Our Policies

Introduction 

These terms and conditions apply between you, the User of this Website (including any sub-domains, unless expressly excluded by their own terms and conditions), and Hawk Management (UK) Limited, the owner and operator of this Website. Please read these terms and conditions carefully, as they affect your legal rights. Your agreement to comply with and be bound by these terms and conditions is deemed to occur upon your first use of the Website. If you do not agree to be bound by these terms and conditions, you should stop using the Website immediately. 

In these terms and conditions, User or Users means any third party that accesses the Website and is not either (i) employed by Hawk Management (UK) limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Hawk Management (UK) Limited and accessing the Website in connection 'with the provision of such services.  

Intellectual property and acceptable use 

• All Content included on this Website, unless uploaded by Users, is the property of Hawk Management (UK) Limited, our affiliates or other relevant third parties. In these terms and conditions, Content means any text, graphics, images, audio, video, software, data compilations, page layout, underlying code and software and any other form of information capable of being stored in a computer that appears on or forms part of this Website, including any such content uploaded by Users. By continuing to use this Website you acknowledge that such Content is protected by copyright, trademarks, database rights and other intellectual property rights. Nothing on this site shall be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark, logo or service mark displayed on the site without the owner's prior written permission 
• You may, for your own personal, non-commercial use only, do the following: 
  1. display and view the Content on a computer screen 
  2. download and store the Content in electronic form on a disk (but not on any server or other storage device connected to a network) 
  3. print copies of the Content 
• You must not otherwise reproduce, modify, copy, distribute or use for commercial purposes any Content without the written permission of Hawk Management (UK) Limited. 
• You acknowledge that you are responsible for any Content you may submit via the Website, including legality, reliability, appropriateness, originality and copyright of any such Content. You may not upload, distribute or otherwise publish through the Website any Content that (i) is confidential, proprietary, false, fraudulent, libellous, defamatory, obscene, threatening, invasive of privacy or publicity rights, infringing on intellectual property rights, abusive, illegal or otherwise objectionable; (ii) may constitute or encourage a criminal offence, violate the rights of any party or otherwise give rise to liability or violate any law; or (iii) may contain software viruses, political campaigning, chain letters, mass mailings, or any form of "spam." You may not use a false email address or other identifying information, impersonate any person or entity or otherwise mislead as to the origin of any content. You may not upload commercial content onto this Website. 
• You represent and warrant that you own or otherwise control all the rights to the Content you post; that the Content is accurate; that use of the Content you supply does not violate any provision of these terms and conditions and will not cause injury to any person; and that you will indemnify Hawk Management (UK) Limited for all claims resulting from Content you supply. 

Prohibited use 

1. In any way which causes, or may cause, damage to the Website or interferes with any other person's use or enjoyment of the Website;
2. In any way which is harmful, unlawful, illegal, abusive, harassing, threatening or otherwise objectionable or in breach of any applicable law, regulation, governmental order;
3. Making, transmitting or storing electronic copies of Content protected by copyright without the permission of the owner. 

Registration 

• You must ensure that the details provided by you on registration or at any time are correct and complete. 
• You must inform us immediately of any changes to the information that you provide when registering by updating your personal details to ensure we can communicate with you effectively. 
• We may suspend or cancel your registration with immediate effect for any reasonable purposes or if you breach these terms and conditions. 
• You may cancel your registration at any time by informing us in writing to the address at the end of these terms and conditions. If you do so, you must immediately stop using the Website. Cancellation or suspension of your registration does not affect any statutory rights. 

Links to other websites 

• This Website may contain links to other sites. Unless expressly stated, these sites are not under the control of Hawk Management (UK) Limited or that of our affiliates. 
• We assume no responsibility for the content of such Websites and disclaim liability for any and all forms of loss or damage arising out of the use of them. 
• The inclusion of a link to another site on this Website does not imply any endorsement of the sites themselves or of those in control of them. 

Privacy Policy and Cookies Policy 

• Use of the Website is also governed by our Privacy Policy and Cookies Policy, which are incorporated into these terms and conditions by this reference. To view the Privacy Policy and Cookies Policy, please click on the following: https://info.hawktraining.com!help-centre/ your-data/ privacy-policy and https://info.hawktraining.com!helpcemre/website/ cookie-policy. 

Availability of the Website and disclaimers 

• Any online facilities, tools, services or information that Hawk Management (UK) Limited makes available through the Website (the Service) is provided "as is" and on an "as available" basis. We give no warranty that the Service will be free of defects and/or faults. To the maximum extent permitted by the law, we provide no warranties (express or implied) of fitness for a particular purpose, accuracy of information, compatibility and satisfactory quality. Hawk Management (UK) Limited is under no obligation to update information on the Website. 
• Whilst Hawk Management (UK) Limited uses reasonable endeavours to ensure that the Website is secure and free of errors, viruses and other malware, we give no warranty or guarantee in that regard and all Users take responsibility for their own security, that of their personal details and their computers. 
• Hawk Management (UK) Limited accepts no liability for any disruption or non-availability of the Website. 
• Hawk Management (UK) Limited reserves the right to alter, suspend or discontinue any part (or the whole of) the Website including, but not limited to, any products and/or services available. These terms and conditions shall continue to apply to any modified version of the Website unless it is expressly stated otherwise. 

Limitation of liability 

• We will not be liable to you in respect of any losses arising out of events beyond our reasonable control. 
• Nothing in these terms and conditions will: (a) limit or exclude our or your liability for death or personal injury resulting from our or your negligence, as applicable; (b) limit or exclude our or your liability for fraud or fraudulent misrepresentation; or (c) limit or exclude any of our or your liabilities in any way that is not permitted under applicable law. 
• To the maximum extent permitted by law, Hawk Management (UK) Limited accepts no liability for any of the following: 
  1. any business losses, such as loss of profits, income, revenue, anticipated savings, business, contracts, goodwill or commercial opportunities; 
  2. loss or corruption of any data, database or software; 
  3. any special, indirect or consequential loss or damage. 

General 

• You may not transfer any of your rights under these terms and conditions to any other person. We may transfer our rights under these terms and conditions where we reasonably believe your rights will not be affected. 
• These terms and conditions may be varied by us from time to time. Such revised terms will apply to the Website from the date of publication. Users should check the terms and conditions regularly to ensure familiarity with the then current version. 
• These terms and conditions together with the Privacy Policy and Cookies Policy contain the whole agreement between the parties relating to its subject matter and supersede all prior discussions, arrangements or agreements that might have taken place in relation to the terms and conditions. 
• The Contracts (Rights of Third Parties) Act 1999 shall not apply to these terms and conditions and no third party will have any right to enforce or rely on any provision of these terms and conditions. 
• If any court or competent authority finds that any provision of these terms and conditions (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of these terms and conditions will not be affected. 
• Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy. 
• This Agreement shall be governed by and interpreted according to the law of England and Wales and all disputes arising under the Agreement (including non-contractual disputes or claims) shall be subject to the exclusive jurisdiction of the English and Welsh courts. 

Hawk Management (UK) Limited details 

• Hawk Management (UK) Limited is a company incorporated in England and Wales with registered number 03501389 whose registered address is Hawk Training, 4th floor, Regal House, 70 London Road, Twickenham, TW1 3QS and it operates the Website www.hawktraining.com. The registered VAT number is 210705948. You can contact Hawk Management (UK) Limited by email on enquiries@hawktraining.com. 

Introduction

We are committed to protecting your privacy. This privacy policy applies to our website and sub-websites and our associated platforms owned or operated by Hawk Training. This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. By using the website(s) or any of our services, you consent to the data practices described in this privacy policy. If you do not agree with the data practices described in this Privacy Policy, you should not use the websites or our services.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time by posting a new version online. You should check this page occasionally to review any changes. This helps you to always be aware of what information we collect, how we use it and under what circumstances, if any, it is disclosed. Your continued use of the website(s), our services, and/or continued provision of Personal Information to us will be subject to the terms of the then-current Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please email privacy@hawktraining.com

If you have any complaints or questions regarding your data or a Subject Access Request (SAR), please email privacy@hawktraining.com

About Us

This website is operated by Hawk Management (UK) Limited (Hawk). Unless stated otherwise, Hawk is the data controller in respect of all personal data collected on our website(s) which means that we are responsible for ensuring that we do so in full compliance with data protection and all related privacy laws.

This Privacy Policy explains what information is collected about you, how we use it and the steps taken to keep it secure.

Please note, our website may contain links to other websites which are provided for your convenience. We are responsible for our own security of the website and practices. For other websites, please refer to their own Privacy Policies.

The Information we collect and its sources

In order to provide our services, we obtain details including:

• contact details of those we deliver apprenticeship or commercial training to and those who work within an organisation as a point of contact for billing, contracts and decision making
• Residential status - for example, where the apprenticeship programme is funded by the government and requires applicants to have a right to work in the UK
• Current study status - for example, where the apprenticeship programme is funded by the government and needs to be verified for eligibility
• National insurance number/date of birth/gender/disability/ethnicity information
• Feedback we receive and your interest in Hawk Training and its services
• Employment details - this is used to contact the employer of an apprentice/learner and for tutor visits as well as employer logins to the e-portfolio systems.
• Emergency contact details of your next of kin or trusted contact in case of an emergency

The information will be obtained from our websites, telephone conversations, emails, written and verbal communications and from records of training sessions or meetings.

We may add information you supply with other information that we obtain from our dealings with you (such as where we have worked with you in the past or you have received training with us in the past).

Information about other people

If you provide information to us about any person other than yourself, you must ensure that they understand how their information will be used and that you are authorised to disclose it to us, and to consent to its use on their behalf, before doing so.

Cookies

This website uses cookies to improve the user’s experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user's device.

Cookies are small files saved to the user's device that track, save and store information about the user's interactions and usage of the website. This allows the website, through its server to provide users with a tailored experience within this website. Users are advised that if they wish to deny the use and saving of cookies from this website on to their device, they should take necessary steps within their web browser’s security settings to block all cookies from this website and its external serving vendors.

This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your device in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google's privacy policy here for further information [ http://www.google.com/privacy.html ].

Other cookies may be stored to your device by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.

If you select decline on our cookie pop up then we won't track your information when you visit our site. But in order to comply with your preferences, we'll have to use just one tiny cookie so that you're not asked to make this choice again.

How we will use your information

All personal information we collect about you or other individuals will be used and protected by us in accordance with current data protection legislation and this Privacy Policy.

We will mainly use your personal information:

• for processing, vetting and screening applications for apprenticeship roles
• to provide services you request from us
• to track and analyse activity on our website(s)
• to create a contact profile for you so we can provide an enhanced user experience, respect your preferences and subscription requests
• to maintain suppression and opt-in lists for newsletters, offers and other marketing emails
• for dealing with enquiries
• to carry out market research in order to improve our services and offer
• for use in statistics reports, such as succession rates
• to relay dietary information to catering services ahead of events you have registered to attend
• for adequate and non-excessive processing
• for processing for a limited purpose
• for access to our e-portfolio systems e-Track, ForSkills, Moodle and storage on our management information systems.
• to contact you in order to reengage and ensure our services are delivered successfully
• to share with emergency services, safeguarding officers or related agencies with your permission to ensure learner welfare and wellbeing is maintained 
  • If you are under 18 and your safety or welfare is at risk, then we have a duty of care to pass on confidential information to external agencies 

Your personal information may be used by the Department for Education (DFE) to exercise its functions and to meet its statutory responsibilities, including under the Apprenticeships, Skills, Children and Learning Act 2009 and to create and maintain a unique learner number (ULN) and a personal learning record (PLR). Your information will be securely destroyed after it is no longer required for these purposes.

Consent and lawful processing of personal data

The legal basis for the collection and processing of your personal data is:

• for administration: which is necessary to fulfil service requests
• where consent is provided or processing may be necessary, to comply with legal obligations
• where explicit consent has been provided for processing sensitive data
• legally required by the Education and Skills Funding Agency (ESFA)

Receiving invitations, information, emails, offers and content

We would like to contact you and/or any person whose information you provide to us with invitations to enjoy other products and services we provide (where you have agreed). This may include newsletters to inform you and/or them about offers and opportunities that are available and about a range of other initiatives in a number of ways, including by text message or by email.

Details on how to opt-in to or opt-out of receiving newsletters and offers can be found on relevant areas of our website, on relevant forms you complete and/or in the electronic message you receive.

Preferences – Subscribing and Unsubscribing

You and any other person you provide information for can change your/their mind about whether you wish to receive details of our offers and opportunities at any time. You may change your preferences using our contact details above or by following the instructions found at the bottom of each of our emails.

Security

We take the security of personal information seriously. We use several layers of security technology such as firewalls and security certificates to safeguard your and other’s information. We also have procedures in place to ensure our computer systems, databases, servers and paper stores are protected against unauthorised disclosure, use, loss and damage.

We only use third party service providers where we are satisfied that they provide their own adequate security of your personal data.

Monitoring

We may monitor or record telephone calls for training and quality purposes.

Data Retention

We have several set durations for the retention of personal information depending on the information used. We regularly review the personal data we hold and will delete anything we no longer need.

For information stored for the purpose of marketing, we normally keep your personal data for 24 months, although we will review your data sooner should you become disengaged with us.

For information stored for the purpose of training and education, we follow the Education and Skills Funding Agency retention policy, personal data will only be retained if a business need exists. We will also not keep your personal data longer than required.

If you are or have been on an apprenticeship programme with us, we are contractually required to retain data for 14 years (+1 for auditing purposes).

If you have applied for an apprenticeship but were unsuccessful in finding an apprenticeship or job then data is retained for up to 180 days.

If you are one of Hawk Training’s employees, then your data will be stored for up to 6 years (+ 1 for auditing purposes) after you have left the company.

Use of your information outside of Europe

We do not currently transfer your personal data outside of the European Economic Area (EEA). If this changes and we do need to transfer your personal data outside of the EEA, then we will take the proper steps to ensure your data is protected in accordance with the Privacy Policy and applicable laws.

Updating and correcting information

You may update or correct personal information online using relevant membership areas or by contacting us at privacy@hawktraining.com. Please include your name and email address when contacting us so we can correctly identify you on our systems and ensure we amend the information for the correct person.

If you are providing updates or corrections about another person, we may require you to provide us with proof that you are authorised to provide that information to us.

Your rights

You have a number of legal rights in respect of your personal data. These include:

• the right of access – Upon your request, we can provide the data we have collected of you. We normally expect to respond to requests within 28 days of receiving them, you can fill in the form here to make a request or by emailing privacy@hawktraining.com
• the right to rectification – You have the right to have inaccurate personal data rectified that we have collected. You may also be able to have incomplete personal data completed.
• the right to erasure – Also known as the ‘right to be forgotten’, you have the right to have your personal data erased if:

1. the personal data is no longer necessary for the purpose which we originally collected or processed it for;
2. we are relying on consent as our lawful basis for holding your data, and you withdraw your consent;
3. we are relying on legitimate interests as our basis for processing and you object to the processing of your data, and there is no overriding legitimate interest to continue this processing;
4. we are processing the personal data for direct marketing purposes and you object to that processing;
5. we have processed the personal data unlawfully;
6. we must do it in order to comply with a legal obligation; or
7. we have processed the personal data to offer information society services to a child.

• the right to data portability – You have the right to receive personal data you have provided to us in a structured, commonly used and machine readable format. You also have the right to request that we transmit this data directly to another data controller.

Apprentice Candidate Privacy Notice

Data controller: Hawk Training

As part of our recruitment process, Hawk Training collects and processes personal data relating to apprenticeship applicants on behalf of employers it is recruiting for. Hawk Training is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does Hawk Training collect?

Hawk Training collects a range of information about you. This includes:

• your name, address and contact details including email address and telephone number;
• your ethnicity, gender and age;
• details of your qualifications, skills, experience and employment history;
• whether or not you have a disability for which Hawk Training needs to make reasonable adjustments during the recruitment process,
• information about your entitlement to work in the UK.; and
• eligibility and motives for wishing to start an apprenticeship programme

Hawk Training may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment such as online tests or assessment days.

Data will be stored in a range of different places, including on your application record, in a password protected CRM system called Maytas and on other IT systems (including email).

Why does Hawk Training process personal data?

Hawk Training needs to process personal data to take steps at your request prior to entering into a contract with you. It also needs to process your personal data on behalf of employers it is recruiting for, in order for them to make recruitment decisions and potentially enter into a contract of employment with you.

In some cases, Hawk Training needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.

Hawk Training has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows Hawk Training to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a position on behalf of an employer. Hawk Training may also need to process data from applicants to respond to and defend against legal claims.

Hawk Training may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. It may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. Hawk Training processes such information to carry out its obligations and exercise specific rights in relation to employment, on behalf of employers that we are recruiting for.

If your application is unsuccessful, Hawk Training may initially keep your personal data on file for up to 6 months in case there are future employment opportunities for which you may be suited. Hawk Training will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time. After a 5-month period, Hawk Training will contact you to ask for your consent to keep your personal data on file for a further 12-month period in case there are future employment opportunities for which you may be suited. Hawk Training will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Personal data gathered during the recruitment process may be shared internally amongst our Business Development Team for the purposes of a recruitment exercise.

If you are successful in your application, Hawk Training will then share your personal data with the prospective employer to obtain pre-employment checks. Hawk Training will also have a duty to share any data relating to your apprenticeship with Apprenticeships Certificates England (ACE), the Education Skills Funding Agency (ESFA) and the relevant awarding body as part of government regulations. 

For more information about this please refer to our Fair Processing Notice.

Hawk Training will not transfer your data outside the European Economic Area.

How does Hawk Training protect data?

Hawk Training takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed by anyone other than members of the Business Development Team, Company Directors, line managers involved in the recruitment process and prospective employers we are recruiting on behalf of. Any application forms, CVs, copies of certificates or information about your entitlement to work in the UK are securely saved in a password protected CRM system called Maytas and hardcopies are shredded and/or deleted after the retention period has ended, unless an offer of employment has been made and accepted.

For how long does Hawk Training keep data?

If your application for employment is unsuccessful, Hawk Training will hold your data on file for 6 months after the end of the relevant recruitment process. If you agree to allow Hawk Training to keep your personal data on file, Hawk Training will hold your data on file for a further 12 months for consideration for future employment opportunities. At this juncture, we will contact you for your consent to retain your information for this extended period. At the end of that period or once you withdraw your consent, your data is deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred over to the relevant employer that we are recruiting on behalf of. The period for which your personal data will be held by your new employer, should be provided to you in your new employer’s employee notice policy. Hawk Training will continue to retain your personal data on file for the duration of your apprenticeship with us. Hawk Training will also have a duty to share any data relating to your apprenticeship with Apprenticeships Certificates England (ACE), the Education Skills Funding Agency (ESFA) and the relevant awarding body as part of government regulations. 

Your rights

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;
• require Hawk Training to change incorrect or incomplete data;
• require Hawk Training to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
• object to the processing of your data where Hawk Training is relying on its legitimate interests as the legal ground for processing.

If you would like to exercise any of these rights, please contact Human Resources via email at privacy@hawktraining.com or by post to Hawk Training, 70 London Road, Twickenham, TW1 3QS.

If you believe that Hawk Training has not complied with your data protection rights, you can contact the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Hawk Training during the recruitment process. However, if you do not provide the information, Hawk Training may not be able to process your application properly or at all.

Automated decision-making

All applications to Hawk Training are reviewed with meaningful human intervention and recruitment processes and decisions are not based solely on automated processing or profiling.

Candidate Privacy Notice

Data controller: Hawk Training (‘the Employer’)

As part of any recruitment process, Hawk Training collects and processes personal data relating to job applicants. Hawk Training is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does the Employer collect?

Hawk Training collects a range of information about you. This includes:

• your name, address and contact details, including email address and telephone number;

• details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration, including benefit entitlements;
• whether or not you have a disability for which Hawk Training needs to make reasonable adjustments during the recruitment process; and
• information about your entitlement to work in the UK.

Hawk Training may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment such as online tests.

Hawk Training may also collect personal data about you from third parties, such as references supplied by former employers and background and criminal record checks from the Disclosure and Barring Service via our umbrella body People Check Ltd. Hawk Training will seek information from third parties only once an offer of employment has been made and accepted and will inform you that it is doing so.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why does the Employer process personal data?

Hawk Training needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.

In some cases, Hawk Training needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.

Hawk Training has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows Hawk Training to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. Hawk Training may also need to process data from job applicants to respond to and defend against legal claims.

Hawk Training may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. It may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. Hawk Training processes such information to carry out its obligations and exercise specific rights in relation to employment.

For some roles, Hawk Training is obliged to seek information about criminal convictions and offences. Where Hawk Training seeks this information from the Disclosure and Barring Service via our umbrella body People Check Ltd, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, Hawk Training may initially keep your personal data on file for up to 6-months in case there are future employment opportunities for which you may be suited. Hawk Training will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time. After a 5-month period, Hawk Training will contact you to ask for your consent to keep your personal data on file for a further 12-month period in case there are future employment opportunities for which you may be suited. Hawk Training will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR team, line managers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

Hawk Training will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. Hawk Training will then share your data with former employers to obtain references for you, and will contact the Disclosure and Barring Service via our umbrella body People Check Ltd to obtain necessary background and criminal record checks.

Hawk Training will not transfer your data outside the European Economic Area.

How does the Employer protect data?

Hawk Training takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed by anyone other than members of the HR team, Company Directors or line managers involved in the recruitment process. Any application forms, CVs, copies of certificates or information about your entitlement to work in the UK are securely saved in a password protected HR management system and are shredded and/or deleted after the retention period has ended, unless an offer of employment has been made and accepted.

For how long does the Employer keep data?

If your application for employment is unsuccessful, Hawk Training will hold your data on file for 6 months after the end of the relevant recruitment process. If you agree to allow Hawk Training to keep your personal data on file, Hawk Training will hold your data on file for a further 12 months for consideration for future employment opportunities. At this juncture, we will contact you for your consent to retain your information for this extended period. At the end of that period or once you withdraw your consent, your data is deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

Your rights

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;
• require Hawk Training to change incorrect or incomplete data;
• require Hawk Training to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
• object to the processing of your data where Hawk Training is relying on its legitimate interests as the legal ground for processing.

If you would like to exercise any of these rights, please contact Human Resources via email at humanresources@hawktraining.com or by post to Hawk Training, 70 London Road, Twickenham, TW1 3QS.

If you believe that Hawk Training has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Hawk Training during the recruitment process. However, if you do not provide the information, Hawk Training may not be able to process your application properly or at all.

Automated decision-making

All applications to Hawk Training are reviewed with meaningful human intervention and recruitment processes and decisions are not based solely on automated processing or profiling.

Hawk Training | Our Equality and Diversity Policy

This document sets out the policy to be implemented throughout Hawk Training's Provision and Services:

1.0  Purpose

Hawk Training is an equal opportunity employer.

This Equality, Diversity and Inclusion Policy is designed to implement the commitment of Hawk Training to equality and inclusion. This policy has been agreed and signed off by Crawford Knott Managing Director.

We are committed to being a successful, caring and welcoming place for all of our employees and applicants for roles with us. We want to create a supportive and inclusive environment where our employees can reach their full potential, without prejudice and discrimination. We are committed to a culture where respect and understanding is fostered and the diversity of people's backgrounds and circumstances will be positively valued.

Equality of opportunity, valuing diversity and compliance with the law is to the benefit of all individuals in our Company as it seeks to develop the skills and abilities of its people. While specific responsibility for eliminating discrimination and providing equality of opportunity lies with managers and supervisors, individuals at all levels have a responsibility to treat others with dignity and respect.

Through this policy and procedure and the training and development of managers and staff, Hawk Training will do all it can to promote good practice in this area in order to eliminate discrimination and harassment as far as is reasonably possible. We will also continue to work towards our dedicated goal of encouraging and promoting equality and diversity within the workforce.

We believe that this vision of equality and diversity brings tangible benefits for our learners, and for the employers that we work with.

For our learners, this includes a training environment personalised to their individual requirements where they can participate fully, give their best and achieve their full potential in a climate free from discrimination or harassment.

For our employers, equality brings benefits for core business, for example:

• A more diverse workforce, bringing a wider range of individual strengths, experiences and perspectives
• Increased employee satisfaction and motivation, which helps attract new staff and retain those already there, reducing recruitment costs and increasing productivity
• Improved understanding of the diverse groups of potential and existing customers, providing a better service and providing access to markets that may not previously have been tapped into
• Finding workers to fill skills gaps
• Improved organisational image across a wider audience.

The Equality Act 2010 introduces the term ‘protected characteristic’ to refer to aspects of a person’s identity explicitly protected from unlawful discrimination. The Act also introduces a Public-Sector Equality Duty to eliminate discrimination, harassment and victimisation, advance equality and foster good relations. This policy is designed to implement these requirements. Appendix A provides further information on these legal requirements.

2.0 EQUALITY, DIVERSITY AND INCLUSION POLICY STATEMENT AND EXPECTATIONS

Hawk Training seeks to create and maintain an inclusive working and learning environment that respects and celebrates difference. This helps create an ethos and culture where all feel valued and empowered, regardless of the many ways that people are different. This may include, for example, age, disability, gender, marriage and civil partnership, pregnancy and maternity, race, religion and belief, sexual orientation, social-economic background or class, and trans gender.

Hawk Training has zero tolerance to any form of bullying, discrimination or harassment, on any of the above or other grounds

We expect all who work and learn at Hawk Training to abide by this policy statement. This includes staff, learners, employers, trustees and visitors.

3.0  ROLES AND RESPONSIBILITIES

During the apprenticeship programme we will introduce equality and diversity this will be done at key stages

1. Induction – During the programme induction we will discuss equality and diversity and the learner’s rights during the apprenticeship. We will make sure the employer has an Equality and Diversity policy and that the apprenticeship is aware and is compliant with this.
2. Learning and Assessment visits- At each visit we will ask the learner key questions regarding their wellbeing that will also cover Equality and Diversity. (Questions found in ILP)
3. Programme Reviews- At each programme review will ask questions to test the learner’s knowledge on Equality and Diversity (questions found in ILP)
4. Surveys – Learners will be surveyed during the programme and at the end of the programme, these surveys will help us identify any issues.

• Moodle – Our e learning platform Moodle. Following the enrolment onto any of our qualifications, All Learners must complete mandatory modules on Safeguarding, Equality, Online Safety and Prevent and British Values. This will be the start of the on-going natural embedding into their curriculum.

There are also other resources under the You Matter tile which is there to support the learner with wellbeing issues including Equality and Diversity.

Hawk Training will

• ensure publications, marketing and promotional materials, key documents such as handbooks, and staff, employer and learner recruitment procedures endorse and support equality and diversity
• seek to recruit the full diversity of staff, to bring a range of experiences and perspectives to the workforce and to provide a range of role models and ambassadors to our learners
• ensure learner recruitment procedures will be free from bias and proactively promote equality and diversity. Recruitment procedures do not use any identifies regarding the learner. Learners are given opportunities to disclose any information they may feel relevant to the recruitment process such as requesting learner support for mental health reasons, but this is up to the individual. Learners have opportunity to disclose any information at each visit with their tutor and will then need to provide consent for this information to be shared, unless it is a safeguarding risk.
• work with learners to plan the learning programme, materials, methods and resources to consider personal needs and aspirations and equality of opportunity without bias or discrimination. Each learner’s programmes are designed to be individual to their needs and information used to support that is only that which has been provided by the learner and is relevant to the programme.
• make participants in the learning process aware that they have a legal and formal duty to play their part in this policy, and positive steps will be taken to ensure no form of unlawful discrimination occurs. This is reviewed with learners and employers at formal reviews.
• ensure that learning takes place in a supportive environment free from discrimination or harassment. Questions are asked around the learner’s wellbeing at each visit and responses recorded on their ILP.
• ensure that equality and diversity is built into all aspects of the apprenticeship programme processes.
• Actively promote British values to help:

• Create ‘safe spaces’ for dialogue and discussion
• Provide opportunities to challenge views and bring a ‘counter-narrative’
• Identify and protect students vulnerable to extremist ideologies
• prepare learners to live and work In Britain’s complex multicultural society

• continue to provide training in equality and diversity to learners and staff, so that all learners and staff at Hawk Training have the opportunity to develop their skills and confidence and to deal with equality & diversity issues in a professional manner
• deal with all allegations of safeguarding, discrimination, harassment and victimisation sensitively and investigate fairly and thoroughly.
• treat any form of discrimination, harassment or victimisation carried out by an individual as a matter for possible disciplinary action

• lead by example in our dealings with learners, employers and any other contacts.
• support employers to improve their equality and diversity practices.
• use analysis of data to inform future planning, for example to improve the representation, participation and success of under-represented and under-achieving groups, and to challenge stereotyping.

Learners are responsible for

• treating tutors, other learners and work colleagues with dignity and respect.
• not doing anything that would discriminate or harass others because of their race, gender, disability, age, sexual orientation, religion, personal background or circumstance
• reporting any issues of discrimination, bullying or harassment

Employers are expected to

• abide by this equality, diversity and inclusion policy.
• have their own equality and diversity policies in place, including those associated polices.

It is the responsibility of all staff, learners, and employers of learners to work together towards combating all forms of discrimination. This includes reporting all incidents of discrimination using Hawk Training procedures.

Breaches of this equality and diversity policy will be taken seriously and may be regarded as misconduct. For staff at Hawk Training, for example, this may result in disciplinary action. For learners, this may involve disciplinary action, including suspension or withdrawal from the training programme. For employers, this may involve cessation of a learning contract.

4.0      SUPPORT FOR DISABLED LEARNERS

We will encourage the integration and inclusion of disabled learners into the Centre. Learners will be offered individualised programmes of development to assist to achieve their personal learning goals. All reasonable adjustments will be made to support disabled learners.

Learners will be invited to access additional support and refer to our Disability Discrimination Statement and Disclosure procedure

Hawk Training provides a wide range of additional support to meet their individual requirements. We respect the individual’s right to confidentiality, so any information provided will be kept private and will not be passed to anyone without the person’s explicit consent.

If a person has requested additional support, they may also arrange a confidential interview with a member of the safeguarding team.

5.0       MONITORING AND EVALUATION

Hawk Training’s Senior Management Team will monitor and evaluate the implementation of this policy, which will include the following:

• Routinely analyse E&D learner statistical reports to identify areas of under-representation and achievement, for example statistics about learner recruitment, success and destination, by gender, age, ethnicity, learning difficulty, disability and safeguarding.
• Report on equality gaps, targets, action and progress at Staff and Management meetings
• Scrutinise reported incidents including incidents of abuse, bullying and harassment and unfavourable treatment;
• Analyse ED&I staff statistical reports, such as outcomes from recruitment and selection, to ensure Hawk Training recruits and retains a diverse workforce.
• Monitoring of learners and employers is also collected independently through ESFA learner and employer surveys and Ofsted learner and parent view platforms.

6.0       LINKS WITH OTHER POLICIES

This equality and diversity policy should be read alongside other Hawk policies and strategies, including:

• Staff recruitment and selection procedures
• Dignity at work policy
• Disclosure and confidentiality policy
• Learning support policy
• Safeguarding policy
• Prevent Policy
• Single Equality Strategy

Appendix A. Legal framework

The policy aims to achieve equality by removing any potential discrimination in the way that our employees are treated by fellow employees or the Company, including:

• people with disabilities
• people of different sexual orientations
• transgendered and transsexual people
• people of different races
• people on the grounds of their sex
• those of faith and of no faith
• in relation to their age
• in relation to their social class or medical condition
• people who work part-time
• those who are married or in a civil partnership
• women who are pregnant, have recently given birth or are breastfeeding.

Discrimination can be either direct or indirect discrimination. Some of the above are protected characteristics under the Equality Act 2010 and discrimination is prohibited unless there is a legal exception under the Equality Act.

The Equality Act 2010 introduces the term ‘protected characteristic’ to refer to aspects of a person’s identity explicitly protected from unlawful discrimination. Nine are identified:

• Race                                                              
• Disability
• Gender
• Age
• Sexual orientation
• Religion and belief
• Gender reassignment
• Pregnancy / maternity
• Marriage / civil partnership.

However, other aspects of a person’s identity, background or circumstance can cause them to experience discrimination, for example a person’s socio-economic status, class, or background. Hawk Training is committed to advancing equality and eliminating discrimination on these and other grounds. We recognise that there are other areas that fall outside of the Act -e.g. name, education, learning or social need.

The Equality Act 2010 introduces a Public Sector Equality Duty, in force from April 2011, https://www.equalityhumanrights.com/en/advice-and-guidance/public-sector-equality-duty, which requires Hawk Training and employers to give due regard to:

• eliminate discrimination, harassment and victimisation
• advance equality of opportunity
• foster good relations.

‘Advance’ involves having due regard to the need to:

1. remove / minimise disadvantages experienced by persons who share a relevant protected characteristic that are connected to that characteristic
2. take steps to meet needs of persons who share a relevant protected characteristic that are different from the needs of persons who don’t share it
3. encourage persons with a relevant protected characteristic to participate in public life or in any other activities where participation by such persons is disproportionately low

‘Foster good relations’ includes having due regard to tackle prejudice and promote understanding.

The Duty covers the nine protected characteristics:

The Equality Act 2010 recognises the following types of discrimination:

• Direct discrimination, including associative and perception discrimination
• Indirect discrimination
• Harassment
• Harassment by others
• Victimisation
• Discrimination arising from a disability
• Failure to make reasonable adjustments

Direct discrimination occurs when someone is treated unfairly, or less favorably than another person, because they have a protected characteristic. This often arises because of assumptions, stereotyping or prejudice. Direct discrimination also covers association discrimination or perception discrimination. This is direct discrimination against someone because they associate with a person who has the protected characteristic or because they are perceived to have a protected characteristic.

Indirect discrimination occurs when a provision, criterion or practice is applied that appears to affect everyone equally but which in fact puts people who share a protected characteristic at a disadvantage.

Harassment occurs when someone behaves in such a way that their conduct has the purpose or effect of creating an environment that is offensive, hostile, degrading, humiliating or intimidating for a person, where:

• this is related to a protected characteristic (except pregnancy and maternity or marriage and civil partnerships)
• this is of a sexual nature (sexual harassment)
• a person is treated less favourably because they have either submitted to or rejected sexual harassment, or harassment related to sex or gender reassignment (this is known as ‘consequential harassment’).

Harassment by others applies to age, disability, gender reassignment, race, religion or belief, sex and sexual orientation.

The Equality Act is clear in terms of the responsibilities of employers ensuing that employees and Learners are not placed at risk from this type of harassment. For example, employers are potentially liable if they are aware that harassment has taken place and have not taken reasonable steps to prevent it from happening again.

Discrimination arising from a disability occurs when a disabled person is treated less favourably than others because of something connected to their impairment

Failure to make reasonable adjustments occurs when an organisation fails to make reasonable adjustments for a disabled person, to avoid the disabled person being placed at a substantial disadvantage when compared with a non-disabled person.

Victimisation occurs when a person experiences disadvantage because they have supported someone in making a complaint or an allegation of discrimination, or because they personally have made an allegation of discrimination.

Appendix A Glossary

(adapted from information provided by the Equality and Human Rights Commission)

Hawk Training | Complaints Policy

1.0  Purpose

Hawk Training is committed to providing a quality service for all learners, employers and stakeholders. Any person, including members of the general public, may make a complaint about any provision of services or facilities that Hawk Training provides.

One of the ways in which we can continue to improve our service is by listening and responding to the views of learners, employers and stakeholders. Therefore, it is important to ensure that:

• Making a complaint is as easy as possible;
• A complaint is treated as a clear expression of dissatisfaction with our service which calls for a response;
• Any complaint is treated seriously - whether it is made in person, by telephone, by letter, by fax, or by email;
• Complaints are dealt with promptly, politely and, where appropriate, informally (for example, by telephone);
• Responses are conducted in the right way: for example, with an explanation, an apology where necessary, or with information on any action to be taken;
• Complaints are learnt from and used to improve services.

Hawk Training will thoroughly investigate any complaint, whether informal or formal, relating to the day-to-day operation of Hawk and the standards of service we provide. Areas excluded from this policy are:

• Assessment decisions or examination results where other forms of redress are more appropriate;
• Employment issues which are covered by Staff Grievance Procedures.
• Whistleblowing – see the Whistleblowing Procedure.

2.0  The difference between a concern and a complaint

A ‘concern’ may be defined as ‘an expression of worry or doubt over an issue considered to be important for which reassurances are sought’. A complaint may be generally defined as ‘an expression of dissatisfaction however made, about actions taken or a lack of action’.

It is in everyone’s interest that complaints are resolved at the earliest possible stage. Many issues can be resolved informally, without the need to invoke formal procedures. Hawk Training will take informal concerns seriously and make every effort to resolve the matter as quickly as possible.

There are occasions when complainants would like to raise their concerns formally. In those cases, all formal complaints should be addressed to Operations Director via telephone or email 0208 891 0992/ Vanessa@hawktraining.com

If for any reason the complainant remains dissatisfied with Hawk Trainings response the situation can be escalated further by contacting the relevant Awarding Organisation and further to the relevant Qualification Regulator.

3.0  Timeliness and Response

Complaints need to be considered and resolved as quickly, and efficiently as possible:  

• All complaints will be taken seriously and dealt with promptly.
• Complainants will receive a reply within 48 hours (working days) from when the complaint is received. If it is not possible to provide a full reply within this time (for instance, because a detailed investigation is required), an interim response, explaining actions being taken to deal with the complaint, key staff involved, timescales for next steps and resolution.
• The full reply will include the outcome and decision of the complaint, what action will be taken if necessary, and will include details of who to contact next if the complaining believes the complaint has not been dealt with properly.
• This will normally be the appropriate senior departmental manager. If, following that second response, a satisfactory outcome has not been achieved; the complaint can be escalated to the Operations Director.
• In the event that a satisfactory response has not been achieved, the complaint will be put forward to an Appeals Panel headed up by the Managing Director who will be responsible for making the final decision in responding to the complaint.
• Complaints are expected to be made as soon as possible after an incident arises (although three months is generally considered to be an acceptable timeframe in which to lodge a complaint); although Hawk Training will consider exceptions.

4.0  Recording Complaints

• Hawk Training will comply with our obligations under the Equality Act 2010. It is common practice to ask for complaints to be made by using a complaint form or in writing, however the complainant may have communication preferences due to disability or learning difficulties and providers must allow alternative methods of contact:
• A complaint may be made in person, by telephone, or in writing;
• In order to prevent any later challenge or disagreement over what was said, brief notes of meetings and telephone calls should be kept, and a copy of any written response added to the record.
• Where there are communication difficulties, recording devices may be used to ensure the complainant is able to access and review the discussions at a later point;
• Hawk Training will record the progress of the complaint and the final outcome. The Operations Director has overall responsibility for keeping these records securely and holding them centrally.
• All staff involved should be aware that complainants have a right to copies.

Hawk Training | Modern Slavery Policy for financial year 2022/2023

1.0 Purpose

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Hawk Management (UK) Limited, trading as Hawk Training has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain. Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Hawk Training has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

2.0 Who we are:

Established in 1989, Hawk Training is an Ofsted 'Outstanding' training provider specialising in apprenticeships. We are passionate about developing people and organisations. Our flexible and innovative approach to delivery is a key strength.

We will work in partnership with you to establish your learning and development strategy, skills gaps of specific staff demographics and budgets to allow us to tailor a programme of delivery to meet your needs. Using cutting edge technology enables us to provide a bespoke service which is cost effective and can take place anytime, anywhere.

3.0 Our high-risk areas

 Hawk Training has not identified any areas of its direct business where there is a high risk of modern slavery, however we do acknowledge through the diverse range of customers we engage with and the recruitment and placement of learners onto apprenticeship programmes there is risk of these customers being involved in Modern Slavery. Our steps to mitigate this risk is through:

1. Embedding training to our apprentices and their employers through our British Values training activity, a mandatory component of every apprenticeship programme that we deliver.  
2. A whistleblowing policy for both staff and apprentices that includes Modern Slavery.

4.0 Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Safer Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
2. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
3. Our Code of Conduct (within our staff handbook). This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
4. Safeguarding policy – on identifying and responding to concerns regarding the safeguarding and protection of children, young people and vulnerable adults.

5.0 Our suppliers

Hawk Training operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery and on-site audits which include a review of working conditions. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy. In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

1. They have taken steps to eradicate modern slavery within their business
2. They hold their own suppliers to account over modern slavery
3. (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate)
4. (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
5. We may terminate the contract at any time should any instances of modern slavery come to light.

6.0 Training

We regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain as part of our Prevent / British Values and Safeguarding.

7.0 Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

1. No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
2. Our internal and external funders audits are at a low risk including checks of our suppliers Approval for this statement

This statement was approved by the Board of Directors on 01/08/2022

Crawford Knott

Managing Director

Hawk Training | Safeguarding Policy

2.0  Policy statement           

Hawk Training believes that it is always unacceptable for a child, young person or adult to experience abuse of any kind and recognises its responsibility to safeguard and promote the welfare of children, young people and adults at risk, by a commitment to practice which protects them.

• The welfare of the child, young person or adult at risk is paramount.
• All children or adults at risk, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity, have a right to equal protection from all types of harm or abuse.
• Working in partnership with children, young people, and adults at risk, their carers and other agencies is essential in promoting the young peoples and adult at risk’s welfare.

• Valuing them, listening to and respecting them

• Adopting child/adult protection guidelines through procedures and a code of conduct for staff and learners

• Recruiting staff and learners safely, ensuring all necessary checks are made

• Sharing information about child/adult protection and good practice with children, parents/carers, staff and learners

• Sharing information about concerns with agencies who need to know, and involving parents/carers and young people/adults at risk appropriately

• Providing effective management for staff through supervision, support and training. Safeguarding and Prevent training will be included in the mandatory induction for staff and will be updated every 3 years.

• Learner development - Following the enrolment onto any of our qualifications, All Learners must complete mandatory modules on Safeguarding, Equality, Online Safety and Prevent and British Values. This will be the start of the on-going natural embedding into their curriculum.

What is Child Protection?

Safeguarding is what we do as a society to protect individuals (in particular, children and vulnerable adults) from harm such as abuse, neglect, and sexual exploitation. Safeguarding ensures children grow up with the best life chances and that all individuals are given safe and effective care.

Child protection is very similar—however, child protection is what we do as a society to protect children who have already experienced abuse, neglect, sexual exploitation, or have otherwise been harmed.

3.0  Scope of this policy

Hawk Training recognises that it has a moral and statutory duty under s175 Education Act 2002 and the Children Act 1989 and Section 26 of the Counter-Terrorism and Security Act 2015 to safeguard and promote the welfare of its learners. These documents offer guidance and outlines procedures that must be followed in all cases of suspected abuse and situations of serious risk.

It applies to all learners under the age of 18 or those over 18 who are considered to be ‘adults at risk’.

• A ‘child’ is anyone under the age of 18 years and up to their 18^th

An adult aged 18 years or over ‘who is or may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation’ (DH, 2000). This definition is taken from the current Department of Health guidance to local partnerships. Other definitions exist in partner organisations.

• What is or may be happening (or happened in the past) to a child/adult in an organisation we inspect (for instance a nursery or school)
• The concern may be brought to our attention by the child/adult themselves through what is said or a change in behaviour, alleged by others or through direct learner visits and observation.
• The concern may be about a current situation or past events and may be about allegations of disclosures of physical abuse, sexual abuse, emotional abuse or neglect, or a combination of one of more of these abuses. Where an adult at risk is concerned it could also involve discriminatory or financial abuse.

4.0  What is abuse?

Abuse and neglect are forms of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. Children and young people may be abused in a family or in an institutional or community setting, by those known to them or, more rarely, by a stranger for example, via the internet. They may be abused by an adult or adults, or another child or children.

Categories of abuse

Physical abuse

• A form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.

Emotional abuse

• The persistent emotional maltreatment of a child, such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to children that they are worthless or unloved, inadequate or valued only for meeting the needs of another person. It may include not giving a child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate

• It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond the child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyber bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

Sexual abuse

• Involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing.

• They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can take place online and technology can be used to facilitate offline abuse.

• Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children (this known as peer-on-peer abuse)

Neglect

• The persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance misuse. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment; protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-takers; or ensure access to appropriate medical care or treatment.

It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

(Definitions taken from Working Together to Safeguard Children 2018)

Other forms of abuse associated with adults at risk include:

Financial Abuse

• Including theft, fraud, exploitation, the misuse of possessions or benefits and pressure applied in relation to financial transactions

• That is based on a person’s disability including harassment.

• This can sometimes happen in residential homes, nursing homes or hospitals when people are mistreated because of poor or inadequate care, neglect and poor practice that affects the whole of that service.

'Keeping Children Safe in Education (KCSIE 2023) recognise other safeguarding issues which may give cause for concern:

• Child Sexual Exploitation (CSE) Child sexual exploitation is a form of sexual abuse where children are sexually exploited for money, power or status. It can involve violent, humiliating and degrading sexual assaults. In some cases, young people are persuaded or forced into exchanging sexual activity for money, drugs, gifts, affection or status. Consent cannot be given, even where a child may believe they are voluntarily engaging in sexual activity with the person who is exploiting them. Child sexual exploitation does not always involve physical contact and can happen online. A significant number of children who are victims of sexual exploitation go missing from home, care and education at some point.

Some of the following signs may be indicators of sexual exploitation:

• Children who appear with unexplained gifts or new possessions

• Children who associate with other young people involved in exploitation

• Children who have older boyfriends or girlfriends

• Children who suffer from sexually transmitted infections or become pregnant

• Children who suffer from changes in emotional well-being

• Children who misuse drugs and alcohol

• Children who go missing for periods of time or regularly come home late

• Children who regularly miss school or education or don’t take part in education

Child on child sexual violence and sexual harassment

Child criminal exploitation: County Lines:

County Lines is a very serious issue where criminal gangs set up a drug dealing operation in a place outside their usual operating area. Gangs will move their drug dealing from big cities (e.g.  London, Manchester, Liverpool etc.) to smaller towns to make more money. This can have a big effect on the community who live there and bring with it serious criminal behaviour.

• Can affect any child or young person (male or female) under the age of 18 years.
• Can affect any vulnerable adult over the age of 18 years.
• Can involve force and/or enticement-based methods of compliance and is often accompanied by violence or threats of violence;
• Can be carried out by individuals or groups, males or females and young people or adults; and;
• Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, cognitive ability, physical strength, status and access to economic or other resources.

Some of the signs of county lines involvement and exploitation are:

• A child or young person going missing from school or home or significant changes in emotional well-being

• A person meeting unfamiliar adults or a change to their behaviour

• The use of drugs and alcohol

• Acquiring money or expensive gifts they can’t account for

• Lone children from outside of the area

• Individuals with multiple mobile phones, tablets or ‘SIM cards’

• Young people with more money, expensive clothing, or accessories than they can account for

• Unknown or suspicious looking characters coming and going from a neighbour’s house

• Relationships with controlling or older individuals or associations with gangs

• Suspicion of self-harm, physical assault or unexplained injuries

• Female Genital Mutilation (FGM) Professionals in all agencies, and individuals and groups in relevant communities, need to be alert to the possibility of a girl being at risk of FGM, or already having suffered FGM. There is a range of potential indicators that a child or young person may be at risk of FGM, which individually may not indicate risk but if there are two or more indicators present it could signal a risk to the child or young person.

• Victims of FGM are likely to come from a community that is known to practise FGM. Staff should note that girls at risk of FGM may not yet be aware of the practice or that it may be conducted on them, so sensitivity should always be shown when approaching the subject. Warning signs that FGM may be about to take place, or may have already taken place, can be found in the

Female genital mutilation (FGM) Signs, indicators and effects - NSPCC.

• Where a professional discovers that an act of FGM appears to have been carried out on a girl who is aged under 18, he or she should personally report it to the police. Those failing to report such cases to the police will face disciplinary sanctions unless the professional has good reason not to. They should still consider and discuss the case with the DSL and involve Children Social Care as appropriate.

https://www.gov.uk/government/publications/mandatory-reporting-of-female-genital-mutilation-procedural-information

• Staff may hear about the possibility of FGM happening or having happened to a Learner's family member, e.g. sister/female cousin:

• A tutor may hear reference to FGM in conversation between Learners.

• A Learner may confide that they or a sister/cousin is to have a ‘special procedure’ to become a woman;

• A learner may report that they or their sister/cousin is going out of the country for a prolonged period;

A learner may disclose the worry about them or a sister/cousin being at risk:

• The referral procedures set out in this policy also apply where there are concerns about children/young people or adults who may have been drawn into terrorism. In accordance with the Department for Education Statutory Guidance 2015. Hawk Training recognises its duty to have due regard to the need to prevent learners from being drawn into terrorism and adopts appropriate protocols to minimise the risk.

• The Designated Safeguarding Lead is the designated Prevent Duty person responsible for coordinating action within Hawk and liaising with other agencies. Hawk will implement prevention measures such as applying appropriate restrictions to internet sites likely to promote terrorist and extremist materials, discussing these dangers with learners when appropriate in suitable forums, and undertaking Prevent awareness staff training periodically to ensure that staff are able to identify learners at risk and know how to intervene.

• The Senior Designated Safeguarding Lead will also assess and manage appropriately any risks identified in the vicinity of the organisation, including those posed by any visiting speakers, and will maintain a register of all visiting speakers. Hawk will work in partnership with the Richmond LSCB over such matters; the level of risk will determine the most appropriate referral. Further information is available from the government Channel guidance on radicalisation and in part 1 of Keeping Children Safe in Education in Education 2022.

• So-called ‘honour-based’ violence (HBV) encompasses crimes which have been committed to protect or defend the honour of the family and/or the community, including Female Genital Mutilation (FGM), forced marriage, and practices such as breast ironing. All forms of so called HBV are abuse (regardless of the motivation) and should be handled and escalated as such. If in any doubts staff should speak to the designated safeguarding lead. Professionals in all agencies, and individuals and groups in relevant communities, need to be alert to the possibility of a child being at risk of HBV, or already having suffered HBV.

• Abuse linked to faith or belief is where concerns for a child’s welfare have been identified, and could be caused by, a belief in witchcraft, spirit or demonic possession, ritual or satanic abuse features; or when practices linked to faith or belief are harmful to a child.

• Any abuse that takes place against those who are branded (or labelled) either as a witch or as having been possessed by an evil spirit is unacceptable. Significant harm (including murder) can occur because of concerted efforts to ‘excise’ or ‘deliver’ evil from a child (or vulnerable adult).

This type of abuse is under-reported.

Spotting the signs that this abuse exists can prevent escalation from ‘subtle’ harms that may often go unnoticed by many, to ‘extreme’ situations where there is loss of life. Witchcraft beliefs are used to blame a person (rather than circumstances) for misfortune that happens in life.

It can take place for some of the following reasons:

• Abuse as a result of being accused of being a ‘witch’

• Abuse as a result of a child being accused of being possessed by ‘evil spirits’

• Ritualistic abuse which is prolonged sexual, physical and psychological abuse

• Satanic abuse which is carried out I the name of ‘Satan’ and may have links to cults

• Other harmful practice linked to faith or belief

Other forms of abuse that be a concern include:

Abuse of trust, Bullying including cyberbullying, deaf and disabled children and abuse, domestic violence and abuse, drugs, gang and youth violence, homophobia, faith abuse, fabricated or induced illness, internet abuse, mobile phone use of abusive images, peer sexual abuse, racism, trafficking/sexual exploitation and teenage relationship abuse.

Further information is available in part 1 of 'Keeping Children Safe In Education 2023' and The Prevent Duty 2015, which all staff are expected to read

The effects of child abuse/adult abuse are wide-ranging and profound. They vary accordingly to the type of abuse and how long it has been endured but can include:

• behavioural problems
• educational problems
• mental health problems
• relationship difficulties
• drug and alcohol problems
• suicide and self-harm
• in extreme cases, death following abuse.

In relation to adults at risk the government set out key principles in its guidance document ‘No Secrets” (DOH, 2000) which said, “the protection of vulnerable adults should always receive a high priority and that all agencies should be able to clearly demonstrate they are able to respond to abuse with prompt, timely and appropriate action”.

Individual organisations may also wish to have internal guidelines for their staff. Again, organisations are encouraged to adopt these procedures as their main guidance, but to add an appendix outlining internal arrangements such as contact details.” SCIE Report 39: Protecting adults at risk: London multi-agency policy and procedures to safeguard adults from abuse.

The Prevent Duty is the duty in the Counter-Terrorism and Security Act 2015, to have due regard to the need to prevent people from being drawn into terrorism.

5.0  Recognising abuse

All staff should be aware of the signs of abuse and neglect so that they are able to identify cases of children, young people or adults who may be in need of help or protection. Staff should be advised to maintain an attitude of 'it could happen here' where safeguarding is concerned. When concerned about the welfare of a child, young person or adult, staff should always act in their best interest.

Young people who regularly go missing from home and work may be at risk of sexual exploitation and abuse, this must be viewed as a safeguarding concern.

It is recognised that some staff will have little if any contact with young people/adults at work and consequently may not be in a position to recognise abuse.

Child abuse can and does occur both within a child/young person’s/adult’s family and in institutional or community settings. It is acknowledged that some individuals seek to use childcare and community organisations to gain access to children, and that it is necessary to have an open mind when the possibility arises that a member of staff or a learner employed by Hawk Training is suspected of abuse or inappropriate activity.

Physical signs that may indicate that a child or vulnerable adult is being or has been abused:

• Unexplained or suspicious injuries, particularly if such an injury is unlikely to have occurred accidentally
• An injury for which the child’s or adult’s explanation appears inconsistent
• Bruising/burns/cigarette burns/fractures which are unexplainable
• Genital injuries/infections/bleeding or discomfort
• Sudden speech disorders, delayed development, failure to grow
• Constant hunger, stealing food, frequently dirty, smelly,
• Untreated medical conditions or lack of treatment for illness or injury

A behavioural sign that may indicate a child or adult has been abused or is being abused:

• Inappropriate sexual awareness or sexually explicit behaviour

• The child appears distrustful of adults

• Unexplained changes in behaviour
• Concerning behaviour
• Aggressive behaviour or severe temper outburst
• Running away, not wanting to go home
• Cover up clothing to hide injuries
• Flinching when approached, fear of adults, fear of men or women
• Depression, low mood, self-harm, eating disorders
• Sexualised language, play, drawings or knowledge
• Nightmares, bed wetting
• Behaving increasingly secretively, possessing unexplained amounts of money, gifts
• Drug and alcohol abuse, suicide
• Excessive lack of confidence, need for approval, attention or affection
• Missing classes, appointments, being continually late
• Difficulty forming relationships, no friends

The recognition of abuse is not easy, and it is not the place of staff to make such a judgement. However, it is their responsibility to act on concerns in order to safeguard the welfare of the child/adult. If you feel uneasy about something you have seen or heard which could be deemed to be child abuse, seek advice from a Hawk Training Designated Safeguarding Lead (DSL).

Doing nothing is not an option!!!

In some cases of suspected abuse parents/carers may not be informed first. This is the decision of the Designated Safeguarding Lead.

Reasonable physical restraint to prevent a child from harming themselves, another person, or from causing serious damage to property is not deemed to be abuse.

6.0 How to respond to signs or suspicions of abuse

All Hawk Training staff should report their concerns to a member of the Hawk Training Safeguarding Team, there will always be a member of the designated safeguarding team available to respond to any allegations/suspicions/concerns of abuse. The safeguarding team include members of the senior management team. All members of the team will receive training to carry out these roles and this will be reviewed and updated on a regular basis.

Sometimes concerns about a child/adult may not be about abuse. You may be concerned that a child or family may need some help in making sure all of a child/adult’s needs are met or to address a particular problem. Examples of this might be where a child is suffering because of poverty, getting into trouble in the community, or has a disability and needs extra help. In these instances, staff would still be expected to ask for advice from a member of the safeguarding team.

7.0 How to respond to a child/young person or adult telling you about abuse

What to do:

• stay calm

• listen, hear and believe

• ask open ended questions for clarification only

• give the child/young person/adult time to say what they want

• reassure and explain that they have done the right thing in telling. Explain that only those people who need to know will be informed

• act immediately in accordance with the procedure in this policy

• record in writing as near as verbatim as possible what was said as soon as possible

• report to a member of the safeguarding team

• record the events in a ‘safeguarding concerns report’

• consider their immediate safety

What not to do:

• do not over-react. It is extremely unlikely that the child/young person/adult is in immediate danger

• do not probe for more information, questioning the child/young person/adult may affect how their disclosure is received at a later date

• do not make assumptions, paraphrase and do not offer alternative explanations

• do not promise confidentiality to keep secrets or that everything will be ok (it might not)

• do not try to deal with it yourself

• do not make negative comments about the alleged abuser

• do not ‘gossip’ or disclose any information with colleagues about what has been said to you

• do not make the child/young person/adult repeat the story unnecessarily
  

It is the duty of anyone who works with children/young people/ adults to report and record disclosure of abuse. An Incident Procedure form must be completed, and the required processes followed.

It is not for staff to decide whether or not a suspicion or allegation is true. All suspicions or allegations must be taken seriously and dealt with accordingly to this procedure. If the disclosure is made by a parent/guardian/carer, you should follow the same procedure and refer them to a Designated Safeguarding Lead.

Individual staff should never deal with abuse disclosures in isolation and should always refer to a Designated Safeguarding Lead with responsibility for child/adult protection. The decision whether or not to report suspected abuse to Social Services or the Police will be made collectively by the Safeguarding Team.

No member of staff should give a learner their personal phone numbers, email address or home address or have a ‘Facebook’ link with a learner.

8.0       Once a referral is made to the Designated Safeguarding Lead

The Designated Safeguarding Lead will make an initial assessment of the allegation; consult with the staff involved and other designated staff as appropriate. This will usually involve speaking to the learner at the earliest opportunity. A first priority is to ensure that the learner is not in any immediate danger. Designated staff will seek medical attention if the learner is suffering from a serious injury.

The learner may be asked to repeat the disclosure they have made. Every effort will be made to communicate with the learner in a way that is appropriate to their age, understanding and preference. This is especially important for learners with a disability or those whose preferred language is not English.

The learner will be asked if there are younger children or any other adults who might also be at risk. However, the Designated Safeguarding Lead will avoid asking leading questions and will not attempt to investigate the allegations. A written account will be made of the disclosure and the context and the learner may be asked to sign it.

If the learner wishes to take the allegation forward, the DSL should support the learner in contacting Social Services, the Police or the NSPCC. When a learner is not sure about taking the allegation forward, the Designated Safeguarding Lead can, without necessarily identifying the person in question, discuss concerns with Social Services or the Police, so that an informed decision can be reached.

Following consultation, the will Designated Safeguarding Lead ask for the learner’s views, if it is clear that they can understand the significance and consequences of a referral to Social Services or the Police (or Forced Marriage Unit or Counter-Terrorism Team).

It remains the responsibility of the Safeguarding Team to take whatever action is necessary to ensure the learner’s safety and that of any other children or adults who may be at risk. This may on occasion involve a referral against the wishes of the learner involved.

Where practicable, concerns will be discussed with a parent or guardian unless this may, either by delay or the behavioural response it may prompt, place the learner at risk of harm. The learner’s view will also be considered in deciding whether to contact their parent/guardian. A written record will be made of any discussion with parents/carers or guardians.

In the event of a decision to report, a member of the Safeguarding Team should inform the learner of the proposed action and the reasons for the decision. Ideally this should happen before the appropriate agency is informed, unless doing so would place the young person/adult at greater risk.

The Designated Safeguarding Lead should contact the Social Services Department of the appropriate local authority by telephone in the first instance and record the date and time that this took place. The Designated Safeguarding Lead will agree with the recipient of the referral what the learner and parents/carers will be told, by whom and when. The Designated Safeguarding Lead will make a confirmation of the referral in writing within 48 hours.

All concerns, discussions, decisions made and reasons for those decisions will be recorded. Written records will be kept confidential in a securely locked location and in accordance with the Data Protection Act/GDPR However, where the police are involved then such records may need to be disclosed.

At Hawk Training the Designated Safeguarding Lead will be the contact if Social Services or the Police require further information about the learner and if necessary, represent the Hawk Training at multi-agency strategy discussions or child protection case conferences.

There may be instances where more than one member of the designated staff will be involved in a particular disclosure. On occasion, they may work collaboratively to deal with a case.

9.0       Confidentiality

The legal principle that the “welfare of the child is paramount” means that taking action to safeguard the child, young person is most important. Privacy and confidentiality should be respected, but if doing nothing leaves a child at risk of harm, the child’s safety has to come first. So legally, it is fine to share information if someone is worried about the safety of a child/adult. When a concern or worry is raised, not everyone needs to know about it. This respects the child/adult’s, family and or staff’s rights to privacy.

The Senior Safeguarding Lead:

• Will be a member of the senior management team

• Will deal with any concerns raised against the Designated Safeguarding Lead

• Will ensure the organisation’s safeguarding policy is implemented, monitored and that safeguarding practices are regularly reviewed and evaluated.

10. Role of the Designated Safeguarding Lead's (DSL)

• To appoint designated staff members with responsibility for child and adult protection, this will include members of the senior management team.

• To arrange and attend regular safeguarding supervision and access ad hoc advice.

• To review and monitor the policy and its procedures annually, or if there has been a change.

• Safeguarding team to periodically access serious case reviews via NSPCC - https://learning.nspcc.org.uk/case-reviews/recently-published-case-reviews

• To ensure that all new staff are subject to an enhanced Disclosure and Barring (DBS) check

• To ensure a risk assessment is undertaken in admitting a learner who may pose a threat to others

• To frequently monitor and obtain feedback from IT Department regarding attempted breaches.

• To ensure a risk assessment is carried out on all external speakers prior to the arranged presentation, including the hire of rooms.

• To reserve the right to refuse employment to any person who may pose a risk to children, young people or vulnerable adults

• To provide appropriate staff training at the recommended level, at least every 2 years for Senior Designated Safeguarding Leads/ Designated Safeguarding Lead DSL’s, including all other staff) to ensure staff are aware of the issue of protection from abuse and the procedures to follow starting from their initial induction.

• To refer any young person or vulnerable adult to Social Services or other appropriate agency e.g. the Police or NSPCC, when the person requests it, or the situation necessitates it.

• To ensure the person who discloses abuse is offered all possible appropriate support around the time of and after disclosure.

• To support staff who deal with a disclosure relating to safeguarding

• To keep records of a disclosure in a confidential file

• To make the policy & procedures available to all staff and learners on the internal communication system.

• To raise awareness of the policy and procedures to our associate organisations

• To work together with the Local Safeguarding Children’s Boards, Adult Protection Committees and Prevent leads.

11. Safer recruitment

The Management team are responsible for ensuring that Hawk Training follows recruitment procedures that help to deter, reject or identify people who might abuse children whether through volunteer or paid employment. All recruitment panels will have at least one member who has completed Safer Recruitment training.

Hawk Training endeavours to ensure that we do our utmost to employ ‘safe’ staff by following the guidance in 'Keeping Children Safe in Education, 2022’ together with the local authority and the organisation’s individual procedures.

Safer recruitment means that all applicants will:

• complete an application form

• provide two referees, including at least one who can comment on the applicant’s suitability to work with children

• provide evidence of identity and qualifications

• be checked through and registered with the Disclosure and Barring Service as appropriate to their role, (for more information Gov.uk) *

All new members of staff will undergo an induction that includes familiarisation with the child/adult protection policy and identification of their own safeguarding training needs. All staff sign to confirm they have received a copy of the child/adult protection policy.

• will be responsible, on a regular basis, in a school or college, for teaching, training, instructing, caring for or supervising children; or

• will carry out paid, or unsupervised unpaid, work regularly in a school or college where that work provides an opportunity for contact with children; or

• engage in intimate or personal care or overnight activity, even if this only happens once.

Self-disclosure form

As part of our duty to safeguard and promote the welfare of our Learners and staff, and in particular children and vulnerable adults, all staff are required to complete an Annual Self Declaration form. It is your responsibility as an employee to notify the HR Department of any convictions that occur as soon as they arise.

Single Central Record

Hawk Training have a single central record covering all members of staff:

The information recorded for all staff includes the following information:

• an identity check;

• a barred list check;

• an enhanced DBS check/certificate;

• mandatory training – safeguarding, Prevent and Channel and Keeping Children Safe in Education

• a check of professional qualifications; and

• a check to establish the person’s right to work in the United Kingdom.

Hawk Training recognise that we have a legal duty to refer to the DBS anyone who has harmed, or poses a risk of harm, to a child or vulnerable adult; where the harm test is satisfied in respect of that individual; where the individual has received a caution or conviction for a relevant offence, or if there is reason to believe that individual has committed a listed relevant offence; and that individual has been removed from working (paid or unpaid) in regulated activity, or would have been removed had they not left. The DBS will consider whether to bar the person. Referrals should be made as soon as possible after the resignation or removal of the individual. Guidance on referrals can be found on GOV.UK.

12. Allegations of abuse made against members of hawk staff or an employer.

Any allegation made against a member of staff or another learner will be treated seriously and investigated immediately. A SDSL will report to the Directors and appropriate action will be taken to safeguard the welfare of the child/young person, adult at risk or any others who it may affect. If necessary, Children’s social care and the Police may have to be notified.

This is about managing cases of allegations that might indicate a person would pose a risk of harm if they continue to work in regular or close contact with children, young people (and in some cases adults at risk) in their present position, or in any capacity. It should be used in respect of all cases in which it is alleged that a member of Hawk Training staff has:

• behaved in a way that has harmed a child, or may have harmed a child;
• possibly committed a criminal offence against or related to a child; or
• behaved towards a child or children in a way that indicates he or she would pose a risk of harm to children.

Employers have a duty of care to their employees. They should ensure they provide effective support for anyone facing an allegation and provide the employee with a named contact if they are suspended. It is essential that any allegation of abuse made against a member of staff is dealt with very quickly, in a fair and consistent way that provides effective protection for the child/young person and at the same time supports the person who is the subject of the allegation.

Allegations of abuse from a staff member towards any learner should be reported to the Senior Designated Safeguarding Lead as soon as possible. The Senior Designated Safeguarding Lead will follow the guidelines set out in 'Working Together to Safeguard Children 2018’ and 'part 4 of Keeping Children Safe in Education 2023’' and seek advice from the Local Authority Designated Officer (DO) or Safeguarding Adults services (London Borough of Richmond upon Thames). The Senior Designated Safeguarding Lead will take appropriate action following the advice of the DO.

Whistleblowing

All staff should feel able to raise concerns about poor or unsafe practice and potential failures in Hawk Training’s safeguarding regime and know that such concerns will be taken seriously by the Senior Safeguarding Lead.

Appropriate whistleblowing procedures which are reflected in staff training and behaviour policies and these concerns should be brought to the attention of the Senior Safeguarding Lead.

Where a staff member feels unable to raise an issue within Hawk Training or feels that their genuine concerns are not being address, other whistleblowing channels may be open to them.

Appendices

• Suicide protocol

• Domestic Abuse process

• Reporting procedure if a concern is identified during a visit with a learner or workshop

Hawk Training | Prevent Strategy

1.0  Purpose

EQUALITY, DIVERSITY AND INCLUSION POLICY STATEMENT AND EXPECTATIONS

2.0  The Prevent Agenda

Keeping Children Safe in Education - September 2023

The Prevent Strategy aims to:

• Respond to the ideological challenge of terrorism and the threat was faced from those who promote it.
• Prevent people from being drawn into terrorism and ensure that they are given appropriate advice and support.
• Work with sectors and institutions where there are risks or radicalisation, which we need to address.

Terrorism in the UK context

Local management of Prevent

Source: https://www.gov.uk/government/publications/channel-guidance

3.0 Hawk Training – current practices which contribute to Prevent

• Our safeguarding policy refers to the Prevent agenda to ensure it is within the protective work we carry out to safeguard our Learners, visitors and members of staff.
• Training sessions on specific and wider Prevent Agenda issues maximise the opportunities for expert input to develop staff awareness.
• Our work to promote Equality and Diversity within Hawk Training, through providing information advice and guidance, teaching, including incorporating British Fundamental Values.       This contributes to good community relations and reduces the risk of radicalisation.  

4.0  Prevent Risk Assessment

Prevent Referrals

Hawk Training | Safer Recruitment

1.0    Purpose

Hawk is committed to safeguarding and promoting the welfare of all learners in its care. The Company expects all employees, contractors, and volunteers to share this commitment. This policy overlaps with the following company policies:

•    Recruitment and selection
•    Policy on giving references
•    Policy on requesting references

2.0 Aims and objectives

The aim of the Safer Recruitment policy is to:
•    Ensure the best possible staff are recruited based on their merits, abilities, and suitability for the position.
•    Ensure job applicants are considered equally and consistently.
•    Ensure that no job applicant is treated unfairly on any grounds including race, colour, nationality, ethnic or national origin, religion or religious belief, sex, or sexual orientation, marital or civil partner status, disability, or age
•    Ensure compliance with all relevant legislation, recommendations, and guidance, including the statutory guidance 
•    Provide guidance on the documents and process to be followed.

The Management team are responsible for ensuring that Hawk Training follows recruitment procedures that help to deter, reject, or identify people who might abuse children whether through volunteer or paid employment. All recruitment panels will have at least one member who has completed Safer Recruitment training.

Hawk Training endeavours to ensure that we do our utmost to employ ‘safe’ staff by following the guidance in 'Keeping Children Safe in Education 2022' together with the local authority and the organisation’s individual procedures.

3.0    Requirement of applicants

Safer recruitment means that all applicants will:

•    complete an application form
•    provide two referees, including at least one who can comment on the applicant’s suitability to work with children
•    provide evidence of identity and qualifications
•    be checked through and registered with the Disclosure and Barring Service as appropriate to their role, (for more information Gov.uk) 

All new members of staff will undergo an induction that includes familiarisation with the child/adult protection policy and identification of their own safeguarding training needs. All staff sign to confirm they have received a copy of the child/adult protection policy.
Both the Safeguarding Team and Team Managers are alerted of any DBS that have passed or failed by the HR Department.

For most appointments, an enhanced DBS check with barred list information will be required as the majority of staff will be engaging in regulated activity. A person will be considered to be in 'regulated activity' if as a result of their work they:

•    will be responsible, on a regular basis, in a school or college, for teaching, training, instructing, caring for or supervising children; or
•    will carry out paid, or unsupervised unpaid, work regularly in a school or college where that work provides an opportunity for contact with children; or
•    engage in intimate or personal care or overnight activity, even if this only happens once.

4.0 Self-disclosure form

As part of our duty to safeguard and promote the welfare of our Learners and staff, and in particular children and vulnerable adults, all staff are required to complete an Annual Self Declaration form in August. It is the employee’s responsibility as an employee to notify the HR Department of any convictions that occur as soon as they arise.

5.0 Single central record

In addition to HiBob, Hawk Training have a single central record covering all members of staff:

The information recorded for all staff includes the following information:
•    an identity check;
•    a barred list check;
•    an enhanced DBS check/certificate;
•    a check of professional qualifications; and
•    a check to establish the person’s right to work in the United Kingdom.
•    mandatory training – safeguarding, Prevent, Channel, Keeping Children Safe in Education

Hawk Training recognise that we have a legal duty to refer to the DBS anyone who has harmed, or poses a risk of harm, to a child or vulnerable adult; where the harm test is satisfied in respect of that individual; where the individual has received a caution or conviction for a relevant offence, or if there is reason to believe that individual has committed a listed relevant offence; and that individual has been removed from working (paid or unpaid) in regulated activity, or would have been removed had they not left. The DBS will consider whether to bar the person. Referrals should be made as soon as possible after the resignation or removal of the individual. Guidance on referrals can be found on GOV.UK. 

6.0    Allegations of abuse made against members of hawk staff or an employer

Any allegation made against a member of staff, or another learner will be treated seriously and investigated immediately. A SDSL will report to the Directors and appropriate action will be taken to safeguard the welfare of the child/young person, adult at risk or any others who it may affect. If necessary, Children’s social care and the Police may have to be notified.

This is about managing cases of allegations that might indicate a person will pose a risk of harm if they continue to work in regular or close contact with children, young people (and in some cases adults at risk) in their present position, or in any capacity. It should be used in respect of all cases in which it is alleged that a member of Hawk Training staff has:

• behaved in a way that has harmed a child, or may have harmed a child;
• possibly committed a criminal offence against or related to a child; or
• behaved towards a child or children in a way that indicates he or she would pose a risk of harm to children.

Employers have a duty of care to their employees. They should ensure they provide effective support for anyone facing an allegation and provide the employee with a named contact if they are suspended. It is essential that any allegation of abuse made against a member of staff is dealt with very quickly, in a fair and consistent way that provides effective protection for the child/young person and at the same time supports the person who is the subject of the allegation.

Allegations of abuse from a staff member towards any learner should be reported to the Senior Designated Safeguarding Lead as soon as possible, who will then inform the Directors. The Senior  Designated Safeguarding Lead will follow the guidelines set out in 

7.0    Whistleblowing

All staff should feel able to raise concerns about poor or unsafe practice and potential failures in Hawk Training’s safeguarding regime and know that such concerns will be taken seriously by the Senior Designated Safeguarding Lead.
Appropriate whistleblowing procedures which are reflected in staff training and behaviour policies and these concerns should be brought to the attention of the Senior Designated Safeguarding Lead.
Where a staff member feels unable to raise an issue within Hawk Training or feels that their genuine concerns are not being address, other whistleblowing channels may be open to them.

General guidance can be found at:
https://www.nspcc.org.uk/what-you-can-do/report.../whistleblowing-advice-line/

Hawk Training | Confidentiality Policy 

1.0 PURPOSE

To ensure that learners' rights to confidentiality of personal information are protected which also includes any information relating to an employer, client or stakeholder.

2.0 VALUES

We believe that all learners, employers and stakeholders should have the right to expect that information acquired or held about them will be treated with confidentiality and with respect.

3.0 SCOPE

Information may be held about learners, employers or stakeholders at many stages of the learning process including:

• Initial contact and information regarding eligibility
• At Initial Assessment and Pre-Induction stage for purposes of recruitment and/or funding
• Disclosing information about a disability or learning need
• During information, advice or guidance sessions or discussions
• When being referred for additional or specialist information or support
• When disclosing information of a personal nature including financial or residency information or any criteria that warrants Additional Social Needs funding
• During assessment and review
• Sensitive information revealed during discussion in a workshop learning session still comes under this Confidentiality Policy
• During completion of Individual Learning Plans
• When giving feedback.

Learners have rights under the Data Protection Acts1984 and 1998. These protect personal information from being used inappropriately. Under the Acts, this information must be destroyed when it ceases to be relevant. Everyone also has a right to see information held about them if they ask.

Our policy goes beyond the legal requirement and aims to be learner and employer centred by meeting the standard set within the framework of the National Information, Advice and Guidance Board's "Principles for Coherent Delivery of IAG Services." Transparency regarding use of information held about learners is an important aspect of the policy.

Confidential information may also be disclosed in some workshop sessions, particularly where learners are discussing personal issues - for example, in personal development, community education or family learning programmes. The Confidentiality Policy applies in these situations. Information submitted to the WEA website is governed by the Privacy Policy available on the website and not by this Policy

4.0 THE POLICY

This policy requires that:

• All staff maintain a high standard of confidentiality
• All staff are made fully aware of the policies on Data Protection, Confidentiality and
Confidentiality and Disclosure.
• All staff abide by the principles of these policies, and report any breach in confidentiality or weaknesses in the systems guaranteeing confidentiality
• Where there may be legal requirements for disclosure for example in cases of a suspected criminal offence; where there is a likelihood of harm to an individual or premises; or a safeguarding issue advice must be sought from a senior team manager or director.

Individuals are made aware of:

1. Their entitlements to confidentiality and transparency
2. Their right to see any personal information held about them
3. Their right to refuse to give personal information and any likely impact on them,
4. How information collected about them is used and stored.

5.0 IMPLEMENTATION

All staff are responsible for implementing the Confidentiality Policy according to their roles. Breaches of confidentiality or weaknesses in systems should be reported to departmental line managers and action taken through the Senior Management or fed back to an appropriate director.

Links to other policies and documents
This policy is part of a suite of Learner Support Policies defining learner support entitlements. There are particular links with:
• Information, Advice and Guidance Policy and associated Referrals Procedures
• Learner Complaints and Appeals Procedures
• Disclosure and Confidentiality Policy
• The Equality Policy.

Hawk Training | Health and Safety Policy 

1.0   AIM

It is the aim of Hawk Training Group to safeguard the health and safety of all its employees, learners and visitors whilst at work and to pursue a policy which, as far as is reasonably practicable promotes the ‘Safe Learner’ and ensures learners ‘feel safe’ and that:

 Our business is conducted in accordance with the best practices for the promotion of health and safety at work including the prevention of general and occupational risks;

• A safe and healthy working environment for learners on and off site is established and maintained at all operating locations and that risk assessment is carried out for physical hazards;

• First aid, fire-fighting and evacuation measures are in place in all training and staff rooms for which employees, learners and visitors receive both verbal and written instructions;

• There is full compliance with National Legislation for the health and safety both for employees at work, learners and the general public;

• Accredited standards of training and instruction in matters of health and safety will be provided and maintained at all levels of employment and in particular relevant staff are qualified to carry out risk assessments on employer premises and/or work placements;

• Co-operation of employees and learners, in promoting safe and healthy conditions and systems of work is encouraged by discussion and effective joint consultation;

• An efficient advisory service in matters of health and safety is provided by our contractual partners, and reference should also be made to the HSE – website: www.hse.gov.uk.

• The Health & Safety Officer is responsible for reviewing and updating this policy where necessary, this will also be reviewed as an origination annually.

2.0   RESPONSIBILITIES AND ORGANISATION

Andy Tyrer is the Health and Safety Officer. However, every staff member employed by Hawk Training has a responsibility for maintaining a healthy and safe working environment, which is free from hazards and may compromise the health and safety of others. It is the responsibility of all management and staff to:

• Co-operate actively in promoting the ‘Safe Learner’ and achieving the aims of the Health and Safety policy statements and practice in order that learners ‘feel safe’;

• Take reasonable care for the health and safety of themselves and of others who may be affected by their acts or omissions;

• Work safely and efficiently by following correct operating procedures and by meeting statutory obligations;

• Not to interfere or misuse anything which is provided in the interest’s health and safety;

• Report and co-operate in the investigation of all accidents and incidents that lead, or may potentially lead, to injury and any shortfall in the protection arrangements.

Staff must adhere to ‘Staff Health and Safety Practice’ appended to this policy.