Company Policies

A2O People are committed to delivering the highest quality solutions to meet our clients’ needs. We are dedicated to maintaining standards and investing in systems, training and procedures that enable us to constantly improve performance, efficiency and knowledge.

Our Company Policies include

1. Corporate Social Responsibility
2. Diversity & Inclusion
3. Health & Safety Policy
4. Quality Assurance
5. Environmental Policy
6. Training and Development Policy
7. Complaints Handling & Appeals Policy
8. Anti-Bribery and Corruption Policy
9. Whistleblowing Policy
10. Data Protection Policy

 

Corporate Social Responsibility Policy

A2O Peoples’ commitment is reflected in the practices and policies which recognise good Corporate Social Responsibility to be at least equal in importance to all our prime business goals and responsibilities.

We aim to align our values and behaviour with the expectations and needs of all our stakeholders through our focus on 6 key areas;

• Workplace - we want to provide an equal and diverse workplace. We prioritise everyone’s welfare, health and safety in line with sector best practice and relevant legislation. We will constantly seek ways to improve our people practices and our engagement with our employees, associates and delegates.
• Customers - our relationship with our customers is at the heart of our business strategy. We will show integrity and seek to build trust in all our business interactions ensuring an appropriate “duty of care” in respect of stakeholders, delegates, customers and suppliers.
• Community - we want to make a positive and long term contribution to the communities in which we operate.
• Giving back – we reward our own success through undertaking volunteering work and we donate to good causes.
• Environment - we recognise our responsibility to reduce our impact on the environment.
• Society - we see the bigger picture, we seek ways to benefit society as a whole.

We aim to have our CSR goals embedded as part of our culture and ensure that all of our team are fully engaged and committed to achieving these objectives.

 

Revised: Mar 2017

Reviewed: April 2019

Signed by………………..

Director of A2O People

The next review of this policy will be in March 2021.

 

 

Equal Opportunities, Diversity and Inclusiveness policy

EQUAL OPPORTUNITIES

A2O People is committed to a policy of equal opportunities for all employees, trainees and applicants and meeting the requirements of the Equality Act 2010. A2O People will treat everyone equally irrespective of sex, sexual orientation, marital status, age, disability, race, colour, ethnic or national origin, religion, or membership or non-membership of a Trade Union and places an obligation upon all staff to respect and act in accordance with the policy.

A2O People shall not discriminate unlawfully when deciding which candidate / contract worker is submitted for a vacancy or assignment, and that each candidate is assessed only in accordance with the candidate's merits, qualification and ability to perform the relevant duties required by the particular vacancy.

We will endeavour to ensure that employees making selection and recruitment decisions will not discriminate, whether consciously or unconsciously. We will adopt a consistent, non-discriminatory approach to the advertising of vacancies. Short-listing and interviewing will be carried out by more than one person where possible. Interview questions will be related to the requirements of the job and will not be of a discriminatory nature. We will comply with temporary workers legislation in accordance with the Agency Workers Regulations 2010. Promotion and selection for training will be made on merit.

A2O People will make necessary adjustments to ensure that trainees are not discriminated against and have an equal opportunity to participate in training activities.

HARASSMENT

A2O People is committed to providing a work environment free from unlawful harassment, because of race, colour, creed, sex, sexual orientation, marital status, national origin or ancestry, physical or mental disability, age or religion or any other basis protected by legislation

All staff and associates are expected to conduct themselves in a professional and considerate manner at all times. A2O People will not tolerate behaviour such as:

1. Making threats, physical violence, swearing at others, persistent rudeness
2. Isolating, ignoring or refusing to work with certain people
3. Telling offensive jokes or making derogatory comments or gestures
4. Displaying offensive material, or the distribution of such material via email / text message or any other format
5. Physical conduct such as assault, unwanted touching, or any interference because of sex, race or any other protected basis
6. Retaliation for having reported or threatened to report harassment
7. Any other forms of harassment or victimisation

If you believe that you have been unlawfully harassed, you should immediately report this to one of A2O People’s Directors followed by a written complaint as soon as possible after the incident. Your complaint should include:

·        Details of the incident;

·        The name or names of the individual or individuals involved; and

·        The name or names of any witness or witnesses

A2O People will undertake a thorough investigation of all allegations of harassment. We encourage staff to resolve misunderstandings and problems informally wherever possible, depending on the circumstances. However, whether dealt with informally or formally, it is important for staff who may have caused offence to understand that it is no defence to say that they did not intend to do so, or to blame individuals for being over sensitive. Any employee who is found to be responsible for unlawful harassment will be subject to the disciplinary procedure and any sanction may include termination.

 

DIVERSITY AND INCLUSION

We are passionately committed to inclusion and equality in the workplace.

We define Diversity as the presence of unique individuals, men and women from different cultures, nations, ethnic groups, generations, backgrounds, skills, abilities and all the other differences that make each of us who we are.

Inclusion is the creation of a work environment where each person is valued for his or her distinctive skills, life experiences and perspectives and where everyone has an opportunity to fully participate in creating business success.

Employing people from a wide range of backgrounds, ages and life experiences can add significant value to organisations. Open and inclusive recruitment processes provide a greater choice of talent for employers to choose from. Diverse workforces lead to better staff retention rates, a better understanding of different markets and a more creative mix of people. Diversity is not only good in itself but is also good for business.

Our policies and practices include;

• Diversity is not only respected, it is celebrated. We value the differences between people and empower people to bring all their experiences, skills, ideas, opinions and insight to work.
• We recognise that drawing from as diverse a talent pool as possible ensures that we get the best people for our and our clients business. We will seek to attract, develop, promote and retain a diverse workforce and board.

 

Revised: Mar 2017

Reviewed: April 2019

 

Signed by………………..

Director of A2O People

The next review of this policy will be in March 2021.

​

 

Health and Safety Policy

A2O People is committed to the prevention of injury and ill health associated with its activities. We recognise that our approach to Safety and Health contributes to our business performance and supports the quality of the service we provide.

We are committed to

• providing safe training facilities for delegates and places of work
• providing a safe system of work
• providing adequate plant and equipment
• recruiting competent and safety conscious staff

We believe that all accidents and health related incidents are preventable and we are committed to the continual improvement of our Safety & Health management and performance together with complying with legal and good practice obligations as a minimum.

We will meet our commitments through appropriate training and qualifications of our staff, managing and monitoring all accidents and incidents, regular review of our Health & Safety practices and promotion of a culture of health and safety throughout the organisation.

 

Policy

We organise ourselves to ensure that:

• we promote effective communications to all our employees, delegates, volunteers, associates, agency staff and contractors and their representatives
• all employees, delegates and associates understand their duties and responsibilities for SHE management in the workplace
• this policy is available to interested parties

 

People

We support people by ensuring that:

• direction, training, supervision and where appropriate specialist support is provided to enable employees to discharge their duty to work responsibly and with due consideration for safety, health and the environment
• contractors and associates working on behalf of A2O People are competent to do so and have systems to comply with all the relevant legislation, guidance, standards and procedures
• human factors are considered in the management of our operations and organisational changes
• bringing this policy to the attention of all of our employees, associates and delegates ensuring that they understand their own responsibilities for health and safety in the workplace
• we expect every employee, associate and delegate to give their full cooperation to this policy, and to take reasonable care for their own safety and that of others involved in or affected by our activities. This includes all sub-contractors, consultants or visitors 
• employees, associates and delegates are encouraged to report any hazard or potential hazard that could cause harm

 

Performance

We continually improve performance by ensuring that

·        we monitor performance and take effective action to manage areas of concern

-        all adverse events are investigated and the lessons learnt are communicated to interested parties

 

Processes

We manage our risks by ensuring that:

• hazards are identified for new work activities, assessing the level of risk and seeking ways that eliminate or adequately control the risk
• we provide the instruction, training and supervision to our employees, associates and delegates as necessary
• safe systems of work are followed so that people are equipped to manage SHE risks and obligations
• the workforce are provided with safe plant and equipment

​

Revised: Mar 2017

Reviewed: April 2019

 

Signed by………………..

Director of A2O People

The next review of this policy will be in March 2021.

​

 

Quality Assurance Policy

This policy statement establishes the basis on which A2O People will lead its organisation toward the continual improvement of its quality management processes. We are working to build a company that is regarded by its employees and associates as one they are proud to work for, that communicates with them, listens and responds appropriately, and values and invests in them.

A2O People are committed to working towards the requirements contained within the Quality Management Systems standard BS EN ISO 9001:2008.

A2O People are members of REC (Recruitment Employment Confederation), the main representative body for the recruitment industry.  We comply with the REC Code of Practice to demonstrate our commitment to professional and ethical recruitment.

We are registered with the Information Commissioner's Office and comply with the good practices and obligations to protect information under the Data Protection Act.

A2O People is committed to:

·        Establishing and communicating meaningful quality objectives and performance targets to all staff

·        Ensuring that any nonconformities are recorded, and seeking ways to eliminate the causes that lead to non-compliance

·        Ensuring that the services we provide are suitable for the defined purpose and delivered in a timely and cost effective way

·        Ensuring its future success through customer satisfaction to secure ongoing repeat business

·        Giving all employees, associates and volunteers the opportunity to develop to their full potential and undertaking staff training to raise the professional level and the quality of services provided

·        Complying with regulatory, statutory and customer requirements

·        Respecting privacy and committing to not sell, share, or rent data other than to enable us to provide our HR and recruitment related services

·        Ensuring our associates are fully aware of the requirement for quality and are given all necessary information

·        Utilising a process of continual improvement where everyone is encouraged to review working practices and suggest methods for improvement

Revised: Mar 2017

Reviewed: April 2019

Signed by………………..

Director of A2O People

The next review of this policy will be in March 2021.

 

 

Environmental Policy

This policy statement establishes the basis on which A2O People will lead its organisation toward the continual improvement of its environmental management processes.

The nature of our work as a consultancy means that we do not have a high environmental impact. However we still endeavour to reduce the environmental impact of our services and are committed to working towards the requirements contained within the Environmental Management Systems standard BS EN ISO 14001: 2004 as applicable to our type of business.

We are committed to:

• Complying with and exceeding all applicable legal requirements and any other requirements needed to meet environmental targets
• Regular review of our of environmental impacts
• Managing all operations performed by A2O People’s workforce including all staff, volunteers, associates and contractors to ensure we minimise our environmental impact

​

Revised: Mar 2017

Reviewed: April 2019

 

Signed by………………..

Director of A2O People

The next review of this policy will be in March 2021.

 

 

Training and Development Policy

A2O People Ltd has a belief in the need to develop employees based on the principles that the organisation:

• thinks of its workforce as an asset as well as a cost, and believes that it should invest in that asset;
• believes that all its employees have the potential to grow, both in their work role and personally, and it shall endeavour to provide opportunities for this growth;
• considers it appropriate to base such training and development opportunities on the requirements of the business, and decisions about investment in staff training and development will be made accordingly;
• believes that responsibility for training and development should be shared between the organisation and its workforce;
• will ensure that appropriate procedures are in place to plan, deliver and evaluate training and development activity;
• wants to empower its staff members to take some ownership of their own development, with support from their managers and the organisation as a whole;
• believes that its line managers have a key role to play in people development;
• works within recognised good practice guidelines, such as the national standard of Investors in People, to ensure that both the quality and quantity of training and development is relevant and "fit for purpose";
• regularly reviews its overall level of investment in staff training and development to ensure that adequate and appropriate resources are provided; and
• plans its training and development activities in line with industry standards, and here relevant maintains relationships with relevant bodies, such as Sector Skills Councils.

Training and development initiatives

The organisation provides a range of training and development opportunities to staff. These fall into four broad categories:

• Programmes relating to the enhancement of skills for an employee's current position. These include internal and external courses providing technical training, for example on the use of software packages, and specialist training relating to the skills that employees require for their job.
• Programmes leading to a professional or academic qualification. The organisation encourages employees who wish to do so to pursue continuous professional development and where appropriate to gain further qualifications.
• Programmes that have a specific management or supervisory focus. These include internal and external courses on manager development, supervisory skills for line managers, and leadership development programmes.
• Health and safety training. This includes courses in manual handling, risk assessment, fire safety, first aid, and food and hygiene regulations.

Decisions on the suitability and applicability of programmes will be determined through the performance review process, during which individual training and development needs are identified within a personal development plan. Progress on the acquisition of new skills and knowledge will be monitored throughout this process.

Roles and responsibilities for implementation

Both line managers and employees have a responsibility to implement training and development initiatives. There will be an opportunity to discuss development needs through the performance review process and agree appropriate courses of training or study. Line managers should encourage their staff to undertake relevant programmes. Employees are expected to take up the opportunities provided and report back to their line manager on their applicability once completed.

Line managers have a responsibility to monitor and evaluate the effectiveness of learning for employees who have undergone training and development. Line managers can should provide feedback on internal and external training programmes, including their quality and cost effectiveness. Line managers should ensure that employees implement the skills that they have gained through training.

Planning and implementing new initiatives

Any new training initiatives will be planned as a result of training needs analysis activities, which in turn are part of the organisation's performance review process. In addition, the organisation is committed to reviewing training initiatives so that relevant training and development is provided for skills in specific job areas, where work procedures have changed, or where new standards are introduced. Any new training and development programmes offered to staff will be publicised through the organisation's normal communication channels, including the intranet, staff notices and departmental meetings. The organisation will make use, where appropriate, of e-learning, and training will be provided to staff in how to access materials while at work and from home.

Individual requests for training and development

Employees can request training and development at any time but this will usually be done within the performance review process, as outlined above. Employees should channel requests through their line manager.

Monitoring and evaluating investment in training and development

The organisation firmly believes that it is critical to the success of both the planning and delivery of training and development activities that the resources invested are monitored and the outcomes achieved are measured. Such outcomes may be demonstrated at an individual, departmental and corporate level. Senior managers have an important role to play in this process. The organisation uses its evaluation findings for future business planning and the planning of continued investment in staff training and development. Accordingly the evaluation findings are regularly shared with the senior executive team.

Coaching and mentoring

The organisation encourages line managers to provide coaching and mentoring support for staff who are undergoing training and development. Managers have a responsibility to ensure that the skills and knowledge of more experienced staff members are shared with more junior employees to ensure that learning occurs in a planned way.

Recording of training and development activities

All training attended will be recorded along with costs, including, for example, travel and subsistence expenses and the cost of textbooks. On completion of any internal or external course the employee will complete a course evaluation form, countersigned by the line manager. Analysis of the evaluation forms gathered will be undertaken and used within the overall evaluation of training and development.

Equal opportunities

Decisions relating to training and development should be made fairly and consistently, and equality of opportunity should be provided for all staff in this area.

Induction training

All new members of staff and all those changing job role will receive appropriate inductions.

 

Revised: March 2017

Reviewed: April 2019

 

Signed by………………..

Director of A2O People

The next review of this policy will be in March 2021.

 

 

Complaints Handling & Appeals Policy

We are committed to providing a high-quality professional service to all our clients.  When something goes wrong, we need you to tell us about it.  This will help us to improve our standards.

If you have a complaint, please contact us with the details. This can be in person, by phone, email or letter.

 

What will happen next?

1. We will send you a letter or email acknowledging receipt of your complaint within three days of receiving it, enclosing a copy of this procedure.

2. We will then investigate your complaint. This will normally involve passing your complaint to our Director, Shane Keaney who will review the matter and speak to the member of staff who acted on this matter.

3. Shane Keaney will then discuss with you and hopefully resolve your complaint. He will do this within 14 days of sending you the acknowledgement letter.

4. Within three days of the discussion, Shane Keaney will write to you to confirm what took place and any solutions he has agreed with you.

5. If you do not want a meeting or it is not possible, Shane Keaney will send you a detailed written reply to your complaint, including his suggestions for resolving the matter, within 21 days of sending you the acknowledgement letter. 

6. At this stage, if you are still not satisfied, you should contact us again and we will arrange for Jackie Stone, or someone unconnected with the matter at the firm, or appropriate alternative (such as review by mediation) to review the decision.

7. We will write to you within 14 days of receiving your request for a review, confirming our final position on your complaint and explaining our reasons.

8. Should you still not be satisfied with our response you may appeal our decision with the relevant awarding organisations or accreditation bodies.

9. We log all complaints, undertake analysis of any root causes and make sure any trends are acted upon.

Revised: March 2017

Reviewed: April 2019

 

Signed by………………..

Director of A2O People

The next review of this policy will be in March 2021.

 

 

Anti-Bribery and Corruption Policy

We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by UK laws, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

This Policy applies to any individual or organisation we come into contact with during the course of our work and is applicable to all persons working directly for A2O People or on our behalf.

It is not acceptable for any person working for A2O People or on our behalf to:

• give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received;
• give or accept a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;
• accept a payment, gift or hospitality from a third party that you know or suspect is offered with the expectation that it will provide a business advantage for them or anyone else in return;
• make or accept, facilitation payments or "kickbacks" of any kind. 

If you have any suspicions, concerns or queries regarding a payment, you should raise these with your Director. The Company will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken.

This policy allows reasonable and appropriate hospitality or entertainment given to or received openly, not secretly, from third parties, for the purposes of:

• establishing or maintaining good business relationships;
• improving or maintaining our image or reputation; or
• marketing or presenting our products and / or services effectively. 
• all offers of gifts or Corporate Entertainment / Hospitality to and from Clients with a monetary value of £50 or more must be notified to your Director for approval
• all accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off the record” to facilitate or conceal improper payments.
• we appreciate that practice varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all circumstances the gift, hospitality or payment is reasonable and justifiable. The intention behind it should always be considered.

Revised: Jan 2017

Reviewed: April 2019

 

Signed by………………..

Director of A2O People

The next review of this policy will be in March 2021.

 

 

Whistleblowing Policy

It is important that any criminal behaviour or other wrongdoing by an employee, or any individual undertaking work with A2O People is reported and properly dealt with. A2O People is committed to ensuring that no member of staff, trainee or associate should feel at a disadvantage in raising legitimate concerns.

This Whistleblowing policy is underpinned by the Public Interest Disclosure Act 1998 (known as the Whistleblowers Act). This gives legal protection to employees against being dismissed or penalised by their employers as a result of publicly disclosing certain serious concerns. A2O People extend this to ensuring that any trainee or associate is not penalised as a result of publicly disclosing legitimate concerns.

 

Scope

This policy is intended to cover concerns which are in the public interest and may at least initially be investigated separately but might then lead to other procedures e.g. disciplinary. These concerns could include:

·        Financial malpractice or impropriety or fraud

·        Failure to comply with a legal obligation or Statutes

·        Dangers to Health & Safety or the environment

·        Criminal activity

·        Improper conduct or unethical behaviour

·        Attempts to conceal any of these

 

Confidentiality

A2O People will treat all such disclosures in a confidential and sensitive manner. The identity of the employee, trainee or associate making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.

 

Procedure

If an employee, trainee or associate has a concern, they should first raise it with a Director of A2O People, verbally or in writing.  If they feel that this person may be involved or do not wish to approach them, then they should approach another member of the A2O team.

If the employee feels a senior manager / trustee may be involved, the employee may report the matter to the relevant awarding organisations or accreditation bodies for further investigation.

A2O People will ensure that an investigation takes place and make an objective assessment of the concern.  The employee, trainee or associate will be kept advised of progress and the organisation will ensure the action necessary to resolve the concern is taken.

In all cases, the employee, trainee or associate is encouraged to exhaust A2O People’s internal procedures before contacting external sources.

Updated: March 2017

Reviewed: April 2019

 

Signed by………………..

Director of A2O People

The next review of this policy will be in March 2021.

 

 

Data Protection Policy

As a training provider, business advisor / consultancy and recruitment business it is necessary for the Company to collect and process both personal data and on occasion sensitive personal data.  It is required to do so in the normal and proper conduct of business operations and to comply with legislation.  It is required to keep this data for different periods depending on the nature of the data.  

The Company processes personal data in relation to trainees, work-seekers, external training providers, current and former staff, business partners / associates and individual client contacts and is a data controller for the purposes of the Data Protection Laws. The Company has registered with the ICO and its registration number is ZA086256.

The Company may hold personal data on individuals for the following purposes:

• Staff administration;
• Advertising, marketing and public relations;
• Accounts and records;
• Administration and processing of trainees’ and work-seekers’ personal data for the purposes of providing training, certification, and work-finding services, including processing using software solution providers and back office support;
• Administration and processing of clients’ personal data for the purposes of supplying/introducing work-seekers and providing training / coaching / business advisory services;

 

1. The data protection principles  

The Data Protection Laws require the Company acting as either data controller or data processor to process data in accordance with the principles of data protection. These require that personal data is:

1. Processed lawfully, fairly and in a transparent manner;
2. Collected for specified and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. Accurate and kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
5. Kept for no longer than is necessary for the purposes for which the personal data are processed;
6. 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; and that
7. The data controller shall be responsible for, and be able to demonstrate, compliance with the principles.

 

2. Legal bases for processing

The Company will only process personal data where it has a legal basis for doing so. Where the Company does not have a legal reason for processing personal data any processing will be a breach of the Data Protection Laws.

The Company will review the personal data it holds on a regular basis to ensure it is being lawfully processed and it is accurate, relevant and up to date.

Before transferring personal data to any third party (such as past, current or prospective employers, parties in the employers supply chain assisting them in the recruitment process, recruiters working in partnership with A2O People, workshop facilitators, training providers responsible for the delivery of courses, educators and examining bodies, suppliers, customers and clients, intermediaries such as umbrella companies, persons making an enquiry or complaint and any other third party (such as software solutions providers and back office support)), the Company will establish that it has a legal reason for making the transfer in accordance with the EU General Data Protection Regulations.

 

3. Privacy by design and by default

The Company has implemented measures and procedures that adequately protect the privacy of individuals and ensures that data protection is integral to all processing activities such as data minimisation and retention.

 

4. Privacy notices

Where the Company collects personal data from the individual, the Company will give the individual a privacy notice at the time when it first obtains the personal data.

The Company shall provide any information relating to data processing to an individual in a concise, transparent, intelligible and easily accessible form, using clear and plain language. The information shall be provided in writing, or by other means, including, where appropriate, by electronic means.

Where the Company collects personal data other than from the individual directly, it will give the individual a privacy notice within a reasonable period after obtaining the personal data, but at the latest within one month.  If the Company intends to disclose the personal data to a third party then the privacy notice will be issued when the personal data are first disclosed (if not issued sooner).

Where the Company intends to further process the personal data for a purpose other than that for which the data was initially collected, the Company will give the individual information on that other purpose and any relevant further information before it does the further processing.

 

5. Subject access requests

The individual is entitled to access their personal data on request from the data controller.

 

6. Rectification

The individual or another data controller at the individual’s request, has the right to ask the Company to rectify any inaccurate or incomplete personal data concerning an individual.

If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to rectify the personal data unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.

 

7. Erasure

The individual or another data controller at the individual’s request, has the right to ask the Company to erase an individual’s personal data.  

If the Company receives a request to erase it will ask the individual if s/he wants his personal data to be removed entirely or whether s/he is happy for his or her details to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise).  The Company cannot keep a record of individuals whose data it has erased so the individual may be contacted again by the Company should the Company come into possession of the individual’s personal data at a later date.

If the Company has made the data public, it shall take reasonable steps to inform other data controllers and data processors processing the personal data to erase the personal data, taking into account available technology and the cost of implementation.

If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to erase the personal data, unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.

 

8. Restriction of processing

The individual or a data controller at the individual’s request, has the right to ask the Company to restrict its processing of an individual’s personal data where:

• The individual challenges the accuracy of the personal data;
• The processing is unlawful and the individual opposes its erasure;
• The Company no longer needs the personal data for the purposes of the processing, but the personal data is required for the establishment, exercise or defence of legal claims; or
• The individual has objected to processing (on the grounds of a public interest or legitimate interest) pending the verification whether the legitimate grounds of the Company override those of the individual.

If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to restrict the personal data, unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.

 

9. Data portability

The individual shall have the right to receive personal data concerning him or her, which he or she has provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller in circumstances where:

• The processing is based on the individual’s consent or a contract; and
• The processing is carried out by automated means.

Where feasible, the Company will send the personal data to a named third party on the individual’s request.

 

10. Object to processing

The individual has the right to object to their personal data being processed based on a public interest or a legitimate interest. The individual will also be able to object to the profiling of their data based on a public interest or a legitimate interest.

The Company shall cease processing unless it has compelling legitimate grounds to continue to process the personal data which override the individual’s interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

The individual has the right to object to their personal data for direct marketing.

 

11. Enforcement of rights

The Company shall act upon any subject access request, or any request relating to rectification, erasure, restriction, data portability or objection or automated decision making processes or profiling within one month of receipt of the request. The Company may extend this period for two further months where necessary, taking into account the complexity and the number of requests.

Where the Company considers that a request under this section is manifestly unfounded or excessive due to the request’s repetitive nature the Company may either refuse to act on the request or may charge a reasonable fee taking into account the administrative costs involved.

 

12. Automated decision making

The Company will not subject individuals to decisions based on automated processing that produce a legal effect or a similarly significant effect on the individual, except where the automated decision:

• Is necessary for the entering into or performance of a contract between the data controller and the individual;
• Is authorised by law; or
• The individual has given their explicit consent.

The Company will not carry out any automated decision-making or profiling using the personal data of a child.

 

13. Reporting personal data breaches

a. Personal data breaches where the Company is the data controller: 

Where the Company establishes that a personal data breach has taken place, the Company will take steps to contain and recover the breach. Where a personal data breach is likely to result in a risk to the rights and freedoms of any individual the Company will notify the ICO.

Where the personal data breach happens outside the UK, the Company shall alert the relevant supervisory authority for data breaches in the effected jurisdiction.

b. Personal data breaches where the Company is the data processor:

The Company will alert the relevant data controller as to the personal data breach as soon as they are aware of the breach.

c. Communicating personal data breaches to individuals

Where the Company has identified a personal data breach resulting in a high risk to the rights and freedoms of any individual, the Company shall tell all affected individuals without undue delay.

The Company will not be required to tell individuals about the personal data breach where:

• The Company has implemented appropriate technical and organisational protection measures to the personal data affected by the breach, in particular to make the personal data unintelligible to any person who is not authorised to access it, such as encryption.
• The Company has taken subsequent measures which ensure that the high risk to the rights and freedoms of the individual is no longer likely to materialise.
• It would involve disproportionate effort to tell all affected individuals. Instead, the Company shall make a public communication or similar measure to tell all affected individuals.

 

14. Human Rights Act 1998

All individuals have the following rights under the Human Rights Act 1998 (HRA) and in dealing with personal data these should be respected at all times:

• Right to respect for private and family life (Article 8).
• Freedom of thought, belief and religion (Article 9).
• Freedom of expression (Article 10).
• Freedom of assembly and association (Article 11).
• Protection from discrimination in respect of rights and freedoms under the HRA (Article 14).

 

If you need to notify us of a data protection issue or if have a complaint or query about the Company’s handling of personal data then please contact Shane Keaney by emailing connect@a2opeople.co.uk or calling +44 1278 732073.

You also have the right to raise concerns with the Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.

Issued: April 2018

Reviewed: April 2019

Signed by………………..

Director of A2O People

The next review of this policy will be in March 2021.