Policies

Thank you for choosing to be part of our community at Warwickshire Institute of Sport (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at enquiries@warksis.ac.uk.

When you visit our website warksis.ac.uk, mobile application, Facebook application, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites or Apps and our services.

This privacy policy applies to all information collected through our website (such as warksis.ac.uk), mobile application, Facebook application, (“Apps“), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Services“).

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

Information That We Collect.

Personal information you disclose to us. In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when registering at the Services or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or Apps or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:

• Publicly Available Personal Information. We collect first name, maiden name, last name, and nickname; ID; passport number; current and former address; phone numbers; email addresses; birth, marriage, divorce, and death records; family member names and their related information; criminal records and mugshots; social media; and other similar data.

• Social Media Login Data. We may provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS” below.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information Collected Through Our Apps.

In Short:  We may collect information regarding your geo-location, mobile device, and Facebook permissions when you use our apps.

If you use our Apps, we may also collect the following information:

• Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings. 
• Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
• Facebook Permissions. We by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, checkins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.

Information collected from other sources

In Short:  We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

We may obtain information about your from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL, and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links). We will inform you about the source of information and the type of information and the type of information we have collected about you within a reasonable period after obtaining the personal data, but at the latest within one month.

How Do We Use Your Information?

In Short:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).

• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

• Fulfil and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services or Apps.

• To post testimonials. We post testimonials on our Services or Apps that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at enquiries@warksis.ac.uk and be sure to include your name, testimonial location, and contact information.

• Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. For more information, see our Cookie Policy.

• Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions.

• Request Feedback. We may use your information to request feedback and to contact you about your use of our Services or Apps.

• To protect our Services. We may use your information as part of our efforts to keep our Services or Apps safe and secure (for example, for fraud monitoring and prevention).

• To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.

• To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.

• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• To deliver services to the user. We may use your information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services or Apps, products, marketing and your experience. We may use and store this information in aggregated and anonymised form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

Will Your Information Be Shared With Anyone?

In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services or Apps, which will enable them to collect data about how you interact with the Services or Apps over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. 

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services or Apps. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. See our Cookie Policy for further information.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Do We Use Cookies and Other Tracking Technologies?

In Short:  We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

How Do We Handle Your Social Logins?

In Short:  If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services or Apps offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. If you login using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Services or Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

How Long Do We Keep Your Information?

In Short:  We keep your information for as long as necessary to fulfil the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

What Are Your Privacy Rights?

In Short:  You may review, change, or terminate your account at any time.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you have questions or comments about your privacy rights, you may email us at enquiries@warksis.ac.uk.

Account Information.

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

• Cookies and similar technologies. Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services or Apps. To opt-out of interest-based advertising by advertisers on our Services or Apps visit https://www.aboutads.info/choices/. For further information, please see our Cookie Policy.

• Opting out of email marketing. You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

• Contact us using the contact information provided.

Controls For Do-Not-Track Features.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

Do We Make Updates To This Policy?

In Short:  Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

Contact Us About This Policy.

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Daniel Holloway, by email at enquiries@warksis.ac.uk.

Location and Access to this Policy 

This policy will be accessible through contacting Warwickshire Institute of Sport via: enquiries@warksis.ac.uk 

Warwickshire Institute of Sport uses cookies on www.warksis.ac.uk, including any other media form, media channel, mobile website, or mobile application related or connected thereto to help customise the site and improve your experience. 

We reserve the right to make changes to this Cookie Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Cookie Policy. Any changes or modifications will be effective immediately upon posting the updated Cookie Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Cookie Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Cookie Policy by your continued use of the site after the date such revised Cookie Policy is posted.

By using the service, you consent to the use of cookies.

Scope.

Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the service, your choices regarding cookies and further information about cookies.

What are Cookies.

A cookie is a string of information which assigns you a unique identifier that we store on your computer. Your browser then provides that unique identifier to use each time you submit a query to the site. We use cookies on the site to, among other things, keep track of services you have used, record registration information, record your user preferences, keep you logged into the site, facilitate purchase procedures, and track the pages you visit. Cookies help us understand how the site is being used and improve your user experience.

How Warwickshire Institute of Sport uses Cookies.

When you use and access the service, we may place a number of cookies files in your web browser.

We use cookies for the following purposes: to enable certain functions of the service, to provide analytics, to store your preferences, to enable advertisements delivery, including behavioural advertising.

We use both session and persistent cookies on the service and we use different types of cookies to run the Service.

Types of Cookies.

The following types of cookies may be used when you visit the Site:

Advertising Cookies.

Advertising cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the Site and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any personal information about you.

Analytics Cookies.

Analytics cookies monitor how users reached the Site, and how they interact with and move around once on the site. These cookies let us know what features on the site are working the best and what features on the Site can be improved.

Our Cookies.

Our cookies are “first-party cookies”, and can be either permanent or temporary. These are necessary cookies, without which the site won’t work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser, but may affect the functionality of the site.

Personalisation Cookies.

Personalisation cookies are used to recognise repeat visitors to the Site. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit the Site.

Security Cookies.

Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorised parties.

Site Management Cookies.

Site management cookies are used to maintain your identity or session on the site so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.

Third-Party Cookies.

Third-party cookies may be place on your computer when you visit the site by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser.

Your Choices Regarding Cookies.

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

Find Out More Information About Cookies.

You can learn more about cookies and the following third-party websites:

• AllAboutCookies: https://www.allaboutcookies.org/
• Network Advertising Initiative: https://www.networkadvertising.org/

Other Tracking Technologies.

In addition to cookies, we may use web beacons, pixel tags, and other tracking technologies on the Site to help customise the Site and improve your experience. A “web beacon” or “pixel tag” is tiny object or image embedded in a web page or email. They are used to track the number of users who have visited particular pages and viewed emails, and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, you can limit their use by controlling the cookies that interact with them.

Privacy Policy.

For more information about how we use information collected by cookies and other tracking technologies, please refer to our Privacy Policy posted on the Site. This Cookie Policy is part of and is incorporated into our Privacy Policy. By using the Site, you agree to be bound by this Cookie Policy and our Privacy Policy.

Location and Access to this Policy.

This policy will be accessible through contacting Warwickshire Institute of Sport via: enquiries@warksis.ac.uk 

Warwickshire Institute of Sport considers the welfare of children, young people and vulnerable adults of paramount importance and aims to safeguard and promote their welfare, safety and health by providing an open, caring, responsive and supportive learning environment which responds to needs immediately. Warwickshire Institute of Sport will ensure that all children, young people and vulnerable adults who access the facilities feel safe and will put in place procedures and staff training to achieve this. 

Scope & Purpose 

The Policy is consistent with: 

• The legal duty to safeguard and promote the welfare of children, as described in Section 175 of the Education Act 2002 and the statutory guidance ‘Keeping Children Safe in Education’ (2018) 
• Working Together To Safeguard Children (2018) 
• Safeguarding Children and Safer Recruitment in Education (2012) 
• Guidance for Safer Working Practice for Adults who work with Children and
  Young People in Education Settings (2015) 
• Protecting the UK against terrorism (2015)

There are four main elements to the Safeguarding Policy: 

• • Prevention. E.g. positive atmosphere, teaching and support for children, young people and vulnerable adults, safer recruitment procedures
  • Protection. By following agreed procedures, ensuring staff are trained and supported to respond appropriately and sensitively to Child Protection concerns; 
  • Support. To children, young people and vulnerable adults and staff who may have been abused
  • Working with key partners. Including staff, parents/carers, employers, and visitors, to ensure appropriate communications, due diligence and actions are undertaken

This policy applies to all key partners. Warwickshire Institute of Sport recognises that safeguarding is the responsibility of all staff. Warwickshire Institute of Sport will ensure that all key partners are aware of the safeguarding policy by offering it accessibly via email.

Where the business provides services or activities directly under the supervision or management of staff, arrangements for safeguarding will apply. Where services or activities are provided separately by another body, Warwickshire Institute of Sport will seek assurance in writing that the body concerned has appropriate policies and procedures in place to safeguard children, young people and vulnerable adults and that there are arrangements to liaise on these matters where appropriate. 

Procedures for Safeguarding Children, Young People and Vulnerable AdultS.

Warwickshire Institute of Sport will:

Establish and maintain an ethos where children, young people and vulnerable adults feel secure and are encouraged to talk, and are listened to; 

Ensure that children young people and vulnerable adults know that there are adults in the college whom they can approach if they are worried or are in difficulty; 

Include in the curriculum activities and opportunities which provide children, young people and vulnerable adults with the skills they need to stay safe from abuse and to know to whom they can turn for help; 

Ensure every effort is made to establish effective working relationships with our key partners. 

Operate safer recruitment procedures and make sure that all appropriate checks are carried out on new staff and volunteers who will work with children, young people and vulnerable adults including references, DBS checks and prohibition from teaching checks.

Safeguarding in the Curriculum.

The following areas are among those that may be addressed in the wider curriculum: 

• Bullying & Cyberbullying 
• Drugs, alcohol and substance abuse 
• E-Safety & Internet safety 
• Domestic violence 
• Relationships 
• Diversity issues
• Extremism and radicalisation 
• Harassment 

Roles & Responsibilities 

All adults working with or on behalf of children, young people and vulnerable adults have a responsibility to safeguard and promote their welfare. This includes a responsibility to be alert to possible abuse and to record and report concerns.

Governing Body.

In accordance with the Statutory Guidance ‘Keeping Children Safe in Education’ April 2018, the Governing Body will ensure that: 

• Warwickshire Institute of Sport has a safeguarding policy, procedures and training in place which are effective and comply with legislation. The policy is available publicly; 
• Warwickshire Institute of Sport operates safer recruitment practices, including appropriate use of references and checks on new staff and volunteers. Staff involved in recruitment will undertake safer recruitment training; 
• There are procedures for dealing with the protection of vulnerable young people from being drawn into terrorism and radicalisation 
• There are procedures for dealing with allegations of abuse against members of staff and volunteers; 
• There is a senior member of Staff who is designated to take lead responsibility for dealing with child protection and it is ensured that there is always cover for this role; 
• All staff and volunteers undertake appropriate training which is regularly updated and that new staff and volunteers who work with children, young people and vulnerable adults are made aware of the arrangements for child protection and their responsibilities.
• Protection” will be used as part of this induction; Staff will receive regular updates of their knowledge and skills as required and at least annually. 
• Any deficiencies or weaknesses brought to the attention of the Governing Body will be rectified without delay; 
• Effective policies and procedures are in place and updated annually including a behaviour ‘code of conduct’ for staff and volunteers; 

The Director.

The Director of Warwickshire Institute of Sport will ensure that: 

• The policies and procedures adopted by the Governing Body are effectively implemented, and followed by all staff; 
• Sufficient resources and time are allocated to enable staff to discharge their responsibilities, including taking part in strategy discussions and other inter-agency meetings, and contributing to the assessment of children, young people and vulnerable adults; 
• Allegations of abuse or concerns that a member of staff or adult working within the business may pose a risk of harm to a child, young person or vulnerable adult are notified and dealt with; 
• All staff and volunteers feel able to raise concerns about poor or unsafe practice in regard to children, young people and vulnerable adults and such concerns are addressed sensitively and effectively in a timely manner; 
• All staff are made aware that they have an individual responsibility to pass on safeguarding concerns and that if all else fails to report these directly to children’s or adult social care services or the police.
• All staff are made aware of the risks of children, young people and vulnerable adults being drawn into terrorist related activity and how to recognise and report the signs. 

Designated Safeguarding Lead (DSL).

The responsibilities of the Designated Safeguarding Lead include: 

• The provision of information to the Local Safeguarding Children’s Board (LSCB)/Local Authority on safeguarding and child protection; 
• Liaison with the Governing Body and the Local Authority on any deficiencies brought to attention of the Governing Body and how these should be rectified without delay; 
• Referral of cases of suspected abuse to Specialist Services First Response Children’s Duty (and/or Police where a crime may have been committed); 
• Acting as a source of support, advice and expertise within Warwickshire Institute of Sport; 
• Attending and contribute to child protection conferences when required 
• Ensuring each member of staff has access to and understands the college’s child protection policy especially new or part-time staff who may work with different educational establishments; 
• Ensuring all staff have induction training covering child protection and are able to recognise and report any concerns immediately 
• Keeping detailed, accurate and secure written records of concerns and referrals; 
• Obtaining access to resources and training for all staff and attending refresher training; 
• Maintaining and monitoring child protection records, including monitoring and acting upon individual concerns, patterns of concerns or complaints, in accordance with section on ‘Records and Monitoring’ below; 

Records, Monitoring & Transfer.

Well-kept records are essential to good child protection and safeguarding practice. All staff are clear about the need to record and report concerns about a child, young person or vulnerable adult. The Designated Safeguarding Lead is responsible for such records and for deciding at what point these records should be passed over to other agencies. 

Records relating to actual or alleged abuse or neglect are stored apart from normal student or staff records. Normal records sometimes have markers to show that there is sensitive material stored elsewhere. This is to protect individuals from accidental access to sensitive material by those who do not need to know. 

Child protection safeguarding records are stored securely, with access confined to the Designated Safeguarding Leads. 

Child protection safeguarding records are reviewed regularly to check whether any action or updating is needed. This includes monitoring patterns of complaints or concerns about any individuals and ensuring these are acted upon. 

When children, young people and vulnerable adults transfer to the programme, their safeguarding records must also be transferred. Safeguarding records will be transferred separately from other records and best practice is to pass these directly to a Designated Safeguarding Lead in the receiving college with any necessary discussion or explanation and to obtain a signed and dated record of the transfer. 

In the event of a child, young person or vulnerable adult moving out of area and a physical handover not being possible then the most secure method will be found to send the confidential records to a named Designated Safeguarding Lead.

Working in Partnership.

• Support for learners 
• Warwickshire Institute of Sport recognises that children, young people and vulnerable adults who are abused or who witness violence may find it difficult to develop a sense of self-worth and view the world in a positive way. For such children, young people and vulnerable adult’s, the programme may be one of the few stable, secure and predictable components of their lives. Other children, young people and vulnerable adults may be vulnerable because, for instance, they have a disability, are in care, or are experiencing some form of neglect. The programme will seek to provide such children, young people and vulnerable adults with the necessary support and to build their self-esteem and confidence; 
• It is recognised that children, young people and vulnerable adults sometimes display abusive behaviour and that such incidents must be referred on for appropriate support and intervention. 
• Complaints or concerns raised by children, young people and vulnerable adults will be taken seriously and followed up in accordance with the complaints process 
• Peer-on-peer abuse: This can be understood as bullying, physical abuse, sexual violence and sexual harassment, sexting, and so-called initiation ceremonies. We recognise the gendered nature of peer on peer abuse. Any form of this abuse will not be tolerated.

In the event of a disclosure of this nature Warwickshire Institute of Sport will formally risk assess the situation considering the alleged victim, alleged perpetrator and other children/adults. This will be done on a case by case basis and alleged victims will be taken seriously. This risk assessment and subsequent actions will be kept under review and DSL will ensure that we are engaging with children’s social care, the police and specialist services as required. 

Support for Staff.

As part of their duty to safeguard and promote the welfare of children, young people and vulnerable adults, staff may hear information, either from the child/young person, vulnerable adult or as part of a disclosure or from another member of staff that will be upsetting. Where a member of staff is distressed as a result of dealing with a child protection/safeguarding concern, he/she should in the first instance speak to the Designated Safeguarding Lead about the support he/she requires. The Designated Safeguarding Lead will seek to arrange the necessary support. 

Working With Key Partners.

Warwickshire Institute of Sport will: 

• Outline our safeguarding policies and procedures to all visitors and key partners highlighting their responsibilities as visitors to the business in regards to safeguarding by providing them with the details of what to do should there be a safeguarding concern. 
• Ensure due diligence of all key partners and stakeholders is undertaken including their provision for safeguarding and child protection policies and procedures being in place as well as knowing how to contact our safeguarding lead. 
• Ensure that parents/carers have an understanding of the responsibility placed on the staff for child protection/safeguarding by ensuring this the Safeguarding Policy is available; 

Recruitment and Selection of Staff.

Safer recruitment processes are based on the Statutory Guidance: ‘Keeping children safe in education 2018’ and ‘Safeguarding Children and Safer Recruitment in Education’. Warwickshire Institute of Sport will provide all the relevant information in references for a member of staff about whom there have been concerns about child protection inappropriate conduct. Cases in which an allegation has been proven to be unsubstantiated, false or malicious will not be included in employer references. 

All new staff and volunteers receive a safeguarding induction and are briefed on the code of conduct for adults working with children, young people and vulnerable adults. 

Linked Policies, Procedures & Guidance.

• The policy will be implemented by procedures which will: 
• Promote the prevention of abuse of children and vulnerable adults. 
• Protect children and vulnerable adults 
• Support children and vulnerable adults who may have been subjected to or affected by abuse 
• Work with parents and carers, where appropriate , to ensure communications and actions are undertaken swiftly, smoothly and sensitively Related policies, procedures and guidance include: 
  • Anti-Bullying and Harassment, including Cyberbullying
  • Safer Recruitment of Staff 
  • Disclosure and Barring Service (DBS) 
  • Allegations against persons who work with children and vulnerable adults 
  • Staff and Student Discipline 
  • Electronic Communications 
  • Trips and visits 
  • Tackling radicalisation policy 
  • Work experience and extended work placements 
  • First aid 
  • Administration of medicines 
  • Personal Care Procedures 
  • Health and Safety 
  • Nursery Policies, procedures and codes of practice 
  • Security 
  • Equality and Diversity 
  • E-safety 
  • Extended college activities 

The above list is not exhaustive but when undertaking development or planning of any kind, Warwickshire Institute of Sport will consider the implications for safeguarding and promoting the welfare of children, young people and vulnerable adults. 

Prevent.

Warwickshire Institute of Sport recognises that a Prevent policy, is to create and maintain a safe, healthy and supportive learning and working environment for all our students, staff and visitors alike. We recognise that extremism and exposure to extremist materials and influences can lead to poor outcomes for students.

We focus upon key areas to monitor that Prevent is implemented in the most efficient and effective way possible.

• To promote and reinforce shared values, including British Values; to create space for free and open debate; and to listen and support the student voice.
• To breakdown segregation among different student communities including by supporting inter-faith and inter-cultural dialogue and understanding; and to engage all students in playing a full and active role in wider engagement in society.
• To ensure student safety and that the organisation is free from bullying, harassment and discrimination.
• To provide support for students who may be at risk of radicalisation, and appropriate sources of advice and guidance.
• To ensure that students and staff are aware of their roles and responsibilities in preventing violent and non-violent extremism.

We, at Warwickshire Institute of Sport will ensure that the relevant training for staff is undertaken on an annual basis, with certification for all staff, understanding that Prevent is an integral part of a safe learning environment for all.

Location and Access to this Policy.

This policy will be accessible through contacting Warwickshire Institute of Sport via: enquiries@warksis.ac.uk 

Policy Statement

Warwickshire Institute of Sport embraces the diversity of its workforce and would expect all staff to respect their students’, colleagues’ and volunteers’ differences.

Purpose

Warwickshire Institute of Sport will not tolerate behaviour in the form of discrimination, victimisation, harassment or bullying. Legislation and associated regulations exist to protect employees, and there are a number of policies and procedures in place to support the legislation.

Warwickshire Institute of Sport is committed to the promotion of equality of opportunity for all and values the diversity of its students, staff and other stakeholders. The purpose of this policy is to provide equal opportunities to all who learn and work for and with Warwickshire Institute of Sport irrespective of gender, race (including colour, nationality, ethnic and national origins), disability, age, sexual orientation, religion and belief, including political belief (or lack of religion or belief), gender reassignment, marriage and civil partnership and pregnancy and maternity. These are known as protected characteristics in employment law.

Warwickshire Institute of Sport is also committed to ensuring equal treatment for all staff regardless of the type of contract they are employed on e.g. fixed-term or part-time.

Warwickshire Institute of Sport opposes all forms of unlawful and unfair discrimination (forms of discrimination are outlined in Appendix A).

Warwickshire Institute of Sport will also give due regard and consideration to spiritual, moral, social and cultural values or beliefs of both staff and students in so far as these do not contravene either Warwickshire Institute of Sport Policy or any legislation and to actively support decision making and personal choices which are made free from oppression, coercion or fear.

Warwickshire Institute of Sport will work with all stakeholders to seek positively to remove conditions and barriers which place people at a disadvantage and promote community harmony and social cohesion by actively promoting equality for all and celebrating diversity.

All of Warwickshire Institute of Sport’s students and members of staff will be helped and encouraged to develop their full potential within an ethos which recognises and values the benefits that a diverse workforce supporting a diverse student body can bring to both the local and wider community.

This policy has been prepared taking account of prevailing legislation and new legislative requirements and follows effective practice by enabling Warwickshire Institute of Sport to demonstrate that all Equality and Diversity practices are fair, equitable and transparent. Accordingly, the policy has been subject to an Equality Impact Assessment and is suitable for publication under the Freedom of Information Act.

Scope

This policy applies to all students and staff, wherever they learn or work and operates within the framework of Warwickshire Institute of Sport’s mission, vision and values. This includes temporary workers or organisations working in partnership with Warwickshire Institute of Sport where contractual arrangements are put in place.

The policy will be implemented within the framework of the Equality Act 2010 and will include the extended protections for carers and disabled people. The Equality Act supersedes all previous Equality legislation including:

• Equal Pay Act 1970 ( Equal Value Amendment 1984)
• Sex Discrimination Act 1975 (Gender Reassignment Regulations 1999) & (Indirect Discrimination & Burden of Proof Regulations 2001)
• Race Relations Act 1976 ( Race Relations Amendment Act 2000)
• Disability Discrimination Act 1995 & DDA (Amendment) 2005

Access

All key materials used to market learning and employment opportunities will explicitly convey our positive attitude to Equality and Diversity. Means of distribution will be kept under review to ensure information reaches those who do not traditionally respond to learning or employment opportunities available within Warwickshire Institute of Sport.

Guidance and admissions procedures will be clear, transparent and free from unfair discrimination. All appropriately qualified applicants will be given equal consideration during the selection process and entry qualifications will only include those that are necessary and justifiable.

Efforts will be made to ensure that any kind of gender stereotyping within the Curriculum is challenged, for example, ensuring that female students are encouraged and supported to enrol into courses which are more commonly associated with male students and male students are equally encouraged and supported to enrol into courses more commonly associated with female students.

Enrolments of International Students will be carried out in accordance with the requirements of the UK Border Agency and within associated legal frameworks.

Effective plans will be in place to make the learning environment safe, welcoming and accessible for all groups of students, employees and other users in terms of timing and location of provision, physical access, amenities and services, including off campus activities.

What is Diversity?

Diversity encompasses a multitude of areas such as gender, race, disability, physical ability, mental capacity, education, sexual orientation, religious beliefs, values, age, personality, experiences, culture and the way each area approaches work. This list is not exhaustive. Embracing diversity means acknowledging, understanding, and appreciating the differences between individuals and developing a workplace that enhances their value. By being flexible in our approaches it is then possible to achieve a rewarding environment.

The Benefits of Diversity Management

A diverse workforce can offer a wide range of resources, skills, ideas and energy to the organisation. Organisations that embrace diversity reap the benefits of resourcing from a wider pool of talent, broaden their markets, improve productivity and raise the community profile.

Diversity management can benefit an organisation in a number of ways, such as:

• Improve opportunities within the organisation through internal promotion;
• Utilise the knowledge of different areas of the community;
• Understand market segments and student behaviour;
• Become an employer of choice;
• Have a more representative ‘balanced’ workforce;
• Value and respect employees, attracting/ and retaining a wider talent pool.

The Difference between Diversity and Equality

Diversity and equal opportunities are often regarded as the same thing. However, there are differences. Valuing diversity is about seeing everyone as individuals, valuing the abilities and skills they can bring to an organisation.

It is not about seeing people first and foremost in terms of the membership of a particular group. Equality of regard for people is about emphasising inclusiveness, openness and fairness, offering a positive outlook on the many differences, as well as similarities that can affect how people interact and perform with each other in the workplace. Diversity is about respecting differences within minority groups and not expecting everyone to conform to the ways of majority groups.

Widening diversity is something that is initiated internally, where a culture for diversity has developed over time. Equal opportunities are usually prompted by external factors such as legislation and codes of practice.

Managing diversity is concerned with improving quality within an organisation, with a focus on qualitative issues and good practice, whereas equal opportunities focus on improving numbers. This might include increasing the number of women in management positions, or increasing the number of ethnic minorities or raising the age profile.

Valuing people, and their many diverse qualities, enhances employee potential, therefore enhancing the services that an organisation can provide. Equal opportunities aims to ensure that no group receives less favourable treatment because of their differences, ensuring all people are treated equally. This is about adapting to individual needs rather than treating everyone the same.

Diversity focuses on being proactive and finding opportunities to enhance an organisation, a service or a programme. Equal Opportunities is reactive and will focus on existing problems while trying to redress the balance.

A diverse culture is something that can develop with support but an equal opportunities culture is socially constructed by specific measures being put into place. Managing diversity encourages people to reflect on and change their own practices and systems, resulting in a diverse culture.

Diversity at work is not only concerned with keeping within the confines of the law, but would also gradually seek to educate every staff member so that discrimination would become a thing of the past.

Discrimination

Direct discrimination will occur where in like for like circumstances, a person is treated, or would have been treated, less favourably than others on the grounds of race, gender, sexual orientation, religion or belief, age or personal characteristics.

Indirect Discrimination

Indirect discrimination occurs when an employer applies a provision, criterion or practice to everyone that puts, or would put, a group of people at a particular disadvantage compared to others. Furthermore, the individual complainant can show that he or she suffered that disadvantage compared to others.

Furthermore, the individual complainant can show that he or she suffered that disadvantage and the employer cannot show the provision, criterion or practice to be a proportionate means of achieving a legitimate aim (within the limits of what is needed to achieve the business objective). This definition covers formal requirements, conditions and provisions, as well as informal practices. An example of indirect discrimination would be a requirement for all staff to be clean shaven. In this example, the same requirement is applied equally to all staff, but would particularly disadvantage those of a particular faith.

Curriculum

A diverse portfolio of relevant programmes will be offered which are responsive to student needs and enable students to study at an appropriate level with good opportunities for success and progression. Progression routes will be clearly published and advice given impartially. A range of delivery locations and methods inclusive by design will be used to minimise barriers to learning.

Inclusive learning practices including teaching students strategies for effective learning behaviours, perseverance, growth mindset and social skills; diverse and inclusive teaching and learning materials; evidence-based teaching and learning strategies which have high effect sizes with regard to student achievement such as providing effective formative feedback, reciprocal teaching and problem-solving teaching as well as differentiation of teaching and formative assessment based on catering for individual student needs whilst challenging each student appropriately with stretch targets enabling ambitious learning progress.

Learning materials which are free from bias, which celebrate diversity and challenge stereotyping will be used throughout the curriculum. If discriminatory material is used to support a teaching point, students should be challenged to think critically about the resource and if they don’t conclude so themselves, the discriminatory nature of the resource should be pointed out by the member of staff using the material.

Opportunities to promote Equality and Diversity, wherever possible and appropriate, should be capitalised upon by all members of staff. This will require students to be able to think critically about equality & equity, human and earth rights, ethical thinking, decision-taking and behaviour as well as diversity.

Provision of additional learning support tailored to individual needs is provided to all who require it and are eligible to support access, success and progression. Support mechanisms will be in place to catch students who may academically fail in order to help them succeed.

Warwickshire Institute of Sport’s robust Safeguarding and Prevent Handbook will be communicated to and adhered to be all staff at all times. Staff and student safety and wellbeing is of paramount importance and all instances of raised concerns will be documented and discussed at monthly Senior Leadership Team (SLT) meetings.

Student Experience

Induction procedures, which familiarise students with Warwickshire Institute of Sport’s policies and processes and commitment to Equality and Diversity, will be delivered to all new students (full-time, part-time). This will include work on values of listening, showing respect and tolerance, valuing diverse perspectives as well as equipping students with learning strategies to help them succeed. This is also inline with the fundamental British values that are embedded into the curriculum; democracy, rule of law, individual liberty, mutual respect and tolerance for those with different faiths and beliefs. The Safeguarding and Prevent Handbook and Tutorial Policy demonstrates Warwickshire Institute of Sport’s commitment to ensure that students are familiar with and understand the Fundamental British Values (FBV), and are able to implement them effectively to become upstanding members of society. .

Equal opportunities in the workplace will be promoted and monitored for work-based students with work placements being assessed and monitored to ensure equality practices are being consistently operated.

Employment and Professional Development

Equality of opportunity exists for all staff and for recruitment purposes this extends to include potential employees. Equality of opportunity is also applied to career promotion opportunities where individuals meet the minimum criteria as well as access to Continued Professional Development (CPD) and other training opportunities. Warwickshire Institute of Sport’s commitment to non-discriminatory process of recruitment and selection is outlined in the Equal Opportunities Policy.

Warwickshire Institute of Sport is committed to the Two Ticks Scheme, operated by the Department for Work and Pensions (DWP) and accredited by Job centre Plus, whereby those applicants who formally disclose a disability and meet the requirements of the Guaranteed Interview Scheme will be guaranteed an interview for any vacancy.

Workforce Data in relation to HR & Professional Development including recruitment and selection, staff training and staff promotion will be reviewed annually by the Managing Director of Warwickshire Institute of Sport.

All Warwickshire Institute of Sport staff (regardless of their type of contract, hours of work or any other protected characteristic listed in Section 1.1) have equal access to career progression and development opportunities which are available at Warwickshire Institute of Sport.

Warwickshire Institute of Sport takes account of the changing needs of individual members of staff and will implement reasonable adjustments, where this is required in accordance with advice from the Occupational Health Service e.g. someone who is or who becomes disabled during their employment.

Warwickshire Institute of Sport will take advantage of national initiatives and programmes which provide opportunities for BAME and disabled staff and managers to develop their careers e.g. the Network for Black Professionals and will collaborate wherever possible to recruit staff from any under-represented groups within Warwickshire Institute of Sport.

The Senior Leadership Team (SLT) of Warwickshire Institute of Sport plan to ensure that Equality Impact Assessments (EIAs) are carried out on all policies and procedures, recruitment and selection documentation and all consultation papers, where proposals have either a direct or indirect impact on staff.

Genuine Occupational Requirement (GOR)

In very limited circumstances it will be lawful for an employer to treat people differently if it is a GOR.

Where there is a genuine requirement for a particular type of person to do a particular job, the employee must be able to justify a sound business reason for this.

This may occur if it is necessary that, for example, an individual of a particular religion is required to do a job.

Victimisation

Victimisation will occur where a person is treated less favourably because he or she carried out a ‘protected act’, i.e. has alleged that discrimination or harassment has taken place; has presented a claim to an employment tribunal; or has acted as a witness in a discrimination or harassment case.
Protection against victimisation will not apply if allegations are false and not made in good faith.

Harassment and Bullying

Any form of bullying, harassment or victimisation discrimination within Warwickshire Institute of Sport is unacceptable and should be challenged by staff. In a teaching context, where appropriate, this should also be used as an opportunity for wider learning.

Harassment and bullying are defined in many ways. For instance, unwanted remarks, inappropriate jokes or ridicule, unwelcome physical contact, suggestions or demands for sexual favours, racial shunning or segregation.
In general terms, behaviour which affects the recipient’s dignity, relating to age, gender, race, nationality, disability, religion, sexual orientation or any personal characteristic of the individual. This can include an isolated incident or a series of incidents.

Unacceptable behaviour might include the spreading of malicious rumours; insulting an individual; circulating emails or memoranda containing critical confidential information; picking on someone; setting up an individual to fail; victimisation; unfair treatment, circulating offensive material; constantly undermining and criticising a competent worker; or preventing promotional opportunities.

Sexual harassment is unlawful under the Sex Discrimination Act. This constitutes unwanted behaviour of a sexual nature, or other behaviour with a sexual reference, which affects the dignity of men and women at work.
Racial harassment is unlawful under the Race Relations Act. This constitutes unwanted behaviour of a racial nature, or other behaviour based on racial grounds, which affects the dignity of men and women at work.

Harassment on the grounds of religion or belief, or sexual orientation, is where unwanted conduct causes a violation of one’s dignity or creates an intimidating, hostile degrading, humiliating or offensive environment.

Any allegations will be dealt with sensitively and investigated fairly and thoroughly. Disciplinary action may be taken when necessary.

Relevant Legislation

The following are the main Acts and Regulations relevant to this policy. The list is not exhaustive.

Disability

The Equality Act, 2010, makes it unlawful for employers to discriminate against a prospective or current member of staff on grounds of disability. Under Section 20 of the Equality Act (2010) it is upheld as a duty for the employer to make reasonable adjustments, so that a person with a disability is not disadvantaged. This means that it is unlawful for employers to treat a person or person with a disability less proportionately than those who are not disabled without a good reason.

A reference to a disabled person is a reference to a person who has a disability, under the Act (2010), stating that a person has a disability if:

• The Person has a physical or mental impairment;
• The impairment has a substantial and long-term adverse effect on the person’s ability to carry out normal day-to-day activities

Race

Race Relations Act 1976 (RRA) defines racial grounds as meaning colour, race, nationality or ethnic origins.

Direct discrimination occurs when a person is treated less favourably than another person who is not of the same racial group.

The Commission for Racial Equality (CRE) have issued a Codes of Practice for the purpose of eliminating discrimination employment.

Race Relations (Amendment) Act 2000

The RR (A) Act (2000) placed certain requirements on public sector bodies (such as colleges, government departments, local authorities, the police and NHS), and these requirements came into force in May 2002. The general duty is to pay due regard, when carrying out functions, to eliminate unlawful discrimination, and promote equal opportunities and good relations between persons of different racial groups.

Under the Race Relations Act 1976 (RRA), public Authorities, including further and higher education institutions, have a statutory general duty to promote race equality. The duty is made up of three distinct parts:

• To work to eliminate unlawful racial discrimination
• To promote equality of opportunity
• To promote good race relations

Sex Discrimination

The Sex Discrimination Act 1975 (SDA) forbids discrimination directly or indirectly against a person on the grounds of sex or marital status.

Direct sex discrimination is when a person is treated less favourably on account of their sex in relation to issues such as recruitment, selection, training, promotion and selection for redundancy.

Indirect discrimination is when an employer imposes a requirement or condition which fewer persons of one sex can fulfil.

In exceptional circumstances there may be a GOR.

Employment Equality (Sex Discrimination) Regulations 2005 introduced a new definition of indirect discrimination in employment matters prohibiting harassment and sexual harassment in employment and making it clear that less favourable treatment of women on grounds of pregnancy or maternity leave is unlawful sex discrimination.

Gender Reassignment

The Sex Discrimination Act was extended in 1999 to make it unlawful to discriminate in employment on the grounds of an employee intending to, undergoing, or having undergone gender reassignment.

If it is known to the employer it is good practice to ask individuals how they wish to be treated.

Human Rights

The Human Rights Act 1998 incorporates a substantial part of the European Convention for the Protection of Human Rights and Fundamental Freedoms. The articles of convention which could have an impact on employment law in the United Kingdom are:

• Article 8: The right to respect for private and family life;
• Article 9: Freedom of thought, conscience and religion;
• Article 10: Freedom of expression;
• Article 11: Freedom of assembly and association.

It is important to be aware of and not to breach the Human Rights of individuals as this also can result in tribunal proceedings.

Equal Pay

The Equal Pay Act 1970 states that if a person, male or female, is doing ‘like work’ of equal value compared to a person of the opposite sex in the same employment, they are entitled equal pay.

This Act does not permit claims for equal pay with other people of the same gender, or between different employers.

The Equal Pay (Questions and Replies) Order 2003 allows people to question their employer on matters they understand to be discriminatory on the grounds of gender, race and disability. A questionnaire can be submitted requesting information from the employer in order to establish if a person is receiving equal pay. This questionnaire can be submitted as evidence to a tribunal. Employers are required to answer the questionnaire.

However, there may be times when some of the information requested may impinge on what is protected by the Data Protection Act. This can also result in tribunal proceedings.

Sexual Orientation

The Employment Equality (Sexual Orientation) Regulations 2003 cover discrimination in the workplace such as job applicants and those already in employment.

Discrimination is prohibited in the arrangements made by an employer when determining who should be offered employment opportunities, promotion, training and protection from dismissal.

This includes discrimination towards someone with orientation towards the same gender (lesbian or gay men), opposite gender (heterosexual) or both genders (bisexual).

There can be no justification for direct or indirect discrimination unless in very exceptional circumstances a GOR applies.

Care should be taken when considering social gatherings within the workplace. For example, invitations should be carefully worded so they are free of bias.

Religion or Belief

The Employment Equality (Religion or Belief) Regulations (2003) are designed to protect those who suffer discrimination on the grounds of religion, religious belief or similar philosophical belief. The Regulations will make it unlawful to discriminate on matters of employment against ‘workers’, which includes employees and contractors. This means it is unlawful for employers to discriminate in relation to recruitment and selection, employee terms and conditions, promotion, transfers, dismissals and training.

People who hold no religious belief are also protected as the regulations do not require the complainant to have a religion or belief.

There can be no justification for direct or indirect discrimination unless in very exceptional circumstances a GOR applies.

Religious Observance

Warwickshire Institute of Sport provides and advises on apparel products to represent the organisation during working hours. However, as an organisation, no dress code on staff is imposed at an impact detrimental to religion and/or beliefs. There are some requirements as listed below:

Health and safety requirements may mean that for certain tasks specific items of clothing such as sports kits, overalls, protective clothing, etc. need to be worn. Where wearing such items conflicts with a religion or belief, the issue will be sympathetically considered by the line manager, with the aim of finding a satisfactory but safe compromise.

Dress should conform to the current majority view in our society of what constitutes decency.

Wearing clothing with slogans which are considered discriminatory is not permitted.

Religious activities during work time

All staff, regardless of their religious belief or non-belief, are required to work in accordance with their contract.

Warwickshire Institute of Sport will, however, treat sympathetic requests from staff who require flexibility over how the hours that are worked. This may relate for example, to staff who need to pray at certain times of the day, or who may require an extra hour at midday on a Friday.

Special Festivals

Warwickshire Institute of Sport acknowledges that owing to current bank and public holidays those of Christian faith are guaranteed time off at Christmas and Easter. In the interest of equality Warwickshire Institute of Sport will support and consider favourably requests from those of other religions to book up to three days of their holiday entitlement to enable them to celebrate their own special religious festival(s).

Extended Leave

Requests for extended leave for the purpose of pilgrimages, or visiting relatives abroad for weddings, birth or deaths will be treated sympathetically. The needs of the Organisation, and extra burden placed on other staff, will be taken into account when considering extended leave requests. If extended leave extends beyond the annual leave entitlement, the granting of any excess days will be on unpaid basis.

Age

The Employment Equality (Age) Regulations 2006.

These regulations apply to all people who apply for work. In addition they will cover access to vocational training, professional associations, employers’ organisations, etc.

The Age Regulations will prohibit direct and indirect age discrimination, harassment and victimisation.

One of the main requirements is to abolish employer’s mandatory retirement age below age 65, unless employers can objectively justify such a retirement age.

The Rehabilitation of Offenders

People with criminal records are protected by the Rehabilitation of Offenders Act 1974, which makes it unlawful for an employee to take account of (or be informed of) a person’s previous offending history once the conviction has become ‘spent’. However, some sentences cannot be spent, and others may be ‘spent’ but still have to be declared when the individual is applying to work with Warwickshire Institute of Sport in a capacity that will mean that they will be in contact with children, young people and vulnerable adults.

Since the introduction of the Disclosure Barring Service (DBS) Record, employees and applicants in sensitive jobs have to give consent to a search being made for details of any previous or current convictions and for employers to be advised of the outcome.

The Disclosure service provides a means to carry out checks through DBS on staff or applicants and allows for decisions to be made about recruiting staff who have a criminal record.

Applicants are offered equal opportunities when going through the recruitment process. They are informed at the outset that they have the opportunity to discuss criminal convictions, ‘spent’ or ‘unspent’, in confidence with a HR representative and/or Senior Leadership Team (SLT) member.
All posts at Warwickshire Institute of Sport fall into the category where they require either a Standard or Enhanced Disclosure check as set out within our DBS Policy. Therefore, anyone who applies to work at Warwickshire Institute of Sport will be expected to declare any convictions ‘spent’ or ‘unspent’ and will be subject to consideration of suitability for appointment in accordance with our policies and procedures.

Data Protection

When collecting, storing and analysing data, a full account must be taken of the Data Protection Act 1998. Therefore it is imperative to ensure that personal data collected is used appropriately in accordance with the Act. Our General Data Protection Regulation Policy (GDPR) outlines all policy and processes.

Work Life Balance

The Employment Relations Act 1999 and the subsequent Employment Act 2002 (which introduced new changes to the former), allow for greater flexibility in the workplace.

Maternity (if applicable)

Warwickshire Institute of Sport administers not only a statutory maternity scheme but also an occupational maternity scheme.

Paternity Leave (if applicable)

To be entitled, you must have worked for Warwickshire Institute of Sport for 26 weeks or more by the 15th week before the child is expected to be born. You will be eligible for 2 weeks in a 1 or 2 weeks block at any one time. The entitlement to pay is 2 weeks’ full pay if you meet the requirements.

Adoption Leave

There is no length of service requirement for staff to be entitled to adoption leave.

Recruitment and Selection

Warwickshire Institute of Sport has a Safer Staff Recruitment Policy which sets out the procedure to be followed. Vacant posts are advertised in a number of ways to attract a wide variety of applicants.

Monitoring and Reviewing

The effectiveness of this policy will be reviewed through:

• Regular analysis of student participation, retention, achievement, success and progression.
• Regular analysis of the staffing profile in relation to recruitment, staff turnover, retention and levels of responsibility.
• Regular analysis of access to professional development opportunities and to promotion for staff in minority groups.
• Self-assessment and quality improvement structures for all curriculum and service areas.

Management Responsibilities

The Managing Director of Warwickshire Institute of Sport will take responsibility for ensuring that the principles outlined in this policy will be integrated throughout their strategic and operational decision making process.

The Managing Director and SLT members will monitor their performance against the standards set out in this policy and according to the relevant legislation. They will set agreed annual targets for improvement, which will be monitored by the Directors.

The Managing Director of Warwickshire Institute of Sport will ensure that staff employed by Warwickshire Institute of Sport have access to regular mandatory training opportunities to ensure that they understand the principles implicit within this policy and the relevant legislation.

Breaches of the policy by staff or students will be regarded as misconduct and in some cases gross misconduct and therefore could potentially lead to disciplinary action.

Appendices

Appendix A: Definitions of Discrimination

Discrimination can occur either directly or indirectly. Direct discrimination cannot be legally justified and individuals can be held personally liable by tribunals and/or other UK/EU courts.

Direct Discrimination occurs when a person is treated less favourably than others would be treated in the same circumstances on the grounds of having a protected characteristic.

Indirect Discrimination occurs when applying a provision, criterion or practice which puts someone from a particular group having one or more protected characteristics at a particular disadvantage. Indirect discrimination may only be justified in exceptional circumstances if it can be shown that the action was reasonable in managing the business or organisation, i.e. that it is “a proportionate means of achieving a legitimate aim”. A legitimate aim might be any lawful decision made in running the business or organisation, but if there is a discriminatory effect, the sole aim of e.g. reducing costs is likely to be deemed unlawful. In this context, being proportionate means being fair and reasonable, including showing e.g. that ‘less discriminatory’ alternatives to any decision made have been considered, documented and recorded.

Discrimination by Association is direct discrimination against someone because they associate with another person who possesses one or more protected characteristic. For example, disability discrimination against someone who is a carer of a disabled dependant.

Discrimination Linked to a Perceived Characteristic is direct discrimination against an individual because of a belief that they possess a particular protected characteristic. It applies even if the person does not actually possess that characteristic, for example, discrimination against someone because they are thought to be gay but are not.

Harassment is defined as being “unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual”. Employees are able to complain of behaviour that they find offensive, even if it is not directed at them and the complainant need not possess the relevant characteristic themselves.

Victimisation takes place where one person treats another less favourably because he or she has asserted their legal rights in line with the Equality Act (2010) or helped someone else to do so. This includes making a complaint, taking legal action, providing evidence related to proceedings or alleging that discrimination has taken place. Victimisation may occur if, for example, a student alleges that they have encountered racism from a tutor, and as a result they are ignored by other staff members. An employee is not protected from victimisation if they have maliciously made or supported an untrue complaint.

Genuine Occupational Requirements – Under current legislation, certain jobs/roles may be restricted to a particular characteristic if the characteristic is a “genuine occupational requirement” (GOR) for the job, or for the context within which it is carried out. However, the circumstances in which this applies are very limited and would be exceptional at Warwickshire Institute of Sport.

Location and Access to this Policy.

This policy will be accessible through contacting Warwickshire Institute of Sport via: enquiries@warksis.ac.uk

Policy here.

Statement

Warwickshire Institute of Sport is fully committed to protecting the personal data of students, employees, suppliers and other stakeholders in accordance with the requirements of the European Union Data Protection Regulations 2016.

Purpose

The purpose of this policy is to protect the “rights and freedoms” of natural persons (i.e. living individuals) and to ensure that personal data is not processed without their knowledge, and, wherever possible, that it is processed with their consent. All processing of personal data must be conducted in accordance with the data protection principles as set out in Article 5 of the GDPR. Warwickshire Institute of Sport’s policies and procedures are aligned to ensure compliance with the principles.

Procedures

Whose Data We Hold

At Warwickshire Institute of Sport, to enable our company to carry out the processes required to operate, we hold personal data. Through our secure systems, we may hold data on the following individuals:

• Current Students (enrolled)
• Prospective Students
• Carefully selected Third Parties
• Staff
• Suppliers

The above list is not exhaustive and may be amended to during the review process. A detailed list can be found within our Data Flow Chart.

What Data We Hold

In order for us to provide our services and to manage those services we will ask prospective and existing students and/or clients to share personal information with us. The circumstances in which we use the information, the reasons why we ask for it and details of how we will use it are explained within this policy.

The information we collect about students and clients varies depending on particular circumstances and requirements and may include, for example:

• General information about the student
• Full Name
• Address
• Contact details
• National Insurance Number
• Date of Birth

This can be used to confirm ESFA eligibility for funding.

Financial details, such as bank account details, can be used to pay employer incentive payments.

For Warwickshire Institute of Sport staff members, sensitive personal information, such as:

• Disclosure and Barring Service (DBS) Checks
• Information about the client’s website such as the IP address (unique number identifying the computer)
• Address
• Personal Contact Details
• Previous Employment History
• Financial Information (Bank Account Details)

We may collect personal information from the following sources:

• A client or someone connected as part of a tender opportunity
• Publicly available sources of information, such as social media and networking sites.

If our clients have provided information to us about someone else, we will confirm to them that they have the consent of these individuals to share their personal information with us.

Where The Data Is Stored

Our data is stored within our secure, online platform, that underpin our robust and reliable information security management systems. The following data is stored on the below software systems.

Current Student Information	Google Suite (G Suite)	Double Password Authentication Requirement
Staff Information	BambooHR | Sentry (SCR)	Password Protected and Regular Password Changes
Prospective Student Information	Active Campaign (CRM)	Password Protected and Regular Password Changes
Third Party Information	Active Campaign (CRM)	Password Protected and Regular Password Changes

Paper based data may also be stored within secured filing cabinets at our Head Office with access given to approved staff members only.

Our service providers may use cloud-based computer systems (i.e. network of remote servers hosted on the internet which process and store your information) to which foreign law enforcement agencies may have the power to require access.

Our contracts with these firms will detail the necessary requirements to ensure your information is protected. We will assess these firm’s security arrangements from time to time ensuring that they are only using your information as agreed.

The personal information we and our carefully selected third parties collect will not be transferred to, stored and processed outside the European Economic Area (EEA).

What The Data is Used For and Who is it Shared With

We and/or our carefully selected third parties may collect and use personal information under the following circumstances or for the following reasons:

• To provide services relating to training such as our programmes for young people
  • Assessing the ESFA eligibility criteria for attracting government funded programme
  • Providing the services described within student and employer documents
  • The collection and use of information such as the students name, address, date of birth, is necessary to establish funded payments.
  • Without this information, we will be unable to assess the eligibility of the student.
• Where we have a justifiable reason, such as:
  • Keeping records about the student and our correspondence with them. This also means we can appropriately and effectively manage our relationship with the student as well as satisfy any legal and regulatory obligations we may have to keep such records.
  • Preventing and detecting fraud, financial crime and anti-money-laundering. We may use the personal information to prevent fraud and in doing so may:
    • Collect personal information about the students from databases as described within our Privacy Notice and from publicly available sources (such as social media and networking sites);
    • Share the personal information with fraud prevention agencies. The personal information will be checked with and recorded by a fraud prevention agency. If false or inaccurate information is provided and fraud is identified, details will be passed to the fraud prevention agency.
    • Share the personal information with operators within the government-run organisations such as the ESFA and Ofsted;
    • We may anonymise and combine the information the student has given us to understand more about them, create new products and services as well as helping us with our marketing.
• Where we have been given permission:
  • To use your sensitive personal information in order to provide you with a qualification certificate or funding incentives
  • We may share information with third parties in order to carry out the above activities.

The Legal Bases for Processing

All data that is processed within Warwickshire Institute of Sport is done so on a necessary basis in order to service student and trusted third party requests. We will legally process the data on a ‘legitimate interest basis’ for the sole purpose of providing the student with details of training programmes, qualification details and funding eligibility.

We will contact them, in order to communicate our products and/or services which we believe may be of interest to them and which relate to your general training and development needs. This activity is only applicable to Warwickshire Institute of Sport.

There may be times when we will require the permission to provide information about products and services to such as:

• Where the product or service is not similar to those that we currently provide to the student, but we believe they may be interested in it; or
• When the student and client has opted out of us sending details of or contacting them in relation to the products and services we offer.

We may communicate by post, email, SMS, telephone and/or digital methods such as social media and online advertising unless it has been made clear that the recipient does not want us to.

Where the student is no longer enrolled on an ESFA funded programme with us or we have provided them with training in the past, we will keep them informed about our products and services for a period of up to 3 years if contacting them by telephone or for up to 5 years if contacting you via other means.

We may look to develop and enhance the information we hold about students and clients with the aim of improving our product and service offerings and how we communicate these to them, where they have given us permission or where we believe that our products and service may be of interest.

We may collect personal information about them or share the information with carefully selected third party databases which, when combined with the personal information you have given us, helps us to target and tailor communications which we believe may be more relevant.

Details of these Third Parties can be found on our Data Flow Chart within this policy.

Privacy Notice

A student can request a paper copy of this from our office by contacting our Data Controller or visiting our website using the link below.

https://warksis.ac.uk/policies/ 

A copy should be read together with this GDPR policy.

The GDPR includes provisions that promote accountability and governance. These complement the GDPR’s transparency requirements. The accountability principle in Article 5(2) requires demonstration and compliance with the principles and states explicitly that this is your responsibility.

Accountability

The General Data Protection Regulation (GDPR) includes provisions that promote accountability and governance. These complement the GDPR’s transparency requirements.

The accountability principle in Article 5(2) requires a demonstration that there is compliance with the principles of which it is stated explicitly that this is your responsibility.

Warwickshire Institute of Sport will demonstrate compliance with the data protection principles by implementing data protection policies, adhering to codes of conduct, implementing technical and organisational measures, as well as adopting techniques such as data protection by design, DPIAs, breach notification procedures and incident response plans.

There are eight key data protection principles. These principles state that personal data must:

• Be fairly and lawfully processed
• Be processed for limited purposes and not in any manner incompatible with those purposes
• Be adequate, relevant and not excessive
• Be accurate
• Not be kept for longer than is necessary
• Ne processed in accordance with individuals’ rights
• Be secure
• Not be transferred to countries without adequate protection

Within certain departments, there may be additional specific rules in place, and it is important that these are familiar before handling personal data.

Data Retention

We will keep your information only for as long as is reasonably necessary for the purposes set out in our privacy notice and to fulfil our legal and regulatory obligations. The table below outlines the data retention period for documentation purposes that Warwickshire Institute of Sport will hold.

Application Form	Duration of employment/Programme of Study
References received	1 year
Payroll and tax information	6 years
Sickness records	3 years
Annual leave records	2 years
Unpaid leave/special leave records	3 years
Annual appraisal/assessment records	5 years
Records relating to promotion, transfer, training, disciplinary matters	1 year from end of employment
References given/information to enable references to be provided	5 years from reference/end of employment
Summary of record of service e.g. name, position held, dates of employment	10 years from end of employment
Records relating to accident or injury at work	12 years

For further information about how long we will keep your information, please contact the Data Controller using the contact details outlined in the data controller section of this notice.

Amendments to Data and Data Deletion Subject Access Requests

We will review all data that we hold for students on an annual basis.

Should you require access to the information that we hold, students must contact our data controller, Daniel Holloway. All requests must be made in writing or by email to enquiries@warksis.ac.uk

We are unable to release information to which would lead to a data breach of another individual. The release of information will be processed without charge. However, should we find that the request for information is manifestly, unfounded or excessive we reserve the right to issue a charge for this information or refuse to provide the information requested.

Amendments To Data

The data that we hold will come from information we have obtained directly from the student and/or a family member/carer with their consent or available in the public domain. The student can amend the information that has been given by them to Warwickshire Institute of Sport by speaking to our staff members. Should they wish to amend the information that we have obtained from the sources detailed in our data flow chart, they would need to contact these persons/organisations directly to amend their data. For example, if our DBS Checking has an incorrect address, we would be unable to amend this and the request to amend the data should be directed to dbscheckonline.org.uk, our external DBS Provider.

Data Deletion

The information that we hold within our client and student files can be deleted, at their request, by contacting our Data Controller if suitable within our legal and regulatory obligations. This request should be made in writing either by letter or email. All personal information will be removed from the paperwork and it will be scanned to our system. The contents of the file will be deleted completely from our systems. The deletion letter will sit within your file, which notes only the student name. This will allow us to keep a note of the deletion however no personal information will be sorted.

With regards to documentation, in certain circumstances we may be required to retain information
to allow Warwickshire Institute of Sport to be able to provide proof of training and learning. In this instance we will notify the student of the information that we require to retain and why this is required.

All requests for data access, amendment or deletion will be dealt with within 28 days as required by the ICO (Information Commissioner’s Office).

Data Controller

Our Data Controller is Daniel Holloway and can be contacted on the details below

Email: enquiries@warksis.ac.uk
Phone: +44 (0)24 7524 0360

Data Breaches

A Data Breach, as defined by the Information Commissioner’s Office (ICO), is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.

Any Data Breach will be reported to Daniel Holloway, Data Controller, upon discovery.

Steps will then be taken to establish the below;

• The categories of data that have been breached
• The individuals that may have been affected
• A description of how the breach may affect the individuals
• The details of our Data Controller
• Details on how the breach has been rectified or the steps that we plan to take to rectify

Warwickshire Institute of Sport will report any breach to the ICO where as a result of the above any actions could lead to an individual’s rights and/or freedoms being affected. All breaches will be reported to the ICO within 72 hours of the discovery of the breach.

A log is kept internally of any data breaches, reportable to the ICO or otherwise, which will be made available to the ICO on request for audit purposes. Where we have not reported a breach, an explanation will be kept as to why this decision has been made. Where a breach is considered ‘high risk’ to a person’s rights and freedoms, we will notify the individuals concerned without undue delay.

Individual Responsibilities

All individuals are responsible for the correct treatment of any personal data that they come into contact in the course of their role. If there is any doubt about how a piece of personal data can, or should be handled, please seek advice from your senior leader and/or manager. If they are unavailable, you must not disclose any information until you are clear as to whether or not you should.

Any breaches of this policy will be fully investigated, and may be dealt with under the Company Disciplinary Policy, and may be treated as gross misconduct.

Location and Access to this Policy.

This policy will be accessible through contacting Warwickshire Institute of Sport via: enquiries@warksis.ac.uk 

Warwickshire Institute of Sport has a staged complaints procedure which aims to resolve concerns swiftly and fairly.

The purpose of the procedure is to investigate complaints in a way that: 

• Encourages informal resolution of issues and concerns if possible
• Is fair and equitable
• Treats complaints with appropriate seriousness 

Scope & Responsibility.

This procedure covers complaints relating to:

• Any policy obtained by Warwickshire Institute of Sport, procedure or process
• Academic and support services
• The conduct or actions of a college member of staff
• Misleading or inaccurate information regarding academic programmes, fees or services

This procedure is not used for:

• Complaints about academic judgements, examination decisions, academic appeals or assessment outcomes
• Appeals against disciplinary actions

It is the responsibility of all members of staff to ensure that the procedure is adhered to within the stages and timelines.

Definitions.

Warwickshire Institute of Sport uses the following definitions specific to this procedure: 

• A complaint is the expression of a specific concern 
• ‘Days’ refers to Monday – Friday within academic term time
• Timescales specified will be adhered to wherever possible but may be extended during academic holiday periods. On these occasions the complainant will be notified.

Procedure.

• Complaints should be made as soon as possible after the events or actions (or lack of actions) which have prompted the complaint. Warwickshire Institute of Sport will not normally consider complaints that are made more than one calendar month after the incident or event complained about. In exceptional circumstances, a complaint may be considered outside this timeline 
• A complainant may be invited for a meeting as part of any investigation relating to the complaint and may be accompanied by a parent/carer, employer or other representative. Details of any support needs will need to be declared prior to any meeting
• The business will make reasonable adjustments, where necessary, to ensure that the complaints procedure is fair, equitable and accessible to all 
• Where it is inappropriate or not possible for a student or other stakeholder to make a complaint, this may be done on their behalf by another person, who has a legitimate interest in the complaint and has the complainant’s knowledge and written consent. That interest must be made clear to Warwickshire Institute of Sport

Stage One – Informal.

Every attempt should be made to resolve any complaint on an informal basis in the first instance. Learners should discuss the issue with an appropriate member of staff who may be connected with the complaint. If this is not possible, it may be discussed with any of the following: 

• Academic Tutor 
• Programme Area Leader / Curriculum Manager 
• Academy Manager

Any potential concern by an employer or other stakeholder should be raised in the first instance with the relevant manager for the area or service concerned.

All members of staff dealing with any informal complaint must endeavour to resolve the issue within 10 working days. If longer time is needed, this should be communicated to the complainant and the agreed outcome logged in relevant documents, in order to ensure that a record is maintained.

Stage Two – Formal.

A complaint may be progressed to Stage Two if it has not been possible to resolve the issue informally.

Stage 2 complaints must be made in writing to enquiries@warksis.ac.uk, identifying, where possible; 

• The nature of the complaint
• If appropriate, the individual against whom the complaint is being made
• Independent evidence supporting the case 
• An indication of the action sought from the business

The complaint will be logged and acknowledged within five working days.

An appropriate manager will be appointed by the Director to investigate the complaint. The complainant will be informed of the progress of the investigation at key points throughout the process. 

The outcome of the complaint will be communicated in writing within 10 working days of the date of acknowledgement unless previously stated otherwise. If more time is needed to investigate the complaint, the complainant will be informed and given a revised deadline. 

The outcome from the investigation and proposed response will be sent to the Director for approval, before responding to the complainant. All correspondence relating to a formal complaint at Stage Two must be logged and stored centrally. 

The response must include one of the following decisions: 

• Dismissal of the complaint as unfounded 
• Determination that the complaint is trivial and that no further action be taken 
• Proposal of a resolution to the complaint 

Stage Three – Appeals.

A complainant may appeal the outcome of Stage Two within 10 days. The appeal should clearly state the reasons for the appeal, which may be that: 

• There is a procedural irregularity in the conduct of the complaint investigation
• There is new evidence to support the complaint that can be substantiated, including extenuating circumstances, which were not known at the time, and may have affected the outcome had it been known and there is valid reason for not making it known at the time 

An appeal should be sent to the Director by emailing enquiries@warksis.ac.uk. A response will be issued within 10 working days, where possible. 

The Director will appoint an independent person to review the complaint, and once the investigation has been completed, a report and its findings will be forwarded to the Director for approval. 

The Director will make a decision as to the final outcome of the appeal and recommendations if any. This will be communicated in writing to any parties involved. 

This is the final stage of the Complaints Procedure. 

External Appeal.

If a complaint remains unresolved after appeal, Warwickshire Institute of Sport can provide the appropriate external contact, in order for an external appeal to be made. 

Contact should be made to enquiries@warksis.ac.uk for relevant details. Before this is done, all stages of the Complaints Procedure must have been exhausted.

Contact Information.

Students can take advice and support from Warwickshire Institute of Sport either prior to making a complaint or during the complaints process at: 

Westwood Campus, University of Warwick, Coventry, Warwickshire, CV4 8AH

T: +44 (0)24 7524 0360

E: enquiries@warksis.ac.uk

Location and Access to this Policy.

This policy will be accessible through contacting Warwickshire Institute of Sport via: enquiries@warksis.ac.uk