BRIGHT FUTURES

POLICIES & PROCEDURES

SAFEGUARDING

Safeguarding Policy and Procedures for Bright Futures written December 2021

Bright Futures is committed to safeguarding and promoting the welfare of young people and vulnerable adults and has a statutory and moral duty to ensure that while receiving education, training, or taking part in any of our group or 1-2-1 sessions they are safeguarded.

The Children Act defines a child as a person under the age of 18 years.
Safeguarding responsibilities also extend beyond the age of 18 to a group of vulnerable adults. A vulnerable adult is defined as a person aged eighteen or over, who has either a dependency upon others or a requirement for assistance in the performance of basic functions. This can be as a result of a learning or physical disability, a physical or mental illness or an addiction to alcohol.

This policy applies to all learners, staff, volunteers, and visitors working with Bright Futures

Designated Safeguarding Officer is: Laura Rigby

We are committed to ensuring that Bright Futures provides a safe environment in which young people can receive high quality training when working with us.

Takes appropriate action to see that young people and adults are kept safe at their place of training / employment and during all sessions.

Handle confidential information of a personal and/or sensitive nature following the correct procedures and that staff receive guidance on the management and disclosure of confidential information, where appropriate.

In pursuit of these aims, Bright Futures will approve and annually review policies and procedures with the aim of:

Ensuring the safe recruitment of any coaches and for children/ young people in all sessions.

Promoting a safe environment for the young people to learn in, both when training and when in 1:1 sessions and raise awareness of issues relating to the welfare of young people and their families.

Aiding the identification of young people at risk of significant harm, and providing procedures for reporting concerns

Establishing procedures for reporting and dealing with allegations of abuse against members of staff or clients

Supporting staff to manage vulnerable learners.

Ensuring that any sensitive matters are dealt with in a confidential manner.

Bright Futures and Bright Futures Coaches should keep themselves and others safe from:

Physical abuse – including assault, hitting, slapping, pushing or inappropriate physical sanctions.

Sexual abuse – including rape, sexual harassment, or sexual photography. Psychological abuse – including emotional abuse, threats of harm, humiliation, controlling, intimidation, harassment, verbal abuse, cyber bullying, or isolation.

Discriminatory abuse – including forms of harassment, slurs or similar treatment because of race, gender/gender identity, age, disability, sexual orientation, or religion.

Domestic abuse – including psychological, physical, sexual, financial, emotional, or so- called. ‘honour’ based violence.

Self-neglect – this covers a wide range of behaviour such as neglecting to care for your personal hygiene, health, or surroundings and includes behaviour such as hoarding.

Neglect – including ignoring medical, emotional, or physical care needs.

Financial or material abuse – including theft, fraud, or internet scamming.

Radicalisation/Extremism – defined as vocal or active opposition to fundamental human values of our society, including democracy, the rule of law, individual liberty and mutual respect and tolerance of.

If you notice a change in a someone’s behaviour or are concerned in any way about the safety or wellbeing of a young person please report it to the Safeguarding Officer, who will take appropriate action.

Staff are expected to:

Complete safeguarding training as required.
Familiarise themselves with the Safeguarding policy and associated procedures. Safeguard and promote the welfare of children, young people and vulnerable adults. Alert the Designated Safeguarding Officer if they have concerns about a child or young person.

Designated Safeguarding Officer:

The Designated Member of Staff for Safeguarding is Laura Rigby, she has a specific responsibility for championing the importance of safeguarding and promoting the welfare of children / young people who are learners at Bright Futures.

The Designated Safeguarding Officer will:

Act as the first point of contact with regards to all safeguarding matters.
Attend up-dated training.
Provide support and training for staff and volunteers.
Ensure that we are in line with the Safeguarding Vulnerable Groups Act 2006
Support staff to make effective referrals to the Children and Families Services and any other agencies where there are concerns about the welfare of a child.
Keep copies of all referrals to Children and Families Services and any other agencies related to safeguarding children.
Ensure that all staff specific responsibility for safeguarding children receive the appropriate training to undertake this role.
Manage and keep secure the safeguarding records.
Ensure that all staff and volunteers understand and are aware of reporting and recording procedures and are clear about what to do if they have a concern about a child.
Liaise with the Safeguarding Officer about any safeguarding issues.
Ensure that the safeguarding policy is regularly reviewed and updated.
Keep up to date with changes in local policy and procedures and are aware of any guidance issued concerning safeguarding.

Safer Recruitment of Staff

Bright Futures undertakes to ensure that their staff are fit to work in a training provider setting with children. It also reserves the right to refuse to employ staff whom it has a reasonable belief may pose a risk to its learners.

Bright Futures has systems in place to prevent unsuitable people from working with children and to promote safe practice. These systems apply to all new staff and require the following checks to be made prior to appointment:

Minimum of two references, one of which should be from a previous employer documentary evidence checks of identify, nationality, residency and “right to work” status.

Enhanced DBS (Disclosure & barring service) check with barred list information*

Documentary evidence of qualifications (as applicable to role)

Satisfactory completion of the Bright Futures Training Programme.

Where subcontractors are delivering courses on the premises, the provider must provide written assurance that all relevant staff will be DBS checked.

In accordance with the Regulations, records of all checks carried out are kept in a single central record.

*If a DBS check is delayed for any reason the staff member will not be subject to lone working with apprentices aged under 18. They must always have a member of staff present who is fully DBS checked until the point they receive a full DBS check.

Staff Development and Training

Bright Futures Safeguarding policy, procedure and guidance will be issued to all new staff as part of their induction. All staff will be supported to recognise warning signs and symptoms in relation to specific safeguarding issues and will receive training relating to Safeguarding.

What to do if you suspect someone is being abused.

All staff, volunteers and others working in direct contact with sessions must be alert to the signs of abuse.
Anyone who suspects that abuse is taking place inside or outside of a Bright Futures Session, or to whom a learner discloses issues relating to safeguarding, should contact the Designated Safeguarding Officer immediately.
Staff who are not Designated Safeguarding Officers, but who are approached with concerns about a child, must bring the concerns raised to the attention of the Designated Safeguarding Officer immediately.
All staff to whom a learner discloses issues that may be related to safeguarding must keep written records of concerns. Such records must be kept securely, separate from the main learner files and in locked locations.
The Designated Safeguarding Officer will develop effective links with relevant agencies and cooperate as required with any enquires regarding child protection matters, including attendance at case conferences.

Allegations of Abuse Against Members of Staff

Allegations of abuse, or concerns raised against members of staff, will always be treated seriously. The allegations need to be applied with common sense and judgement. All cases must be referred to the Designated Safeguarding Officer who will follow the Safeguarding Procedure in the same way as for other safeguarding allegations.

The Designated Safeguarding Officer will take the appropriate steps to ensure the safety of the
child and any others who may be at risk. The Designated Safeguarding Officer will also inform the staff member, in order that training provider procedures may be followed, and an investigation is carried out. If the allegation or concern is against the Designated Safeguarding Officer.

This may result in possibly criminal (police) investigations and/or a child protection investigation, carried out by Social Services.

Disclosure & Barring Service (DBS)

Bright Futures has a responsibility to ensure safe recruitment and employment practices.

New and existing staff who frequently or intensively works with children in training supervision, care, and advice must be checked through the DBS. This information will then be kept securely. Relevant details will be kept on a Single Central Record that will be subject to annual checks and audits.

Reporting Cases to the Disclosure and Barring Service (DBS)

Bright Futures has a statutory duty to carry out reports, and provide relevant information to
the DBS where there are grounds for believing, following an investigation, that an individual is unsuitable to work with children, young people or vulnerable adults, or may have committed misconduct. The responsibility for reporting cases to the DBS lies with the Designated Safeguarding Officer.

Resignations

If, during the course of an investigation relating to safeguarding, an employee tenders his or her resignation, or ceases to provide their services, Bright Futures is not prevented from following up an allegation in accordance with these procedures. Every effort will be made to reach a conclusion in cases relating to the welfare of children, young people or vulnerable adults, including those where the person concerned refuses to co-operate with the process.

Support for Staff

Bright Futures is aware that safeguarding cases can be distressing and that staff who have been involved may find it helpful to talk about their experiences, in confidence, with one of the Designated Safeguarding Officers or with a trained counsellor. Staff wishing to be referred for counselling should discuss with the Safeguarding lead.

Reviewed by: Laura Rigby 20/1/2024

Next review date: 20/1/2025

SAFER RECRUITMENT

Bright Futures Safer Recruitment Policy – March 2023

This policy is to ensure that the individuals responsible for recruitment and selection always hire and promote the most appropriate applicant or employee in a safe, fair and consistent manner, free from discrimination and to ensure that relevant processes are followed to protect vulnerable groups.

We are committed to safeguarding and promoting the welfare of children and vulnerable young adults, which is reflected within our recruitment and selection activities. We will ensure that the recruitment and employment of staff is carried out in line with relevant statutory guidance on safer recruitment for education and vulnerable adult settings, and make sure that those involved with the recruitment and employment of staff to work with children and young adults receive appropriate safer recruitment training.

It is our policy to look to fill any open position by internal promotion or transfer wherever possible. All applicants will be assessed objectively on their merits in accordance with our Equal Opportunities policy. Any person involved in the selection and interview processes who have a conflict of interest should declare it immediately to your line manager.

Advertisement

The individual(s) placing the advertisement(s) must ensure that they use a variety of media to reach a broad cross-section of potential applicants and must include the following points:

The job title
Our commitment to safeguarding and promoting the welfare of children and vulnerable young adults
Detail which confirms applicants will undergo strict vetting procedures and safeguarding checks before appointment and relevant pre-employment checks (this includes but is not limited to: DBS checks, qualification checks, reference checks and identity checks)
The safeguarding responsibilities of the post as per the job description and/or personnel specification
Whether the post is exempt from the Rehabilitation of Offenders Act (ROA) 1974

The salary or pay scale
Any significant benefits applicable to the position
Any minimum qualifications for the position
Any particular skills and/or experience required for the position
Any required training which must be completed on confirmation of successful appointment
Any typical features of the position (e.g. part-time, fixed-term, outside UK etc)
The closing date for applications

Care will be taken to avoid specifying requirements for the position which are potentially discriminatory either directly or indirectly.

Job description

Where we use job descriptions to assist in the drafting of a job advert, we will ensure the details incorporated are concise and relevant to the job role being advertised and include any safeguarding requirements.

Where personnel specifications are used along with the job advert only those details which are relevant such as essential or desirable knowledge, skills and experience will be included, along with any safeguarding requirements.

Applications

Application forms will seek only information which is necessary for the selection process.

Where the role involves engaging in regulated activity relevant to children and/or vulnerable young adults, we will include a statement in the application form that it is an offence to apply for the role if the applicant is barred from engaging in regulated activity relevant to children.

Applicants will be required to provide:

Personal details including current and former names, current address and national insurance number
Details of their present (or last) employment and reason for leaving
Full employment history (since leaving school, including education, employment and voluntary work) including reasons for any gaps in employment.

Qualifications, the awarding body and date of award
Details of referees/references

A statement of the personal qualities and experience that the applicant believes are relevant to their suitability for the post advertised and how they meet the personnel specification

We will only accept a curriculum vitae (CV) alongside a completed application form. A CV on its own will not contain adequate information.

At each stage of the process, applicants will be kept informed and should expect to be told the following:

When they can expect to hear whether their application is to be progressed to the next stage of the recruitment process
What the next stage will involve

Decisions taken to either reject or accept an application will be checked and approved by HR before they are communicated to the applicant.

Shortlisting

Short-listed candidates will be asked to complete a self-declaration of their criminal record or information that would make them unsuitable to work with children or young adults, to give candidates the opportunity to share relevant information and allow this to be discussed and considered at interview before the DBS certificate is received.

We will ensure that at least two people carry out the shortlisting exercise. For consistency, the same people will carry out the interview, where possible.

During the shortlisting process, we may carry out an online search on the shortlisted candidates, as part of our due diligence. If the search identifies any incidents or issues that are publicly available online, we will explore these with the applicant at interview.

Selection tests

We will use a range of selection techniques to identify the person most suitable for the post. Where selection tests are used in the recruitment process, they will be checked by HR to ensure:

They are free from any discriminatory element
The test is directly relevant for the position being interviewed for.
The individual is suitable qualified and not a risk to our clients Prior to the interview

Where possible, we will obtain references prior to interview so that any concerns raised can be explored further with the referee and taken up with the candidate at interview.

Interview

The interview will be conducted by two members of staff and thorough notes taken.

All questions asked will be directly relevant to one or more of the selection criteria that have been identified for the position.

No assumptions will be made nor will questions about the applicant’s personal circumstances be asked.

During the interview we will seek to determine the applicant’s suitability to work with children and/or young adults and explore any potential areas of concern.

Any information about past disciplinary action or substantiated allegations will be considered in the circumstances of the individual case.

Interview questions will be structured to include:

Finding out what attracted the candidate to the post being applied for and their motivation for working in this field
Exploring their skills and asking for examples of experience of working with children and/or young adults which are relevant to the role
Probing any gaps in employment or where the candidate has changed employment or location frequently, asking about the reasons for this

Whether they have the physical and mental capacity for the specific role.

After the interview

Once the interview has taken place and the decision has been made, we will contact the successful individual and arrange the start date for the position. page5image960845760 page5image960532736

Candidates may be asked to carry out a short trial period (paid) of up to a week before we make an offer. Relevant vetting, safeguarding and pre-employment checks will be carried out before the commencement of any trial period.

If at any point during the recruitment process, any issues arise then you should report your concerns to HR who will review your concerns.

Vetting and pre-employment checks

Offers of employment will be subject to us receiving satisfactory pre-employment checks, including an enhanced DBS check from the Disclosure and Barring Service. We will be legally obliged to defer start dates if the relevant checks are not completed by the specified start date.

Offers of employment will also be subject to satisfactory references being obtained, proof of any relevant qualifications, satisfactory identity checks and evidence of the applicant’s right to work in the UK. Where candidates have lived or worked outside the UK, we will carry out any further checks we consider appropriate.

Internal recruitment

It is important that we recruit people that are suitable for the position and who will deliver a high standard of education to our pupils/students. We take the recruitment, development, and promotion of our staff seriously and we do this by following a fair and non-discriminatory process. We are committed to the safeguarding and welfare of our clients and will ensure that all relevant checks are completed to ensure safe recruitment is conducted in line with our processes and procedures, and relevant statutory guidance.

Any opportunities for promotion will be advised and open to all members of staff and if you feel you have the skills and experience to bring to the role then we welcome your application and any questions that you may have.

Record keeping

We will keep a clear record of all information considered in the decision making, along with decisions made.

The Equality Act 2010 places a positive obligation on the Organisation to make all adjustments that are deemed reasonable where these have the purpose of removing or reducing substantial disadvantages faced by disabled individuals, when compared to non-disabled individuals.

The duty arises in relation to any:

Workplace provision, criterion or practice
Physical feature within the workplace
Provision of auxiliary aids or service

Our commitment as an employer

The Organisation is committed to taking positive and proactive steps throughout the recruitment process and the ongoing employment of our workforce to ensure appropriate and effective adjustments are put in place.

This commitment covers the following areas of our organisation; this is a non-exhaustive list and adjustments to other areas may be appropriate depending on the circumstances:

Application process
Recruitment assessments
Interview process
Induction sessions
Workloads
Working hours
Workspaces
Training sessions
Car parking
Access to facilities such as canteen facilities

Absence management

As an employer, we would encourage all employees to submit any requests or raise adjustment matters with their line manager as soon as possible. Any requests or matters raised will be treated positively and sensitively in line with our commitment, and no detriment, harassment or unfavourable treatment will result as a consequence of an employee bringing any adjustment matters to the attention of their line manager.

Internal process

To aid the introduction of appropriate and effective workplace adjustments, the Organisation will follow a standard process of consideration, unless adjustments are necessary to remove any disadvantages faced by the employee as a result of this process.

Once the Organisation is aware, or can reasonably be expected to be aware, that an employee is disabled, a discussion on reasonable adjustments will be held between the employee and their line manager. This meeting will provide the opportunity for an open and honest discussion about the disadvantages faced by the employee at work and the identification of potential adjustments that could reduce or remove these. At the meeting, the reasonable adjustment action plan will also be filled in to contain a record of these discussions.

Full consideration will be given to each adjustment to determine whether it:

Reduces or removes the disadvantage faced by the disabled individual and It is reasonable for the organisation to make
A confirmation of the adjustments that will be put in place after this meeting will be sent to the employee in writing.
A copy of this confirmation and the completed reasonable adjustment action plan will be placed on the employee’s personnel file to ensure this is accessible by the employee’s current and future line managers.

Using trial periods

To ensure the organisation is meeting their commitment of putting in place appropriate and effective adjustments, the use of a trial period for adjustments may be introduced where appropriate.

A trial period allows the organisation and the employee to evaluate the practical impact of any agreed adjustments, ensuring that these go as far as possible at reducing or removing the disadvantages faced by the individual.

A trial period will only be used where this is agreed by the employee and will be for a short period. A review at the end of the trial period will be used to assess the practical suitability of the adjustment and may, if this is not suitable, lead to amendments or alternative adjustments being introduced.

Reviewing adjustments

As part of our ongoing commitment, the Organisation will undertake periodic reviews of agreed adjustments to ensure these remain suitable and have the continued required effect.

A review will be undertaken once an adjustment has been in place for at least three months, and will be repeated at least every six months. The employee is encouraged to fully participate in these reviews to allow full consideration of the effectiveness of the adjustment.

The outcome of this review may be that the adjustment in place continues, is altered or alternative adjustments are introduced.

Medical advice page8image960546592 page8image960553968

To aid the consideration of suitable adjustments, the Organisation will encourage employees to provide any medical advice or guidance they have received from medical experts. Any advice or guidance provided will be fully reviewed and used to consider the effectiveness of introducing, and continuing, the workplace adjustments.

It may be the case that an Occupational Health (OH) referral is suitable to receive expert advice on workplace adjustments. In these circumstances, the employee’s consent will be sought in advance of any referral.

Concerns

If an employee has any concerns regarding the making or consideration of workplace adjustments, they are encouraged to raise this to the attention of their line manager as soon as possible. Once made aware, the line manager will undertake an investigation and feedback to the employee concerned.

Alternatively, where this is not appropriate, an employee may raise any concerns through the internal grievance policy. The policy is available to view in the employee handbook.

Reviewed: March 2024

Next review: March 2025

DATA PROTECTION

Bright Futures follows the following principles to protect your privacy:

We do not collect more information than is necessary
We do not use your data for purposes other than those specified
We do not keep your data if it is no longer needed
We only provide your data to select third party clients for the specific purposes listed in this policy.

If you have any questions about this policy or more generally about our use of your personal information, you may contact us by writing to us at Data Protection, Bright Futures Training & Coaching Ltd, 167-169 Great Portland Street (5TH FLOOR) London W1W5PF email us at [email protected] or phone us on +44 07814 709127

This policy is effective as at 01 Dec 2021

Bright Futures reserves the right to amend the policy at any time.

How we collect your personal information

These are the main ways we collect your information:

From your employer, if our services are procured by them on your behalf
From you if you contact us direct in person, via our associate network, by telephone or via our website to request information about our services and events
If you buy a service directly from us
If you reply to our direct marketing campaigns
If your contact details are obtained from third parties, such as recruitment agencies or third- party data profiling companies, where you have either given your consent for that company to pass information on to us or we are using your data on a legitimate interest basis
From third-parties and partners working with us to deliver a service (e.g. associate Coaches etc)
If we acquired your personal data from other sources, for example social media sites
From our website’s technological capabilities.
If you give personal information to us on behalf of someone else you must ensure that you have their permission and that they have been provided with this Privacy Policy before doing so.

Please help us to keep your information up to date by informing us of any changes to your contact details or privacy preferences by emailing [email protected]

What information may be collected about you.

We may collect the following information:

Name
Email address
Other relevant personal information (e.g. date of birth)
Related background to support a coaching session

We may only process your personal information where we have a lawful basis for processing it. What this lawful basis is, depends on the type of personal information you provide and the service we are providing. Where we want to process personal information for a specific purpose that is not identified in this Privacy Policy we will notify you at that time.

The use of your information set out above is permitted under UK data protection law on the basis of these principal legal grounds:

Where you have consented to the use (you will have been presented with a consent form in relation to any such use and may withdraw your consent at any time)
Where necessary to enter into or perform our contract with you
Where we need to use it to comply with our legal obligations
Where we use it to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights (our legitimate interests include but are not limited to promoting the business and tailoring news and offers to your profile, research and development of our services).

There may be uses that are permitted on the basis of other grounds; where this is the case we will use reasonable endeavours to identify the ground and communicate it you as soon as possible after becoming aware of the new basis.

What we do with the information we gather

We require information to understand your needs and provide you with the best possible service.
The main uses of your information are:

Internal record keeping and account management purposes (e.g. fulfilling and managing our contractual and service obligations)
Reviewing your career history, skills and capabilities to consider your suitability for future / different job opportunities
Providing you with the service you have requested from us
Improving our services
Contacting you by email, SMS, phone or mail for account administration and / or processing orders and fulfilling contractual obligations and / or taking payment for such orders
Customising our website according to your interests
Sending promotional emails or contacting you by telephone with information which we think you may find interesting
Contacting you for market research purposes
Complying with legal requests to fulfil our legal obligations to law enforcement, regulators and the court service.

Marketing

We send commercial emails to individuals at our clients or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws.

Our targeted email messages typically include cookies, and similar technologies that allow us to know whether you open, read or delete the message and links you may click.

When you click a link in a marketing email you receive from Bright Futures, we will also use a cookie to log what pages you view and what content you download from our website.

Please also refer to the section on Cookies.

Targeted emails from Bright Futures Training & Coaching Ltd may include additional privacy information as required by applicable laws.

We may also combine data from publicly available sources and from our different email, website and personal interactions with you.

We combine this data to better assess your experience with Bright Futures Training & Coaching LTD and to perform other activities described throughout our privacy policy.

Third parties to whom we may transfer your data

Personal information which we collect may be transferred to or accessed by a third party without your consent if it there is a legitimate interest or contractual obligation to do so.

The types of third parties are:

Associates and partners who are responsible for / involved with the provision of services to you
Third party providers who provide us with systems and services that enable us to deliver our own services effectively
Law firms who provide legal advice to us (e.g. if there is a legal dispute)
This is only shared in a secure manner, using a consistent security protocol. When we share with other parties we ensure that they only use your personal data for the purpose it was collected and do not allow them to abuse this agreement.

Website information

Our website, brightfutures.me.uk is hosted by a third-party and is administered by Bright Futures.

The primary purpose of our website is to help you learn more about Bright Futures, our people and our services. We want you to feel secure when visiting our website and are committed to maintaining your privacy when doing so.

We use Google Analytics and cookies to improve our service, website user experience and to analyse how the website is used. This helps us to find out:

How many people visit our websites
Which pages and parts of pages are most popular
How long people spend in each area of the website
What information people are looking for.

These insights help us understand what customers want from our website and, consequently, how we can improve the website in the future.

Google Analytics uses cookies to collect non-personally identifiable information like:

Browser types
Operating systems
Third party sites that direct you to us
The time and date of a visit
Location data
Traffic data
Other communication data
Resources accessed and downloaded
This is used to filter traffic and to look up user domains and report on statistics.

We analyse your IP and browser information to determine what is most effective about our website and help us identify ways to improve it.

Customer Relationship Management (CRM) databases

Bright Futures Training & Coaching LTD uses customer relationship management (CRM) database technology to manage and track our marketing activities.

Our CRM databases include personal data belonging to individuals at existing clients and at other companies with whom we already have a business relationship or wish to develop one.

The personal data used for these purposes includes relevant business information such as contact data, publicly available information and other business information obtained by Bright Futures Training & Coaching LTD people based on their personal interactions with you.

Third party links and cookies Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website(s). Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

How we use cookies

Cookies are alphanumeric identifiers which enable our systems to recognise your browser in order that we can provide you with easy use of the various services available on the website.

Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

How we keep your information safe

The security of your information is very important to us. As part of our commitment to keeping your data safe, our technical experts maintain physical, electronic and managerial procedures to keep safe the information we collect.

We use technical and organisational security measures including encryption and authentication tools to protect your personal information from unauthorised access by third parties, manipulation, falsification, loss, destruction or unauthorised disclosure.

Although data transmission over the Internet or website cannot be guaranteed to be secure, we and our business partners work hard to maintain physical, electronic and procedural safeguards to protect your information in accordance with applicable data protection requirements.

Our main security measures are:
Tightly restricted access to your data on a ‘need to know’ basis and for the communicated purpose only
Access driven by role defined user profiles with password protection
Firewalled IT systems to prohibit unauthorised access e.g. from hackers
Permanently monitored access to IT systems to detect and stop misuse of personal data.
Only authorised employees and checked agents, contractors and sub-contractors, who provide a particular data processing service for us, are permitted access to your data. These people will only be allowed access to your data for the purposes identified within this Privacy Policy and processing it on our behalf or for IT security and maintenance.

How long we hold your information for
The time period for which we keep information varies according to what we use the information for. Unless there is a specific legal requirement for us to keep information, we will keep your information only for as long as it is necessary, relevant and useful for the purpose for which it was collected. We restrict access to your information to only those persons who need to use it for the relevant purpose.

Our retention periods are based on business needs and your information that is no longer needed is either anonymised or destroyed securely.

For financial records

We will retain your account information including financial records for seven years in line

with tax and contract requirements. To perform a contract

In relation to your information used to perform any contractual obligation with you we may retain that data whilst the contract remains in force plus six years to deal with any queries or claims thereafter.

For recruitment services
In the case of unsuccessful job applicants, we will generally hold your CV and supporting documentation for period of three years from the date of application.

In the case of successful job applicants, we will hold your CV and supporting documentation from the date of application for the full duration of your employment.

In the case of interim appointments, we will hold your CV and supporting documentation for the period that you are registered with us.
With Executive Search activity we will hold your CV and supporting documentation for the period of the assignment.
For our associates we will hold CVs and supporting documentation for the period that you are registered with us.

For marketing purposes:
We retain your personal information for as long as is necessary, but only for the relevant purpose that we collected it for.

For employment purposes:
We retain your personal information for the duration of employment and for 6 months following the end of employment.

Where claims are contemplated:
In relation to any information where we reasonably believe it will be necessary to defend or prosecute or make a claim against you, us or a third party, we may retain that data for as long as that claim could be pursued.

Who we may share your information with:

Your personal information may be accessed by our employees, associates, authorised agents and contractors from countries inside and outside the European Economic Area (EEA) for any of the purposes set out in this policy.

Where a third party is processing your data on our behalf, we will take steps to ensure that such third party gives us commitments that it will process your data in line with EU law.

If a third party processing your data on our behalf is located in a non-EU country that does not have data protection laws equivalent to those in the EU, we will always take appropriate additional steps to ensure that your personal information is kept safe and secure by those processing your data on our behalf. This will generally involve ensuring that such third party agrees to sign up to a formal legal agreement committing such party to comply with standards equivalent to those that would apply where that party to be located within the EU.

Accessing your information:
You have the right to request access to the information we have on you. You can submit a request by emailing us at [email protected].

We will provide you with a copy of the data we process about you. In order to comply with your request, we may ask you to verify your identity.

We will fulfil your request electronically, unless you expressly specify a different method and will respond no later than one month following receipt of your request.

Controlling your personal information

You may choose to restrict or control the collection or use of your personal information in the following ways: Whenever you are asked to fill in a form on the website or elsewhere, ensure that you do not tick any box requesting permission to use your personal information for specific purposes (e.g. marketing) or, by using unsubscribe or opt-out mechanisms in emails we send to you if you have previously agreed to us using your personal information for direct marketing or other specific purposes and wish to change your mind, by notifying us as outlined below.

if you believe that we are holding personal information which is incorrect, out of date or incomplete and wish for that to be corrected, by notifying us as outlined below.

If you wish for your personal information to be erased from our systems, by notifying us as outlined below.

We may directly market to you by post or telephone or email on the basis that we consider we have a legitimate interest in marketing to you in this way and that it does not substantially impact on your privacy.

You have a right to object to this at any time and may request that we cease to contact you for direct marketing in this manner at any point. We will comply with any such request.

Where you have given consent to us holding data for a particular purpose, that consent may be withdrawn by you at any time. You may withdraw your consent by contacting us by any method that you wish to communicate with us, including e-mail or telephone.

You are entitled to request that we erase your personal information at any time, for example where you cease to be an active customer of ours. Whilst we will generally seek to comply with your request, there will be circumstances where we are entitled to retain such personal information (e.g. in respect of legal claims or to ensure that any activity on your account (e.g. monies owing) may be resolved).

How to contact us about this privacy policy

If you want to remove a consent, request that we cease contacting you for direct marketing purposes or request erasure or transfer of your personal information, you may do so at any time by writing to us at Data Protection, Bright Futures Training & Coaching ltd,167-169 Great Portland Street (5TH FLOOR)
London W1W5P For email us at [email protected] or phone us on +44 07814 709127

We will not sell or lease your personal information to third parties for their control. We will only share your personal information with third parties in order to either to fulfil our contractual obligation to you, or to provide our services to you, or are required by law to do so.

If you believe that any information we are holding on you is incorrect, out of date or incomplete, please write, email or call us as soon as possible, using the details set out above. We will promptly correct any information found to be incorrect. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections.

Last reviewed January 2024

Next review: January 2025

(COVID-19) WORKPLACE

It is the policy of Bright Futures, including all and any trading names connected to ensure and protect the health and safety of all employees, workers and any other persons connected with the operations of the Company due to the ongoing Coronavirus Pandemic (COVID 19).

This policy does not form part of any contract of employment or contract for work.

This policy applies to all employees, workers and contractors engaged with the Business. This policy would come into affect if government guidelines directed the need, if the science guidelines advised. Otherwise our business would act on business as usual.

Minimising the spread of COVID -19

In order to guard the transmission of COVID-19, the following steps will be taken:

1.Customers, delivery drivers, contractors and all other non staff members shall be permitted onto the premises and the following measures shall be implemented to protect the health and safety of employees and workers.

2.The Business shall ensure that the regularity with which the premises is cleared is adequately increased to reduce the risk of surface, equipment and any and all other tools used by employees and others being contaminated.

3.The Business shall ensure proper ventilation of the premises they work in wherever possible and all those subject to this policy shall assist in letting fresh air into enclosed spaces wherever possible (for example by opening windows)

4.All persons subject to this policy:

A. If legally advised to wear a face covering whenever in a part of the business premises which is open to the public or otherwise where they are likely to come into close contract with members of the public, Bright Futures will recommend we follow government directed guidelines.

B. Are encouraged to meet or congregate outdoors wherever this may be possible. C. Should maintain regular hand washing and hand sanitising.

D. Should assist with the ventilation of the Business premises (for example keeping the windows open)

E. Should assist with the sanitising and wiping down of surfaces and equipment where appropriate.

Remote Working

In response to the COVID-19 pandemic, remote working arrangements have been put in place.

Staff members should work from home where they are able to:

Employees who are able to work from home should do
Whilst working in Business premises follow guidelines previously stated

Workplace Testing

It is government advice that workplace routine rapid testing will assist in containing the spread of COVID-19 cases.

The Business has a workplace testing scheme in place. The following will apply to the testing procedure:

1.Testing will take place at home
2.Testing will take place weekly
3.In the event of any positive result, staff members should immediately follow

government advice regarding self isolation and any further testing. Participation in the testing scheme is a mandatory requirement.

General

The Business asks that all employees and workers familiarise themselves with this policy and all new working procedures which may be implemented from time to time due to COVID_19.

Where an employee or worker has any concerns or questions relating to their duties as a result of the coronavirus, please contact: Laura Rigby 07814 709127

This policy shall be updated from time to time as may be required.

Signed L RIGBY Date 5/1/2023 LAURA RIGBY (FOUNDER)

SOCIAL VALUE AGENDA

The company Bright Futures was inspired by a young lady, whilst Life Coaching at 'The Princes Trust' charity.

Whilst coaching her and discussing her future, she looked the Founder Laura Rigby straight in the eye, and said; "Laura, I do NOT have a"Bright Future!" This was her inner core belief based on her life experiences to date. It struck me that she was not alone in her own negative beliefs about herself. She will never be forgotten as she inspired Bright Futures to help young people educate, connect and empower them self with the mental fitness tools to fulfil their own Bright Future!

Our approach is to Educate & Coach by Virtual Video & Passionate In person with authentic, raw and inspiring content.

We take awareness of Mental Health to a useful and empowering level for young people who can live a trauma informed life, knowing and being equipped with Mental Fitness Tools to change and build positive belief systems for themselves.

At Bright Futures we believe we're all made for more. We’re here for a reason and, it usually will take us a while to find what our purpose is. For those that feel lost and stuck, Bright Futures acts as a guide!

Our Speciality is Mental Fitness Coaching

What is Mental Fitness? The very thoughts running through your mind can help to manifest your goals, or draw you closer to your greatest fears. Mental Fitness is being aware and taking actions to control it!

Building MENTAL FITNESS will ultimately help you with resilience, enhance self awareness and ultimately become your own inner cheerleader. Applied action of the tools will open up your own unique potential and enables you to like the person you are and giving yourself the best chance of achieving the best version of yourself.

Our ambition is to Educate & Coach, 1 Million Young People in the UK by 2025 by working with Education Authorities, Home Office, Police Commissioner's, Councils, Youth Organisations, Charities and Parents.

The Founder, Laura Rigby's priorities;

Create simple effective tools that can be accessed online and have in person Coaching, workshops and short masterclasses that will imbed the learnings and fuel confidence to take empowered action.

Connect and educate senior decision makers with the knowledge of Bright Futures; Mental Fitness Memberships and the difference that can have when raising young people. Establish a Nationwide Bright Futures Coaching Team that can deliver the Mental Fitness Membership throughout the UK, fulfilling our ambition to educate & Coach 1 Million Young People by 2025

This will be reviewed and actions taken to reflect on goals and vision.

The vision and focus is clear and the future is certainly bright with a determined passionate team.

Written January 2022
Last reviewed: January 2024
Next review: January 2025.

EQUAL OPPORTUNITES AT WORK

Purpose

Policy for Equal Opportunities at Work

It is the policy of Bright Futures and all and any trading bodies and names connected to us to commit to promoting, encouraging and ensuring equality and diversity in the workplace and to eradicate unlawful and unfair discrimination within our workplace. The purpose of this policy is to ensure that all employees feel represented and respected within the workplace in a safe and encouraging environment. In addition to eradicating discrimination in the provision of services to them by the Employer.

Scope of this Policy

The Employer extends all rights and responsibilities set out under this policy equally to all employees regardless of their status as full-time or part-time employees who are on fixed term or substantive term contracts. This policy will also extend to persons who are not employees but are contracted to perform services or provide goods on behalf of the Employer such as agency staff and contractors.

All employees should follow and have a responsibility to implement this policy in particular directors, managers, supervisors and any and all other staff who participate in the participate in the employment process or who make decisions which will effect other employees.

Equality Commitments

To achieve the aims and goals contained within this policy, the Employers undertakes the following;

1.The Employer shall never unlawfully discriminate against any persons due to their protected characteristics under the Equality Act 2010, namely discrimination based on a person's:

Age
Disability
Gender reassignment
Marriage and Civil Partnership
Pregnancy and Maternity
Race (Including skin colour, nationality, ethic origin or Country of Origin)
Religion or Beliefs
Sex
Sexual Orientation

2. In Fulfilling this policy the Employer shall combat, oppose, exclude and avoid and and all forms of discrimination which are lawful under the Equality Act 2010. An employees' protected characteristics shall not be reason to discriminate on the grounds of: terms and conditions of employment; dismissal, redundancy, grievance and disciplinary procedures; pay and benefits; selection for employment, training, legitimate requests for different or flexible working hours.

3. The Employer pledges to encourage all employees to progress and develop their skills and knowledge during their time at the Employer by partaking in any and all training and development opportunities which may arise with the Employer.

4. Principally, the Employer shall only employ and promote employees based on their merit, abilities, experience, qualifications and aptitude rather than on any of their protected characteristics, apart from where allowed, necessary and legal exemptions of this are permitted under the Equality Act 2010.

5. The Employer shall provide relevant and necessary Equality and Diversity training to management and all other employees concerning their rights and responsibilities under the policy.

6. All and any forms of bullying, intimidation or any other forms of harassment shall not be tolerated under any circumstances and where an employee believes that they have suffered such behaviour due to one or any of their protected characteristics this should be reported to a relevant line manager or other colleague who is in a position of seniority or authority. Any and all claims of bullying, or other forms of harassment, shall be handled in the strictest confidence by the Employer and relevant investigations will be carried out in accordance with adopted procedure. Where any employee is found liable bullying, victimisation or any other act of unlawful discrimination they may be subject to disciplinary action under the Employer's disciplinary procedure.

7. At relevant and regular intervals the Employer shall review and, where necessary, reform its procedures and practices around employment in order to safeguard fairness and to keep them in line with any relevant changes in the law.

8. The Employer shall at all times observe and scrutinise the composition of the employee workforce in relation to its age, sexual orientation, beliefs, religion, sex, race and all other protected characteristics while encouraging diversity and equality in order to fulfil the purpose of this policy. This practice shall include assessing the effectiveness of this policy in action and reviewing and implementing changes in order to address any issues which may arise as a result.

Application of this Policy

This policy is applicable to the behaviour and conduct of all employees and persons during the course of their duties for the Employer and shall apply where employees are on and off site. All employees and persons engaged with the Employer should consider the consequences of their actions in relation to this policy and be aware that their conduct may impact the reputation and standing of the Employer professionally.

Certain areas of application are as follows.

This policy will be reviewed at regular intervals by the employer and may be amended from time to time. This policy does not form part of an employment contract and is used as guidance only.

This policy for Equal Opportunities at Work is robustly endorsed by the Employer at all levels of management.

Signed: L RIGBY Date: 17/12/2021

Reviewed by Laura Rigby January 2024

Next review : January 2025

COMPLAINTS

Complaints Policy and Procedures for Bright Futures December 2021

Policy Statement

The purpose of this policy is to provide a clear statement of intent with regards to the assessment, handling and investigation of customer complaints. Bright Futures complaint handling policy and procedure has been created to meet general standards and requirements and complies with standard compliant handling procedures, including the Financial Ombudsman Service (FOS) regulations.

The aim of this policy is to ensure that all customer complaints, either written or verbal, are handled in a consistent and regulated manner and that further complaint incidents are mitigated and where possible, prevented. Where a customer has cause to complain, the complaints handling procedure will be followed in every instance and a record will be made of the complaint nature and details to help improve our services and reduce the occurrence of similar complaints.

Purpose

Bright Futures are committed to delivering a fair, open and clear process for complaints and ensure a satisfactory outcome for all customers who raise a complaint.
This policy sets out our intent and objectives for how we handle complaints, from offering a clear and approachable system for customers to complain, through to conducting root cause analysis on all complaints received to identify the cause, issues, and corrective actions regarding the complaint, and to implement measures to prevent reoccurrences where applicable.

Scope

The policy relates to all staff (meaning permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, and agents engaged with Bright Futures in the UK or overseas) within the organisation and has been created to ensure that staff deal with the area that this policy relates to in accordance with legal, regulatory, contractual, and business expectations and requirements.

Objectives

Bright Futures objectives are laid out below regarding customer complaint handling. For the purposes of this policy, a complaint is defined as any customer contact whereby a negative communication or outcome has occurred. The customer does not have to formally address their communication as an official complaint or to request a response for Bright Futures to treat the incident as a complaint and to follow the related procedures.

Bright Futures objectives for a complaint handling are:

To provide a fair complaints procedure which is clear and easy to use for anyone wishing to make a complaint
To ensure that our complaints procedure is fully accessible so that people know how to contact us to make a complaint

To make sure everyone at Bright Futures knows what to do if a complaint is received

To make sure all complaints are investigated fairly and in a timely way

To gather information which helps us to improve what we do and how we do it

To ensure that the appointed person is involved in any complaints relating to personal data

Bright Futures objectives for the complaint handling process are:

1. Complaints will be investigated and responded to within 8 weeks from the initial customer contact

2. Customers will be sent a copy of the l complaints procedure

3. Complaint responses will always be provided in writing (unless the complainant makes a specific request for an alternate form of communication, which will be provided in addition to the written format)

4. Complaint procedures will be available upon written and/or verbal request 5. All complaints will be investigated by a founder Laura Rigby

6. Complaint records will be used to revise company procedures and to improve communication and business practices where applicable

Procedures & Guidelines

Raising a Complaint

Customers who request Bright Futures complaint handling procedure will be provided a copy of the procedure and form either by email, in a .pdf format or in the post, and will be asked to raise their complaint in writing as soon as possible after the incident.

NOTE: Complaints are to be raised in writing, however verbal complaints will be accepted and dealt with as per the same procedures.

If a customer telephones Bright Futures and wishes to raise a complaint, we will try to resolve the complaint then and there. Even if the complaint is resolved at the time, the customer must still be offered the option of receiving the complaints handling procedure prior to ending the call and the call should be logged in the complaints record.

Data Protection Related Complaints

Where a complaint is related to the processing of personal data, this policy ensures that Bright Futures complies with the data protection laws and notification requirements.

Every individual has the right to lodge a complaint with the supervisory authority (ICO) where they consider that the processing of personal data relating to them infringes the General Data Protection Regulation (GDPR) or we have breached data protection law. All individuals using our products or services and those employed by us are notified of this right via our Privacy Notice, in our complaint handling procedures and in our information disclosures.

The supervisory authority with which the complaint has been lodged, is responsible for informing the complainant on the progress and the outcome of the complaint, including the possibility of a judicial remedy where the supervisory authority does not handle a complaint or does not inform the data subject within three months on the progress or outcome of the complaint lodged.

Informal Complaint Resolution

Such instances are where an investigation is not required because the nature of the complaint is clear, and a resolution can be obtained without further review of the facts. Where we resolve a complaint within the timeframe, the details are still logged on our complaint register, and the complainant is still informed of their rights.

Bright Futures takes every opportunity to resolve complaints at the first initial point of contact where feasible and possible. Informal resolution is always attempted where the issues raised are straightforward and potentially easily resolved, requiring little or no investigation. Most face to face and telephone issues can be resolved in this manner, however the complainant is always offered the option of making the complaint formal if the resolution is not to their satisfaction.

Where an informal complaint is received, it is acceptable for the point of contact or addressed employee to attempt to resolve the issue without involving the appointed person. However, any issue relating to data protection infringes or breaches, no matter how small or informal, are always brought to the attention of the appointed person.

Frontline staff are trained to deal with basic issues and informal complaint resolution and are aware of their obligations and the subsequent reporting lines. Such employees are equipped to attempt to resolve a complaint relevant to their area of service or expertise, wherever possible.

Timeframe for Informal Resolution

It is the aim of Bright Futures to resolve informal complaints immediately, or at least within the first 24-hours. Such complaints and issues will have a quick, but informative response and do not need to have an investigation or enter the formal complaint process.
No matter how small or informal the complaint, if a satisfactory resolution has not been achieved within 3 working days of the complaint being raised or identified, the issue is passed to the Appointed Person to enter the formal complaint process.

Responding to a Complaint

Where an official complaint has been received or the informal complaint was unable to be resolved at the frontline point of contact, a written acknowledgement is sent to the customer within 3 working days. The response should detail the complaint handling procedure and provide approximate timelines and expectations for the investigation and future responses.

A trained Manager, the Appointed Person is the only staff member who should respond to customers regarding their complaints.

Investigating the Complaint

The designated employee will be assigned the role of investigating complaints and will gather all necessary documents, recordings, and information to make an independent review of the incident.

If internal interviews are to be conducted, a note taker will be present alongside the investigator and interviewee and a copy of the interview notes will be written up and signed by the interviewer and interviewee prior to them being added to the complaint history.

Investigations must utilise all the facts and any previous related information to produce an, unbiased outcome and an expected course of action.

A complaint reference should be assigned and all documents relevant to the complaint should have the reference written on them for continuity.

The reference will also be added to the Complaints Register so that complaint and documents can be audited and traced back in the future.

All employees are provided with clear guidelines of when a complaint is formal and requires an appropriate investigation.

Complaints must be referred to the Data Protection Officer where:

The complainant has requested such a referral or investigation
The complaint involves any type of personal data issue
The informal complaint resolution stage failed or was inappropriate
There is a conflict of interest between the complainant and an employee
The issues are complex and require an investigation
The complaint represents a high or serious risk to the company
The facts are unclear, or the complaint will require additional time to resolve
The complainant is identified as being vulnerable
There has been any media contact or attention
Child protection issues are involved
The issues do or may affect more customers (whether identified or not)

Informal Complaint Resolution

Bright Futures considers and responds to all complaints and issues, no matter how they are raised or what they refer to. Some issues and complaints we can resolve immediately or within a 3-working day timeframe and are referred to as informal complaints. Such instances are where an investigation is not required because the nature of the complaint is clear, and a resolution can be obtained without further review of the facts.

Where we resolve a complaint within the timeframe, the details are still logged on our complaint register, and the complainant is still informed of their rights.

Timeframe for Informal Resolution

No matter how small or informal the complaint, if a satisfactory resolution has not been achieved within 3 working days of the complaint being raised or identified, the issue is passed to the Appointed person to enter the formal complaint process.

Responding to a Complaint

A trained manager, the Appointed Person are the only staff members who should respond to customers regarding their complaint.

Complaint Recording

All complaints, whether formal or informal, are recorded on a Customer Complaint Register. The register should consist of the below information and should be audited on a frequent basis to ensure that incidents are not being repeated and improvements are being made.

Date
Nature of Complaint
Department(s) Involved
Complaint Reference
Lead Investigator
Decision Letter Sent (Y/N)
Date Complaint Closed

The log is made available to any relevant authority, ombudsman or body who relates or oversee the firms’ complaints, as well as being made available with the local Trading Standards should a representative work alongside the organisation.

Patterns and Analysis

The complaint log and issues forms are reviewed monthly by the appointed person to identify any patterns or reoccurring issues. Bright Futures are dedicated to improving our performance, services, and functions through the auditing of our complaint records and our investigation process.

Where gaps or patterns are identified, we put corrective actions and mitigating solutions into place as soon as possible and keep the function, process, or person under a weekly review until a satisfactory improvement is noted.

Responsibilities

Bright Futures will ensure that all staff are provided with the time, resources, and support to learn, understand, and deal with customer complaints and that full training will be provided for new and existing employees on the complaint handling policy, procedures, and expectations.

The Appointed Person has the role of overseeing, investigating, and recording all customer complaints and is responsible for regular auditing of the complaints log to ensure mitigating actions and improvements are put into place where possible.

The Appointed Person

Bright Futures has an Appointed Person who is provided with the training and support to understand, investigate, and respond to complaints of all types.

The Appointed Person has full authority and internal credibility to ask questions, carry out investigations and interviews, obtain and analyse evidence, recommend policy, and process changes and be involved in department functions for the purposes of complaint handling.

Reviewed by Laura Rigby Date: January 2024