+44 0191 607 0225

  +44 0191 607 0225

  hello@theopportunity.global

Michaela

Policies


Your privacy is very important to us. Accordingly, we have developed this policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information.

The following outlines our privacy policy:

  • Before or at the time of collecting personal information, we will identify the purposes for which information is being collected and how long we will retain this information.
  • We will collect and use personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
  • You have the right to opt out and request for your data to be ‘forgotten’ at any time.
  • We will only retain personal information as long as necessary for the fulfilment of those purposes.
  • We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
  • Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
  • We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
  • We will make readily available to customers information about our policies and practices relating to the management of personal information.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.

Our Commitment:

Gradvert is committed to the protection of all personal and sensitive data for which it holds responsibility as the Data Controller and the handling of such data in line with the data protection principles and the Data Protection Act (DPA

Changes to data protection legislation shall be monitored and implemented in order to remain compliant with all requirements.

The member(s) of staff responsible for data protection is Gradvert’s Managing Director, Michaela Reaney.

Gradvert is also committed to ensuring that it’ staff are aware of data protection policies, legal requirements and adequate training is provided to them.

The requirements of this policy are mandatory for all staff employed by Gradvert and any third party contracted to provide services within the school.

Notification:

Our data processing activities will be registered with the Information Commissioner’s Office (ICO) as required of a recognised Data Controller. Details are available from the ICO: 

Changes to the type of data processing activities being undertaken shall be notified to the ICO and details amended in the register.

Breaches of personal or sensitive data shall be notified immediately to the individual(s) concerned and the ICO.


Personal and Sensitive Data:

All data within Gradvert’s control shall be identified as personal, sensitive or both to ensure that it is handled in compliance with legal requirements and access to it does not breach the rights of the individuals to whom it relates.

The principles of the Data Protection Act shall be applied to all data processed:

  1. Processed fairly and lawfully.
  1. Obtained only for lawful purposes and is not further used in any manner incompatible with those original purposes.
  1. Accurate and, where necessary, kept up to date.
  1. Adequate, relevant and not excessive in relation to the purposes for which it is processed.
  1. Not kept for longer than is necessary for those purposes.
  1. Processed in accordance with the rights of data subjects under the DPA.
  1. Protected by appropriate technical and organisational measures against unauthorised or unlawful processing and against accidental loss, destruction or damage.
  1. Not transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection of the personal information.


Fair Processing / Privacy Notice:

We shall be transparent about the intended processing of data and communicate these intentions via notification to staff, delegates, clients and stakeholders prior to the processing of individual’s data.

Notifications shall be in accordance with ICO guidance and, where relevant, be written in a form understandable by those defined as young adults or adults under the legislation. 

The intention to share data relating to individuals to an organisation outside of our organisation shall be clearly defined within notifications and details of the basis for sharing given. Data will be shared with external parties in circumstances where it is a legal requirement to provide such information.

Any proposed change to the processing of individual’s data shall first be notified to them.


Data Security:

In order to assure the protection of all data being processed and inform decisions on processing activities, we shall undertake an assessment of the associated risks of proposed processing and equally the impact on an individual’s privacy in holding data related to them.

Risk and impact assessments shall be conducted in accordance with guidance given by the ICO:

Security of data shall be achieved through the implementation of proportionate physical and technical measures. Nominated staff shall be responsible for the effectiveness of the controls implemented and reporting of their performance.

The security arrangements of any organisation with which data is shared shall also be considered and these organisations shall provide evidence of the competence in the security of shared data.

Data Access Requests (Subject Access Requests):

All individuals whose data is held by us, has a legal right to request access to such data or information about what is held. We shall respond to such requests within 40 days and they should be made in writing to Michaela Reaney.

A charge may be applied to process the request.

https://ico.org.uk/media/for-organisations/documents/1586/personal_information_online_small_business_checklist.pdf

https://ico.org.uk/media/for-organisations/documents/1131/definition-document-colleges-of-further-education.pdf


Photographs and Video:

Images of staff and learners may be captured at appropriate times and as part of training activities. Consent of use of any images will be obtained in line with our image consent policy.

Unless prior consent from parents/learners staff has been given, we shall not utilise such images for publication or communication to external sources.

It is our policy that external parties (including parents/ carers/ other learners) may not capture images of staff or learners during such activities without prior consent.


Data Disposal: 

Our organisation recognises that the secure disposal of redundant data is an integral element to compliance with legal requirements and an area of increased risk.

All data held in any form of media (paper, tape, electronic) shall only be passed to a disposal partner with demonstrable competence in providing secure disposal services.

All data shall be destroyed or eradicated to agreed levels meeting recognised national standards, with confirmation at completion of the disposal process. 

Disposal of IT assets holding data shall be in compliance with ICO guidance:

https://ico.org.uk/media/for-organisations/documents/1570/it_asset_disposal_for_organisations.pdf

Introduction

Gradvert is committed to ensuring equal opportunities, fairness of

treatment, dignity, the encouragement of diversity and the elimination of all forms of discrimination in the workplace or learning environment for all its’ employees, job applicants and learners.  

The Company aims to create an environment in which all individuals can make best use of their skills, free from discrimination or harassment, and in which all decisions are based on merit.  

A key objective of this policy is so that The Company can provide a working / learning environment in which all people who work for, or with Gradvert, feel

comfortable and confident that they will be treated with respect and dignity.

  1. Policy Statement

1.1. It is Gradvert’s aim to ensure that no employee, job applicant, or learner receives less favourable facilities or treatment (either directly or indirectly) in recruitment, employment, or training and assessment on grounds of:

  • age
  • disability
  • gender reassignment
  • marriage
  • pregnancy and maternity
  • race
  • religion or belief
  • sex
  • sexual orientation

 (the protected characteristics)

1.2. The Company intends that its’ workforce and learners be truly representative of all sections of society and each employee and learner feels respected and able to give off their best.

1.3. The Company opposes all forms of unlawful and unfair discrimination or

victimisation. To that end the purpose of this policy is to provide equality and

fairness for all in The Company’s employment and training.

1.4. All employees and learners, whether part-time, full-time or temporary, will be treated fairly and with respect. Selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability. 

1.5. All employees and learners will be helped and encouraged to develop their full potential, and the talents and resources of the workforce will be fully utilised to maximise the efficiency of The Company.

1.6. Employees and learners of Gradvert will not discriminate directly or

indirectly, or harass customers or clients because of age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, and sexual orientation, in the provision of The Company’s or, in the case of learners their employers’, goods and services.

1.7. This policy and the associated arrangements shall operate in accordance with statutory requirements.  In addition, full account will be taken of any guidance or Codes of Practice issued by the Equality and Human Rights Commission, any Government Departments, and any other statutory bodies.

  1. Gradvert’s Commitment:

2.1. To promote equality in the workplace and learning environment which is good management practice and makes sound business sense and conforms to all employments standards required by law.

2.2. To create an environment in which individual differences and the contributions of all our employees and learners are recognised and valued.

2.3. That every employee is entitled to a working environment that promotes dignity and respect to all, and every learner is entitled to a learning environment that promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated.

2.4. Training, development and progression opportunities are available to all

employees.

2.5. All learners have access to training and assessment appropriate to their learning programme.

The Company will review and monitor its’ employment practices and

procedures, and those covering the training it delivers, to ensure fairness.

2.7. Breaches of The Company’s Equality Policy will be regarded as misconduct and could lead to disciplinary action.

2.8. The Policy will be monitored and reviewed annually.

  1. Responsibilities of Management

3.1.  Responsibility for ensuring the effective implementation, operation and

monitoring of the arrangements will rest with the Senior Management Team and Directors.  

3.2. All managers will ensure that they and the employees within their departments operate within this policy and arrangements, and that all reasonable and practical steps are taken to avoid discrimination.  Each line manager will ensure that:

3.2.1.  All employees within their department are aware of the policy and the arrangements, and the reasons for the policy.

3.2.2. Grievances concerning discrimination are dealt with properly, fairly and as quickly as possible.

3.2.3. Proper records are maintained.

  1. Responsibilities of Employees

4.1.   Responsibility for ensuring that there are no unlawful discrimination rests with all employees and learners, and the attitude of employees and learners are crucial to the successful operation of fair practices.  In particular, all employees and learners should:

4.1.1. Comply with the policy and arrangements.

4.1.2. Not discriminate in their day to day activities or induce others to do so.

4.1.3. Not victimise, harass or intimidate other employees, learners or groups who have, or are perceived to have one or more of the protected characteristics.

4.1.4. Ensure no individual is discriminated against or harassed because of their association with another individual who has a protected characteristic.

4.1.5. Inform their line manager, or in the case of learners any member of

 Gradvert staff, if they become aware of any discriminatory practice.

4.1.6. Equality information is included in induction programmes for employees

and learners. 

4.1.7 Equality issues will be discussed with learners at relevant milestones in their programmes

  1. Related Policies

5.1. All employment policies and arrangements have a bearing on equality of opportunity. 

5.2. The Company policies will be reviewed regularly, and any discriminatory elements removed.

  1. Grievances/ Discipline

6.1. Employees have a right to pursue a complaint concerning discrimination or victimisation via The Company Grievance Procedures, Policy; learners should use the Appeals Procedure which is covered in the Appeals Policy.

6.2. Discrimination and victimisation will be treated as disciplinary offences and they will be dealt with under the company Disciplinary Procedure as detailed in Policy

  1. Monitoring & Review

7.1. The Company deems it appropriate to state its intention not to discriminate and assumes that this will be translated into practice.  Accordingly, it will periodically monitor and measure the effectiveness of the policy and arrangements.

7.2. If monitoring shows that The Company or its’ learners are not representative, or that sections of our workforce or learners are not progressing properly within The Company or their learning programmes, then an action plan will be developed to address these issues.  This will include a review of recruitment and selection procedures, the delivery of leaning programmes, and Company Policies and practices.

Purpose and Scope    Gradvert Ltd is committed to operating a proactive and reactive approach towards safeguarding the welfare of children, young people and adults who, through the delivery of our services, we have some form of contact with. This is also applicable to staff and volunteers.
 
We will:
 
• Promote positive personal welfare and safety,
 
• Provide support (including utilising signposting),
 
• Respond promptly and effectively to any concerns.    The protection of children, young people and adults is set out in legislation and guidance, such as: Working Together to Safeguard Children 2015; Children Act 1989 & 2004; The Children (Northern Ireland) Order 1995; Children (Scotland) Act 1995; Children and Young People (Scotland) Act 2014; Social Services and Wellbeing (Wales) Act 2014; Human Rights Act 1998; Care Act 2014; Adult Support and Protection (Scotland) Act 2007; Protection of Older People in Wales 2014; Safeguarding Vulnerable Adults: A Shared Responsibility 2010 (Northern Ireland); The Counter-Terrorism and Security Act 2015; The Prevent Duty (England, Wales and Scotland). (The difference of legislation across the four nations in the UK is recognised).     This policy has been developed to:
 
• Establish best practice across Gradvert Ltd,
 
• Ensure Gradvert Ltd applies a robust safeguarding framework within legislative and guidance parameters,
 
• Reflect Gradvert Ltd Values,
 
• Enable all staff to act appropriately if any concerns are identified relating to the welfare of an individual,
 
• Provide a clear process for reporting and recording concerns.   “Safeguarding is everyone’s business” (Care Act 2014) and all Gradvert Ltd employees and volunteers have a responsibility regarding safeguarding towards children, young people and adults (to include clients, learners, internal and external staff). This policy provides a framework for exercising our duty of care appropriately and effectively, should any concerns be identified that may impair,
 
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or be likely to impair, someone’s development or health, quality of life, or if someone is at risk of significant harm (including all forms of abuse).    This policy, and any associated documents, applies to all employees and volunteers of Gradvert Ltd, regardless of role or position. 
 
It is recognised all supply chain partners providing a service for Gradvert Ltd have a requirement to have their own safeguarding policies reflecting legislative requirements and best practice.  All supply chain partners must ensure their employees and sub-contractors follow their policies.     This policy will be reviewed biannually or following relevant developments within legislation, guidance and lessons from Serious Case Reviews (SCRs).      Roles and Responsibilities    The Safeguarding Champion retains responsibility for the overall implementation and management of this policy, alongside providing relevant reporting to the Managing director. 
 
The Safeguarding Champion is also the Single Point of Contact (SPOC) with regards to our duties under the Prevent Strategy (2011) and is the Designated Safeguarding Officer (DSO).
 
They are also the lead for: Mental Capacity and Deprivation of Liberty Safeguards; Child Sexual Exploitation (CSE) and Female Genital Mutilation (FGM).
 
The Managing Director has accountability for ensuring Gradvert Ltd fulfils its safeguarding responsibilities. All employees and volunteers across all divisions have a responsibility to ensure they adhere to this policy.     In addition, managers are responsible for promoting and monitoring the application of this policy across their team(s).    Regular reviews of the use and application of this policy, across all divisions and offices, will be undertaken by the Safeguarding Champion. All relevant associated policies, procedures and information will be available in the Safeguarding section on Gradverts company website.
 
The Safeguarding Champion is available for support and guidance regarding the application of this policy. In the absence of the Safeguarding Champion, the Deputy Safeguarding Champion will be available.      Definitions and Language    For the purposes of this policy, the following terms are defined as such:    Child: “every human being below the age of 18 years”
 
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(Article 1, United Nations Convention on the Rights of the Child).
 
Acknowledgement that Adult Support and Protection (Scotland) Act 2007 states adult “means a person aged 16 or over” (Section 53(1).
 
Young people: The United Nations uses ‘young people’ to refer to those aged between 15 and 24 years. 
 
Adult: an adult is aged 18 and older. Depending on their circumstance, they may also be an ‘adult at risk’, for which this policy will use the following definition: “an adult who is an older person; or is affected by disability, illness, or physical or mental infirmity; or has an impairment of, or disturbance in, the functioning of the mind or brain; and as a result, may be unable to safeguard their own well-being, property, rights or other interests. In addition, an adult is at risk if: “another person’s conduct is causing (or is likely to cause) the adult to be harmed, or the adult is engaging (or is likely to engage) in conduct which causes (or is likely to cause) self-harm” (Adult Support and Protection (Scotland) Act 2007 s.3(2).   Safeguarding: “the action we take to promote the welfare of children and protect them from harm” (Working Together to Safeguard Children 2013, p.7). For the purposes of this policy, ‘safeguarding’ means the action we take to promote the welfare of children, young people and adults and protect them from harm.    Welfare: “physical and mental health and happiness” (Cambridge Online Dictionary, 2016) .   Concern: anything that may cause worry about another person or contributes to a person feeling uncomfortable or unsure about the safety or welfare of someone else or themselves (including indications of potential radicalisation and expressions of extremist views).    Harm: “ill-treatment or the impairment of health or development” (Children Act 1989 s.31(9 & 10)). For the purposes of this policy, this definition is applied to children, young people and adults. This policy also recognises that harm applicable to children and young people includes “impairment suffered from seeing or hearing the ill-treatment of another” (Children Act 1989 as amended by Children and Adoption Act 2002).   The definition of harm also includes abuse in all its forms and bullying. For the purposes of this policy, the following types of abuse and bullying, as provided by the Social Care Institute for Excellence (SCIE) for adults (2016), and as provided by the National Society for Prevention of Cruelty to Children (NSPCC) for children and young people (2016) are recognised: 
 
Adults Children and Young People Neglect or acts of omission Neglect Sexual Abuse Sexual abuse Physical abuse Physical abuse Domestic abuse Domestic abuse
 
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Psychological / Emotional abuse Emotional abuse Financial or material abuse Online abuse Modern Slavery  Child sexual exploitation (CSE) Discriminatory abuse Female Genital Mutilation (FGM) Organisational or institutional abuse Bullying and Cyberbullying Self - neglect Child trafficking  Hate crime  Grooming  Harmful sexual behaviour  
 
The above table does not provide an exhaustive list of concerns that are relevant to this policy. Other concerns to be noted can include: homelessness; depression; suicidal thoughts and intent; self-harm or injury; eating disorders; use of substances; cyber-bullying and radicalisation. It is recognised that abuse and bullying can occur online for adults as well as for children and young people.    Confidentiality    Gradvert Ltd is not afforded powers of being able to keep private any information relating to a safeguarding concern. Therefore, a key component to any professional relationship between Gradvert Ltd employees and members of the public accessing our services is the sharing of our confidentiality status: i.e. If a concern is identified or raised, that indicates a child, young person or adult is being harmed, or is at risk of being harmed, or requires additional support, that concern will be shared with a manager. 
 
This may also result in a referral to an external agency, such as health services, the police or social services. No concerns relating to a potential safeguarding issue can be kept private.    This policy recognises information sharing is a significant element to effective safeguarding practice: “Early sharing of information is the key to providing an effective response where there are emerging concerns” (Care and Support Statutory Guidance 2014, p. 239, s.14.34). When information relating to a concern is shared, it must be: within the values and principles of care and trust; safety and dignity; on a ‘need to know’ basis and within information sharing guidelines.  (For more details, see Safeguarding guidance document).    
 
Actions    All concerns relating to the safeguarding of children, young people and adults must be recorded and appropriate actions taken in a timely manner. In the first instance, information relating to the concern will be shared with the safeguarding champion (in required situations, it will be emergency services).  Details on time scales can be found in the Safeguarding guidance documents. All concerns must be reported via the Concern Report Form, available online via the company one drive.  All reports are sent to besafe@gradvert.com, which in turn go to the Safeguarding Champion and Deputy. 
 
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  Data Protection    All information relating to concerns will be stored and monitored in line with Gradvert Ltd Data Protection and Document Retention policies. The information must be viewed only by relevant persons and on a ‘need to know’ basis.     
 
 
 
Recruitment    Employees will be recruited and selected according to Gradvert Ltd Recruitment and Selection Policy, reflecting best practice recommendations from guidance such as:
 
The Warner Report (1992), the Bichard Enquiry (2004), and lessons identified in Serious Case Reviews (SCR);    All relevant positions within Gradvert Ltd will be subject to satisfactory checks, including references, employment checks and with the Disclosure and Barring System (DBS) Check (England and Wales), Disclosure Scotland and Access NI (Northern Ireland), where required;   Training and Awareness    • All Gradvert Ltd employees and volunteers will receive training on safeguarding awareness, through a combination of online and face-to-face training, with ongoing support being provided by the line manager and the Designated Safeguarding Lead,
 
• Updated alerts will be included in regular communications to staff and supply chain partners,
 
• Safeguarding awareness will feature in Personal Development Reviews (PDRs),
 
• All offices will have safeguarding posters clearly on display for staff and members of the public,
 
• People accessing our services will be made aware of our safeguarding policy verbally and through written format,
 
Contact Details    Safeguarding Champion/Designated Safeguarding Lead/Single Point of Contact: wendy.bates@gradvert.com   Telephone:  0191 607 0225 
 
Deputy Contact: Catherine.alderson@gradvert.com  Telephone:  0191 607 0225

Introduction
 
Gradvert Ltd takes all reasonable steps to promote and safeguard the welfare of all individuals engaged in any activity.  Robust safeguarding arrangements are in place at Gradvert Ltd and these are regularly reviewed to keep all learners safe.  Gradvert Ltd is committed to the promotion of an inclusive learning community which does not allow any individual or group of individuals to be marginalised, stigmatised or excluded.
 
We have a responsibility to promote values of openness and respect and to facilitate free debate which is a characteristic of being a British citizen.
 
In accordance with our standard practice the Gradvert Ltd policy will be updated annually in line with emerging government information, advice and guidance or before that should the necessity arise.  
 
Government Policy
 
Prevent is the key part of the Contest Strategy which aims to stop people from becoming terrorists or supporting terrorism.  Early intervention is a the heart of Prevent in diverting people away from being drawn into terrorist activity as Prevent happens before any criminal activity takes place.  It is about recognising, supporting and protecting individuals who might be susceptible to radicalisation.
 
The 2011 Prevent Strategy objectives are as follows:-
 
 Respond to the ideological challenge of terrorism and the threat we face from those that promote it  Prevent people from being drawn into terrorism and ensure that they are given appropriate support  Work with sectors and institutions where there are risks of radicalisation that we need to address
 
Section 21 of the Counter Terrorism and Security Act 2015 places a duty on certain bodies  to have “due regard to the need to prevent people from being drawn into terrorism”.  The government’s Prevent Strategy was published in 2011 and forms part of an overall Counter Terrorism Strategy known as CONTEST.  The Contest Strategy has four elements which are detailed below:
 
 Pursue  Protect  Prepare  Prevent
 
The government’s Prevent Strategy was explicitly changed in 2011 to deal with all forms of terrorism and target not only violent extremism but also non-violent extremism which can create an atmosphere conducive to terrorism and can popularise the views which terrorists exploit.
 
The United Kingdom currently faces a range of terrorist threats.  All terrorist groups who pose a threat to the UK seek to radicalise and recruit people to their cause.  A system of threat levels has been created which represents the likelihood of an attack in the near future.  The current government threat level from international terrorism in the UK is ‘severe’ which means that a terrorist attack is a strong possibility.
 
Definitions
 
The following definitions have been adopted for use within this document:
 
Radicalisation is defined as the process by which people come to support terrorism and extremism and, in some cases, then participate in terrorist groups.
 
Extremism is vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.
 
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In the Common Inspection Framework September 2015, inspectors make their judgement on safeguarding under the ‘Effectiveness of Leadership and Management’ based on whether “learners are suitably protected from the risks associated with radicalisation and extremism”.
 
Key Documents
 
This policy should be read in conjunction with the following documents and guidance: 
 
Gradvert Ltd Policies and Procedures:
 
 Safeguarding Children & Young Adults Protection Policy  Gradvert Ltd Single Equality Scheme  Health & Safety Policy  Data protection Policy & Procedure   Social Networking Policy
 
External documentation:
 
 Prevent Duty Guidance – updated in July 2015  Keeping Children Safe in Education – September 2018  HM Government Prevent Strategy (2015)  The role of Further Education Organisations in Preventing Violent extremism: Next Steps (DIUS 2009)
 
Aims and Objectives
 
The aim of the Gradvert Ltd Prevent Policy is to ensure that we are able to monitor, manage and deal effectively with the threat posed by any individual or group of individuals engaging in violent extremism in the name of ideology or belief.
 
1. To develop staff and consortia members knowledge of Prevent. 2. To ensure that learners, and all employees of Gradvert Ltd are aware of their roles and responsibilities in preventing violent extremism and radicalisation. 3. To promote and reinforce shared values, to create space for free and open debate, and support the learner voice. 4. To document and recognise current practice across the company which effectively manages the risk of learners being exposed to extremism and becoming radicalised.
 
 
 
 
 
Gradvert Ltd Responsibilities
 
To ensure that Gradvert Ltd effectively manage risks and is able to deal appropriately with issues around radicalisation and extremism the company will:
 
 Understand the nature of the threat from extremism and how this may impact directly or indirectly on the company.  Understand and manage potential risks within the organisation and from external influences including the display of extremist materials and the hiring of external premises   Respond rapidly and appropriately to events in local, national or international news that may impact on the organisation.  Ensure measures are in place to minimise the potential for acts of extremism within the organisation.  Ensure plans are in place to respond appropriately to a threat or incident within the organisation.  Adopt effective IT security and promote this to all staff and learners
 
 
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Teaching, Learning & supporting Learners
 
Gradvert Ltd is committed to providing a curriculum which promotes knowledge, skills and understanding in order to build the resilience of all learners, by undermining extremist ideology and supporting the learner voice.  This will be achieved through:
 
 Embedding equality, diversity and inclusion across the curriculum and promoting community cohesion  Promoting wider skill development such as social emotional wellbeing  Developing a curriculum which recognises local needs, challenges extremism and promotes universal rights  Teaching and learning strategies which explore controversial issues in a way which promotes equality, diversity and inclusion  Use of external organisations to support learning and promote respect
 
To ensure that the organisation community remains safe the following support will be in place for learners:
 
 Effective support services which provide clear information, advice and guidance on preventing learners from being drawn into extremism and radicalisation  Literature written in clear and simple language which promotes equality, diversity and inclusion and undermines extremist ideology  Support for learners and staff and guidance on how to access support through community partners  Clear channels of communication to listen to the voice of the local community and understand local tensions  Support for at risk learners through safeguarding and mentoring processes  A focus on closing the achievement gaps for all learners
 
 
Staff Responsibilities
 
The Quality and Compliance Specialist of Gradvert Ltd, Wendy Bates (who is a Designated Safeguarding Officer) holds overall responsibility for ensuring that the Prevent policy is implemented across the company and any concerns are shared with the relevant organisations in order to minimise the risk of learners becoming involved with terrorism.  She is assisted by the Deputy Safeguarding Lead (Catherine Alderson) in this task.
 
The Designated Safeguarding Officer will ensure that staff and learners are aware of the Prevent Agenda and appropriate training is in place.  She will also ensure that as far as is possible all consortia members undergo consistent training from reputable training organisations, including Counter Terrorism units.
 
All staff have been trained to L2 in Understanding Prevent and Safeguarding Strategies.
 
All staff at Gradvert Ltd have a responsibility to:
 
 Provide an ethos which upholds the organisation’s mission, vision and values and promote respect, equality and diversity and inclusion  Report any concerns around extremism or radicalisation via the safeguarding reporting channels  Report and remove any literature displayed around the organisation that could cause offense or promote extremist views  Support the development of staff and learner understanding of the issues around extremism and radicalisation and participate in training when requested  Participate in engagement with local communities, schools and external organisations as appropriate.
 
Referrals
 
Where there is an identified/potential risk that a learner may be involved in supporting or following extremism, further investigation by the police will be requested, prior to other assessments and interventions.  The Designated Safeguarding Officer is responsible for contacting the local Police or the Local Children’s Safeguarding Board for further advice and guidance.
 
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Any member of staff who identifies such concerns must report these to the Designated Safeguarding Officer or deputies as soon as possible for action – this will be recorded in the usual manner on the Gradvert Ltd ‘Safeguarding Report Form’.
 
Incidents in relation to extremism are expected to be very rare but immediate action will be adopted when there is information that a violent act is imminent, or where weapons or other materials may be in the possession of a learner or a community member.  In this situation, a 999 call will be made and the organisation’s Leadership and Management team informed as soon as practicably possible.
 
Where a child or vulnerable adult is thought to be in need or at risk of significant harm or where investigations need to be carried out a referral to Social Services will be made in line with the organisation’s safeguarding procedures following advice from the appropriate agencies.
 
 
Training
 
 Training on PREVENT will be delivered as and when there is a necessity to ensure that all staff have up to date information and briefings.  This will be delivered by either the Designated Safeguarding Officer or a variety of partners known to the organisation – such as College of Policing PREVENT Channel training (which staff complete).  We also have links with the G7-Prevent Regional lead for the DFE and Newcastle City Council Prevent Lead and briefings/updates have been delivered to staff.  All new staff to the organisation will receive Prevent training as part of their Induction programme, and certificates are kept by the Designated Safeguarding Officer.  All staff (to whom it is relevant) are asked to register with the DBS update Service.  All staff will be trained on Education and Training ‘Prevent for Practitioners’ and also Safeguarding in FE’.   The statutory guidance – Keeping Children Safe in Education – September 2018 –  The DSO updates and plans training for all staff in line with requirements and ensures that Hot Topics are delivered to all staff in relation to Prevent and Safeguarding.  As part of our ongoing commitment to the consortia members whom we sub-contract 
 
Access & monitoring of IT systems
 
In order to safeguard individuals from accessing extremist materials while using company equipment Gradvert Ltd will ensure:
 
 There is the ability to log and retain records of all electronic communication (web browsing, email exchanges etc.,) by users on the organisation network.  Appropriate staff are able to monitor any aspects of its telephone, mobile phones and computing facilities that are made available to staff, learners and visitors  Only organisation approved software will be supported by the organisation and allowed to be used  All unauthorised software that breaches organisation policy or presents a risk to staff or learner safety will be removed and appropriate action taken  All unusual or suspicious events, and any breaches of security are reported via the safeguarding reporting channels for further investigation.
 
Partnership Working
 
Gradvert Ltd maintain well-established partnerships; including Police CTU, Local Children’s Safeguarding Board for the boroughs and councils within the areas of delivery and established agencies throughout the area, this enables a network of support to be created and for information exchange where possible to take place.
 
Other
 
A Risk Assessment for the Prevent Strategy accompanies this Policy as Appendix 1.
 
A Policy exists for Freedom of Speech, Events and British Values and is available on our website alongside all other policies and documents referring to Safeguarding.

 

 

Complaints Policy

This policy summarises the procedure to be followed to process complaints received from clients regarding the quality of service delivered by Gradvert Ltd:

  1. Complaints may originate from learners, employers or assessors directly or indirectly.  Complaints may be received either verbally or in writing.

 

  1. Each instance of complaint must be reported/directed to the relevant Line Manager. Upon  receipt of the complaint the individual will complete the appropriate sections of a

      Complaints Record Form for appropriate action. 

 

  1. Every effort will be made to resolve the complaint and to provide a full response to the complainant within 7 working days.

 

  1. Once the complaint has been resolved the employee will complete the relevant sections of the Complaints Record Form, which will then be signed off by the line manager.

 

  1. The Managing Director (Michaela Reaney) will be responsible for maintaining all records relating to a complaint, using an appropriate Complaints Record Form as the basis for monitoring the progress made in resolving the complaint. Records will include all written complaints received, and copies of all statements from relevant parties.

 

  1. Completed Complaints Record forms will be reviewed on a regular basis for apparent adverse trends in service quality as part of the Management Review of the Quality System and to monitor equality and diversity.

 

Procedure:

 

  1. Complaint received
    • All complaints will be treat on an individual basis and, depending on how a complaint is received, will dictate the appropriate course of action.

 

  1. Telephone complaint

 

  • Upon receipt of a telephone complaint the person dealing with the call should in the first instance pass the complaint on to the Managing Director (Michaela Reaney) and in the event of them being absent the call should be passed on to the most appropriate person. If neither is available, then the person taking the call should take details of the complaint and complete the Complaint Record Form.

 

  • The complaint will be logged into the Complaints register by the Line Manager and a copy of the complaint form will be forwarded to the appropriate person.

 

  • Once the complaint has been resolved the complaint form will be completed accordingly and a final letter / email sent to the complainant with the outcome.

 

 

  1. Written complaint
    • Upon receipt of a written complaint, either postal or via email, the complaint will be forwarded to the Managing Director (Michaela Reaney) who will contact the complainant by phone and complete the Complaints Form. In the event of the Managing Director (Michaela Reaney) not being available and it is known they will not be so within the next 24 hours, the most appropriate person should then make the call and complete the Complaints form. If neither is available the person who picked up the email should take the action to call the complainant and complete the Complaints form.

 

  1. Review
    • Complaints will be reviewed on a yearly basis by the Managing Director (Michaela Reaney) and an analysis of complaints will be compiled.

 

  • The Managing Director (Michaela Reaney) will liaise with the staff to discuss continuous improvements and identify trends. Any actions to be put into place to ensure business practices are having a positive impact on complaints.