Policies

Please read below all the Sherlock Healthcare Policy Documents

Privacy Policy

In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our employees, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

 

This notice applies to current and former employees and workers.

 DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

  1. processing is fair, lawful and transparent
  2. data is collected for specific, explicit, and legitimate purposes
  3. data collected is adequate, relevant and limited to what is necessary for the purposes of processing
  4. data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
  5. data is not kept for longer than is necessary for its given purpose
  6. data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  7. we comply with the relevant GDPR procedures for international transferring of personal data

 

TYPES OF DATA HELD

We keep several categories of personal data on our employees in order to carry out effective and efficient processes. We keep this data in a personnel file relating to each employee and we also hold the data within our computer systems, for example, our holiday booking system.

Specifically, we hold the following types of data, as appropriate to your status:

  1. personal details such as name, address, phone numbers
  2. name and contact details of your next of kin
  3. your photograph
  4. your gender, marital status, information of any disability you have or other medical information
  5. right to work documentation
  6. information on your race and religion for equality monitoring purposes
  7. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter
  8. references from former employers
  9. details on your education and employment history etc
  10. National Insurance numbers
  11. bank account details
  12. tax codes
  13. driving licence
  14. criminal convictions
  15. CCTV footage
  16. building access card records
  17. IT equipment use including telephones and internet access.
  18. information relating to your employment with us, including:
  • job title and job descriptions
  • your salary
  • your wider terms and conditions of employment
  • details of formal and informal proceedings involving you such as letters of concern, disciplinary and grievance proceedings, your annual leave records, appraisal and performance information
  • internal and external training modules undertaken
  • information on time off from work including sickness absence, family related leave etc

 

COLLECTING YOUR DATA

You provide several pieces of data to us directly during the recruitment period and subsequently upon the start of your employment.

 

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.

 

Personal data is kept in files or within the Company’s HR and IT systems.

 

LAWFUL BASIS FOR PROCESSING

The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the employment contract we have with you, including ensuring you are paid correctly.

 

The information below categorises the types of data processing, appropriate to your status, we undertake and the lawful basis we rely on.

 

Activity requiring your data

Lawful basis

Carry out the employment contract that we have entered into with you e.g. using your name, contact details, education history, information on any disciplinary, grievance procedures involving you

Performance of the contract

Ensuring you are paid

Performance of the contract

Ensuring tax and National Insurance is paid

Legal obligation

Carrying out checks in relation to your right to work in the UK

Legal obligation

Making reasonable adjustments for disabled employees

Legal obligation

Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion

Our legitimate interests

Making decisions about salary and other benefits

Our legitimate interests

Ensuring efficient administration of contractual benefits to you

Our legitimate interests

Effectively monitoring both your conduct, including timekeeping and attendance, and your performance and to undertake procedures where necessary

Our legitimate interests

Maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained

Our legitimate interests

Implementing grievance procedures

Our legitimate interests

Assessing training needs

Our legitimate interests

Implementing an effective sickness absence management system including monitoring the amount of leave and subsequent actions to be taken including the making of reasonable adjustments

Our legitimate interests

Gaining expert medical opinion when making decisions about your fitness for work

Our legitimate interests

Managing statutory leave and pay systems such as maternity leave and pay etc

Our legitimate interests

Business planning and restructuring exercises

Our legitimate interests

Dealing with legal claims made against us

Our legitimate interests

Preventing fraud

Our legitimate interests

Ensuring our administrative and IT systems are secure and robust against unauthorised access

Our legitimate interests

Providing employment references to prospective employers, when our name has been put forward by the employee/ex-employee, to assist with their effective recruitment decisions

Legitimate interest of the prospective employer

 

SPECIAL CATEGORIES OF DATA

Special categories of data are data relating to your:

  1. health
  2. sex life
  3. sexual orientation
  4. race
  5. ethnic origin
  6. political opinion
  7. religion
  8. trade union membership
  9. genetic and biometric data.

We carry out processing activities using special category data:

  1. for the purposes of equal opportunities monitoring
  2. in our sickness absence management procedures
  3. to determine reasonable adjustments

Most commonly, we will process special categories of data when the following applies:

  1. you have given explicit consent to the processing
  2. we must process the data in order to carry out our legal obligations
  3. we must process data for reasons of substantial public interest
  4. you have already made the data public.

 

FAILURE TO PROVIDE DATA

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment, or administer contractual benefits.

 

CRIMINAL CONVICTION DATA

We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to determine your suitability, or your continued suitability for the role. We rely on the lawful basis of performance of the contract to process this data.

 

WHO WE SHARE YOUR DATA WITH

Employees within our company who have responsibility for recruitment, administration of payment and contractual benefits and the carrying out performance related procedures will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processed in line with GDPR. 

Data is shared with third parties for the following reasons: for the administration of payroll.

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

 

PROTECTING YOUR DATA

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

 

RETENTION PERIODS

We only keep your data for as long as we need it for, which will be at least for the duration of your employment with us though in some cases we will keep your data for a period after your employment has ended. Some data retention periods are set by the law.

 

AUTOMATED DECISION MAKING

Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

 

EMPLOYEE RIGHTS

You have the following rights in relation to the personal data we hold on you:

  1. the right to be informed about the data we hold on you and what we do with it;
  2. the right of access to the data we hold on you. More information on this can be found in our separate policy on Subject Access Requests;
  3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
  4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
  5. the right to restrict the processing of the data;
  6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
  7. the right to object to the inclusion of any information;
  8. the right to regulate any automated decision-making and profiling of personal data.

More information can be found on each of these rights in our separate policy on employee rights under GDPR.

 

CONSENT

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.

 

MAKING A COMPLAINT

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.

 

DATA PROTECTION COMPLIANCE

Our appointed compliance officer in respect of our data protection activities is:

 

Hilton Mutariswa

Company Director

hilton@sherlockhealthcare.co.uk

0121 603 0845

 

Equality & Diversity Policy

INTRODUCTION

  • We are an equal opportunities employer. We are committed to equality of opportunity and to providing a service and following practices which are free from unfair and unlawful discrimination. The aim of this policy is to ensure that no applicant or member of staff receives less favourable treatment on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation, or is disadvantaged by conditions or requirements which cannot be shown to be relevant to performance. It seeks also to ensure that no person is victimised or subjected to any form of bullying or harassment.

 

  • We value people as individuals with diverse opinions, cultures, lifestyles and circumstances. All employees are covered by this policy and it applies to all areas of employment including recruitment, selection, training, deployment, career development, and promotion. These areas are monitored and policies and practices are amended if necessary to ensure that no unfair or unlawful discrimination, intentional, unintentional, direct or indirect, overt or latent exists.

 

  • The Registered Manager has particular responsibility for implementing and monitoring the Equality and Diversity in Employment Policy and, as part of this process, all personnel policies and procedures are administered with the objective of promoting equality of opportunity and eliminating unfair or unlawful discrimination.

 

  • All employees, workers or self-employed contractors whether part time, full time or temporary, will be treated fairly and with respect. Selection for employment, promotion, training, or any other benefit will be on the basis of aptitude and ability. All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the Company.

 

  • 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. The personal commitment of every employee to this policy and application of its principles are essential to eliminate discrimination and provide equality throughout the Company.

 

OUR COMMITMENT AS AN EMPLOYER

  • To create an environment in which individual differences and the contributions of our staff are recognised and valued.
  • Every employee, worker or self-employed contractor is entitled to a working environment that promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated.
  • Training, development and progression opportunities are available to all staff.
  • Equality in the workplace is good management practice and makes sound business sense.
  • We will review all our employment practices and procedures to ensure fairness.

 

OUR COMMITMENT AS A SERVICE PROVIDER

  • We aim to provide services to which all clients are entitled regardless of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation, offending past, caring responsibilities or social class.
  • We will make sure that our services are delivered equally and meet the diverse needs of our service users and clients by assessing and meeting the diverse needs of our clients.
  • This policy is fully supported by senior management and has been agreed with employee representatives
  • This policy will be monitored and reviewed annually.
  • We have clear procedures that enable our clients, candidates for jobs and employees to raise a grievance or make a complaint if they feel they have been unfairly treated.
  • Breaches of our equality and diversity policy will be regarded as misconduct and could lead to disciplinary proceedings.

 

POLICY STATEMENTS

AGE

We will:

  • ensure that people of all ages are treated with respect and dignity;
  • ensure that people of working age are given equal access to our employment, training, development and promotion opportunities; and
  • challenge discriminatory assumptions about younger and older people.

 

DISABILITY

We will:

  • provide any reasonable adjustments to ensure disabled people have access to our services and employment opportunities; 
  • challenge discriminatory assumptions about disabled people; and
  • seek to continue to improve access to information by ensuring availability of loop systems, braille facilities, alternative formatting and sign language interpretation.

RACE

We will:

  • challenge racism wherever it occurs;
  • respond swiftly and sensitively to racists incidents; and
  • actively promote race equality in the Company.

GENDER

We will:

  • challenge discriminatory assumptions about women and men;
  • take positive action to redress the negative effects of discrimination against women and men;
  • offer equal access for women and men to representation, services, employment, training and pay and encourage other organisations to do the same; and 
  • provide support to prevent discrimination against transsexual people who have or who are about to undergo gender reassignment.

SEXUAL ORIENTATION

We will:

  • ensure that we take account of the needs of lesbians, gay men and bisexuals; and
  • promote positive images of lesbians, gay men and bisexuals.

RELIGION OR BELIEF

We will:

  • ensure that employees’ religion or beliefs and related observances are respected and accommodated wherever possible; and
  • respect people’s beliefs where the expression of those beliefs does not impinge on the legitimate rights of others.

PREGNANCY OR MATERNITY

We will:

  • Ensure that people are treated with respect and dignity and that a positive image is promoted regardless of pregnancy or maternity;
  • challenge discriminatory assumptions about the pregnancy or maternity of our employees; and
  • ensure that no individual is disadvantaged and that we take account of the needs of our employees’ pregnancy or maternity.

MARRIAGE OR CIVIL PARTNERSHIP

We will:

  • Ensure that people are treated with respect and dignity and that a positive image is promoted regardless of marriage or civil partnership;
  • challenge discriminatory assumptions about the marriage or civil partnership of our employees; and
  • ensure that no individual is disadvantaged and that we take account the needs of our employees’ marriage or civil partnership.

EX-OFFENDERS

We will:

  • prevent discrimination against our employees regardless of their offending background (except where there is a known risk to children or vulnerable adults).

EQUAL PAY

We will:

  • ensure that all employees, male or female, have the right to the same contractual pay and benefits for carrying out the same work, work rated as equivalent work or work of equal value.

Modern Slavery Statement

ORGANISATION

This statement applies to Sherlock Healthcare Services Ltd (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2020/21.

ORGANISATIONAL STRUCTURE

Sherlock Healthcare Services Ltd
Registered office address:
20-22 Wenlock Road, London, England, N1 7GU Company status
Active
Company type
Private limited Company

The labour supplied to the Organisation in pursuance of its operation is carried out in the United Kingdom, West Midlands, Birmingham.

DEFINITIONS

The Organisation considers that modern slavery encompasses:

  • Human trafficking;

  • Forced work, through mental or physical threat;

  • Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;

  • Being dehumanised, treated as a commodity or being bought or sold as property;

  • Being physically constrained or to have restriction placed on freedom of movement.

COMMITMENT

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK.

SUPPLY CHAINS

In order to fulfil its activities, the Organisation’s main supply chains include those related to supply of residential care services in the United Kingdom.

POTENTIAL EXPOSURE

In general, the Organisation considers its exposure to slavery/human trafficking to be [relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

STEPS

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

  • reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery;

  • measures in place to identify and assess the potential risks in supply chains;

  • undertaking impact assessments of our services upon potential instances of slavery;

  • creating action plans to address risk to modern slavery;

  • actions taken to embed a zero tolerance policy towards modern slavery;

KEY PERFORMANCE INDICATORS

The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

• Robust recruitment procedures

POLICIES

The Organisation has the following policies which further define its stance on modern modern slavery policy; a corporate social responsibility policy; supplier code of conduct; recruitment policy.

TRAINING

The Organisation provides the following training to staff to effectively implement its stance on modern slavery induction training, training on modern slavery policies.

SLAVERY COMPLIANCE OFFICER

The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation obligations in this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

 

Date of approval: 17/03/2020

Signed by: Hilton Mutariswa, Director

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