Anti-slavery and human trafficking policy
Policy Statement This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers. PR Agency One Ltd strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain.
We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains.
We expect that our suppliers will hold their own suppliers to the same high standards. Commitments Modern Slavery and Human Trafficking Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking.
Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
Commitments
We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
- We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
- The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
- We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
- We take a risk based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
- Consistent with our risk based approach we may require:
- employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct
- Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code
- As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
- If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action.
This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships
Issued By James Crawford, managing director
. When printed, uncontrolled copies must be disposed of after use, unless required as a formal record. Controlled copies must be returned to the controlled copy file.
Corporate Social Responsibility Policy
We believe that a commitment to the principles of corporate social responsibility (CSR) not only makes good business sense but also complements our core business strategy and corporate values. Our policy is based on the following principles:
- To minimise the impact and maximise the benefits that our work has on the environment and people around us.
- To integrate our CSR considerations into all our business decisions.
- To comply with, and exceed where practicable, all applicable legislation, regulations and codes of practice.
- To review, annually report, and to continually strive to improve our CSR performance.
In developing our strategy and setting out our policy for the first time we aim to deliver gradual but continuous improvements in our performance every year. As a result, our approach continues to evolve as we learn lessons along the way.
PR AGENCY ONE DATA PROTECTION POLICY FOR GDPR
DATA PROTECTION POLICY
PR Agency One Ltd (herein referred to as “the business”) has a data protection policy and a Data Protection Controller (DPC), named as James Crawford
General Statement of the business’s Duties and Scope
The business is required to process relevant personal data regarding members of staff, volunteers, and customers as part of its operation and shall take all reasonable steps to do so in accordance with this Policy.
Data Protection Controller
The business has appointed the Managing Director as the Data Protection Controller (DPC) who will endeavour to ensure that all personal data is processed in compliance with this Policy and the Principles of the Data Protection Act 1998. The Freedom of Information Act 2000 and the Protection of Freedoms Act 2012 are also relevant to parts of this policy. The business recognises The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) adopted 27 April 2016, the two-year transition period and the application date of 25 May 2018 and is actively working towards compliance with that directive.
The Principles
The business so far as is reasonably practicable complies with the Data Protection Principles (the Principles) contained in the Data Protection Act to ensure all data is:-
- Fairly and lawfully processed
- Processed for a lawful purpose
- Adequate, relevant and not excessive
- Accurate and up to date
- Not kept for longer than necessary
- Processed in accordance with the data subject’s rights
- Secure
- Not transferred to other countries without adequate protection
Definitions
- The business is ‘PR Agency One Ltd’.
- Data Subject, an individual who is the subject of the personal data.
Personal Data
Personal data covers both facts and opinions about an individual where that data identifies an individual. For example, it includes information necessary for employment such as the member of staff’s name and address and details for payment of salary. Personal data may also include sensitive personal data as defined in the Act.
Processing of Personal Data
Consent may be required for the processing of personal data unless processing is necessary for the performance of the contract of employment. Any information which falls under the definition of personal data and is not otherwise exempt, will remain confidential and will only be disclosed to third parties with appropriate consent.
Use of those services indicates acceptance and may grant additional consent as to how the business may process personal data. The business processes some personal data for direct marketing and fund-raising purposes, data subjects have the right to request an opt-out to these activities, which must be respected.
Sensitive Personal Data
The business may, from time to time, be required to process sensitive personal data. Sensitive personal data includes data relating to medical information, gender, religion, race, sexual orientation, trade union membership and criminal records and proceedings.
Rights of Access to Information
Data subjects have the right of access to information held by the business, subject to the provisions of the Data Protection Act 1998 and the Freedom of Information Act 2000. Any data subject wishing to access their personal data should put their request in writing to the DPC. The business will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event, within 40 days for access to records and 21 days to provide a reply to an access to Data Protection Policy Lent 2017 3 information request. The information will be imparted to the data subject as soon as is reasonably possible after it has come to the business’s attention and in compliance with the relevant Acts.
Exemptions
Certain data is exempted from the provisions of the Data Protection Act which includes the following:-
- National security and the prevention or detection of crime
- The assessment of any tax or duty
- Where the processing is necessary to exercise a right or obligation conferred or imposed by law upon the business, including Safeguarding and prevention of terrorism and radicalisation
The above are examples only of some of the exemptions under the Act. Any further information on exemptions should be sought from the DPC.
Accuracy
The business will endeavour to ensure that all personal data held in relation to all data subjects is accurate. Data subjects must notify the data processor of any changes to information held about them. Data subjects have the right in some circumstances to request that inaccurate information about them is erased. This does not apply in all cases, for example, where records of mistakes or corrections are kept, or records which must be kept in the interests of all parties to which they apply.
Enforcement
If an individual believes that the business has not complied with this Policy or acted otherwise than in accordance with the Data Protection Act, the member of staff should utilise The business grievance procedure and should also notify the DPC.
Data Security
The business will take appropriate technical and organisational steps to ensure the security of personal data.
All staff will be made aware of this policy and their duties under the Act.
The business and therefore all staff and pupils are required to respect the personal data and privacy of others and must ensure that appropriate protection and security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to all personal data.
An appropriate level of data security must be deployed for the type of data and the data processing being performed. In most cases, personal data must be stored in appropriate systems and be Data Protection Policy Lent 2017 4 encrypted when transported offsite. Other personal data may be for publication or limited publication within the business, therefore having a lower requirement for data security.
External Processors
The business must ensure that data processed by external processors, for example, service providers, Cloud services including storage, web sites etc. are compliant with this policy and the relevant legislation.
Secure Destruction
When data held in accordance with this policy is destroyed, it must be destroyed securely in accordance with best practice at the time of destruction.
Retention of Data
The business may retain data for differing periods of time for different purposes as required by statute or best practices, individual departments incorporate these retention times into the processes and manuals. Other statutory obligations, legal processes and enquiries may also necessitate the retention of certain data.
The business may store some data such as data capture, photographs, achievements, books and works etc. indefinitely in its archive.
Ethics and Anti-Bribery Policy
About Our Policy
It is the stated and publically declared policy of the company to conduct all of our business in an honest and ethical manner.
The company will take a zero-tolerance approach to bribery and corruption. The company is committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.
This policy does not form part of any employee’s contract of employment and we reserve the right to amend or modify it at any time without prior notification.
As with all our policies the company will regularly review this policy to ensure it remains pertinent, relevant and enforceable.
Within the Organisation – who must comply with this policy?
This policy applies to all persons working for PR Agency One Ltd or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
The definition of bribery?
Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way.
Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
– Bribery includes offering, promising, giving, accepting or seeking a bribe.
– All forms of bribery are strictly prohibited.
– Specifically, our rules of engagement include
- Employees must not give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
- Employees may not accept any offer from a third party that is known or suspected to have been made with the expectation that a business advantage will be forthcoming
- Employees may not give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure.
– Employees must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
Gifts and hospitality
– This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
– A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
– Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in the name of the company and never in the name of an individual be they directly employed, associated with or connected to the company in any way.
– Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.
Record-keeping
– Employees must declare and keep a written record of all hospitality or gifts given or received. Employees must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with the company’s expenses policy and record the reason for expenditure.
– All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.
How to raise a concern
If an employee or associate is offered a bribe, or are asked to make one, or if the employee and/or associate suspects any bribery, corruption or other breach of this policy has occurred or may occur, the Employee and/or the associate must notify one of the Company Director’s as to the possible breach, as soon as possible.
