Definitions

  • Fresh Start Direct Ltd will be referred to as ‘the Company’ throughout the policy
  • The term ‘staff’ in used to cover all Company employees, Tutors, contractors and workers
  • The term ‘student’ is used to cover any learner placed with the Company
  • The term ‘Client’ refers to any local authority, school, parent or body that commissions the services
    of the Company to work with a student or students
  • An ‘Identifiable Natural Person’ is one who can be identified, directly or indirectly, in particular
    by reference to an identifier such as a name, an identification number, location data, an online
    identifier, or to one or more factors specific to the physical, physiological, genetic, mental,
    economic, cultural, or social identity of that natural person
  • A ‘Data Subject’ is the identified or Identifiable Natural Person to which the data refers
  • ‘Data Controller’ is a natural or legal person, Public Authority, Agency or other body which, alone
    or jointly with others, determines the purpose and means of the Processing of Personal Data
  • A ‘Data Processor’ is a natural or legal person, Public Authority, Agency or other body which
    Processes Personal Data on behalf of a Data Controller
  • ‘Personal Data’ is any information that relates to a living individual who can be identified from
    that information
  • The ‘Data Protection Officer’ (DPO) may be contacted in writing;
  • The Data Protection Officer
    Fresh Start Direct Ltd
    Castle House
    Castle Hill Avenue
    Folkestone
    Kent. CT20 2TQ
    or by email: dataprotectionofficer@freshstartedu.co.uk
  • The terms ‘processing’, ‘process’ or ‘processed’ are used to cover any operation or set of operations
    performed on Personal Data or on sets of Personal Data, whether or not by automated means. Operations
    performed may include collection, recording, organisation, structuring, storage, adaptation or
    alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making
    available, alignment or combination, restriction, erasure or destruction.
  1. Introduction

    The Company is a specialist online Education Service. We work to a high standard of Safeguarding and Data Protection. The services of the Company are commissioned by Local Authority Departments, Schools and Colleges and parents or carers.

    We hold data for up to 85 years for a variety of reasons. Data is processed as necessary by the Company’s staff members to ensure that the students placed with us get the maximum benefit from their time with us and are safe guarded effectively. We use historic data to review and assess our effectiveness with different groups of students and their progress and the outcomes that they have achieved. We also keep all data to ensure that we can respond effectively to any Safeguarding matter or questions concerning behaviour, or effectiveness of staff or service. We may contact past and existing Clients from time to time about other services we offer, with the option to opt-out from this form of communication.

    This policy sets out the obligations of the Company regarding Data Protection and the rights of Clients, staff, and students, in respect of their Personal Data under the Data Protection Act 2018

    This policy sets out the procedures that are to be followed when dealing with Personal Data. The

    Data Protection Policy Page 4 of 17 Fresh Start Direct Ltd © 2018

    procedures and principles set out herein must be followed at all times by staff.

    The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all Personal Data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

  2. The Data Protection Principles

    This policy aims to ensure compliance with the Regulation. The Regulation sets out the following principles with which any party handling Personal Data must comply. All Personal Data must be:

    • Processed lawfully, fairly, and in a transparent manner in relation to the Data Subject
    • Collected for specified, explicit, and legitimate purposes and not further processed in a
      manner that is incompatible with those purposes; further processing for archiving purposes in the
      public interest, scientific or historical research purposes or statistical purposes shall not be
      considered to be incompatible with the initial purposes
    • Adequate, relevant and limited to what is necessary in relation to the purposes for which it is
      processed
    • Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure
      that Personal Data that is inaccurate, having regard to the purposes for which they are processed,
      is erased or rectified without delay
    • Kept in a form which permits identification of Data Subjects for no longer than is necessary
      for the purposes for which the Personal Data is processed; Personal Data may be stored for longer
      periods insofar as the Personal Data will be processed solely for archiving purposes in the public
      interest, scientific or historical research purposes or statistical purposes subject to
      implementation of the appropriate technical and organisational measures required by the Regulation
      in order to safeguard the rights and freedoms of the Data Subject
    • Processed in a manner that ensures appropriate security of the Personal Data, including
      protection against unauthorised or unlawful processing and against accidental loss, destruction or
      damage, using appropriate technical or organisational measures.
  3. Lawful, Fair And Transparent Data Processing

    The Regulation seeks to ensure that Personal Data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the Data Subject. The Regulation states that processing of Personal Data shall be lawful if at least one of the following applies:

    • The Data Subject has given consent to the processing of his or her Personal Data for one or
      more specific purposes
    • Processing is necessary for the performance of a contract to which the Data Subject is a
      party or in order to take steps at the request of the Data Subject prior to entering into a
      contract
    • Processing is necessary for compliance with a legal obligation to which the Data Controller
      is subject
    • Processing is necessary to protect the vital interests of the Data Subject or of another
      Identifiable Natural Person
    • Processing is necessary for the performance of a task carried out in the public interest or
      in the exercise of official authority vested in the Data Controller
    • Processing is necessary for the purposes of the Legitimate Interests pursued by the Data
      Controller or by a third party, except where such interests are overridden by the fundamental
      rights and freedoms of the Data Subject, which require protection of Personal Data, in
      particular where the Data Subject is a child.
  4. Processed For Specified, Explicit And Legitimate Purposes

    1. The Company collects and processes the Personal Data set out in Point 20 of this policy. This may include Personal Data received directly from Data Subjects, for example, contact details used when a Data Subject communicates with us and data received from third parties, for example, Local Authority departments, Police, the Courts, schools, teaching and support staff and parents, carers, family members and those connected with a student or their family who are providing information about students with whom the Company is working, has worked, or may be required to work. It may also include information from Social Media or other sources and where there may be Safeguarding or Behaviour concerns.
    2. The Company only processes Personal Data for the specific purposes set out in Point 20 of this policy or for other purposes expressly permitted by the Regulation. The purposes for which we process Personal Data will be informed to Data Subjects at the time that their Personal Data is collected, where it is collected directly from them, or as soon as possible (not more than one calendar month) after collection where it is obtained from a third party.
  5. Adequate, Relevent And Limited Data Processing

    The Company will only collect and process Personal Data for and to the extent necessary for the specific purpose(s) informed to Data Subjects as under Point 4.

  6. Accuracy Of Keeping Data Up To Date

    The Company shall ensure that all Personal Data collected and processed is kept accurate and up-to-date. The accuracy of Personal Data shall be checked when it is collected and at regular intervals thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend, erase or anonymise that data, as appropriate.

  7. Timely Processing

    The Company shall not keep Personal Data for any longer than is necessary in light of the purposes for which that data was originally collected and processed. When the data is no longer required, all reasonable steps will be taken to anonymise or erase it without delay.

  8. Secure Processing

    The Company shall ensure that all Personal Data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. Further details of the data protection and organisational measures which shall be taken are provided in Points 21 and 22 of this policy.

  9. Accountability

    The Company shall keep written internal records of all Personal Data collection, holding, and processing, which shall incorporate the following information:

    1. The name and details of the Company, its DPO, and any applicable third-party Data Controllers
    2. The purposes for which the Company processes Personal Data
    3. Details of the categories of Personal Data collected, held, and processed by the Company; and the categories of Data Subject to which that Personal Data relates
    4. Details and categories of any third parties that will receive Personal Data from the Company
    5. Details of any transfers of Personal Data to non-European Economic Area countries, including all mechanisms and security safeguards
    6. Details of how long Personal Data will be retained by the Company
    7. Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of Personal Data.
  10. Privacy Impact Assessments

    The Company shall carry out Privacy Impact Assessments as and when required under the Regulation. Privacy Impact Assessments shall be overseen by the Company’s DPO and shall address the following areas of importance:

    1. The purpose(s) for which Personal Data is being processed and the processing operations to be carried out on that data
    2. Details of the Legitimate Interests being pursued by the Company
    3. An assessment of the necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed
    4. An assessment of the risks posed to individual Data Subjects
    5. Details of the measures in place to minimise and handle risks including safeguards, data security, and other measures and mechanisms to ensure the protection of Personal Data, sufficient to demonstrate compliance with the Regulation.
  11. The Rights of Data Subjects

    The Regulation sets out the following rights applicable to Data Subjects:

    • The right to be informed
    • The right of access
    • The right to rectification
    • The right to erasure (also known as the ‘right to be forgotten’)
    • The right to restrict processing
    • The right to data portability
    • The right to object
    • Rights with respect to automated decision-making and profiling.
  12. Keeping Data Subjects Informed

    1. The Company shall ensure that the following information is provided to every Data Subject when Personal Data is collected:
      1. Details of the Company including, but not limited to, the identity of the DPO
      2. The purpose(s) for which the Personal Data is being collected and will be processed (as detailed in Point 20 of this policy) and the legal basis justifying that collection and processing
      3. Where applicable, the Legitimate Interests upon which the Company is justifying its collection and processing of the Personal Data
      4. Where the Personal Data is not obtained directly from the Data Subject, the categories of Personal Data collected and processed
      5. Where the Personal Data is to be transferred to one or more third parties, details of those parties
      6. Where the Personal Data is to be transferred to a third party that is located outside of the European Economic Area (EEA), details of that transfer, including but not limited to the safeguards in place. See Point 23 of this policy for further details concerning such third country data transfers
      7. Details of the length of time the Personal Data will be held by the Company or, where there is no predetermined period, details of how that length of time will be determined
      8. Details of the Data Subject’s rights under the Regulation
      9. Details of the Data Subject’s right to withdraw their consent to the Company’s processing of their Personal Data at any time
      10. Details of the Data Subject’s right to complain to the Information Commissioner’s Office (the ‘supervisory authority’ under the Regulation)
      11. Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the Personal Data and details of any consequences of failing to provide it
      12. Details of any automated decision-making that will take place using the Personal Data (including but not limited to profiling), including information on how decisions will be made, the significance of those decisions and any consequences.
    2. The information set out in Point 12.1 shall be provided to the Data Subject at the following applicable time:
      1. Where the Personal Data is obtained from the Data Subject directly, at the time of collection
      2. Where the Personal Data is not obtained from the Data Subject directly, for example, from another party:
        • If the Personal Data is used to communicate with the Data Subject, at the time of the
          first communication, or
        • If the Personal Data is to be disclosed to another party, before the Personal Data is
          disclosed, or
        • In any event, not more than one month after the time at which the Company obtains the
          Personal Data.
  13. Data Subject Access

    1. A Data Subject may make a Subject Access Request (SAR) at any time to find out more about the Personal Data which the Company holds about them. The Company is normally required to respond to SARs within one month of receipt. This can be extended by up to two months in the case of complex and or numerous requests, and in such cases the Data Subject shall be informed of the need for the extension.
    2. All SAR’s received must be made in writing to the DPO. A SAR must describe the information required and be accompanied by proof of identity to ensure that information is only shared with the Data Subject themselves.
    3. The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a Data Subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
  14. Rectification Of Personal Data

    1. If a Data Subject informs the Company that Personal Data held by the Company is inaccurate or incomplete, requesting that it be rectified, the Personal Data in question shall be rectified, and the Data Subject informed of that rectification, within one month of receipt the Data Subject’s notice. This can be extended by up to two months in the case of complex requests, and in such cases the Data Subject shall be informed of the need for the extension.
    2. In the event that any affected Personal Data has been disclosed to third parties, those parties shall be informed of any rectification of that Personal Data.
  15. Erasure Of Personal Data

    1. Data Subjects may request that the Company erases the Personal Data it holds about them in the following circumstances:
      1. It is no longer necessary for the Company to hold that Personal Data with respect to the purpose for which it was originally collected or processed
      2. The Data Subject wishes to withdraw their consent to the Company holding and processing their Personal Data
      3. The Data Subject objects to the Company holding and processing their Personal Data, and there is no overriding legitimate interest to allow the Company to continue doing so. See Point 17 of this policy for further details concerning Data Subjects’ rights to object
      4. The Personal Data has been processed unlawfully
      5. The Personal Data needs to be erased in order for the Company to comply with a particular legal obligation.
    2. Unless the Company has reasonable grounds to refuse to erase Personal Data, all requests for erasure shall be complied with, and the Data Subject informed of the erasure, within one month of receipt of the Data Subject’s request. This can be extended by up to two months in the case of complex requests, and in such cases the Data Subject shall be informed of the need for the extension.
    3. In the event that any Personal Data which is to be erased in response to a SAR, has been disclosed to third parties, those parties shall be informed of the erasure, unless it is impossible or would require disproportionate effort to do so.
  16. Restriction Of Personal Data Processing

    1. Data Subjects may request that the Company ceases processing the Personal Data it holds about them. If a Data Subject makes such a request, and unless the Company has reasonable grounds to refuse the restriction of Personal Data, all requests for restriction shall be complied with, and the Data Subject informed of the restriction, within one month of receipt of the Data Subject’s request. This can be extended by up to two months in the case of complex requests, and in such cases the Data Subject shall be informed of the need for the extension. The Company shall retain only the amount of Personal Data pertaining to that Data Subject that is necessary to ensure that no further processing of their Personal Data takes place.
    2. In the event that any affected Personal Data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it, unless it is impossible or would require disproportionate effort to do so.
  17. Objections To Personal Data Processing

    1. Data Subjects have the right to object to the Company processing their Personal Data based on Legitimate Interests, including profiling, direct marketing, including profiling, and processing for scientific and or historical research and statistical purposes.
    2. Where a Data Subject objects to the Company processing their Personal Data based on its Legitimate Interests, the Company shall cease such processing forthwith, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the Data Subject’s interests, rights and freedoms; or the processing is necessary for the conduct of legal claims.
    3. Where a Data Subject objects to the Company processing their Personal Data for direct marketing purposes, the Company shall cease such processing forthwith.
    4. Where a Data Subject objects to the Company processing their Personal Data for scientific and or historical research and statistical purposes, the Data Subject must, under the Regulation, ‘demonstrate grounds relating to their particular situation’. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.
  18. Automated Decision Making

    1. In the event that the Company uses Personal Data for the purposes of automated decision-making and those decisions have a legal, or similarly significant effect on Data Subjects, Data Subjects have the right to challenge to such decisions under the Regulation, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.
    2. The right described in Point 18.1 does not apply in the following circumstances:
      1. The decision is necessary for the entry into, or performance of, a contract between the Company and the Data Subject
      2. The decision is authorised by law
      3. The Data Subject has given their explicit consent.
  19. Profiling

    Where the Company uses Personal Data for profiling purposes, the following shall apply:

    1. Clear information explaining the profiling will be provided, including its significance and the likely consequences
    2. Appropriate mathematical or statistical procedures will be used
    3. Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented
    4. All Personal Data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling. See Points 21 and 22 of this policy for more details on data security.
  20. Personal And Special Category Data

    The following Personal Data may be collected, held, and processed by the Company.

    1. PERSONAL DATA – Clients and students
      Category of Personal Data Purpose of Processing Legal Basis for Processing
      Parents/Carers Names, telephone numbers, email addresses and email letter and telephone correspondence
      and any information provided by the Client.
      Fulfilment of the Contract with the Client.

      Safeguarding and Child Protection.

      Parents/Carers may be contacted from time to time to provide on the effectiveness of the Company’s service and as part of the Company’s continual improvement, and Quality Assurance.

      Legitimate Interest, Legal Obligation, Public Interest
      and Vital Interest.
      Students Names, addresses, date of birth, telephone numbers, email addresses, next of kin,
      emergency contact details, education history and plans, religion, disabilities, physical and
      mental health, medication, gender, sexual orientation, marital status, ethnicity,
      nationality, relatives’ and or carers’ contact details, social services contact details and
      role, Police and other official involvement, general educational and social history, court
      history and orders, financial information, social media history and interactions.
      Future and current students: Fulfilment of our contract with the referring Client.

      Past students: Safeguarding and Child Protection, educational, behavioural and engagement history and attainment.

      Students may be contacted from time to time to provide feedback or to enter competitions to assess the effectiveness of the Company’s methods and as part of the Company’s continual improvement and Quality Assurance.

      Legitimate Interest, Legal Obligation, Public Interest,
      Vital Interest and Statistical Research and Processing.
      Clients Names, telephone number, email addresses, office address, job title, employer, email,
      letter and telephone correspondence, contract(s), tenders, tender submissions, preferences
      and interests, general financial information relating to the commissioning body, payment
      terms and efficiency, usage of the Company’s website.
      Fulfilment of contract with the Client.

      Safeguarding, Child Protection and Behaviour Management and Reporting.

      Statistical Analysis and Review and Quality Assurance.

      Legitimate Interest,
      Legal Obligation,
      Public Interest,
      Vital Interest and Research and Statistical Purposes.
    2. SPECIAL CATERGORY PERSONAL DATA The processing of the data relating to students and their relatives is restricted to what is necessary for the purposes of; carrying out and exercising the requirements of the contract between the Company and the Commissioner of the Company’s service, as is or may be required by law in the UK, to protect the vital interests of the Data Subject or others, in the course of the Company’s legitimate activities with appropriate safeguards ensuring that special category data and Personal Data is not disclosed outside the Company unless required by law. All personal data is subject to the data protection measures of section 21.
    3. DATA RETENTION The Company may retain information about any Data Subject, party to any Contract or referral for up to 85 years. However, information is only held for as long as necessary except as required by law, and for the Company’s lawful business processing. The Company regularly reviews its records, to ensure that we only retain personal information for as long as necessary, for the purposes set out in this policy.Where the Company no longer needs personal information, it will dispose of it, anonymise it, so that the Data Subject is no longer identifiable, or delete it in a secure manner without further notice to the Data Subject.For unsuccessful candidates or Tutors who end their Contract before working with a student, all data will usually be retained for 1 year.
  21. Data Protection Measures

    1. The Company shall ensure that all staff comply with the following when working with Personal Data:
      1. All emails containing Personal Data will be encrypted using secure data encryption for all electronic communication including attachments
      2. Where any Personal Data is to be erased or otherwise disposed of for any reason, including where copies have been made and are no longer needed, it will be securely deleted and disposed of. Hardcopies will be shredded, using a ‘cross cut’ shredder, and electronic copies should be deleted securely
      3. Personal Data may be transmitted over secure networks only; transmission Data Protection Policy Page 15 of 17 Fresh Start Direct Ltd © 2018 over unsecured networks is not permitted in any circumstances
      4. Personal Data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable
      5. Personal Data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be archived. All temporary files associated therewith should be deleted
      6. Where Personal Data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data
      7. Where Personal Data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using Royal Mail Special Delivery Service
      8. No Personal Data may be shared informally and if a member of staff requires access to any Personal Data that they do not already have access to, such access should be formally requested from the DPO
      9. All hardcopies of Personal Data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet or similar
      10. No Personal Data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of the DPO
      11. Personal Data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time
      12. If Personal Data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it
      13. No Personal Data should be stored on any mobile device, including, but not limited to, laptops, tablets and smartphones, whether such device belongs to the Company or otherwise, without the formal written approval of the DPO and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary.
      14. Where permission has been granted by the DPO to store personal information on a personal device the following must be adhered to:
        • Data must never be accessed on a public computer
        • If using a shared device, the user must have their own login, that no-one else has the
          password for
        • All documents must be deleted and recycle bin emptied after they’ve been processed.
      15. No Personal Data should be transferred to any device personally belonging to an employee, and Personal Data may only be transferred to devices belonging to staff where the party in question has agreed to comply fully with the letter and spirit of this policy and of the Regulation, which may Data Protection Policy Page 16 of 17 Fresh Start Direct Ltd © 2018 include demonstrating to the Company that all suitable technical and organisational measures have been taken.
      16. All Personal Data stored electronically should be backed up at regular intervals with backups stored onsite and offsite. All backups should be encrypted using 256 bit encryption and or password protection.
      17. All electronic copies of Personal Data should be stored securely using 256 bit data encryption and or password protection.
      18. All passwords used to protect Personal Data must be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. All software used by the Company is designed to require such passwords
      19. Under no circumstances should any passwords be written down or shared between staff irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords.
  22. Organisational Measures

    The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of Personal Data:

    1. All staff shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Regulation and under this policy, and shall be provided with a copy of this policy
    2. Only staff that need access to, and use of, Personal Data in order to carry out their assigned duties correctly shall have access to Personal Data held by the Company
    3. All staff handling Personal Data will be appropriately trained to do so
    4. All staff handling Personal Data will be appropriately supervised
    5. Methods of collecting, holding and processing Personal Data shall be regularly evaluated and reviewed
    6. The performance of staff handling Personal Data shall be regularly evaluated and reviewed
    7. All staff handling Personal Data will be bound to do so in accordance with the principles of the Regulation and this policy by contract
    8. All staff handling Personal Data must ensure that any and all of their employees who are involved in the processing of Personal Data are held to the same conditions as those relevant employees of the Company arising out of this policy and the Regulation
    9. Where any staff member handling Personal Data fails in their obligations under this policy that party shall indemnify and hold harmless the Company against any costs, Data Protection Policy Page 17 of 17 Fresh Start Direct Ltd © 2018 liability, damages, loss, claims or proceedings which may arise out of that failure.
  23. Transferring Personal Data To A Country Outside The EEA

    The Company does not transfer Personal Data outside the EEA.

  24. Data Breach Notification

    1. All Personal Data breaches must be reported immediately to the Company’s DPO.
    2. If a Personal Data breach occurs and that breach is likely to result in a risk to the rights and freedoms of Data Subjects, for example, financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage, the DPO must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
    3. In the event that a Personal Data breach is likely to result in a high risk, that is, a higher risk than that described in Point 24.2, to the rights and freedoms of Data Subjects, the DPO must ensure that all affected Data Subjects are informed of the breach directly and without undue delay.
    4. Data breach notifications shall include the following information:The categories and approximate number of Data Subjects concernedThe categories and approximate number of Personal Data records concernedThe name and contact details of the Company’s DPO or other contact point where more information can be obtainedThe likely consequences of the breachDetails of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

Implementation of Policy

This policy shall be deemed effective as of 25th September 2018. No part of this policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

This Policy has been approved and authorised by:

Name:
Edward Robbins
Position:
Operations Director
Date:
25th September 2018
Due for Review by:
25th September 2019
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