Complete Complex Care Slavery Human Trafficking Statement
DEFINITIONS
The Company refers to Complete Complex Care.
Complete Complex Care considers that modern slavery encompasses:
- Human trafficking.
- Forced work, through mental or physical threat.
- Being owned or controlled by an employer through mental or physical abuse or the threat of abuse.
- Being dehumanised, treated as a commodity or being bought or sold as property.
- Being physically constrained or to have restriction placed on freedom of movement.
COMPLETE COMPLEX CARE LTD COMMITMENT
- Complete Complex Care Ltd acknowledges its responsibilities under the Modern Slavery Act 2015 and is committed to preventing slavery and human trafficking within its own businesses and in its supply chains. The company understands that this requires an ongoing review of both its internal practices in relation to its labour force.
- The company has a zero-tolerance policy towards modern slavery. It will refrain from entering into business, and/or will discontinue any current business with any other organisation which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
- No labour provided to Complete Complex Care in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.
- Complete Complex Care offers employment contracts on a guaranteed hours basis only; no offers of employment are made on a zero-hour basis.
- Part-time and fixed-term employees within the company are provided with the same pro-rata contractual entitlements as full-time and permanent employees. If these are not offered, The Group is able to rely on objectively justifiable grounds.
- Group employees are offered a competitive remuneration package and the company prides itself on the additional benefits it is able to offer its employees on a wide variety of platforms. It conducts staff surveys on an anonymous basis to give employees a voice on their individual employment, their department and the company as appropriate. Commitment to creating career progression in a supportive environment has been rewarded by high placings for complete Complex Care Limited in well regarded “Best Places to Work” awards.
POTENTIAL EXPOSURE
- The company considers its exposure to modern slavery to be limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
- In the operation of its business, the company’s main supply chains are those related to the provision of services. The company considers its main exposure to the risk of slavery and human trafficking to exist in its supply chains.
STEP
- The Company carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its supply chains.
- The Group has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with slavery and/or human trafficking.
- In accordance with section 54(4) of the Modern Slavery Act 2015, the company has contacted (or attempted to contact) all first tier suppliers to set out our zero-tolerance stance on modern slavery and to ensure that slavery and/or human trafficking is not taking place.
- The company will seek to discontinue business with any first-tier supplier found by the enforcement authorities to be involved in modern slavery.
- The Company encourages use of its whistleblowing policy to report any concerns regarding modern slavery and will investigate any complaints thoroughly.
TRAINING
Upon commencement of employment, all employees undergo a structured induction process. All employees are made aware of the company policies relating to standards of behaviour that it requires from them. In its statement for the previous financial year, the company set itself a target of ensuring that 100% of new starters would complete the induction within two weeks of commencement of employment, of which 99% did complete within this target.
The Company also provides training on awareness of modern slavery to those within the company who have been identified as having responsibilities in this regard, namely those involved in finance and procurement. The company ensures that annual update training is provided.
ASSESSMENT OF EFFECTIVENESS IN COMBATTING MODERN SLAVERYTo ensure effectiveness in combatting modern slavery, the company maintains an accurate supplier list including contact details. It will ensure action is taken in response to reports of modern slavery in its supply chains and any complaints made via the whistleblowing policy will be responded to in accordance with the policy.
POLICIES
The Company a has a Whistleblowing policy is in place which encourages the reporting of any wrongdoing which is in the public interest.
The Company DATA PROTECTION & COMPLIANCE Team
The Company has a Group Data Protection & Compliance team, to whom all concerns regarding modern slavery should be addressed. The Company Data Protection & Compliance team undertakes an annual review of the company obligations towards eradicating modern slavery within its organisation and supply chains.
REVIEW
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2010 and applies to Complete Complex Care Ltd. It will be reviewed each financial year.
GDPR Compliance Statement
Complete Complex Care Ltd — GDPR Compliance Statement
Commitment
We are committed to the principles inherent in the GDPR and particularly to the concepts of privacy by design, the right to be forgotten, consent and a risk-based approach. In addition, we aim to ensure:
- transparency with regard to the use of data.
- that any processing is lawful, fair, transparent and necessary for a specific purpose.
- that data is accurate, kept up to date and removed when no longer necessary.
- that data is kept safely and securely.
Staffing
Our Data Protection Officer (DPO), who works to promote awareness of the GDPR Complete Complex Care Ltd. Our DPO oversees the company’s commitment to best practice and inform and advise the Group and monitors compliance.
Policy
Our privacy policy is available on our website and a copy has been made available to all employees and to contractors and suppliers associated with this organisation. It forms part of the induction training of all new staff and follow-up sessions will be put in place if the legislation changes or further guidance is available.
Right to be forgotten
We recognise the right to erasure, also known as the right to be forgotten, laid down in the GDPR.
Subject access requests
We recognise that individuals have the right to access their personal data and supplementary information and will comply with the one-month timeframe for responses set down in the GDPR. As a general rule, a copy of the requested information will be provided free of charge although we reserve the right to charge a “reasonable fee” when a request is manifestly unfounded or excessive, particularly if it is repetitive. If this proves necessary, the data subject will be informed of their right to contest our decision with the supervisory authority (the Information Commissioner’s Office (ICO)).
As set out in the GDPR, any fee will be notified in advance and will be based on the administrative cost of providing the information.
Data transfers outside the EU
We have put recognised procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of any personal data that is transferred to countries outside the EU. Diligence checks are carried out to ensure that such countries have the necessary safeguards in place, provide enforceable data subject rights and offer effective legal remedies for data subjects where applicable.
Children
The GDPR provides for special protection for children’s personal data and we will comply with the requirement to obtain parental or guardian consent for any data processing activity involving anyone under the age of 16. Systems have been introduced to verify individuals’ ages.
Data loss
If a data breach occurs that is likely to result in a risk to the rights and freedoms of individuals, the people affected will be informed as soon as possible and the ICO will be notified within 72 hours.
Complaints Procedure
Complete Complex Care is committed to providing an efficient and reliable service for its clients. In order to achieve this, Complete Complex Care keeps up to date with technology and employs dedicated well trained staff.
On the rare occasions that any part of our service does not meet your expectations, we have implemented a procedure designed to minimise the inconvenience to our clients and to resolve any complaint in a speedy and satisfactory manner. It is the policy of Complete Complex Care that all complaints are taken seriously and are dealt with in a uniform way.
As a Complete Complex Care client, you will receive acknowledgment from the recipient of the complaint within 2 working days. A proposed resolution to the complaint will be issued to our clients within 10 working days (or 20 working days if it’s a particularly complex or technical response). If, for any reason, there is an unavoidable delay in issuing a response to the complaint, the client will be informed, and a new deadline issued/agreed.
All complaints will be dealt with by our manager on receipt of your complaint. If clients have questions, queries or if they wish to enquire about the progress of a complaint, they can contact the manager.
Should any client be dissatisfied with the handling of a complaint at any time, they should escalate the matter to Care Inspectorate Complaint team where necessary.
Privacy Policy
Complete Complex Care Privacy Policy
PRIVACY NOTICE FOR WEBSITES – GDPR-COMPLIANT WEB VISITORS.
This privacy policy explains how personal data is collected and used when you engage with Complete Complex Care website. It also explains how we process any data that you supply to us on our website.
Complete Complex Care is the Data Controller for any personal data that you supply to us when you engage with us via our website.
What personal data do we collect?
The personal data collected depends on how you use our website. You can browse the site, you can fill in forms on the website to request information or quotes from us, download documents from us, or you can subscribe to our emails, and other activities. Our website collects personal data to provide these services.
What we do with your personal data?
When you visit our website, a record of your visit is made. This data includes your device’s IP address. That data is used completely anonymously, in order to determine the number of people who visit our website and the most frequently used sections of the site. This enables us to continually update and refine the site. If you use any forms on the website to send an email to us, a record will also be made of your name, company name, postal address, email address and your telephone number and any other information you provide.
The following table sets out how we handle your personal data and our legal basis for doing so under GDPR and the Data Protection Act 2018.
What we do | Our legal basis under GDPR |
Use the personal data that you provide on our web forms and questionnaires. | Article 6(1)(b) – when you provide us with your personal data, for instance to obtain a quote for our services, this is a necessary step to take at the request of the data subject prior to entering into a contract. |
Contact you regarding the services we provide. | Article 6(1)(f) – we need to contact you for our legitimate interests so that we can gather more information for the provision of our services, or to deliver those services most effectively. |
Retain your data under our data retention policy. | Article 6(1)(f) – we need to retain your personal data for only as long as necessary under the law to protect our legitimate interests. |
Obtain analytical website usage and data on the devices used by our website visitors. | Article 6(1)(f) – analytical data is obtained by cookies. This data is used to monitor the performance of our website, to improve the website and the services that we offer on our website. This processing is necessary for the purposes of our legitimate interests. |
The following table sets out the categories of personal data that we obtain.
Personal Data | Explanation |
Filling in forms on the website – examples include name, company name, email address, job title, telephone number, postcode. | This data is provided by you on our web forms and questionnaires, either to obtain a quote from us, subscribe to one of our newsletters or marketing communications, request a service from us or as part of the provision of your existing contractual services. |
Location data, IP address online identifier, website analytics. | This data is captured via cookies that are placed on your device, which capture information about the device you are using, cookie identifiers, advertising IDs, and other information. To block cookies, you can manually delete them from your browser’s settings page, and you can also configure your browser to block third party cookies. |
If you no longer wish to receive information about our services, our communications have an unsubscribe option and often a manage your preferences link.
Will we share your data?
Your personal data may be shared on a confidential basis to companies within Complete Complex Care in the UK. It may also be provided to third parties, such as law enforcement, regulatory authorities or where we are legally obliged to share the information.
Where we use data processors who are third parties, we have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period that we instruct.
How long we keep your personal data.
Personal data is retained in line with our data retention policy. The Company keeps most data for 7 years, which covers the 6 years by law in which we must keep certain information for a minimum of 6 years plus the current year. Personal data that is no longer necessary to be kept under the Group’s data retention policy will be deleted. Under the Group’s data retention policy, there are certain exemptions in relation to financial data and health data. A copy of the Group’s data retention policy can be made available upon request.
Your Rights
You have the following rights in relation to personal data held on you by Complete Complex Care:
The right to be informed about how personal data is used (this notice).
The right to access a copy of personal data that the Company holds about you.
The right to rectification of any errors in personal data held by Complete Complex Care.
The right to erasure of any personal data.
The right to restrict processing.
The right to data portability
The right to object.
Rights in relation to automated decision-making including profiling.