safeguarding processes and we promote Equality & Diversity and British Values with our learners to help ensure they are integrated into mainstream society and are less vulnerable to radicalisation and extremism.

What is expected of those raising a concern

Employees making a disclosure are expected to:

• Have a reasonable suspicion about the malpractice.
• Have a reasonable belief that the information and any allegation is true.
• Not make the disclosure for personal gain.

Protection for those raising a concern

DTS recognises that the decision to report a concern can be a difficult one to make, not least because of the fear of reprisal. If an employee raises a concern, which in their reasonable belief is in the public interest, it will be treated as a protected disclosure in accordance with the Public Interest Disclosure Act 1998. This provides legal protection to employees against being dismissed or other detriment by their employer as a result of disclosing a concern. DTS has endorsed the provisions of the act so that no member of staff should fear reprisals, bullying or harassment when raising a concern within the scope of this policy.

DTS will not tolerate any harassment or victimisation of the discloser, including informal pressures, and will treat any allegations of this seriously. Where an allegation of harassment or victimisation of a discloser is upheld, this will be dealt with in accordance with the company's disciplinary procedures.

Confidentiality

The company encourages employees to put their name to any disclosures they make. Concerns expressed anonymously are much less credible and are more difficult to investigate, but they may be considered at the discretion of the company. In exercising this discretion, the factors taken into account will include:

• The seriousness of the issues raised.
• The credibility of the concern.
• The likelihood of confirming the allegations from attributable sources.

All concerns will be dealt with confidentially. It is also imperative that the concern is raised appropriately and discretion and confidentiality is maintained by those raising the concern.

Malicious or fabricated allegations

If an employee makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that employee. However, if an employee makes a malicious or fabricated allegation disciplinary action may be taken.

Raising a concern

Internal reporting

As a first step employees should normally raise concerns with their immediate line manager. However, depending on the seriousness and sensitivity of the issue and the nature of the concern, employees may feel unable to raise the matter with their line manager and in this instance should approach the next level of management. The guiding rule is that employees should address their complaint to the level of management who they believe has no involvement in the matter.

If employees feel unable to raise the matter with their line manager, the matter should be raised with Director of Quality who has responsibility and training in dealing with whistleblowing concerns. A line manager in receipt of an allegation should refer it to the Director of Quality as outlined above.

External Reporting

This policy has been developed in order to provide employees with the guidance and reassurance they need to raise a concern internally. However, it is recognised that there may be circumstances where employees feel it necessary to raise their concerns outside the business and in these circumstances employees have a number of external avenues open to them.

Public Concern at Work is an independent charity and leading authority on public interest whistleblowing and can provide advice on how to raise a concern.

Public Concern at Work

T: 0207 404 6609
E: whistle@pcaw.co.uk www.pcaw.co.uk

Employees can also raise their concerns with the proper authority (guidance is available from GOV.UK - Blowing the whistle: list of prescribed people and bodies). The list includes: Environment Agency, Financial Services Agency, HR Revenue and Customs, Information Commissioner, Health & Safety Executive and Pensions Regulator.

Investigating Procedure

Action taken will depend upon the nature of the concern. Disclosures will be assessed to:

• Determine whether a further investigation should be conducted.
• Determine the form the investigation should take.
• Appoint an investigating officer to undertake the investigation.

If it is decided that an investigation is required, an investigating officer will be appointed who will aim to abide by the following steps:

• Obtain full details and clarifications of the concern.
• Inform the employee against whom the complaint has been made as soon as possible.
• Where the matter relates to a fraud, financial malpractice, bribery, corruption or criminal activity, DTS reserves the right to withhold the nature of the enquiry from the employee, until all evidence has been secured.
• Disclosures relating to matters of fraud, bribery, corruption, financial malpractice or impropriety will be investigated in accordance with DTS Anti-fraud, Bribery and Corruption Policy.
• Investigate the concern with third parties / witnesses where possible and obtain objective statements.
• Secure all evidence in an admissible format.
• The discloser will, as far as possible, be kept informed of progress and, if appropriate, the final outcome of the investigation.
• Reporting of the findings will depend on the nature of the disclosure.
• Confidential records will be maintained for monitoring purposes.

Timescales

Investigations will be conducted as speedily as possible whilst having regard to the nature and complexity of the disclosure.

Outcomes

Depending on the findings of the investigation, outcomes may vary from no further action at all to sanctions against perpetrators. Such sanctions may range from a verbal warning to dismissal without notice in cases of gross misconduct and criminal prosecution. Offences committed as determined by the Bribery Act 2010 carry severe penalties including unlimited fine or up to 10 years imprisonment.

Monitoring and review

This policy will be monitored annually to review its effectiveness and will be updated in accordance with necessary changes.

Health and Safety Policy

Dimensions Training Solutions (DTS) shall endeavour to protect and promote, as far as is reasonably practicable, the health, safety and welfare of all its employees, learners, clients, visitors and others who may be affected by its work activities in accordance with the requirements of the Health and Safety at Work Act 1974, and any relevant, subsequent legislation.

In particular DTS health and safety objectives, where it is reasonably practicable, are to:

• Ensure all employees are competent to undertake their tasks, and to provide them with relevant and adequate training
• Provide and maintain a safe working environment, along with suitable welfare facilities
• Provide adequate control of the health and safety risks arising from our work activities
• Consult with our employees on matters affecting their health and safety
• Provide suitable information, instruction, training and supervision to enable employees to perform their work safely and to understand any risks associated with their activities and the control measures in place
• To provide and maintain work equipment, safe and free from risks to health, by identification, elimination or control of foreseeable hazards in the workplace
• Ensure that suitable arrangements are in place for the safe use, handling, storage and transport of articles and substances for use at work
• Ensure the availability of information on articles and substances used at work, so that precautions can be taken, if necessary, to reduce any risks to health
• Ensure there is a sufficient Health and Safety budget
• Prevent accidents and cases of work-related ill-health
• Undertake risk assessments on a regular basis
• Review and revise the Health and Safety Policy / Statement on a yearly basis.

Name:	Wayne Janse Van Rensburg
Position:	Group Chief Executive
Signature:
Date:	08 October 2018
Review Date:	31 October 2019

Aim

This policy has been produced to enable DTS to comply with its legal duties and responsibilities under the Health and Safety at Work Act 1974 and all relevant statutory provisions.

Scope

This policy statement applies to all employees, locations and activities and takes account of the wide range of health and safety legislation under which our company operates.

It is the policy of DTS to ensure the health, safety and welfare of all employees at DTS premises and all other places of work and activity and to promote awareness of health and safety among employees. We seek to provide and maintain safe and healthy working conditions, equipment and systems of work for all staff, visitors and learners, and to provide such information, training and supervision needed for this purpose.

It is the responsibility of all management to implement the health and safety policy effectively. However, the success of this policy largely rests with all staff at all levels, which have both a moral and legal responsibility to ensure that nothing is done to endanger themselves or others whilst at work.

In addition, colleagues should co-operate with their managers and comply with regulations and procedures for safe and healthy working by being vigilant, having awareness of the Health and Safety Policies and Procedures, and feeding back to line managers any concerns they may have regarding health and safety of their environment.

Senior colleagues and Managers must make themselves familiar with the policy and ensure that their employees are aware of the policy, which can be accessed on the Intranet.

Where non-compliance is being considered by an enforcement authority, the Quality Director must be consulted.

Responsible Persons

The Group Chief Executive is the person responsible for overall Health and Safety.

The Quality Director will have day to day responsibility for ensuring that this policy is implemented, ensuring that any activities undertaken by DTS will be undertaken in a safe manner to safeguard all employees, learners, clients and others such as visitors, etc.

The Quality Director shall monitor the overall effectiveness of the Health and Safety Policy, reviewing the policy annually and revising it if necessary.

The Quality Director will provide a quarterly health, safety and environment performance report that will include a review of all accidents/Incidents including all relevant data.

The Board of Directors

The Board will set the direction for effective health and safety management. Board members will establish a health and safety policy that is much more than a document. The Board will ensure this Health and Safety Policy is an integral part of the Companies culture, of its values and performance standards.

All Board members will take the lead in ensuring:

• The communication of health and safety duties and benefits throughout the organisation.
• Full support of the development of policies and procedures to avoid health and safety problems.
• The provision of sufficient budget and resources to ensure the full implementation of this Health and Safety Policy.
• Prompt response from the Board where difficulties arise, or new risks are introduced.
• Health and Safety is properly addressed.
• The Board own and understand the key issues involved.
• The Board decide how best to communicate, promote and champion health and safety.

All Levels of Management:

All levels of Management are responsible for ensuring that they have read and understood the Health and Safety Policy, and that they and their teams are fully compliant with the Health and Safety requirements under the Policy.

These responsibilities include:

• Ensuring that all new employees are fully inducted into the Company using the relevant Induction form.
• Ensuring that existing employees have also been formally inducted using the relevant Induction form. This includes relocation to new / existing premises.
• Ensuring that all new / existing employees have undertaken the relevant Health and Safety Training as per their Job specification.
• Ensuring that employees (where applicable) are using the latest version of the
• Workplace Suitability Risk Assessment and that they are being completed correctly.
• Ensuring all accidents are reported on the relevant accident report form and the form sent immediately to wellbeing@dimensionstrainingsolutions.co.uk
• Ensuring that all New and Expectant Mothers are assessed as per the new and expectant mother’s procedures.

Specifically, it is the responsibility of any Managers with responsibility for a centre/office to ensure

• The Centre has a Health, Safety and Environment Noticeboard containing all relevant information as described by the Head of Health, Safety and Environment.
• The Health and Safety File is in place and updated regularly.
• The Fire Log Book is in place and is updated as required.
• There are at least two Fire Wardens within the Centre, and that they have been trained and their names are displayed on the Health, Safety and Environment Notice board.
• There is sufficient First Aid Provision within the Centre, as per the First Aid Procedure, that they have been trained, and their names are displayed on the Health Safety and Environment Noticeboard.
• The First Aid kits are maintained on a monthly basis by a designated First Aider / Emergency First Aid at Work.
• Any Personal Emergency Evacuation Plans (PEEPS) are undertaken, and relevant Staff informed.
• Any broken / unwanted equipment is taken out of service and the relevant persons informed.
• Any proposed changes within the Centre/Office with regard to equipment, layout etc. are approved by the relevant Director prior to implementation.
• All Centre/Office Audits/checklists are completed and submitted by the relevant deadline.
• The Centre/Office Risk Assessment is carried out, actions implemented and reviewed as required and reviewed at least annually.
• A Young Person’s Risk assessment is to be undertaken on all young persons (under 18), and relevant Staff informed of any actions.

All Employees:

All employees must make themselves familiar with and conform to the Health and Safety Policy, and shall:

• Take reasonable care for the health and safety of themselves and others.
• Observe any safety rules or instructions devised for their health and safety, including the wearing of personal protective equipment and co-operate fully with management in the investigation of accidents, incidents and near misses.
• Not interfere with or mis-use anything provided in the interest of health and safety. (I.e. block fire exits, prop open fire doors, remove fire extinguishers etc).
• Report all hazards, potential dangers, accidents and damage that may occur in the course of their work to their immediate Line Manager without delay.
• Use and look after all safety / protective equipment as supplied, reporting any defects to their Line Manager.
• To suggest / recommend any suitable, and relevant Health and Safety and Environment improvements.
• Work safely, not removing any device provided for the purpose of ensuring the health and safety of employees.
• Ensure that their work area is kept clean, tidy and free from hazards that cause slips, trips or falls at all times.
• Take responsibility for any visitors, clients, learners, contractors etc they have on the premises. In the event of an evacuation, employees should escort them calmly and quickly to the allocated assembly point.
• Evacuate the building immediately and proceed to the assembly point in the event of an evacuation

Visitors, Clients, Learners, Contractors Undertaking Work and Others

All visitors, clients, learners, contractors, contractor’s mates and others, invited or expected to work on DTS premises are required to fully comply with this Health and Safety Policy and any other specific rules and conditions applicable to them throughout their period of engagement or visit.

All visitors / clients / learners / contractors / contractors mates and others, whilst on the premises, shall:

• Comply with all relevant health and safety legislation appropriate to their area of work activity / equipment / substance use and service provided.
• Comply and co-operate fully with all instructions, safe working practices and guidance as supplied by DTS.
• Ensure co-operation and co-ordination with DTS, providing any health and safety documentation requested.
• Report to the First Aider / Emergency First Aid at Worker (EFAW) any incident, injury or potentially dangerous situation which could cause injury or ill health.
• Ensure that any protective equipment is worn and enforced at all times.
• Ensure sufficient information, instruction, training and supportive supervision is provided so that work can be conducted in a safe and healthy manner, without risk to either themselves, employees or others that may be affected.

Delivery Partners / Delivery Sub-Contractors

All Delivery Partners / Sub - contractors working on behalf of DTS are requested to fully comply with this Health and Safety Policy and any other specific rules and conditions applicable to them throughout their period of contract /programme.

All Delivery Partners / Sub - contractors are required to:

• Complete a Due Diligence form, both before the initial contract and on an annual basis, submitting all relevant health and safety documentation required as appropriate to their area of work activity / equipment / substance use and service provided.
• Comply and co-operate fully with all instructions, safe working practices and guidance as supplied by DTS / as per contractual requirements.
• Ensure co-operation and co-ordination with DTS, submitting any additional health and safety documentation requested.
• Report to the Supply Chain/Partnership Manager / other, immediately any incident, injury or potentially dangerous situation, which could cause injury or ill health to the learner / client DTS employees.
• Ensure that any protective equipment is worn and enforced at all times, where applicable, and where RPE is required that all the appropriate staff have undergone the required face fit tests.
• Ensure sufficient information, instruction, training and supportive supervision is provided so that work can be conducted in a safe and healthy manner, without risk to either themselves, clients, learners, employees or others that may be affected.
• Ensure that clients, learners, employees or others that may be affected are aware of any relevant site evacuation procedures and first aid arrangements.

First Aiders / Emergency First Aid at Work (EFAW)

The names of the current First Aiders / EFAW’s are displayed on all sites, the First Aiders / EFAW’s responsibilities are to:

• Administer limited first aid treatment to those in need.
• Assist the emergency services if called upon to do so.
• After treating the patient, assist the line manager in completing the accident report.
• Ensure the accident report form is sent immediately to the Quality Director wellbeing@dimensionstrainingsolutions.co.uk
• Maintain the first aid kit on a monthly basis.

Fire Wardens

All designated Fire Wardens will undergo the necessary training to ensure they can competently carry out their duties and the names of the current Fire Wardens will be displayed on all sites.

The Fire Wardens responsibilities are to:

• Help in the smooth evacuation of persons on the premises in an emergency situation to the Fire Assembly Point.
• Assist (where applicable) in testing the Call Points within the Centre.
• Assist (where applicable) in testing the disabled toilet emergency alarm.
• Assist with any Personal Emergency Evacuation Plans (PEEPS).
• Complete (where applicable) the Fire Log Book.
• Complete any other duties specified in the Fire Safety Procedure.

Young Persons

DTS have a particular duty of care towards any employed 16-18-year-old. Each young person will fully comply with all the employees’ general responsibilities, and shall:

• Comply with the requirements of the individual ‘Young Persons’ Risk Assessment.
• Comply fully with this Policy and any other Health and Safety guidance given by their Line Manager.
• When in doubt, ask for advice from their Line Manager.

New and Expectant Mothers

In order for DTS to fulfil its legal obligation and in line with individuals own legal obligations, it is the responsibility of any member of staff who is pregnant to notify their Line Manager immediately to ensure appropriate support can be provided.

This will enable an appropriate series of risk assessments to be carried out throughout the pregnancy, safeguarding the employee and their unborn baby from any potential harm. The Line Manager must ensure HR are also notified. Upon the return to work of the New Mother, further assessments will be undertaken.

Risk Assessments

A system for risk assessment is in place, including guidance for managers and a generic risk assessment template that can be used for any circumstance not outlined below.

Centre specific Risk Assessments will be carried out by the Manager responsible for the centre using the Centre Generic Risk Assessment. All risk assessments will be reviewed on a yearly basis or when the work activity changes, whichever is the soonest.

A driving risk assessment will be produced and cascaded down to all staff driving on company business by their Line Manager.

A Lone Worker risk assessment will be produced and cascaded down to staff and specific measures implemented by the relevant Line Manager.

A generic COSHH assessment will be produced and used to produce a specific COSHH assessment by anyone using substances that come under the COSHH Regulations. This will be carried out in consultation with the Business Development Director.

Health and Safety Induction and Training

All new employees, learners, clients agency workers, contractors etc. expected to work on or access DTS premises will receive full information on Fire / Emergency procedures by the relevant responsible person.

The Line Managers are always responsible for the Safety Induction of new employees

A series of mandatory health and safety training is in place and are completed at regular intervals depending on the subject, a training needs analysis is also in place which identifies the training required for each individual role.

Accident/Incident/Near Miss Reporting and Investigation

All accidents/incidents and near misses, however slight, must be reported to the Line Manager.

It is the responsibility of all line managers to ensure they have read and understand the Accident/Incident reporting procedures and report all relevant incidents to the Quality Director within 24 hours.

DTS is under a legal obligation to report certain accidents / incidents to the enforcing authority. Some of these accidents must be reported immediately. Therefore, Quality Director must be made aware of the nature of such accidents / incidents and will liaise with the relevant authorities.

All Managers are made aware of their responsibilities to liaise immediately after a RIDDOR type accident / incident with the Quality Director.

Where appropriate, the scene of any serious accident / incident, as defined under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations, (RIDDOR), must remain undisturbed until the accident has been fully investigated. The Quality Director will ensure that full details of the scene of the accident/incident are recorded and witness statements taken and recorded without delay.

Any hazards identified must be reported immediately to the employees Line Manager.

First Aid

First Aid provision is available on all DTS sites.

All First Aid provision have access to a First Aid kit.

Should an accident occur, the First Aid provision must be contacted immediately.

Fire Discovery / Emergency Evacuation Procedure

Whether on DTS or any other premises colleagues must make themselves aware of the fire safety procedures and in the event of discovering a fire raise the alarm immediately.

Leave calmly by the nearest exit / escape route and proceed to your designated assembly point.

DO NOT ATTEMPT TO TACKLE THE FIRE UNLESS YOU HAVE BEEN TRAINED AND IT IS SAFE TO DO SO. UNDER NO CIRCUMSTANCES PUT YOURSELF AT PERSONAL RISK.

Do not re-enter the building until you have been told it is safe to do so by the most senior person in charge. (Senior Line Manager / Senior Fire Officer)

Escape routes should be kept clear at all times. If a route becomes blocked, it should be cleared of any obstructions immediately and your Line Manager is to be informed.

Employees are to be aware of the location of the fire extinguishers. Fire extinguishers are maintained annually.

Smoking

Smoking is only permitted (including electronic cigarettes) in designated areas. All colleagues must read and understand the No Smoking Policy. E-cigarette chargers are not permitted to be used within any premises and will be deemed a disciplinary offence if anyone is seen to be charging a battery / device.

Consultation with Employees

All employees, at any time, can approach their Line Manager, Senior Manager or Quality Director with a legitimate Health and Safety concern or query.

If any serious Health and Safety concerns arise, affected employees will be informed immediately and the relevant course of action taken.

All employees will be consulted and updated with matters pertaining to Health and Safety using a variety of communication systems and publications.

Information, Instruction and Supervision

The Health and Safety Law poster is displayed on all sites and the Health and Safety Law leaflet issued to all new employees.

All employees will receive the Health, Safety and Environment Leaflet.

All Health and Safety information is displayed / made available in all centres/Offices. Supervision of young workers will be arranged / undertaken / monitored by the Line Manager.

The Health and Safety Policy Statement is displayed on all sites. The Health and Safety Policy is available to all and can be found on the Intranet.

Competency for Tasks and Training

Task specific training will be arranged by the Line Manager.

All training will be identified, arranged and monitored by the Line Manager. Training records / copies of training certificates must be kept.

Safe Plant and Equipment

All plant and equipment requiring maintenance will be maintained appropriately. Any faults with / disused equipment should be reported to Head Office.

Electrical Equipment

DTS shall arrange regular inspection of portable appliance equipment, which will be undertaken by external, competent personnel.

Employees are not to bring personal electrical equipment into the Company without written prior permission from their Line Manager.

Safe Handling and Use of Substances

DTS is responsible for identifying and controlling substances under COSHH and communicating this information to the employees who would be using the substance. COSHH assessments will be undertaken before any hazardous substance is used.

Personal Protective Equipment (PPE)

PPE will be freely issued to employees as required.

The Line Manager will ensure that the correct P.P.E is available to employees, that it is worn and kept in good condition and replaced as necessary.

Waste Disposal

All waste (including items that fall under the Waste Electrical and Electronic Equipment Regulations (WEEE)) will be disposed of in accordance with the Duty of Care imposed by the Environmental Protection Act, any other relevant legislation and in accordance with the DTS Environmental Policy.

Housekeeping and Storage

All employees are to ensure that good housekeeping practices are maintained within their working area. Line Managers are responsible for ensuring this is carried out.

All goods, equipment etc., must be stored in such a way as not to cause a hazard or harm to any employee, client, learner or visitor, in line with the manufacturers’ guidelines / data sheets where appropriate.

Restricted Access

All areas that are deemed out of bounds will not be accessed by any unauthorised employees, clients, learners or visitors.

Visitors to DTS premises

Visited employees are responsible for the health, safety and welfare of their own visitor(s) on the DTS premises. As such, the visitor should be made aware of:

• The signing in / out procedure
• Location of fire routes, fire exits and their assembly point.
• Any hazards they may encounter during their stay.
• Any safety rules they must follow if they need to carry out work on the premises.

In the event of an emergency evacuation, the employee is responsible for their visitor(s), and must ensure that they are escorted to the fire assembly point. If the visitor is missing, the fire service / person in charge should be notified immediately.

Contractors Working on DTS Premises

All works planned and carried out must meet the requirements of the Construction, Design Management Regulations 2015 (CDM 15). All contractors wishing to work on the premises of DTS are required to adhere to the following safety rules:

• Contractors are responsible for providing their own First Aid facilities.
• Contractors are responsible for ensuring that any additional person working for them are fully compliant with the Health and Safety Policy of DTS, are competent, work in a safe manner and do not endanger themselves or others whilst undertaking the work activity.
• All accidents must be reported to DTS First Aid Provision immediately. The area of any serious accident must be undisturbed until it is investigated by the Line Manager unless it poses further serious or imminent danger.
• Smoking is only permitted in designated areas, including the use of e cigarettes on all DTS sites. Contractors wishing to smoke must only do so within these defined areas.
• Contractors are required to adhere to the Health and Safety Policy of DTS. Failure to comply may result in the Contractor being asked to leave the premises.
• The Contractor will provide DTS with their Health and Safety Policy, insurance, risk assessments, and method statements and all documentation to comply with CDM 15 appertaining to the work undertaken, prior to work commencing.
• Under certain working conditions, a Permit to Work is required. These will be issued by the Business Development Director and must be duly completed and adhered to.
• The Contractor is to supply DTS with a Safety Data sheet and COSHH assessment for any hazardous substance that is to be brought onto the premises of DTS, prior to the work commencing.

Young Persons (16-18 yrs.)

A risk assessment will be carried out on the proposed activities of the employed young person. This assessment will take into account the inexperience of the young person, their lack of awareness, maturity and potential risks in their working environment.

Young persons will be provided with full training, information and supervision.

New and Expectant Mothers

A risk assessment will be carried out within one week of the employee advising DTS that they are pregnant.

Further reviews will be carried out when required, up to a maximum of a two-monthly basis.

Should a pregnant employee / new Mother have specific requirements, these can be discussed with their Line Manager or Shared Services.

Welfare Facilities

A self-service kitchen area is available for use by employees, and in some centres/Offices, learners and clients.

Toilet facilities are provided.

Intoxicants and Drug Abuse

DTS may refuse admission to the premises of any employee judged to be incapable of performing his / her duties as a result of intoxicants or drugs. The consequences of which may lead to disciplinary action.

If an employee’s doctor has prescribed drugs, which may influence their ability to perform their duties, then they are required to inform their Line Manager immediately, before commencement of work.

Display Screen Equipment (DSE)

All employees are deemed as ‘Users’ under the Display Screen Equipment Regulations.

Mandatory DSE training is undertaken, complete with a self-assessment at the end of the training and is part of the Safety Induction.

Under the display Screen Equipment Regulations, Reg 5, an employer shall ensure his employee is provided with an appropriate eye and eyesight test where the employee requests one. DTS have appropriate systems in place to accommodate this provision should it be required.

Manual Handling

Mandatory Manual Handling training is undertaken and is part of the Safety Induction.

The Line Manager can be approached should employees have any specific queries about safe lifting.

Employees are to use equipment provided by DTS that will reduce the risk of injury from manual handling.

Use of Mobile Phones Whilst Driving

It is against the Law for anyone to use a handheld mobile phone whilst driving a vehicle on the road.

The use of mobile phones whilst driving is covered in the Driving Policy.

Any employee found to be using a handheld mobile phone whilst driving a company vehicle will be liable to disciplinary action. The use of hands-free mobiles is also not allowed under the DTS Driving Policy.

Employees Using Company Vehicles / Driving on Company Business

All employees are reminded that when using a company vehicle / own vehicle they are in charge of potentially dangerous equipment.

Care should be taken to always drive in a safe manner, taking into consideration other road users, pedestrians and speed limits.

Dangerous or reckless driving that is brought to the attention of the Management may result in disciplinary action.

Legionella

DTS have a duty of care to all employees, visitors and others who may come into contact with our work activity.

All relevant centres/offices that may be at risk from legionella will be identified and risk assessments carried out and any remedial works completed by suitably qualified contractors.

Asbestos

DTS have a duty of care to all contractors who may work on any of its premises, regardless of leasing or owning the property. Therefore, all premises will have at least a management type asbestos survey in place and where appropriate will have a refurbishment or demolition survey carried out which will be available for all contractors at each of the companies sites.

Any asbestos found on our premises will be dealt with, where necessary, by accredited specialist contractors.

There is in place a comprehensive procedure and management plan for the management of asbestos.

Stress at Work

DTS recognises that excessive stress can create a risk to the health and safety of individuals. Every effort will be made to identify and minimize stress caused in the work place, as far as is reasonably practicable.

Equality and Diversity

DTS is committed to ensuring that all employees, learners, clients, contractors and visitors are treated fairly and justly without prejudice, regardless of gender, race, colour, nationality, ethnic or national origin, religion, disability, marital status, age or sexual orientation. Further be found in our Equality and Diversity Policy.

Harassment

DTS declares itself opposed to harassment in any form. The experience of harassment is acknowledged as valid grounds for an employee to make a complaint under the grievance procedure.

DTS will not condone the harassment of any employee within the Company whether these acts are committed by customers, colleagues or others. The Company also does not condone any acts of harassment by employees against fellow colleagues.

Individuals suspected of harassment will be liable to disciplinary action.

Any acts of harassment should be reported to the Line Manager immediately. Further details can be found in the Dignity at Work Policy.

Security Incident

All security precautions are the responsibility of the Line Manager.

Employees are to be aware of the security procedures should an incident take place and should not be fooled into complacency. At all times observe security rules to minimise the possibility of an incident.

Organised Trips for Learners / Clients

All organised trips and visits need thorough planning and organisation. Before taking learners / clients out on a trip DTS will carry out a full written risk assessment to reduce the risk of harm.

Exhibitions

All exhibitions will be thoroughly planned and organised. A Risk Assessment should always be carried out. Should there be any additional requirements, these are to be communicated to the Head of Health, Safety and Environment.

Health and Safety Inspections and Audits

Regular inspections and audits are carried out on DTS premises. Both Management and employees are encouraged to conduct a visual Health and Safety inspection on a daily basis.

Peripatetic Employees and Remote/Lone Working

DTS recognises that during the course of their work, it may be essential for employees to work alone. This may occur as a result of employees arriving to work early or staying late to finish a piece of essential work, travelling for work purposes, using outreach locations, undertaking assessment or sales activities off site or working alone in a centre/office.

Most lone working occurs in normal business hours but occasionally some employees will undertake lone working in the late evening, early in the morning or at the weekend.

DTS is committed to providing a safe working environment for all employees including our peripatetic workforce who may travel within a region, nationwide and to various industries and locations. DTS have a peripatetic workforce and whilst it is not possible to eliminate this or lone working, the risks will be managed through a risk based, preventative approach, and the minimisation of scenarios that might lead to harm.

Noise

DTS activities do not generally involve noise above normally accepted levels, however some colleagues may visit other employer’s premises where the noise levels are high, therefore information, training advice and guidance will be provided where necessary.

Homeworking/Remote Working

The work carried out at home is going to be low-risk, office-type work. Home workers are defined as those who use their home as their office or place of work for the majority of their time. Remote workers are defined as those whose work involves being away from the home base for the majority of the time.

Home working risk assessments will be carried out, this policy and all associated policies and procedures will fully apply to all home/remote workers.

Learner Health and Safety

DTS are committed to ensuring learners are safe and a provision of high quality learning is delivered.

A “safe learner” will, through the quality of their learning experience:

• Gain an understanding of the importance of health and safety.
• Understand how hazards are identified, risks are assessed and the principles of control measures.
• Develop a set of safe behaviours, so that they play an active part in the process and acquire practical, transferable skills from their experience.

We expect colleagues, learners and other employers to share this commitment by complying with our policies and, where appropriate, our procedures and to understand that they too have legal and moral obligations to themselves and to one another.

All workplaces will have the appropriate level of health and safety check and ongoing monitoring carried out through the Workplace Suitability Risk Assessment Process.

Related Documents

Health and Safety Policy Statement

Dignity at Work Policy

Equality and Diversity Policy

Safeguarding Policy

Monitoring and Review

This policy will be monitored annually to review its effectiveness and will be updated in accordance with necessary changes.

Customer Queries and Complaints

Please tell us what you think!

We welcome feedback and complaints from all of our customers or anyone who has been involved with DTS.

Our commitment to handle customer contacts

At DTS we are committed to handling all types of contacts by our customers quickly, accurately, and fairly.

We aim to fully resolve any concerns or problems you might have and if there is anything we cannot resolve or put right straight away we will explain why and say what we can do.

We recognise that feedback from customers is vital in helping us to further improve the services we offer.

We therefore record and analyse the information you give us to ensure that we get to the root cause of any issues you might have.

This policy is applicable to all DTS customers across our various types of provision and sets out how to contact us, how we will handle your contact, how quickly we will respond, and gives full details of our query / complaint handling process.

How to Contact Us

If you are a DTS customer the quickest and way to get a question answered or to resolve a concern is usually to contact your tutor, trainer-assessor, or centre manager.

If you are not currently a DTS customer, or if you are unable to resolve your query via your tutor / trainer-assessor / centre manager, or via our help section you can:

• Call us on 0114 291 5000
  (Our helpline is open Monday - Friday 9am-5pm) Saturday and Sunday: Closed
• Contact us online by completing a short form.
• You can also email us at improve@dimensionstrainingsolutions.co.uk
• Write to us at DTS, Dearing House, 1 Young Street, Sheffield, S1 4UP

What we need to know from you

For us to be able to handle your query effectively we will need the following information when you contact us:

• Your name & location
• What type of programme you are undertaking with DTS
• Your user name (if applicable)
• Full details of what your query or concern is
• The reference number for the query if you are contacting us about an ongoing issue

If you want to remain anonymous then we will still try to deal with your query though it might not always be possible and we will tell you as to what we can and can’t do.

How we will deal with your query or complaint

STAGE 1

Advise the DTS staff member you work most closely with about your query or complaint and give them the chance to resolve the matter. If you’re unhappy with the outcome, or with how long it is taking, or if you think it is not appropriate to raise the issue with them go to Stage 2.

STAGE 2

Contact us via any of the means described in the ‘how to contact us’ section of this policy. We will try to give you an answer straight away, and if we can’t we will work with an appropriate subject expert or operational DTS manager. You will receive an update or resolution within 5 working days.*

*this may be longer over the Christmas/New Year period

STAGE 3

If you remain unhappy with the outcome of your query or complaint you must the put all of your concerns in writing and send a letter to DTS complaints (stage 3), 3rd Floor, Dearing House, 1 Young Street, Sheffield, S1 4UP. The matter will then be independently investigated by the Quality Board. They will look at how your query or complaint was investigated, the response you received, and will speak to the people involved. A reply will be sent within 10 working days of receipt.

How we will deal with your query or complaint

There are some exceptions to this process, in which you should go straight to Stage 3. These are:

Discrimination based on:

• age
• sex
• race, religion or belief
• sexual orientation
• disability
• pregnancy or maternity
• marriage or civil partnership
• gender reassignment

The government’s counter terrorism strategy:

• stopping a terrorist attack that you may have become aware of
• stopping people becoming terrorists, if you are concerned about someone who may be in this situation and wish to make a complaint

Any of the following, relating to yourself or to another person:

• physical abuse
• sexual abuse or inappropriate conduct
• emotional or psychological abuse, or bullying
• financial abuse

External query / complaint review

Stage 3 is the final stage of our internal process. If after following the stages you are still unhappy with the outcome of your query or complaint we will advise you of any third parties you can pursue it with. This will usually depend on the type of learning you have been doing.

For funded learners the Education Skills Funding Agency (ESFA) will investigate complaints if the DTS process has been concluded. The ESFA policy can be found at: https://www.gov.uk/government/publications/sfa-complaints-procedure-about-providers.

Customers undertaking programmes funded by the Department of Work and Pensions (DWP) can go to the Independent Case Examiner (ICE) if they are not happy with the outcome of their query or complaint once the DTS process has been concluded. Further details can be found at: https://www.gov.uk/complain-independent-case-examiner.

Customers under programmes funded by Skills Development Scotland can contact SDS.

Learners or customers undertaking programmes funded by their local authority can complain directly to this authority. If you are unsure who funds your DTS programme, have received a response to your stage 4 complaint and wish to take the matter further, please contact the helpline and quote your reference number to find out who funded the programme.

Data Protection/General Data Protection Regulation (GDPR) Policy

1. Introduction

This policy is applicable to Dimensions Training Solutions Limited trading as DTS.

We must protect personal and confidential data to both comply with the law and to prove to clients, stakeholders and customers that we respect their information and/or their privacy. We are committed to all aspects of GDPR and aim to fulfil all our legal obligations, including under the GDPR regulation.

This Policy sets out how DTS commits to dealing with personal data, including personal and personal sensitive data relating to employees (i.e. personnel files) and claimants.

This Policy will reflect the prevailing laws, regulations and corporate policies. Up-to-date revisions of this Policy will be available on the company intranet.

1.1 Notification

Organisations who process personal data must register with the Information Commissioner’s Office (ICO), the regulator for the DPA. Our notification tells the ICO, and data subjects, about the types of information we process, giving descriptions and reasons for the processing. Our registration reference is 00010475015 (Dimensions Training Solutions Ltd) and is renewed annually.

DTS may not always be the Data Controller in relation to the processing of personal data and may be a Data Processor on behalf of another organisation. In these circumstances, DTS will process personal data in line with the wishes of the Data Controller and will at all times aim to comply with the GDPR and otherwise in line with this Policy.

1.2 Data Protection Principles under GDPR

The GDPR outlines the following principles to follow to ensure compliance with the regulation. Personal data must be:

Lawfulness, fairness and transparency	Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject
Purpose limitation	Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
Data minimisation	Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
Accuracy	Personal data shall be accurate and, where necessary, kept up to date
Storage limitation	Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed
Integrity and confidentiality	Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures
Accountability	The controller shall be responsible for, and be able to demonstrate compliance with the GDPR

These principles apply equally to personal data stored physically (for example, in paper files) and electronically.

1.3 Other relevant privacy legislation

• Human Rights Act 1998
• Privacy & Electronic Communications Regulations 2003
• Freedom of Information Act 2000

2. Scope

This Policy applies to all employees and representatives of DTS, including all contractors, temporary workers, partner organisations and volunteers.

2.1 Supporting Documents

This Policy is supported by more detailed policies, process / procedures, guidelines, schedules and supporting documents. These include but are not limited to those documents listed in Information Security Framework.

3. Responsibilities

Directors	All Directors have a duty to ensure that their directorates comply with legislation affecting the handling of personal data and the supporting regulations and codes.
Data Protection Officer	The Data Protection Officer directly reports to the senior management. The Data Protection Officer is responsible for the implementation and maintenance of this Policy and compliance with it. Employees should direct any questions about data protection in general, this Policy or their obligations under it, to the Data Protection Officer – Data.Protection@learndirect.com
All Employees	All employees are accountable to their managers for compliance with this Policy and related policies, procedures, standards and guidance. All employees have a responsibility to handle personal data in accordance with the principles of the GDPR. Inappropriate processing of personal data may lead to or result in disciplinary action against individual employees.

4. Policy

This Policy requires the appropriate handling of Personal and Sensitive Personal Data in line with the GDPR regulation. This section outlines how we will comply with the data protection Principles outlined in Section 1.2 of this Policy.

4.1 Fair, Lawful and Transparency

DTS will only process personal or sensitive personal data where specific conditions set out in the GDPR are met. Usually, the data subject’s consent to process their personal data is sufficient. Explicit consent is required in order to process sensitive personal data – i.e. informed consent may not be adequate. Where consent is not held another processing condition may apply, however, the Data Protection Officer should be consulted in all cases to ensure compliance with the DPA.

We will tell data subjects what we do with the information we hold or access about them. We will do this by including information in relevant privacy policies, fair processing notices, etc. for example, the following:

• Who the Data Controller is
• The purpose or purposes for which the data are processed
• Any other information to make the processing fair, e.g. include details of third parties to whom the data may be disclosed

For example; we tell users of the DTS website(s) what we will do with their personal data on our website(s) Privacy Policy. The DTS employee contract sets out how we will process employees’ personal and sensitive personal data.

4.2 Specific Purpose

We will only use personal data for the purposes we have stated in our notification to the ICO and/or in line with any commitment given to a Data Controller (in our role as Data Processor) or the Data Subject directly (e.g. in line with a fair processing notice, privacy Policy, etc.).

If we have access to and use information for one purpose, we must not automatically use this information for another, potentially incompatible, purpose.

Employees who plan to use personal data for a new purpose must contact the Data Protection Officer to discuss whether this processing complies with the GDPR.

4.3 Data Minimisation; Accuracy; & Storage limitation

We will only collect, use and disclose the minimum amount of information needed in order to carry out any particular task or processing activity.

We will endeavour to keep records about data subjects which we hold or access accurate and up-to-date.

We will only keep information as long as necessary either to comply with legislation, contractual requirement, industry good practice or our own business requirements. Our Data Retention and Disposal Policy incorporates more details of data retention and secure disposal requirements.

4.4 The rights of Data Subjects

We ensure Data Subjects rights under the GDPR are protected by ensuring a data subject can request:

The right to be informed	The right to be informed encompasses our obligation to provide ‘fair processing information’, typically through a privacy notice. It emphasises the need for transparency over how we use personal data of individuals. The information we supply about the processing of personal data must be: concise, transparent, intelligible and easily accessible; written in clear and plain language, particularly if addressed to a child; and free of charge.
The right of access	Individuals have the right to access their personal data and supplementary information. This is known as a Subject Access Request (SAR). The right of access allows individuals to be aware of and verify the lawfulness of the processing. Under the GDPR, individuals will have the right to obtain: confirmation that their data is being processed; access to their personal data; and their supplementary information – this largely corresponds to the information that should be provided in a privacy notice. We must provide a copy of the information free of charge. However, we can charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive. Information must be provided without delay and at the latest within one month of receipt. We will be able to extend the period of compliance by a further two months where requests are complex or numerous. Certain data may not be disclosed where a relevant exemption applies. We will provide an explanation and a right of appeal in these circumstances. Where we are not the Data Controller, we will forward the request to the Data Controller and otherwise assist in answering the request, where appropriate. For example, where we are a Data Processor we will provide information we hold on behalf of the Data Controller to the Data Controller within a reasonable amount of time to allow them to respond to the request within the statutory time limits. For more information about SAR process, please refer to DTS Subject Access Request process.
The right to rectification	The GDPR gives individuals the right to have personal data rectified. Personal data can be rectified if it is inaccurate or incomplete. We must respond within one month. This can be extended by two months where the request for rectification is complex. If we cannot take any action in response to a request for rectification, we must explain why to the individual, informing them of their right to complain to the supervisory authority (ICO) and to a judicial remedy. DTS employees may check their own personal information held in the HR Portal so that they can correct, update or delete any data. If an employee becomes aware that DTS holds any inaccurate, irrelevant or out-of-date information about them, they must update this information themselves if they are able to. If they are unable to they must notify their line manager or the HR department immediately and provide any necessary corrections or updates to the information.
The right to erasure	The right to erasure is also known as "the right to be forgotten". The broad principle behind this right is to enable an individual to request the deletion or removal of personal data where there is no compelling reason for its continued processing. Individuals have a right to have personal data erased and to prevent processing in specific circumstances: Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed; When the individual withdraws consent; When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing; The personal data was unlawfully processed (i.e. otherwise in breach of the GDPR); The personal data has to be erased in order to comply with a legal obligation. We can refuse to comply with a request for erasure where the personal data is processed for the following reasons: to exercise the right of freedom of expression and information; to comply with a legal obligation for the performance of a public interest task or exercise of official authority; for public health purposes in the public interest; archiving purposes in the public interest, scientific research historical research or statistical purposes; or the exercise or defence of legal claims.
The right to restrict processing	Individuals have a right to "block" or suppress processing of personal data. When processing is restricted, we are permitted to store the personal data to comply with legal or contractual obligations, but not further process it. We can retain just enough information about the individual to ensure that the restriction is respected in future. We will be required to restrict the processing of personal data in the following circumstances: Where an individual contests the accuracy of the personal data, we should restrict the processing until we have verified the accuracy of the personal data; Where an individual has objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and we are considering whether our organisation’s legitimate grounds override those of the individual; When processing is unlawful and the individual opposes erasure and requests restriction instead; If we no longer need the personal data but the individual requires the data to establish, exercise or defend a legal claim; We must inform individuals when we decide to lift a restriction on processing.
The right to data portability	The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services. It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. The right to data portability only applies: to personal data an individual has provided to a controller; where the processing is based on the individual’s consent or for the performance of a contract; and when processing is carried out by automated means; We must provide the personal data in a structured, commonly used and machine readable form. Open formats include CSV files. Machine readable means that the information is structured so that software can extract specific elements of the data. This enables other organisations to use the data. We must respond without undue delay, and within one month. This can be extended by two months where the request is complex or we receive a number of requests. We must inform the individual within one month of the receipt of the request and explain why the extension is necessary. The information must be provided free of charge.
The right to object	If a data subject believes that the processing of personal information about them is causing, or is likely to cause, substantial and unwarranted damage or distress to them or another person, they may notify the organisation in writing to request DTS to put a stop to the processing of that information. Individuals have the right to object to: processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/ historical research and statistics. We must stop processing the personal data unless: we can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or the processing is for the establishment, exercise or defence of legal claims. We must inform individuals of their right to object "at the point of first communication" and in our privacy notice. This must be "explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information".
Rights in relation to automated decision making and profiling	The GDPR applies to all automated individual decision-making and profiling. This may be not applicable to DTS if we are not using any automated means to process personal data. Automated individual decision-making (making a decision solely by automated means without any human involvement) Profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process. We can only carry out this type of decision-making where the decision is: necessary for the entry into or performance of a contract; or authorised by Union or Member state law applicable to the controller; or based on the individual's explicit consent.

4.5 Security of personal data

DTS must take appropriate measures to maintain the security of personal data. We will do this in two ways.

4.5.1 Technical measures

We will maintain an appropriate level of security in our systems when collecting, storing, exchanging and disposing of data. Our Information Security Policies and Procedures will provide more detail on how exactly this will be achieved.

4.5.2 Organisational measures

We will take specific organisational measures including the following:

4.5.2.1 Data Protection Training & Guidance

DTS employees are legally and contractually obliged to protect personal data.

DTS provides training on data protection issues to all employees who handle personal information in the course of their duties at work to help employees to understand their responsibilities. The Information Security Policy sets out when the Information Security & Data Protection training needs to be completed and renewed.

Guidance will be issued regularly via bulletins, newsletters and via the intranet and targeted emails to advise relevant colleagues of specific issues that need to be addressed, useful hints and tips and developments in legislation and company policies.

4.5.2.2 Advice and Support

The Data Protection Officer is responsible for providing an appropriate advice and support service to all directorates. Where appropriate, the Legal Director and/or external legal experts will be consulted to ensure

compliance with all relevant legislation and standards. The advice & support service will include appropriate contract and agreement review.

Any questions about data protection issues should be directed to your line manager in the first instance and escalated as appropriate to the Data Protection Officer –Data.Protection@learndirect.com.

4.5.2.3 Privacy / Data Protection Impact Assessments

When we are planning something new, Privacy / Data Protection Impact Assessments (PDPIAs), previously known as Privacy Impact Assessments (PIAs), help us think about any privacy, confidentiality and information security issues before we start. We should think about the impact new initiatives (e.g. a new project; new or changed Policy; or new information sharing activity) will have on the people whose information we plan to use.

PDPIAs allow us to identify potential risks at the start of a project and develop a plan to manage, mitigate and / or avoid them. This approach can save time and effort later if things do go wrong. PDPIAs help to ensure that we are compliant with the GDPR and other relevant Privacy legislation.

We will seek to conduct a PDPIA for initiatives involving:

• building new IT systems for storing or accessing personal data;
• sharing data with external organisations;
• asking external organisations to share data with us;
• using existing data for a new purpose.

If a project plan changes you should consult the Data Protection Officer to consider whether a new PDPIA may be required.

4.5.2.4 Privacy and Data Protection Forums

Privacy and Data Protection forums will operate in tandem with Information Security forums where appropriate.

4.6 Transfer of personal data outside the European Economic Area

DTS will not transfer personal or sensitive personal data outside the EEA to countries other than those approved by the European Council unless personal / sensitive personal data is suitably protected. The Data Protection Officer should be consulted for any new initiative which may involve the transfer and / or storage of data outside the UK.

We will only transfer and / or store personal data outside the EEA where:

• we have permission (in cases where it relates to information for which we are the Data Processor);
• we are confident it is adequately protected, i.e. we have assessed and found any risk in transferring the personal data is mitigated; and/or
• we have otherwise made the third party contractually aware of their responsibilities, for example by using EU model clauses.

5. Monitoring

DTS may monitor employees by various means including, but not limited to, checking emails and internet use. DTS will retain such data in line with the Data Retention & Disposal Policy.

DTS reserves the right to use covert monitoring. This may be appropriate where there is, or could potentially be, damage caused to the organisation by the activity being monitored and where the information cannot be obtained effectively by any non-intrusive means (for example, where an employee is suspected of stealing property belonging to the organisation). Covert monitoring will take place only with the approval of senior management and HR department.

6. Compliance

6.1 Policy Compliance

Breaches of this Policy and / or security incidents can be defined as events that have, or could have resulted in, loss or damage to DTS assets, or an event that is in breach of DTS information security policies and procedures.

All DTS employees, partner agencies and contractors have a responsibility to report security incidents and breaches of this Policy as quickly as possible through the Incident Reporting Procedures. This obligation also extends to any external organisation contracted to support or access the Information Systems of DTS.

Failure to observe the standards set out in this Policy may also be regarded as serious and any breach will be dealt with in line with Disciplinary Policy. Action taken against employees under Disciplinary Procedure may include dismissal. The Disciplinary Procedure is part of the Local Conditions of Employment.

Any user who does not understand the implications of this Policy or how it may apply to them, should seek advice from their immediate line manager, the Data Protection Officer or the Information Assurance and Security Team.

Occasionally there may be situations where exceptions to this Policy are required, as full adherence may not be practical, could delay business critical initiatives or could increase costs. These will need to be risk assessed on a case by case basis. Where there are justifiable reasons why a particular Policy requirement cannot be implemented, a Policy exemption may be requested in line with the Policy Exemption Process.

6.2 Legal compliance

We have a procedure to ensure that staff know what to do in the event of a security incident, for example an inappropriate disclosure of information leading to a potential breach of the GDPR.

Advice is available to staff, who must report breaches in line with the Incident Reporting Procedures and Security Incident Management Policy to ensure incidents are reported, managed and assessed properly and consistently.

Breaches will be notified to the data subject and the Information Commissioner’s Office (ICO) where required in line with ICO guidance. This will be determined by the Data Protection Officer or Information Assurance and Security Team.

Supply Chain Charges Policy

Dimensions Training Solutions (DTS) review the diversity of its delivery partners on an ongoing basis. This is undertaken to meet the ever changing needs of learners/participants that services are delivered to and to meet the commissioner?s requirements.

The specific details of the services provided by each party, payment terms, rates and payment triggers are set out in detail in each contract. Charges are calculated taking into consideration both the specific services the supplier provides and those services provided by DTS centrally.

Central services and performance management:

• Suppliers have access to learner data and a full suite of MI reports refreshed weekly, including payment data in one integrated system.
• Resource efficient ILR system to allow a complete paperless process.
• DTS online learning is delivered on a robust learning platform which includes learner tracking and tutor monitoring function, together with the capture of all ILR data required for funding.
• Access to online diagnostic courses to assess a learner?s current attainment level.
• DTS online course material for the learner tailored to the learner?s needs. The course material is regularly refreshed and provides state of the art learning combining exercises and videos to guide the learner through their studies including mini online tests at the completion of each section to test knowledge gained.
• Access to DTS specialist staff supporting with Quality, Audit, Finance and Operations.
• Suppliers have access to centre branding, customisable marketing materials and national/regional marketing campaigns.
• Suppliers have access to a portal of information to help, support and manage learners.
• Supply chain management through a dedicated Supply Chain Manager.
• Allocation and performance monitoring of funding allocations
• Support for and aggregation of quality self-assessment and development plans
• Moderation of teaching and learning observations
• An internal assurance programme for funding and compliance

Central services, systems and performance management functions account for c15-25 per cent of funding. Subcontractors benefit from different combinations of these services depending on delivery requirements and as a result, subcontractors can charge DTS differing amounts for learning delivery as agreed in their contract.

This policy will be communicated to current subcontractors via the Provider Portal and a website link. All potential subcontractors will be made aware of the policy as part of the Procurement and Due Diligence process

IAG Road Map

Our promise to you

Whatever you want to achieve with Dimensions Training Solutions (DTS), we want to make sure you enjoy it and receive the best possible service from us.

We will:

• listen carefully to you and help you find the right learning, qualification or support to achieve your goals
• ensure you know what to expect, who will support you and how they can help
• be flexible in how we support you and make it easy for you to get in touch with us
• understand your needs and circumstances to make sure you get the most out of your time with us
• treat you fairly, politely and with respect
• ensure our staff are professional and have the skills and knowledge to support you
• provide help and support if you have a problem, question or complaint
• let you know if you?re eligible for funding or how much you need to pay, and whether you can get help with your costs
• help you work out what your next steps could be so you continue developing new skills, whatever your age and circumstances.

In return, you should:

• complete the activities and work that you agree with us
• participate fully and actively in your programme
• treat DTS staff, learners and customers fairly, politely and with respect
• talk to our staff regularly about your progress
• let us know if you need any extra support to help you achieve your goals.

DTS Information, Advice & Guidance (IAG) Statement of Service

Introduction

The purpose of the Information, Advice and Guidance Service is to support individuals to achieve their aspirations, including their learning and career goals.

Through the delivery of Information, Advice and Guidance, we will support individuals to make decisions about learning and career planning based on their individual needs, circumstances and interests. We place an emphasis on opportunities for independent self-assessment and decision making by providing information and advice that is easy to access, understand, clear, relevant and up to date.

The service aims to support high levels of participation, achievement and progression for both employed and unemployed adults.

What you can expect from the IAG service:

• We will advertise the service so that enquirers and clients know what they can expect and how to access it, including the publication of a Statement of Service which will be displayed on our website and in centres.
• We will offer the service at all stages of all programmes that we deliver.
• The service will be provided in a supportive and confidential capacity and is free of charge.
• The service will be impartial and objective in order to best meet the needs of those who access it.
• Information, advice and guidance will be delivered by appropriately trained, qualified and experienced staff.
• Information, advice and guidance, including our online information and advice is accurate and up to date.
• Information, advice and guidance is provided in a range of formats to suit individual needs.
• The service will be delivered in our centres, from outreach locations or remotely, over the phone and within the workplace to ensure it is accessible to all those who require it.
• DTS will refer or signpost to appropriate and reputable external organisations in order to best meet the needs of those who access the service.
• The service will be quality assured, including seeking the feedback from service users and acting upon it to drive improvements.

Dimensions Training Solutions (DTS) Modern Slavery Statement 2019

Introduction

This statement sets out Dimension Training Solutions (DTS) actions and steps we maintain to prevent slavery and human trafficking. In this statement we aim to give a transparent report on our progress in addressing any risks.

Dimension Training Solutions have a zero-tolerance approach to modern slavery and human trafficking, and we are fully committed to preventing slavery and human trafficking in our activities and supply chains.

Our Business

Dimensions Training Solutions (DTS) is a work-based learning provider offering a range of qualifications. We work across England and deliver contracts with ESFA, ESF and DWP. We have both direct delivery centres and supply chain partners.

Policy

Our policies reflect our commitment to acting ethically and with integrity.

Safeguarding Policy

Our safeguarding policy sets out the legislative requirements to provide a duty of care and provide a clear process for escalating concerns to protect individuals. We have a dedicated helpline and email address to enable people to easily raise any concerns.

Prevent Policy

Our Prevent policy sets out a clear framework to structure and inform our response to safeguarding concerns for those people who may be vulnerable to the messages of extremism. In addition, it provides details of the local inter agency process and expectations in identifying appropriate interventions based on the threshold of need and intervention model and the Channel process

Code of Conduct

Our code of conduct makes it clear to employees the actions and behavior we expect from them when representing the company. We strive to maintain high standards of behavior and strong ethical standards across the business including our supply chain Partners.

Whistleblowing Policy

We encourage all employers, service users and partners to report any concerns related to the direct activity of the business or supply chain partners. The procedure is designed to make it easy for disclosures to be raised, without fear of reprisal.

Equality & Diversity Policy

Our equality and diversity policy ensure that we respect and value the diversity of our learners, customers, employees, supply chain partners, partners, employers and all other people we work with. We strive to create a positive working environment to support learning and improve employment opportunities where everyone is treated with dignity and respect

Due Diligence & Risk Management

We expect the highest standards of conduct throughout our supply chain partners and for everyone to act with honesty and integrity. Part of our due diligence process includes the reviewing of polices to ensure that all supply chain partners we work with have suitable processes in place to reduce risks. Dimensions Training Solutions (DTS) will continue to work with supply chain partners to ensure that they meet the standards and comply with the requirements of the Modern Slavery Act 2015.

Training

Polices and processes are annually reviewed and cascaded to the business via our internal quality update, which ensures all employees are kept up to date. All our employees undergo a series of online training annually, to ensure they have good understanding and knowledge on a variety of subjects.

Effectiveness

Our due diligence processes help us to understand where we have greater risk. Modern slavery signs can be difficult to identify so we ensure that we improve the understanding of where risks are greatest and priorities activity accordingly. Dimensions Training Solutions (DTS) commit to continuing to review policies and procedures and putting in correct controls to mitigate risks of modern slavery and human trafficking across our organisation.

Approval

This statement is made pursuant to section 54(1) of the Modern slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2019. This statement has been validated by the DTS board, signed by our Group Chief Executive and published on our website.

British Values

Policy Aim

The government set out its definition of British values in the 2011 Prevent Strategy. The five key British Values are:

• Democracy
• The rule of law
• Individual liberty
• Mutual respect
• Tolerance of those of different faiths and beliefs and for those without faith

Britain has undergone rapid economic and social change in the last few decades and we live in an increasingly diverse society. We need to ensure that it is possible to live together peacefully, where everyone is a valuable part of our multicultural world.

Ofsted require all training providers to promote Fundamental British Values to learners, and to prepare learners for life in modern Britain. All our learners are expected to learn about British Values as part of their programme of learning with DTS.

DTS are committed to:

• Promoting British Values throughout the programme of learning that defines and explores British Values and opportunities for learners to apply their knowledge to current relevant situations and issues.
• Enabling learners to develop their self-knowledge, self-esteem and self-confidence.
• Enabling learners to distinguish right from wrong and to respect the civil and criminal law of England.
• Encouraging learners to accept responsibility for their behaviour, show initiative, and to understand how they can contribute positively to the lives of those living and working in the local community and to society more widely.
• Enabling learners to acquire a broad general knowledge of and respect for public institutions and services in Britain.
• Further tolerance and harmony between different cultures by enabling learners to acquire an appreciation for and respect for their own and other cultures.
• Encourage respect for other people, for democracy and participation in the democratic processes, including respect for the basis upon which the law is made and applied in Britain.

Note: Within the guide, the term "learner" describes clients/customers/claimants/participants.

Roles and responsibilities

DTS understands the importance of promoting British values through a comprehensive and unprejudiced curriculum. The SLT will ensure that all staff are aware of the requirement to uphold British values through the methods outlined in this policy and will ensure that the appropriate procedures are in place to carry out these methods. Staff will ensure that their lessons are inclusive of, and sensitive to, the fundamental British values. Learners are expected to treat each other and staff with respect, in line with the DTS ethos.

Staff training

DTS staff are made aware of their responsibilities in terms of British values during their induction. If deemed necessary, staff will be offered the opportunity for further training on upholding the British Values Policy. Regular updates are included within the quality update to widen staff knowledge and understanding. Observations of teaching, learning and assessment are frequently completed, and staff provided with any development opportunities as part of the feedback.

Democracy

At DTS learners have a range of ways to air their views; this could be naturally through their learning programme/session, learner surveys, learner forums and contacting one of the DTS team via improve@dimensionstrainingsolutions.co.uk with any suggestions. Our learners are encouraged to have an input into what and how they learn to instil an understanding of democracy for their future. We encourage others to see the bigger picture, encouraging everyone to know that their views count, value each other’s views and talk about their feelings. When appropriate we will demonstrate democracy in action, for example, sharing views. Staff can support the decisions that others make and provide activities that involve sharing and collaboration.

The rule of law

DTS has a high regard for the laws that govern and protect us, the responsibilities that this involves and the consequences when laws are broken. Our learners understand the learner code of conduct and what is expected of them while studying with us. Learners are encouraged to engage in healthy debate in sessions that encourage recognition of the importance of the law. We enable learners to distinguish right from wrong and to respect the civil and criminal law. We encourage learners to accept responsibility for their behaviour, show initiative, and to understand how they can contribute positively to the lives of those living and working in the locality of the community and to society more widely.

Individual liberty

At DTS we foster a safe and supportive environment where learners are actively encouraged to make choices. We support individuals to make decisions about learning and career planning based on their individual needs, circumstances and interests. We place an emphasis on opportunities for independent self-assessment and decision making by providing information and advice that is easy to access, understand, clear, relevant and up to date. Learners are taught about their rights and personal freedoms and are encouraged and advised on how to exercise these safely.

Mutual respect

Respect forms a core pillar of the DTS ethos. Learners are treated with respect and learn to treat each other and staff with respect. We aim to support all learners and to give them the support and guidance they need to achieve success. The learner code of conduct applies to all learners on DTS programmes and is a guide to show what we expect from each person whether it is within our centres, remotely or participating in organised events, activities or work placements.

Tolerance of those of different faiths and beliefs and for those without faith

DTS acknowledges that tolerance is achieved through learner’s knowledge and understanding of their place in a culturally diverse society and the opportunity for learners to experience such diversity. Each month the learner newsletter shares information about different events that take place across several faiths during that month. This is an important way of widening learners understanding. We encourage our staff and learners from different faiths or religions to share their knowledge with their peers to enhance their learning. To further tolerance and harmony between different cultural traditions by enabling Learners to acquire an appreciation of, and respect for, their own and other cultures.

Equality and Diversity Policy

Introduction

Dimensions Training Solutions (DTS) is committed to treating everyone fairly. We respect and value the diversity of our learners, customers, employees, suppliers, partners, employers and all other people we work with. We strive to create a positive working environment to support learning and improve employment opportunities where everyone is treated with dignity and respect. We will challenge any instance of inequality and will anticipate and respond positively to different needs and circumstances so that everyone can achieve their full potential.

Scope and Purpose

This policy applies to:

• Actual and prospective learners (‘learner’ is used as a common term to also denote customer where appropriate)
• Employees (individuals who work or have applied to work for the company either on a permanent, temporary, contractual or voluntary basis)
• Employers and Sub-contractors (external partners who are in receipt of and/or provide services. These are subject to our Due Diligence Policy and an annual review of contract specific policies/processes)

The words "individual(s)" and "everyone" are used in this policy to denote all those above.

DTS strives to ensure all individuals have equal opportunity to access learning and work and to realise their potential. We will not tolerate any inequality or any other actions that may limit ability to participate and succeed. We recognise and celebrate the diversity of our learners, employees and employers. We are committed to ensuring all individuals feel safe, respected and listened to, regardless of their backgrounds or personal attributes. We will recognise and value individual differences and remove barriers that put people at a disadvantage.

We wholly support the requirements of the Equality Act 2010 and the public sector Equality Duty (PSED) which are consistent with our vision and principles. In line with the general Equality Duty, we commit to:

• Eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act.
• Advance equality of opportunity between people who share a protected characteristic and those who do not.
• Foster good relations between people who share a protected characteristic and those who do not.

We will oppose and always challenge any direct or indirect discrimination, harassment or victimisation on the grounds of age, disability, gender reassignment, race, religion or belief, sex, child bearing or caring status, sexual orientation or marital or civil partnership status.

The purpose of this policy is to describe how we will put our vision and principles into practice and fulfil our statutory duties to promote equality, value diversity and eliminate discrimination so that all learners and employees realise their potential. Where learners are learning or training in subcontracted suppliers, the "local" (supplier"s own) learner equality and diversity policy and arrangements will be applied and enforced first but where these do not exist or are incomplete, this policy will be shared and applied.

Equality of Opportunity and Outcome in Learning/Employment

Access to learning and recruitment

We will strive to ensure that learning and recruitment opportunities are available to all. No individual will be excluded from a learning or recruitment opportunity on the grounds of their age, disability, gender reassignment, race, religion or belief, sex, child bearing or caring status, sexual orientation or marital or civil partnership status.

We will record and monitor individual participation/application and withdrawal/rejection of learning/recruitment opportunities to ensure equality of opportunity and fair representation.

For learners: We will support all learners as far as reasonably possible (subject to funding and health and safety requirements) to pursue the learning programme of their choice and make all reasonable efforts to ensure physical access to the learning/workplace environment. In circumstances where this is not possible, we will identify alternative options/provision.

For employees: Wherever possible, all recruitment opportunities will be advertised simultaneously internally and externally and will include an appropriate short statement on equality of opportunity. Selection criteria (role profile) will be kept under constant review to ensure that they are justifiable and non-discriminatory.

Wherever practicable, a panel will be used in the short listing and interviewing process. All applicants and current employees invited to participate in a selection process will be asked if any assistance/adjustment is required to enable them to fully participate. We will ensure all employees who are involved in the recruitment, selection or promotion process understand and support in non-discriminatory recruitment and selection techniques as part of the company Management Development Programme.

In accordance with the company"s commitment to the Positive about Disability scheme, a job interview is guaranteed to all applicants with a disability who meet the minimum criteria for a job vacancy.

We will provide access to appropriate training and development to allow employees to carry out their roles. Each training and development need will be treated on its individual merits and in accordance with the needs of the business.

For employers: We will provide services only to employers who support our commitment to equality and diversity and comply with related requirements. We expect employers to ensure fair access to our programmes and work-based opportunities and to strive to monitor staff participation and performance.

Disclosure and additional support provisions

Before starting and during learning/employment, individuals will be given opportunity (in confidence) to disclose any disability or learning difficulty they may have. This is to ensure we put in place additional or alternative support or adapted working practices where reasonably practical and possible. We will explain why this information is being sought and how it will be used. We will ask individuals to let us know of any personal commitments or barriers which can affect their commitment or time in learning or employment and offer help/alternative ways of working to minimise their impact.

For learners: Where a learner discloses a disability or learning difficulty, we will identify what additional or alternative support provisions need to be put in place in discussion with them.

We will endeavour to secure and provide any additional support for the duration of the learning or employability programme where reasonably practical and with agreed disclosure by the learner. Support could be in the form of additional/alternative assistance, provision of a specialist service, involvement of personal carers/support workers, provision of alternative or adaptive equipment or learning environment etc.

Where it is not reasonably possible to provide required and sufficient (specialist) support to enable a learner to achieve we will contact the learner"s referral agency and/or signpost to more suitable provision.

We will explain where learners are eligible for government funding to enrol and receive additional or alternative support on learning programmes.

All learners will have their learning and access needs assessed to identify suitable learning programmes that are relevant to their development objectives and goals.

For employees: Where an employee declares a disability, reasonable steps will be taken to accommodate this by making reasonable adjustments. The company may consider re- deployment and appropriate re-training to enable the employee to remain in employment where possible.

For employers: We will, where appropriate and with the learner"s permission, share information on any disability, learning difficulty and/or barriers to learning and where appropriate require support/ provision from the employer to accommodate these in the learner"s learning and employment.

Induction and equality training

All individuals will receive an induction into their learning/employment and working environment. We will make everyone aware of our commitment to equality and diversity, the arrangements in place to ensure all people are treated fairly and equally, our standards of behaviour and how to make us aware of any dissatisfaction or concern.

For learners: During learning, we will remind learners of arrangements in place to ensure equality of opportunity and to promote diversity, give regular opportunity to disclose any disability or learning difficulty or adjust additional support provisions and support them to develop their awareness of equality, diversity and inclusivity.

For employees: All new employees are required to complete mandatory equality and diversity e-learning modules. All staff are required to refresh their knowledge by completing learning modules annually and familiarising themselves with any supportive equality guidance. An additional learning module must be completed by employees with people management responsibilities.

For employers: We expect employers to provide staff induction, training and information on equality and diversity arrangements in place within their organisation and what to do should a staff member or an individual on a work placement wishes to make a complaint.

Learning and working environment

We are committed to creating open and conducive learning and working environments where everyone has the right to be treated with dignity and respect. We are opposed to and will not tolerate any form of bullying, harassment or unacceptable behaviour where this makes an individual feel intimidated or offended. We will ensure all individuals have clear routes to report incidents and/or concerns and for these to be managed fairly and fully.

We will strive to ensure all individuals feel comfortable to express their views, experiences and perceptions but in a respectful and non-discriminatory manner. Any form of prejudice, discrimination and/or stereotypical attitudes will be challenged and supported by training on equality and diversity practice

We will ensure that all our learning materials and public and internal communications reflect the diverse society in which we live and enable individual access to working or learning with us.

For learners: We will clearly set out types of behaviour which are unacceptable and procedures to be followed to respond to complaints and/or concerns and outline how people involved will be supported. Where learners are on work placement or employed at an employer"s premises, they will also be subject to their employer"s disciplinary procedure(s).

For employees: We have a separate Dignity at Work Policy for employees which explains how issues of bullying and harassment and complaints of this type will be dealt with.

For employers: We expect employers to have in place and to communicate procedures that deal with staff bullying, harassment, unacceptable behaviour and disciplinary.

Monitoring of learner participation, performance and satisfaction

All individuals will be asked to provide personal information upon starting learning or working on their age, gender, ethnicity, disability and learning difficulties. This information is used for monitoring purposes only and will remain confidential to DTS and (where relevant) funding agencies. If individuals so wish, they may decline to provide this information. We will undertake regular analysis of learner and employee group data to ensure any notable variation is addressed and any participation and/or performance gaps are reduced.

All individuals will be encouraged to give their feedback on their experience of learning or working with DTS and these will analysed to assess levels of satisfaction and to identify any improvements.

For learners: Where appropriate, we will set Company Equality and Diversity Impact Measures (EDIMs) and require our supply chain partners to do the same to address identified variation or gaps between the participation and/or achievement of different learner groups.

For employees: We will encourage employee promotion but this will only take place as a result of objective assessment based on the specific abilities, skills and knowledge required for the post. We will exercise equal access to promotion and opportunities will be advertised on the basis that they are accessible to all employees including those that work full time, part time, from home and those that are office based.

There may be situations where some specialist posts are only suitable for people with particular skills but consideration must still be given to all employees and a fair selection process adopted as some employees may have skills of which the company are unaware.

For employers: We will encourage employers to measure the participation, performance and satisfaction of their staff and support us in developmental work to promote and address under-representation.

Responsibilities

We will:

• Provide learning and working environments that respect difference and protects the diversity of those working within them
• Raise individual awareness of the importance of equality and diversity and good relations between people of different groups
• Develop the awareness and skills of individuals to promote fairness, inclusivity and good relations
• Instill in everyone high expectations of achievement and progression and value positively the achievements they have made
• Ensure that everyone is enabled to achieve positive outcomes, whatever their background
• Ensure fair and equal access to learning and recruitment and take action to promote equality
• Make reasonable and practicable adjustments to enable individuals to participate in learning or work. Where this is not feasible, we will identify alternative options/solutions
• Consult with and involve individuals on their experience of learning and working with DTS
• Embed equality impact evaluation into key business projects, critical policies and where appropriate procedures.
• Create and maintain effective partnerships with employers, suppliers and partners and ensure that they support our commitment to equality and diversity

We will require all individuals:

• To communicate and behave with courtesy, kindness and respect and in accordance with our policies and procedures
• To inform us if they have any additional needs or are experiencing difficulties in learning or working with us
• To value and respect individual differences and the contributions of others
• To maintain a safe and secure learning and working environment
• To take responsibility for their own actions, personal development and performance
• To work to achieve their personal best and allow others to do the same
• To let us know immediately if they are unhappy with any aspect of learning or working with DTS or have witnessed anything of concern.

Complaint/Grievances

We will make all individuals aware of the steps to follow should they wish to raise a concern, grievance or make a complaint. We will aim to fully resolve any concerns or problems as quickly as possible and if we cannot resolve or put right straight away we will explain why and say what we can do. Please note that the Prevent and Safeguarding policies and related procedures should be followed when reporting concerns relating to either Prevent or Safeguarding.

For learners: The quickest and easiest way for a learner to raise a concern or make a complaint is to do so via their tutor, trainer, and assessor or centre manager.

Where a learner is learning through one of our supply chain partners, this will initiate their own procedure first and the learner will be advised of who will take responsibility for resolving their concern or complaint and how long this should take.

Where a learner does not feel able to do this, the following option is available to all learners: Email wellbeing@dimensionstrainingsolutions.co.uk with the details.

For employees: When making a complaint or raising a concern relating to unlawful discrimination, the company"s Grievance Resolution Procedure should be followed. If the complaint involves bullying or harassment the company"s Dignity at Work Policy should be followed. The company will take any complaint seriously and will seek to resolve any grievance which it upholds. Employees will not be penalised for raising a grievance, even if the grievance is not upheld, unless the complaint is both untrue and made in bad faith.

Any employee (found to be) breaching this policy will be regarded as behaving in a manner that constitutes an act of misconduct and will be dealt with through the disciplinary procedure.

For employers: When making a complaint or raising a concern of unlawful discrimination, bullying, harassment and/or unacceptable behaviour by a DTS employee, an employer should:

Where the employer does not feel able to do this, the following option is available: Email wellbeing@dimensionstrainingsolutions.co.uk with the details.

Monitoring and Review

This policy will be monitored annually to review its effectiveness and will be updated in accordance with necessary changes.

This DTS policy is applicable to the following contracts:

ESFA:

• Adult Learner Loans (ALL)
• AEB

ESF for LEP Areas:

• D2N2 – Workforce Development and Business Growth
• D2N2 – Developing a Demand Led System
• Greater Manchester – Skills Support for the Unemployed
• Hertfordshire – Skills Support for the Unemployed
• Lancashire - SSW Basic
• Lancashire – SSW Intermediate and Higher
• Lancashire- SSR
• London – SSU Retail, Tourism and Hospitality
• London – SSU Health and Social Care
• Stoke and Staffordshire – SSR
• West of England – NEETS
• West of England – SSU
• Local London – NEETS
• D2N1 - NEETS
• The Marches – SSW More Developed
• The Marches – SSW Transitional

DWP:

• Gloucestershire - European Social Fund (England) 2014-20
• Work Programme CPA12