my company

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my company

24 May 2023


  • Communications policy
  • Disciplinary and dismissal procedure policy
  • GDPR Policy
  • Grievance procedure

Communications policy


    1. The Employer expects all its electronic and computer facilities to be used in an effective and professional manner and encourages all employees to develop the skills necessary to do so. These facilities are provided by The Employer at its own expense for its own business purposes to assist its employees in carrying out their duties effectively. It is the responsibility of each employee to ensure that this technology is used for proper business purposes and in a manner that does not compromise The Employer or its employees in any way.
    2. This policy applies to the use of The Employer’s technology whilst at work and also when using The Employer’s technology from outside work e.g., when dialling in from home or using a laptop when away on business. This policy document is to be read in conjunction with the disciplinary procedure. If you have any questions about the application of this policy, please contact your line manager.
    3. Misuse of the internet or email can expose both employees and The Employer to legal or financial liability. For example, employees may enter into unintended contracts, breach copyright or licensing arrangements, incur liability for defamation or harassment or introduce viruses into the system. This policy is designed to safeguard both employees and The Employer from such liabilities. It is important that all employees read it carefully and ensure that any use of the internet or email is in accordance with its terms.
    4. This policy applies to employees of The Employer, workers and other contractors who have access to The Employer’s computer systems. Any reference to an employee is a reference to a worker or contractor also. It also applies to personal use of email or the internet where individuals identify themselves as associated with The Employer. The Employer may occasionally modify this policy to take account of changes in technology, law and best practice and will notify employees in writing of any change.

    1. The Employer may provide computers, laptops, and other equipment for use by employees for business purposes only.
    2. Employees are responsible for the safe keeping of equipment issued to them and for the physical and virtual security of the data and software accessed on it or stored thereon.
  3. E-MAIL

    1. Although the primary reason for allowing employees access to email is to help perform duties more effectively, occasional, and essential personal use of email will be allowed provided that it does not interfere with the performance of work duties.
    2. Employees must be aware that email is not an informal communication tool but has the same authority as any other communication to and from The Employer and should be regarded as published information.
    3. Email, just like any other form of communication, should reflect the highest professional standards at all times. Employees should keep messages brief and to the point, ensure that an appropriate heading is inserted in the subject field and that they check the spelling and grammar before sending. They should also double check the recipient before pressing the send button – not only can it be embarrassing if a message is sent to the wrong person, but it can also result in the unintentional disclosure of confidential information about The Employer.
    4. Employees should not transmit anything in an email or fax message that they would not be comfortable writing (or someone else reading) in a letter or a memorandum. Emails leave a retrievable record. Even when employees think that information has been deleted, it can remain on computers and on The Employer’s back-up system. Emails can be recovered as evidence in court proceedings or reviewed by regulators. Electronic messages are admissible as evidence in legal proceedings and have been used successfully in libel and discrimination cases.
    5. Employees should never assume that internal or external messages are necessarily private and confidential, even if marked as such. The internet is not a secure means of communication, and third parties may be able to access or alter messages which have been sent or received. Employees should not send any information in an email which they would not be happy being publicly available. Matters of a sensitive or personal nature should not be transmitted by email unless absolutely unavoidable and if so, should be clearly marked in the message header as highly confidential. The confidentiality of internal communications can only be ensured if they are delivered personally by hand.
    6. Internet messages should be treated as non-confidential. Anything sent through the internet passes through a number of different computer systems all with different levels of security. The confidentiality of messages may be compromised at any point along the way unless the messages are encrypted.

    1. Employees must not download, send (or store) offensive, demeaning or disruptive messages or images by fax or email. This includes, but is not limited to, messages inconsistent with The Employer’s equal opportunities policy and includes without limitation any sexist or racist material or any material which could be offensive on the grounds of, without limitation, a person’s disability, gender reassignment, their age, their sexual orientation, their marital or civil partnership status or their religion or belief.
    2. Employees should therefore not place on the system or send any message or image which could be regarded as personal, potentially offensive, or frivolous to any recipient or to any other person (even if not sent to them).
    3. If employees receive an email or a fax containing material that is offensive or inappropriate to the office environment, then they must delete it immediately. Under no circumstances should such mail or fax be forwarded either internally or externally.

    1. Access to the internet during working time should be limited to matters relating to employment and be for business purposes only. Any unauthorised use of the internet is strictly prohibited. Unauthorised use includes but is not limited to:-

      • Visiting sites, connecting, posting, or downloading any information unrelated to their employment and in particular pornographic or other offensive or illegal material;
      • Engaging in computer hacking and other related activities;
      • Attempting to disable or compromise security of information contained on The Employer’s computers;
      • Perpetration of any form of fraud or software, music or film piracy;
      • Sending offensive or harassing material to other users;
      • Downloading of commercial software or any copyrighted materials belonging to third parties, unless this is covered or permitted under a commercial agreement or other such licence;
      • Hacking into unauthorised areas;
      • Publishing defamatory and/or knowingly false material about The Employer, colleagues and/or customers on social networking sites;
      • Revealing confidential information about The Employer in any personal online posting, upload, or transmission; and
      • Introducing any form of malicious software into The Employer’s network.
    2. Postings placed on the internet may display The Employer’s address. For this reason, Employees should make certain before posting information that the information reflects the standards and policies of The Employer. Under no circumstances should information of a confidential or sensitive nature be placed on the internet.
    3. Information posted or viewed on the internet may constitute published material. Therefore, reproduction of information posted or otherwise available over the internet may be done only by express permission from the copyright holder. Employees must not act in such a way as to breach copyright or the licensing conditions of any internet site or computer programme.
    4. Employees must not commit The Employer to any form of contract through the internet.
    5. If employees produce, collect and/or process business-related information in the course of their work, the information remains the property of The Employer. This includes such information stored on third-party websites such as webmail’s service providers.

    1. Only authorised software is to be installed on The Employer’s equipment. Employees must not install any other software on The Employer’s computers without prior written permission from the IT department.
    2. All software used on The Employer’s computers must be properly licensed. If unlicensed software is found on The Employer’s computers, the licence fee must be paid and a fine can be imposed. If the unlicensed software is not authorised by The Employer the employee will be personally liable for the licence fee and fine. The Employer reserves the right without prior notice to remove any unauthorised software and delete all non-company data and files from its computers.

    1. All Instant Messaging, Blogging and activity on Facebook, Twitter, Instagram, Myspace, or any other social media site is strictly prohibited during working hours and on The Employer’s computers. Private blogs must not contain any reference to The Employer or its’ activities.
    2. The Employer operates or may operate in the future accounts on social media websites for the promotion of activities and events and as a method of communication. Any official account on any social media website may only be set up with written consent from your line manager. Only authorised employees may use these accounts to post online and access to the account by unauthorised employees is strictly prohibited. All information posted on the internet must comply with confidentiality and data protection policies and copyright laws must be respected, with references or sources cited appropriately
    3. Any employee who becomes aware of inappropriate or distasteful social networking activity should maketheir line manager aware of this as soon as possible.

    1. Employees must not allow other employees to use their password. If it is anticipated that someone may need access to an employee’s confidential files in their absence, they should arrange for the files to be copied to somewhere where that person can access them or give them access to the relevant personal folders.

    1. When using The Employer’s email system, be vigilant. Computer viruses are often sent by email and can cause significant damage to The Employer’s information systems.
    2. Any files or software downloaded from the internet or brought from home must be virus checked before use. Employees should not rely on their own pc to virus check any such programmes but should refer direct totheir line manager/ IT department. If you suspect that a file may contain a virus, do not open it and contact your line manager/ IT department immediately.
    3. Employees must not run any ‘.exe’ files. These should be deleted immediately upon receipt without being opened.

    1. The Employer reserves the right to monitor, intercept and read any internal or external email or fax or to listen to or record any telephone conversation for the purposes of monitoring and record keeping to establish facts, to establish compliance with regulatory or self-regulatory procedures, to prevent or detect crime, to investigate or detect the unauthorised use of The Employer’s telecommunication system or to ascertain compliance with The Employer’s practices or procedures. The Employer may also monitor, intercept, read, listen, or record communications to check whether communications are relevant to the business. The Employer also reserves the right to monitor internet usage to check compliance with obligations as set out above.
    2. The Employer has a right to protect the security of its systems, check that use of the system is legitimate, investigate suspected wrongful acts and otherwise comply with legal obligations imposed upon it.
    3. The Employer also reserves the right to read employees’ emails to check for business emails whilst they are absent or out of the office. The Employer may also access Employees’ voicemail to check for business calls whilst they are absent or out of the office. It may therefore be unavoidable that some personal messages will be read or heard.

    1. Where appropriate, The Employer may provide Employees with a mobile telephone and ‘hands free’ equipment sets for usage in vehicles. This equipment remains, at all times, the property of The Employer and must be returned immediately upon request and/or upon termination of employment. Employees provided with mobile telephones must comply with the following rules:

      • It is strictly prohibited to use mobile telephones whilst driving in a ‘handheld’ position. The Employer adopts a zero-tolerance approach to this and noncompliance may result in disciplinary action, up to and including summary dismissal, being taken against you.
      • All Employees provided with mobile telephones should use the telephone predominantly for work related purposes Is private usage allowed? All usage should be reasonable and sensible.
      • Mobile telephones should not be used abroad without the prior written permission of your line manager who must sanction the lifting of the ‘call barring’ facility. All personal calls made abroad, and all work-related calls made abroad (except where prior approval has been sought and given) must be paid for by the employee.

    1. The Employer considers this policy to be extremely important. If an employee is found to be in breach of this policy, then they will be disciplined in accordance with the disciplinary procedure. In certain circumstances, breach of this policy may be considered gross misconduct resulting in immediate termination of employment without notice or payment in lieu of notice. In addition, or as an alternative, The Employer may withdraw internet or email access.



    1. Style and language:

      • All emails should be addressed and signed off in a polite manner i.e. Dear/ Hello, Regards.
      • Emails do not always translate the emotion or feelings that were intended. Therefore, clear concise language should be used, and a review conducted to ensure that the message would not be misinterpreted.
      • Do not use slang or expletives. This is not acceptable business language.
      • If communicating a difficult issue, it may be appropriate to save as a draft and return to the email later to check the context and message given.
      • Lower case should be used in the majority of communications. Capital letters may be used to highlight or accentuate a point but may be interpreted as aggressive.
      • ‘Urgent stamps’ should only be used if they reflect the nature of the communication.
      • Check your email inbox at least once a day for new messages. Please ensure that you delete any unwanted emails, always reply with history, as the ongoing dialogue will be stored in one place rather than on a number of emails. Do not repeat an email request. It may be appropriate to follow up in person or via the telephone.
      • Conduct regular ‘housekeeping’: delete out-dated items and those items that have been superseded by later messages.
      • Manage the communication contained in emails. Remember they can be stored and printed and used as documentary evidence in libel, harassment, or disciplinary cases.
      • Remember data protection laws and only include suitable and relevant information regarding individuals.
    2. Sending Emails

      • Ensure you title all emails and that this accurately reflects the content of the message.
      • If you are sending an attachment, explain what it is in the document
      • Check the attachment prior to sending it to ensure it is the correct document.
      • Prior to sending an email, check the distribution list, re-read it, use spell check and ensure that it is conveying the correct messages to the readers.
    3. Receiving Emails

      • If you have been sent an email with an attachment and you are unsure what it contains, clarify this with the sender. This is particularly important if it is an .exe file. Do not open this file without checking its content as this can result in importing a virus into The Employer’s network with serious consequences where disciplinary action may be taken.
      • Never open email attachments where the sender is unknown to you, or where the subject matter is nothing to do with our business. Emails with curious messages or enticing subjects are used to encourage recipients to open email attachments that trigger viruses.
      • Do not open or respond to any ‘chain letters’.

    1. General

      • Laptops/workstations must be protected by passwords or other access control methods.
      • Back up takes place automatically when logged onto the server.
      • Ensure that the virus detection software is on your laptop/workstation. If new updates are downloaded follow instructions to re-boot your system.
      • Should you have had to load software from a diskette, CD Rom or other external source, it must be checked for viruses by the virus checker on your system.
      • If you have to leave your laptop/workstation unattended, ensure that it is either password locked or in the case of a laptop out of sight and locked away.
      • Laptops must not be left unattended in cars, as they are specifically uninsured in this situation.
      • Do not use your laptop/workstation for any other purpose than that which it was supplied for. It is not appropriate to utilise your laptop or workstation for personal use such as playing games. Use of the internet should be for business purpose only.
      • The theft or loss of your laptop should be reported immediately to your manager.
      • Laptop users who utilise battery power should discharge the battery completely once a week.

    1. General

      • Please do not share your password with anyone.
      • Make your password easy to remember but difficult to guess. In particular avoid any personal references such as car number plates; repeated characters or recognisable words. Good passwords are a mixture of letters, numbers, and punctuation characters.
      • Ensure that you use a screen saver for when you may wish to leave your workstation unattended for a short time. This should be of an appropriate nature – professional – no pin-ups or offensive material.
      • Do not allow anyone else to use your laptop or workstation whilst you are still logged on. Remember that you are responsible for all actions, which are carried out, under your user account.
      • Remember to close down your laptop/workstation at the end of the working day.

    1. General

      • If your virus checker or a fellow employee advises that a mail attachment has a virus, contact our service provider immediately, and telephone the person who sent you the message to advise them that their computer has a virus infection.
      • If you are told that you have a virus on your laptop/workstation then you should contact our service provider immediately.
      • If your laptop/workstation behaves irregularly by running slower than normal or displays odd characters or messages, changes locations etc then please contact our service provider.

    1. General

      • Change the privacy settings on your profile so that only people you have accepted as friends can see your content.
      • Review who is on your ‘friends list’ on your personal profile. In most situations you should not accept friend requests from clients or customers.
      • Ensure personal blogs have clear disclaimers that the views expressed by the author are theirs alone and do not represent the views of The Employer. Make your writing clear that you are speaking on behalf of yourself and not on behalf of The Employer. Ensure that any information published on the internet complies with The Employer’s confidentiality and data protection policies.
      • Ensure that you are always respectful towards The Employer, other Employees and workers, clients, and customers. You should be aware that any disrespectful comments might be seen as libellous.
      • The Employer trademarks and logos may not be used without written consent.
      • Be aware that in and out of work, at all time, you are an ambassador for The Employer. Any actions captured via images, posts or comments online can reflect on The Employer.

Disciplinary and dismissal procedure policy


    1. The aim of the disciplinary procedure is to provide a framework within which managers can work with employees to maintain satisfactory standards of conduct and to encourage improvement where necessary.
    2. It is our policy to ensure that any disciplinary matter is dealt with fairly and that steps are taken to establish the facts.

    1. This procedure does not apply to agency workers or self-employed contractors. It is for guidance only and does not form part of your contract of employment. This procedure does not apply to cases involving:

      • genuine sickness absence;
      • proposed redundancies; or
      • poor performance or capability.
    2. Minor conduct issues can normally be resolved informally between you and your manager. These discussions should be held in private and without undue delay whenever there is cause for concern. In some cases, an informal verbal warning may be given. Formal steps will be taken under this procedure if the matter is not resolved, or if informal discussion is not appropriate (for example, because of the seriousness of the allegation).
    3. Except in cases of gross misconduct, you would not normally be dismissed for a first act of misconduct. We will normally give you a warning and a chance to improve. We may not always apply this principle if your probationary period has not yet been completed.
    4. Any steps under this procedure should be taken promptly unless there is a good reason for delay. We may vary any time limits if it is reasonable to do so.
    5. If you have difficulty at any stage of the procedure because of a disability, you should discuss the situation with your manager or a member of the Human Resources department as soon as possible.

    1. Our aim during an investigation or disciplinary procedure is to deal with matters sensitively and with due respect for the privacy of any individuals involved.
    2. All employees must treat as confidential any information communicated to them in connection with an investigation or disciplinary matter.
    3. You will normally be told the names of any witnesses whose evidence is relevant to disciplinary proceedings against you, unless, in our discretion, we believe that a witness’s identity should remain confidential.
    4. Witnesses must treat as confidential any information given to them in the course of an investigation, including the identity of any employees under investigation.

    1. The purpose of an investigation is for us to establish a fair and balanced view of the facts before deciding whether to proceed with a disciplinary hearing. This may involve reviewing any relevant documents, interviewing you and any witnesses, and taking witness statements.
    2. Investigative interviews are solely for the purpose of fact-finding and no decision on disciplinary action will be taken until after a disciplinary hearing has been held.
    3. You do not normally have the right to bring anyone to an investigative interview. However, we may allow you to bring a companion if it helps you to overcome a difficulty caused by a disability, or any difficulty in understanding English.
    4. You must cooperate fully and promptly in any investigation. This will include informing us of the names of any relevant witnesses, disclosing any relevant documents to us and attending any investigative interviews.
    5. The amount of investigation required will depend on the nature of the allegations and will vary from case to case.

    1. In cases of alleged gross misconduct, we may need to suspend an employee from work while an investigation or disciplinary procedure is on-going. The suspension will be for no longer than necessary and we will confirm the arrangements to you in writing. While suspended you should not visit our premises or contact any of our clients, customers, suppliers, contractors, or employees, unless you have been authorised to do so by your line manager.
    2. Suspension of this kind is not a disciplinary sanction and does not imply that any decision has already been made about your case. You will continue to receive your full basic salary and benefits during the period of suspension.


    1. Following any investigation, if we consider there are grounds for disciplinary action, we will inform you in writing of the allegations against you and the basis for those allegations. This will normally include:

      • a summary of relevant information gathered during the investigation;
      • documents which will be used at the disciplinary hearing; and
      • witness statements which will be used at the hearing, except where a witness’s identity is to be kept confidential, in which case we will give you as much information as possible while maintaining confidentiality.
    2. You will have a reasonable opportunity to consider this information before the hearing.

    1. We will give you written notice of the date, time, and place of the disciplinary hearing, which will normally be held between two days and one week after you receive the written notice.
    2. The hearing will be chaired by your line manager. A member of Human Resources may also be present. You may bring a companion with you to the disciplinary hearing (see Right to be accompanied, below).
    3. You must take all reasonable steps to attend the hearing. Failure to attend a hearing without good reason may be treated as misconduct in itself. If you or your companion cannot attend at the time specified, you should inform us immediately and we will seek to agree an alternative time.
    4. The purpose of the disciplinary hearing is to review the evidence and to enable you to respond to any allegations that have been made against you. If you have a companion, he or she may make representations to us and ask questions but should not answer questions on your behalf. You may confer privately with your companion at any time during the hearing.
    5. It will not normally be necessary for witnesses to be questioned or cross-examined at the disciplinary hearing but, in exceptional cases, the manager responsible may decide in conjunction with Human Resources that a fair hearing could not be held otherwise.
    6. The disciplinary hearing may be adjourned if we need to carry out any further investigations. For example, we may decide to re-interview witnesses in light of any points that have been raised at the hearing. You will be given a reasonable opportunity to consider any new information obtained before the hearing is reconvened.
    7. As soon as possible following the disciplinary hearing, we will inform you in writing of our decision (including details of any misconduct that we consider you have committed, and the disciplinary sanction to be applied) together with the reasons for our decision. We will also inform you of your right of appeal. Where possible we will also explain this information to you in person.

    1. If you wish to appeal you should do so in writing to your line manager’s line manager within one week of the date on which you were informed of the decision.
    2. We will give you written notice of the date, time, and place of the appeal hearing. This will normally be between two days and one week after you receive the written notice. In cases of dismissal the appeal will be held as soon as possible
    3. .

    4. Where practicable, the appeal hearing will be held by a manager who is senior to the person who conducted the disciplinary hearing. You may bring a companion with you to the appeal meeting.
    5. If you raise any new matters in your appeal, we may need to carry out further investigation prior to the appeal hearing. If any new information comes to light, we will provide you with the details. You will have a reasonable opportunity to consider this information before the hearing.
    6. Following the appeal, we may:
      • confirm the original decision; or
      • revoke the original decision; or
      • substitute a different disciplinary sanction.
    7. We will inform you in writing of our final decision as soon as possible after the appeal hearing. Where possible we will also explain this to you in person. There will be no further right of appeal.
    8. The date on which any dismissal takes effect will not be delayed pending the outcome of an appeal. However, if the appeal is successful, you will be reinstated with no loss of continuity or pay.
    9. Right to be accompanied:
      • You may bring a companion to any disciplinary or appeal hearings under this procedure. The companion may be either a trade union official or a colleague. You must tell your line manager who your chosen companion is, in good time before the hearing.
      • Acting as a companion is voluntary and employees are under no obligation to do so. Employees will be allowed reasonable time off from duties without loss of pay to act as a companion.
    10. If your choice of companion is unreasonable, we may ask you to choose someone else. For example, this may be the case:
      • if in our opinion your companion may have a conflict of interest or may prejudice the hearing; or
      • if your companion works at another site and someone reasonably suitable is available at the site at which you work; or
      • if your companion is unavailable at the time a hearing is scheduled and will not be available for more than five working days.
    11. We may, at our discretion, allow you to bring a companion who is not an employee or union official (for example, a member of your family) where this will help overcome a particular difficulty caused by a disability, or where you have difficulty understanding English.

    1. We aim to treat all employees fairly and consistently. Disciplinary action previously taken against other employees for similar misconduct will usually be taken into account but should not be treated as a precedent. Each case will be assessed on its own merits. Depending on the seriousness of the matter any of the following stages may be omitted.
    2. Stage 1: verbal warning

      • You may be given a verbal warning for a minor act of misconduct where you have no other active warnings on your disciplinary record.
      • The warning will set out the nature of the misconduct, the change in behaviour required and the likely consequences of further misconduct.
      • A record of the warning will be placed permanently on your personnel file and will remain active for six months from the date it is given, after which time it will normally be disregarded in deciding the outcome of future disciplinary proceedings. Your conduct may be reviewed at the end of this period and if it has not improved sufficiently, we may decide to extend the active period.
    3. Stage 2: first written warning

      • A first written warning will usually be given for:

        • first acts of misconduct where there are no other active warnings on your disciplinary record; or
        • minor misconduct where there is an active verbal warning on your record.
        • The warning will set out the nature of the misconduct, the change in behaviour required and the likely consequences of further misconduct.
        • The warning will be placed permanently on your personnel file and will remain active for six months from the date it is given, after which time it will normally be disregarded in deciding the outcome of future disciplinary proceedings. Your conduct may be reviewed at the end of this period and if it has not improved sufficiently, we may decide to extend the active period.
    4. Stage 3: final written warning

      • A final written warning will usually be given for:
        • misconduct where there is already an active written warning on your record; or
        • cases where there is no active written warning on file, but we consider that the misconduct is sufficiently serious to warrant a final written warning.
      • The warning will set out the nature of the misconduct, the change in behaviour required and the likely consequences of further misconduct.
      • The warning will be placed permanently on your personnel file and will normally remain active for 12 months or, if we decide that the matter is more serious, for a longer period. Your conduct may be reviewed at the end of this period and if it has not improved sufficiently, we may decide to extend the active period. After the active period it will normally be disregarded in deciding the result of future disciplinary proceedings. In exceptional cases verging on gross misconduct, a warning may remain active indefinitely.
    5. Stage 4: dismissal

      • We may decide to dismiss you in the following circumstances:
        • misconduct where there is an active final written warning on your record; or
        • gross misconduct regardless of whether you have received any previous warnings.
      • Gross misconduct will usually result in summary dismissal, that is, dismissal without notice or payment in lieu of notice. In cases not involving gross misconduct you will be given your full contractual notice period, or payment in lieu of notice.
      • As a guideline (and by means of illustration only) the following are examples of what may constitute gross misconduct:

        • Falsification of records such as Expense/Time Sheets, overtime claims, customer orders.
        • Theft, fraud or intent to defraud.
        • Extensive abuse of the Company’s facilities e.g. personal telephone calls, e-mail, Internet or postal service for personal use
        • Reckless or serious misuse of Company vehicle.
        • Falsification of information on appointment.
        • Sleeping on duty.
        • Rudeness to customers of the Company.
        • Viewing, downloading and copying of pornographic or other offensive material
        • Sending defamatory, abusive, sexist, or racist messages
        • Knowingly using Company systems to create and/or distribute viruses
        • Creating and/or distributing illegal copies of software
        • Hacking attacks on Company systems or third party systems
        • Disclosing Company passwords to access Company computers
        • Accepting a gift which could be construed as a bribe.
        • Sexual, racial or any other form of harassment.
        • Conviction for any serious criminal offence whilst an employee.
        • Wilful damage to the property of the Company or other employees.
        • Assault within the work place
        • Inability to work effectively due to the influence of alcohol or illegal drugs.
        • Unauthorised disclosures of confidential information.
        • Unauthorised absence.
        • Serious insubordination.
        • Breach of Health and Safety rules
        • Smoking
        • This list must not be regarded as exhaustive, but merely illustrative.
    6. Alternative sanctions short of dismissal

      • In appropriate cases we may consider some other sanction short of dismissal, such as:

        • demotion;
        • transfer to another department or job;
        • period of suspension without pay;
        • loss of seniority;
        • reduction in pay;
        • loss of future pay increment or bonus;
        • loss of overtime.
        • These sanctions may be used in conjunction with a written warning.

GDPR Policy

    1. This policy does not constitute legal advice. The policy should be tailored to reflect the Employer’s specific requirements following a data audit in accordance with the legislation, guidance and Codes of Practice issued by the Information Commissioner. This policy is designed to be used in conjunction with a Data Retention Policy and a Data Security Policy, which will be standard across your organisation and not specific to HR. It is recommended that specific legal advice is taken to ensure your compliance.
    2. This policy assumes that you do not send data outside the EU or engage in automation/profiling.
    1. The Employer takes the security and privacy of your data seriously. We need to gather and use information or ‘data’ about you as part of our business and to manage our relationship with you. We intend to comply with our legal obligations under the relevant legislation in respect of data privacy and security. We have a duty to notify you of the information contained in this policy.
    2. This policy applies to current and former employees, workers, volunteers, apprentices and consultants. If you fall into one of these categories then you are a ‘data subject’ for the purposes of this policy. You should read this policy alongside your contract of employment (or contract for services) and any other notice we issue to you from time to time in relation to your data.
    3. The Employer has separate policies and privacy notices in place in respect of job applicants, customers, suppliers and other categories of data subject. A copy of these can be obtained from your line manager.
    4.  The Employer has measures in place to protect the security of your data in accordance with our Data Security Policy. A copy of this can be obtained from your line manager.
    5. The Employer will hold data in accordance with our Data Retention Policy. A copy of this can be obtained from your line manager.We will only hold data for as long as necessary for the purposes for which we collected it.
    6. The Employer is a ‘data controller’ for the purposes of your personal data. This means that we determine the purpose and means of the processing of your personal data.
    7. This policy explains how The Employer will hold and process your information. It explains your rights as a data subject. It also explains your obligations when obtaining, handling, processing or storing personal data in the course of working for, or on behalf of,The Employer.
    8. This policy does not form part of your contract of employment (or contract for services if relevant) and can be amended by The Employer at any time. It is intended that this policy is fully compliant with the relevant legislation. If any conflict arises between those laws and this policy, The Employer intends to comply with the relevant legislation.
    1. Personal data must be processed in accordance with six ‘Data Protection Principles.’ It must:
      • be processed fairly, lawfully and transparently;
      • be collected and processed only for specified, explicit and legitimate purposes;
      • be adequate, relevant and limited to what is necessary for the purposes for which it is processed;
      • be accurate and kept up to date. Any inaccurate data must be deleted or rectified without delay;
      • not be kept for longer than is necessary for the purposes for which it is processed; and
        be processed securely.
    2. We are accountable for these principles and must be able to show that we are compliant.
    1. ‘Personal data’ means information which relates to a living person who can be identified from that data (a ‘data subject’) on its own, or when taken together with other information which is likely to come into our possession. It includes any expression of opinion about the person and an indication of the intentions of us or others, in respect of that person. It does not include anonymised data.
    2.  This policy applies to all personal data whether it is stored electronically, on paper or on other materials.
    3. This personal data might be provided to us by you, or someone else (such as a former employer, your doctor, or a credit reference agency), or it could be created by us. It could be provided or created during the recruitment process or during the course of the contract of employment (or services) or after its termination. It could be created by your manager or other colleagues.
    4. We will collect and use the following types of personal data about you:
      • recruitment information such as your application form and CV, references, qualifications and membership of any professional bodies and details of any pre-employment assessments;
      • your contact details and date of birth;
      • the contact details for your emergency contacts;
      • your gender;
      • your marital status and family details;
      • information about your contract of employment (or services) including start and end dates of employment, role and location, working hours, details of promotion, salary (including details of previous remuneration), pension, benefits and holiday entitlement;
      • your bank details and information in relation to your tax status including your national insurance number;
      • your identification documents including passport and driving licence and information in relation to your immigration status and right to work for us;
      • information relating to disciplinary or grievance investigations and proceedings involving you (whether or not you were the main subject of those proceedings);
      • information relating to your performance and behaviour at work;
      • training records;
      • electronic information in relation to your use of IT systems/swipe cards/telephone systems;
      • your images (whether captured on CCTV, by photograph or video);
      • any other category of personal data which we may notify you of from time to time.
    1. ‘Special categories of personal data’ are types of personal data consisting of information as to:
      • yourracial or ethnic origin;
      • your political opinions;
      • your religious or philosophical beliefs;
      • your trade union membership;
      • your genetic or biometric data;
      • your health;
      • your sex life and sexual orientation; and
      • any criminal convictions and offences.
      • We may hold and use any of these special categories of your personal data in accordance with the law.
    1. ‘Processing’ means any operation which is performed on personal data such as:
      • collection, recording, organisation, structuring or storage;
      • adaption or alteration;
      • retrieval, consultation or use;
      • disclosure by transmission, dissemination or otherwise making available;
      • alignment or combination; and
      • restriction, destruction or erasure.
      • This includes processing personal data which forms part of a filing system and any automated processing.
    1. The Employerwill process your personal data (including special categories of personal data) in accordance with our obligations under the 2018 Act.
    2. We will use your personal data for:
      • performing the contract of employment (or services) between us;
      • complying with any legal obligation; or
      • if it is necessary for our legitimate interests (or for the legitimate interests of someone else). However, we can only do this if your interests and rights do not override ours (or theirs). You have the right to challenge our legitimate interests and request that we stop this processing. See details of your rights in section 12 below.
    3. We can process your personal data for these purposes without your knowledge or consent. We will not use your personal data for an unrelated purpose without telling you about it and the legal basis that we intend to rely on for processing it.
    4. If you choose not to provide us with certain personal data you should be aware that we may not be able to carry out certain parts of the contract between us. For example, if you do not provide us with your bank account details we may not be able to pay you. It might also stop us from complying with certain legal obligations and duties which we have such as to pay the right amount of tax to HMRC or to make reasonable adjustments in relation to any disability you may suffer from.
    1. We have to process your personal data in various situations during your recruitment, employment (or engagement) and even following termination of your employment (or engagement).
    2. For example (and see section 7.6 below for the meaning of the asterisks):
      • to decide whether to employ (or engage) you;
      • to decide how much to pay you, and the other terms of your contract with us;
      • to check you have the legal right to work for us;
      • to carry out the contract between us including where relevant, its termination;
      • training you and reviewing your performance*;
      • to decide whether to promote you;
      • to decide whether and how to manage your performance, absence or conduct*;
      • to carry out a disciplinary or grievance investigation or procedure in relation to you or someone else;
      • to determine whether we need to make reasonable adjustments to your workplace or role because of your disability*;
      • to monitor diversity and equal opportunities*;
      • to monitor and protect the security (including network security) of The Employer, of you, our other staff, customers and others;
      • to monitor and protect the health and safety of you, our other staff, customers and third parties*;
      • to pay you and provide pension and other benefits in accordance with the contract between us*;
      • paying tax and national insurance;
      • to provide a reference upon request from another employer;
      • to pay trade union subscriptions*;
      • monitoring compliance by you, us and others with our policies and our contractual obligations*;
      • to comply with employment law, immigration law, health and safety law, tax law and other laws which affect us*;
      • to answer questions from insurers in respect of any insurance policies which relate to you*;
      • running our business and planning for the future;
      • the prevention and detection of fraud or other criminal offences;
      • to defend The Employer in respect of any investigation or litigation and to comply with any court or tribunal orders for disclosure*;
      • for any other reason which we may notify you of from time to time.
    3. We will only process special categories of your personal data (see above) in certain situations in accordance with the law. For example, we can do so if we have your explicit consent. If we asked for your consent to process a special category of personal data then we would explain the reasons for our request. You do not need to consent and can withdraw consent later if you choose by contacting your line manager.
    4. We do not need your consent to process special categories of your personal data when we are processing it for the following purposes, which we may do:
      • where it is necessary for carrying out rights and obligations under employment law;
      • where it is necessary to protect your vital interests or those of another person where you/they are physically or legally incapable of giving consent;
      • where you have made the data public;
      • where processing is necessary for the establishment, exercise or defence of legal claims; and
      • where processing is necessary for the purposes of occupational medicine or for the assessment of your working capacity.
    5. We might process special categories of your personal data for the purposes in paragraph 7.2above which have an asterisk beside them.In particular, we will use information in relation to:
      • your race, ethnic origin, religion, sexual orientation or gender to monitor equal opportunities;
      • your sickness absence, health and medical conditions to monitor your absence, assess your fitness for work, to pay you benefits, to comply with our legal obligations under employment law including to make reasonable adjustments and to look after your health and safety; and
      • your trade union membership to pay any subscriptions and to comply with our legal obligations in respect of trade union members.
    6. We do not take automated decisions about you using your personal data or use profiling in relation to you. [IF AUTOMATION/PROFILING IS USED THEN EXPLAIN]
    1. Sometimes we might share your personal data with group companies or our contractors and agents to carry out our obligations under our contract with you or for our legitimate interests. [EMPLOYER TO ADD OTHER SITUATIONS]
    2. We require those companies to keep your personal data confidential and secure and to protect it in accordance with the law and our policies. They are only permitted to process your data for the lawful purpose for which it has been shared and in accordance with our instructions.
    4. We do not send your personal data outside the European Economic Area. If this changes you will be notified of this and the protections which are in place to protect the security of your data will be explained. [EMPLOYER TO CONFIRM WHETHER DATA WILL BE SENT OUTSIDE THE EU AND IF SO, WHAT PROTECTIONS ARE IN PLACE.]
    1. Everyone who works for, or on behalf of,The Employer has some responsibility for ensuring data is collected, stored and handled appropriately, in line with this policy and The Employer’sSecurity and Data Retention policies.
    2. The Human Resources department is responsible for reviewing this policy and updating the Board of Directors on The Employer’s data protection responsibilities and any risks in relation to the processing of data. You should direct any questions in relation to this policy or data protection to this person.
    3. You should only access personal data covered by this policy if you need it for the work you do for, or on behalf of The Employer and only if you are authorised to do so. You should only use the data for the specified lawful purpose for which it was obtained.
    4. You should not share personal data informally.
    5. You should keep personal data secure and not share it with unauthorised people.
    6. You should regularly review and update personal data which you have to deal with for work. This includes telling us if your own contact details change.
    7. You should not make unnecessary copies of personal data and should keep and dispose of any copies securely.
    8. You should use strong passwords.
    9. You should lock your computer screens when not at your desk.
    10. [Personal data should be encrypted before being transferred electronically to authorised external contacts. [Speak to IT for more information on how to do this.]]
    11. Consider anonymising data or using separate keys/codes so that the data subject cannot be identified.
    12. Do not save personal data to your own personal computers or other devices.
    13. Personal data should never be transferred outside the European Economic Area except in compliance with the law and with authorisation from your line manager.
    14. You should lock drawers and filing cabinets. Do not leave paper with personal data lying about.
    15. You should not take personal data away from Company’s premises without authorisation from your line manager.
    16. Personal data should be shredded and disposed of securely when you have finished with it.
    17. You should ask for help from your line manager if you are unsure about data protection or if you notice any areas of data protection or security we can improve upon.
    18. Any deliberate or negligent breach of this policy by you may result in disciplinary action being taken against you in accordance with our disciplinary procedure.
    19. It is a criminal offence to conceal or destroy personal data which is part of a subject access request (see below). This conduct would also amount to gross misconduct under our disciplinary procedure, which could result in your dismissal.
    1. We have robust measures in place to minimise and prevent data breaches from taking place. Should a breach of personal data occur (whether in respect of you or someone else) then we must take notes and keep evidence of that breach. If the breach is likely to result in a risk to the rights and freedoms of individuals then we must also notify the Information Commissioner’s Office within 72 hours.
    2. If you are aware of a data breach you must contact your line manager immediately and keep any evidence you have in relation to the breach.
    1. Data subjects can make a ‘subject access request’ (‘SAR’) to find out the information we hold about them. This request must be made in writing. If you receive such a request you should forward it immediately to your line manager who will coordinate a response.
    2. If you would like to make a SAR in relation to your own personal data you should make this in writing to your line manager. We must respond within one month unless the request is complex or numerous in which case the period in which we must respond can be extended by a further two months.
    3. There is no fee for making a SAR. However, if your request is manifestly unfounded or excessive we may charge a reasonable administrative fee or refuse to respond to your request.
    1. You have the right to information about what personal data we process, how and on what basis as set out in this policy.
    2. You have the right to access your own personal data by way of a subject access request (see above).
    3. You can correct any inaccuracies in your personal data. To do you should contact your line manager.
    4. You have the right to request that we erase your personal data where we were not entitled under the law to process it or it is no longer necessary to process it for the purpose it was collected. To do so you should contact your line manager.
    5. While you are requesting that your personal data is corrected or erased or are contesting the lawfulness of our processing, you can apply for its use to be restricted while the application is made. To do so you should contact your line manager.
    6. You have the right to object to data processingwhere we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop.
    7. You have the right to object if we process your personal data for the purposes of direct marketing.
    8. You have the right to receive a copy of your personal data and to transfer your personal data to another data controller. We will not charge for this and will in most cases aim to do this within one month.
    9. With some exceptions, you have the right not to be subjected to automated decision-making.
    10. You have the right to be notified of a data security breach concerning your personal data.
    11. In most situations we will not rely on your consent as a lawful ground to process your data. If we do however request your consent to the processing of your personal data for a specific purpose, you have the right not to consent or to withdraw your consent later. To withdraw your consent, you should contact your line manager.
    12. You have the right to complain to the Information Commissioner.You can do this be contacting the Information Commissioner’s Office directly. Full contact details including a helpline number can be found on the Information Commissioner’s Office website ( This website has further information on your rights and our obligations.

Grievance procedure


    1. It is The Employer’s policy to ensure that employees with a grievance relating to their employment can use a procedure which can help to resolve grievances as quickly and as fairly as possible. The Employer reserves the right to depart from the precise requirements of this procedure when it is expedient to do so.

    1. In the first instance you should talk to your immediate supervisor, to see if the matter can be resolved locally.

    1. Stage 1
      • If the issue cannot be resolved by your immediate supervisor, or if you feel that the grievance has not been resolved by any action taken or not taken by your immediate supervisor, or it is not appropriate to raise the matter with your immediate supervisor, then you should raise the matter in writing to your line manager.
      • Your line manager will arrange a meeting with you to discuss the matter. You will receive a formal invitation to attend the meeting and have the right to be accompanied by a work colleague or trade union representative. Following the meeting your line manager will notify you of his/her decision in writing with the right of appeal.
      • If you are satisfied, then no further action will be taken.
    2. Stage 2
      • In any instance where the issue cannot be resolved satisfactorily, you have the right of appeal to your line manager’s line manager. You should, within five working days of the date of the decision at Stage 1, appeal in writing (setting out the grounds of your appeal) to that manager.
      • You will be entitled to have a meeting with that manager to discuss the matter. You will receive a formal invitation to this meeting and will have the right to be accompanied at this meeting by a work colleague or trade union representative. The manager will endeavour to give his/her decision within seven working days of the date of the meeting. The manager’s decision is final.