Policies – Foundation Coeur D'amour

Data Protection Act 2018 Policy

Introduction
This Policy sets out the obligations of Foundation Coeur D’amour regarding data protection and the rights of customers and business contacts (“clients”) in respect of their data under the Data Protection Act 2018 (Formally EU Regulation 2016/679 General Data Protection Regulation (“GDPR”)). The Data Protection Act 2018 defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company. The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

The Data Protection Principles
This Policy aims to ensure compliance with the Data Protection Act 2018. The Data Protection Act 2018 sets out the following principles with which any party handling personal data must comply. All personal data must be: • Processed lawfully, fairly, and in a transparent manner in relation to the data subject. • Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes. • Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed. • Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay. • Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the Data Protection Act 2018 in order to safeguard the rights and freedoms of the data subject. • Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

The Rights of Data Subjects
• The Data Protection Act 2018 sets out the following rights applicable to data subjects. • The right to be informed • The right of access, • The right to rectification, • The right to erasure (also known as the ‘right to be forgotten’), • The right to restrict processing, • The right to data portability, • The right to object; and • Rights with respect to automated decision-making and profiling.Lawful, Fair, and Transparent Data Processing
The Data Protection Act 2018 seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The Data Protection Act 2018 states that processing of personal data shall be lawful if at least one of the following applies: • The data subject has given consent to the processing of their personal data for one or more specific purposes. • The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them. • The processing is necessary for compliance with a legal obligation to which the data controller is subject. • The processing is necessary to protect the vital interests of the data subject or of another natural person. • The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or • The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. • If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s health), at least one of the following conditions must be met: • The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so); • The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent. • The processing relates to personal data which is clearly made public by the data subject. • The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity. Specified, Explicit, and Legitimate Purposes The Company collects and processes the personal data set out in this Policy. This includes: • Personal data collected directly from data subjects OR • Personal data obtained from third parties. • The Company only collects, processes, and holds personal data for the specific purposes set out in this Policy (or for other purposes expressly permitted by the Data Protection Act 2018). • Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data. Adequate, Relevant, and Limited Data Processing The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed). Accuracy of Data and Keeping Data Up to Date • The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up to date. This includes but is not limited to, the rectification of personal data at the request of a data subject. • The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate. Data Retention • The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed. • When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay. • For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.

Secure Processing
The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided later in this Policy.
Accountability and Record-Keeping
The Company’s Data Protection Officer is Jolie Kabemba,
E-Mail: Coeur.amour.trust@gmail.com@gmail.com
Tel: 07904395293

The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the Data Protection Act 2018 and other applicable data protection legislation. • The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information: • The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors. • The purposes for which the Company collects, holds, and processes personal data. • Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates. • Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards. • Details of how long personal data will be retained by the Company; and • Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data. Data Protection Impact Assessments • The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data. • Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following: 1. The type(s) of personal data that will be collected, held, and processed. 2. The purpose(s) for which personal data is to be used. 3. The Company’s objectives. 4. How personal data is to be used. 5. The parties (internal and/or external) who are to be consulted. 6. The necessity and proportionality of the data processing with respect to the 7. purpose(s) for which it is being processed. 8. Risks posed to data subjects. 9. Risks posed both within and to the Company; and 10. Proposed measures to minimize and handle identified risks. Keeping Data Subjects Informed The Company shall provide the information set out in section (i) below to every data subject: Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose: a) if the personal data is used to communicate with the data subject, when the first communication is made; or b) if the personal data is to be transferred to another party, before that transfer is made; or c) as soon as reasonably possible and in any event not more than one month after the personal data is obtained. (i) The following information shall be provided: • Details of the Company including, but not limited to, the identity of its Data Protection Officer. • The purpose(s) for which the personal data is being collected and will be processed (as detailed in this Policy) and the legal basis justifying that collection and processing. • Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data. • Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed. • Where the personal data is to be transferred to one or more third parties, details of those parties. • Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place, o Details of data retention. o Details of the data subject’s rights under the Data Protection Act 2018. o Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time. o Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the Data Protection Act 2018). o Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and o Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

Data Subject Access
• Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why. • Data subjects wishing to make a SAR may do so in writing, using the Company’s Subject Access Request Form, or other written communication. SARs should be addressed to the Company’s Data Protection Officer at Foundation Coeur D’amour. 7 BELL YARD LONDON WC2A 2JR – Tel: 07904 395293 Email: contact.amour.trust@gmail.com • Responses to SARs shall normally be made within one month of receipt, however, this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed. • All SARs received shall be handled by the Company’s Data Protection Officer. • The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive. Rectification of Personal Data • Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete. • The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed. • In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data. Erasure of Personal Data Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances: a) It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed. b) The data subject wishes to withdraw their consent to the Company holding and processing their personal data. c) The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so), d) The personal data has been processed unlawfully. e) The personal data needs to be erased in order for the Company to comply with a particular legal obligation. Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed. In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

Restriction of Personal Data Processing
Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further. In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so). Objections to Personal Data Processing Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling) and processing for scientific and/or historical research and statistics purposes. Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims. Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately. Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Data Protection Act 2018, “demonstrate grounds relating to his or her particular situation”. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest. Personal Data Collected, Held, and Processed The following personal data is collected, held, and processed by the Company: Data Ref. Type of Data Purpose of Data Electronic and hard copy Learner records [name, Date of Birth, Address and telephone and picture photo] Data Security – Transferring Personal Data and Communications The Company shall ensure that the following measures are taken with respect to all, communications and other transfers involving personal data: • All emails containing personal data must be encrypted using Encryption software. • All emails containing personal data must be marked “confidential”. • Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances. • Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable. • Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted using deletion software. • Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data. • Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using Royal Mail Registered or 1st or 2nd Class Signed For post; and • All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”. Data Security – Storage The Company shall ensure that the following measures are taken with respect to the storage of personal data: • All electronic copies of personal data should be stored securely using passwords and data encryption. • All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar. • All personal data stored electronically should be backed up at least daily with backups stored onsite. All backups should be encrypted using data encryption. • No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of the Data Protection Officer and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and • No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Data Protection Act 2018 (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken). Data Security – Disposal When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Data Security – Use of Personal Data The Company shall ensure that the following measures are taken with respect to the use of personal data: • No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from The Data Protection Officer, • No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorization of The Data Protection Officer, • Personal data must be handled with care at all times and should not be left unattended or on view to unauthorized employees, agents, sub-contractors, or other parties at any time. • If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period, the user must lock the computer and screen before leaving it; and • Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of Juliana Forbes to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.

Data Security – IT Security
The Company shall ensure that the following measures are taken concerning IT and information security: • All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. • Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords. • All software (including, but not limited to, applications and operating systems) shall be kept up to date. The Company’s IT staff shall be responsible for installing any and all, security-related updates after the updates are made available by the publisher or manufacturer, unless there are valid technical reasons not to do so; and • No software may be installed on any Company-owned computer or device without the prior approval of the Company.

Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data: • All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Data Protection Act 2018 and under this Policy and shall be provided with a copy of this Policy. • Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company. • All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so. • All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised. • All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise. • Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed. • All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy. • The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed. • All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Data Protection Act 2018 and this Policy by contract. • All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all, of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Data Protection Act 2018; and • Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

Transferring Personal Data to a Country Outside the EEA The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA. The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies: o The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data. o The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the Data Protection Act 2018); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
o The transfer is made with the informed consent of the relevant data subject(s); o The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
o The transfer is necessary for important public interest reasons.
o The transfer is necessary for the conduct of legal claims.
o The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
o The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

Data Breach Notification

• All personal data breaches must be reported immediately to the Company’s Data

Protection Officer.
• If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality,
discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
• In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.

• Data breach notifications shall include the following information:
o The categories and approximate number of data subjects concerned.
o The categories and approximate number of personal data records concerned.,br> o The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained).
o The likely consequences of the breach.
o Details of the measures taken, or proposed to be taken, by the Company to address the
breach including, where appropriate, measures to mitigate its possible adverse effects.

This policy has been approved & authorised by:

Name: Jolie Kabemba
Position: Chair Trustee
Date: 12 May 2024
Signature:
Review of Policy: 12 May 2025

Foundation Coeur D’amour – Conflict of Interest Policy

All staff, volunteers, and committee members/trustees of [Your-Organisation-Name] will strive to avoid any conflict of interest between the interests of the Organization on the one hand, and personal, professional, and business interests on the other. This includes avoiding actual conflicts of interest as well as the perception of conflicts of interest. The purposes of this policy is to protect the integrity of the Organization’s decision-making process, to enable our stakeholders to have confidence in our integrity, and to protect the integrity and reputation of volunteers, staff and committee members. Examples of conflicts of interest include: 1 A committee member who is also a user who must decide whether fees from users should be increased. 2 A committee member who is related to a member of staff and there is a decision to be taken on staff pay and/or conditions. 3 A committee member who is also on the committee of another organisation that is competing for the same funding. 4 A committee member who has shares in a business that may be awarded a contract to do work or provide services for the organisation. Upon appointment each committee member will make a full, written disclosure of interests, such as relationships, and posts held, that could potentially result in a conflict of interest. This written disclosure will be kept on file and will be updated as appropriate. In the course of meetings or activities, committee members will disclose any interests in a transaction or decision where there may be a conflict between the organisations best interests and the committee members best interests or a conflict between the best interests of two organisations that the committee member is involved with. *Option 1: After disclosure, I understand that I may be asked to leave the room for the discussion and will not be able to take part in any vote or decision making that relates to the conflict of interest. *Option 2: After disclosure, I understand that I will be asked to leave the room for the discussion and will not be able to take part in the decision making. Any such disclosure and the subsequent actions taken will be noted in the minutes. This policy is meant to supplement good judgment, and staff, volunteers and committee members should respect its spirit as well as its wording.
Date Adopted: Jolie Kabemba

Equality Policy

Introduction

Foundation Coeur D’amouris committed to equality in its provision of services and in all its employment practices, policies and procedures. This includes recruitment, training, remuneration and promotion and equal terms and conditions of employment. It is committed to the creation of a non-discriminatory working environment. This policy applies to employees whether part-time, full-time, fixed term or temporary, contractors, volunteers and trustees. Statement of values Foundation Coeur D’amour aims to The provision of education and training to enable such people to integrate and adapt to life within the wider community. The relief of those in need because of youth, age, ill health, disability, financial hardship or other disadvantage in London in such ways as the trustees see fit from time to time. We are committed to social justice and working with those who are most excluded and disadvantaged. Foundation Coeur D’amour celebrates our society as diverse in race, culture, faith and other beliefs, sexuality, abilities, gender and age. Foundation Coeur D’amour is committed to challenging disadvantage and inequality and aims to promote diversity and equality in all areas of its work and structures. Foundation Coeur D’amourbelieves: • In working towards a just and participatory society • That all people have equal rights to work towards social justice and to participate in decision-making processes and local action • That priority should be given to working with communities and groups whose full participation in society is limited by economic disadvantage or discrimination The role of La Juliette is to affirm and enable people who may well feel quite frightened and isolated to adjust to and adapt to life in a culture and environment that is very different to what they have been used to. This organisation’s services will help these people to better integrate into the way of life in the UK help them to become more self-supporting and hopefully enable them to make a positive contribution to their local community. • Discrimination Direct Discrimination is when you treat someone less favourably than others for unlawful means, for example not employing someone because of their gender or disability. Foundation Coeur D’amour will treat direct discrimination as a disciplinary matter. Indirect Discrimination is when a policy, practice or procedure that applies to everyone might disadvantage a particular group, and which cannot be justified in relation to the job. La Juliette will monitor and regularly review its policies, practices and procedures in order to ensure that they do not disadvantage any particular group. Discrimination by association is direct discrimination against someone because they associate with another person who possesses one of the applicable protected characteristics (age, disability, gender reassignment, sex, race, religion or belief and sexual orientation). It is unlawful and Foundation Coeur D’amour will treat it as a disciplinary manner. Perception discrimination is direct discrimination against an individual because others think they possess a particular protected characteristic. It applies even if the person does not possess that characteristic. It is unlawful and La Juliette will treat it as a disciplinary matter in relation to age, race, religion or belief, sexual orientation, disability, gender reassignment and sex Harassment is unwanted conduct that violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive working environment. La Juliette will treat harassment as a disciplinary matter. Victimisation is when you treat someone less favourably or discriminate against them because they have pursued or intend to pursue their rights relating to alleged discrimination. La Juliette will treat victimisation as a disciplinary matter. Positive discrimination is unlawful. Positive action to address imbalances in the workforce is allowed in particular circumstances. Examples would include setting equality targets (but not quotas which are unlawful); encouraging people from particular groups to apply where they are under-represented; and training for promotion or skill training for employees from under-represented groups who show potential. Foundation Coeur D’amour will use positive action to address imbalances that are apparent from monitoring data. Statement of intent Our intention is to ensure that no user of La Juliette services, job applicant or employee receives less favourable treatment due to a protected characteristic (i.e. age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation), unrelated criminal convictions, or membership or non-membership of a trade union. All employees have a responsibility to cooperate with measures to ensure equal opportunity and non-discrimination. We aim to create a culture that respects and values each other’s differences, that promotes dignity, equality and diversity, and that encourages individuals to develop and maximise their true potential. We aim to remove any barriers, bias or discrimination that prevent individuals or groups from realising their potential and contributing fully to La Juliette performance and to develop an organisational culture that positively values diversity. We are committed wherever practicable, to achieving and maintaining a workforce that broadly reflects the local community in which we operate. Every possible step will be taken to ensure that individuals are treated fairly as users of Foundation Coeur D’amour services and in all aspects of their employment at La Juliette. Legislation You should be aware that whilst an employer can be held liable in law for acts of discrimination committed by employees, individual employees can also be held personally liable in law for acts of discrimination that they commit, authorise, contribute to or condone. You should therefore be aware that the following acts are unlawful and would constitute misconduct or gross misconduct liable to disciplinary action, which may include summary dismissal: • Discriminating in the course of employment or prospective employment against fellow or future employees in job, transfer or promotion applications on the grounds established in this Equality Policy • Inducing or attempting to induce employees to practise unlawful discrimination • Indulging in verbal or physical, sexual or racial harassment of a nature that is known, or should be known, to be offensive to the victim • Victimising individuals who have made allegations or complaints of any discrimination or harassment or provided information about such discrimination or harassment Every employee is responsible for ensuring Foundation Coeur D’amour Equality Policy is applied to our dealings with our clients and suppliers and should, in addition, be aware that it is unlawful to commit, authorise, contribute to or condone acts of discrimination on the grounds of a protected characteristic (i.e. age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation), in the provision of goods and services. Breaches of the policy by suppliers could result in termination of contracts for services. Full details of relevant legislation that Foundation Coeur D’amour will apply can be found in Appendix A Implementation Trustees is responsible for the policy’s day-to-day implementation. Consultation will take place with all staff about the implementation and development of this policy. La Juliette will collect monitoring information about the implementation of this policy and from this information will produce an action plan detailing how it will promote equality through its work. To achieve a workforce that is truly representative of all sections of society selection for employment or promotion or any other benefit will be on the basis of merit and ability only. Selection for training will be on the basis of job requirements only. Intimidation, harassment and bullying will not be tolerated and may lead to disciplinary action. If you perceive a problem in recruitment, selection, training, promotion or the application of terms and conditions of employment you should raise it in the first instance with your line manager or another appropriate manager. All cases of such behaviour will be investigated and we will treat all complaints fairly, quickly and with confidentiality. Any grievance arising from the Equality Policy will be dealt with using the existing Grievance Procedure. Any employee who has taken action, in good faith, over allegations of discrimination or harassment, will not be victimised by being treated any less favourably than any other employee as a consequence of taking such action. Foundation Coeur D’amour will monitor the practical effects of the policy by regularly collecting and reviewing relevant information. You are expected to co-operate in work being undertaken to monitor, review and implement this policy. We will use our induction, supervision, appraisal and learning and development policies to ensure that staff and trustees have the skills to support good practice on equality and diversity. We will use the supervision and appraisal process to encourage staff to make suggestions and contribute to the ways in which we promote equality as an organisation and with the users of our services. We will ensure that venues that we use for meetings, workshops and training events are accessible and will make reasonable adjustments where necessary. We will aim to ensure that our communications are accessible, including our web site. When necessary we will make specific provision, such as the engaging a British Sign Language interpreter, to ensure that our communication is accessible. We will bring this policy to the attention of our trustees, staff, volunteers, suppliers and service users when they join Foundation Coeur D’amour and by making use of our communications. We will monitor the use of our services and make use of this monitoring information when planning future developments. Review The Trustee Board will keep this policy under review, with input from the Management Team and staff. This review and our action plan will be included as part of our annual Business Plan. Appendix A In it employment practices and service provision Foundation Coeur D’amour will take full account of the following legislation: The Equality Act 2010 • Consolidates previous legislation. It is unlawful to treat somebody less favourably than another person because of a protected characteristic i.e.race; age; disability; gender reassignment; religion or belief; sex; sexual orientation; marriage and civil partnership; and pregnancy and maternity • It is unlawful to discriminate against somebody because they associate with another person on grounds of age, disability, gender reassignment, race, religion or belief, sex ,sexual orientation • It is unlawful to discriminate against somebody because others think they possess one of these protected characteristics: Age, disability, gender reassignment, race, religion or belief, sex ,sexual orientation • It is unlawful to have a rule or policy that applies to everyone but disadvantages people with the following protected characteristics: Age, disability, gender reassignment, race, religion or belief, sex ,sexual orientation; marriage and civil partnership • Employees can complain about behaviour that they find offensive even if it is not directed at them on the basis of the following protected characteristics: Age, disability, gender reassignment, race, religion or belief, sex ,sexual orientation • Employers are potentially liable for harassment of their staff by people they don’t employ on the basis of the following protected characteristics: Age, disability, gender reassignment, race, religion or belief, sex ,sexual orientation • It is unlawful to treat somebody badly (victimisation) because they have made or supported a complaint or grievance under the Act (applies to all protected characteristics) Rehabilitation of Offenders Act 1974 • Ex-offenders have certain employment rights if their convictions become ‘spent’, including not having to declare spent convictions and protecting them against dismissal or exclusion (with certain exceptions such as for those working with children). Part-time Workers (Prevention of Less Favourable Treatment) Regulations 2000 • The regulations aim to ensure that part-time workers are not treated less favourably than comparable full-time workers, including having the same rates of pay and pro rata holiday entitlement. Fixed-term Employees (Prevention of Less Favourable Treatment) Regulations 2002 • The regulations aim to ensure that employees on fixed-term contracts are treated no less favourably than comparable permanent employees, including having the same terms and conditions of employment. The Asylum and Immigration Act 1996 • This places a responsibility on employers to ensure that all employees are not in breach of immigration rules. It covers the checks that an employer must do to ensure that employees are eligible to work in the UK, checking passports, visas etc.

Safeguarding

Provide simple, practical help in people’s home, such as helping with the cooking, cleaning and washing, helps people to get out and about to local park or city centre and to get to certain key places such as schools, doctors, shop, social services and so on. Foundation Coeur D’amour will not tolerate the abuse of adults in any of its forms and is committed to safeguarding adults with care and support needs from harm.

This policy outlines the steps Foundation Coeur D’amour will take to safeguard an adult with care and support needs if they are deemed to be at risk or at risk. This policy sets out the roles and responsibilities of Foundation Coeur D’amour in working together with other professionals and agencies in promoting the adult’s welfare and safeguard them from abuse and neglect. Foundation Coeur D’amour will ensure that decisions made will allow adults to make their own choices and include them in any decision-making. Foundation Coeur D’amour will also ensure that safe and effective working practices are in place. This policy is intended to support staff and volunteers working within Foundation Coeur D’amour to understand their role and responsibilities in safeguarding adults. All staff and volunteers are expected to follow this policy. The key objectives of this policy are for all employees and volunteers of Foundation Coeur D’amour to: • have an overview of adult safeguarding. • be clear about their responsibility to safeguard adults. • ensure the necessary actions are taken when an adult with care and support needs is deemed to be at risk. This policy is based on: – The Care Act 2014 and the Care and Support statutory guidance – London Safeguarding Adults policy and procedures – Islington Safeguarding Adults Board’s local procedures and appendices Under the Human Rights Act 1998, everyone has the right to live free from abuse and neglect. https://www.equalityhumanrights.com/en/human-rights/human-rights-act Copies of this policy should be available within Foundation Coeur D’amour and Foundation Coeur D’amour will not tolerate the abuse of adults in the organisation and staff and volunteers should be made aware of how this policy can be accessed.

What is Safeguarding adults?

‘Safeguarding means protecting an adult’s right to live in safety, free from abuse and neglect. It is about people and organisations working together to prevent and stop both the risks and experience of abuse or neglect, while at the same time making sure that the adult’s well-being is promoted including, where appropriate, having regard to their views, wishes, feelings and beliefs in deciding on any action. This must recognise that adults sometimes have complex interpersonal relationships and may be ambivalent, unclear or unrealistic about their personal circumstances.’ Care and Support Statutory Guidance, Department of Health, updated February 2017 All adults should be able to live free from fear and harm. But some may find it hard to get the help and support they need to stop abuse. An adult may be unable to protect themselves from harm or exploitation due to many reasons, including their mental or physical incapacity, sensory loss or physical or learning disabilities. This could be an adult who is usually able to protect themselves from harm but maybe unable to do so because of an accident, disability, frailty, addiction or illness. Foundation Coeur D’amour adheres to following the six key principles that underpin safeguarding work (See Care Act guidance) – Empowerment – Prevention – Proportionality – Protection – Partnership – Accountability Foundation Coeur D’amour will not tolerate the abuse of adults in staff and volunteers should ensure that their work reflects the principles above and ensure the adult with care and support needs is involved in their decisions and informed consent is obtained. LA JULIETTE should ensure that the safeguarding action agreed is the least intrusive response to the risk. Partners from the community should be involved in any safeguarding work in preventing, detecting and reporting neglect and abuse. Foundation Coeur D’amour should be transparent and accountable in delivering safeguarding actions. What is Making Safeguarding Personal (MSP)? MSP means a case should be person-led and outcome-focused. The individual should be involved in identifying how best to respond to their safeguarding situation by giving them more choice and control as well as improving quality of life, wellbeing and safety. Foundation Coeur D’amour will not tolerate the abuse of adults Foundation Coeur D’amour will ensure that adults are involved in their safeguarding arrangements and each individual is dealt with on a case by case basis. As adults may have different preferences, histories and lifestyles, the same process may not work for all. Who do adult safeguarding duties apply to? The Care Act 2014 sets out that adult safeguarding duties apply to any adult who: • has care and support needs, and • is experiencing, or is at risk of, abuse and neglect, and • is unable to protect themselves from either the risk of, or the experience of abuse or neglect, because of those needs. Who do I go to if I am concerned? The named responsible person for safeguarding duties for Foundation Coeur D’amour is [Consider providing an out-of-hours contact number should this apply to your organisation]. All staff and volunteers should contact Foundation Coeur D’amour for any concerns/queries they have in regard to safeguarding adults. [An alternative name can be provided if relevant for your organisation]. A log of the concern must be kept. Foundation Coeur D’amour will be responsible for making decisions about notifying adult social services if required and consider alternative actions, where necessary. Foundation Coeur D’amour will also ensure that the safeguarding adult’s policies and procedures are in place and up to date. They will ensure a safe environment is promoted for staff volunteers and adults accessing the service Juliana Forbes will ensure they are up to date with their safeguarding adults training. What should I do if I am concerned? Staff and volunteers at Foundation Coeur D’amour who have any adult safeguarding concerns should: 1. Respond – Take emergency action if someone is at immediate risk of harm/in need of urgent medical attention. Dial 999 for emergency services. – Get brief details about what has happened and what the adult would like done about it, but do not probe or conduct a mini investigation. – Seek consent from the adult to take action and to report the concern. Consider whether the adult may lack the capacity to make decisions about their own and other people’s safety and well-being. If you decide to act against their wishes or without their consent, you must record your decision and the reasons for this. 2. Report – Name the person to whom staff/volunteers need to report any potential safeguarding concerns. This will usually be the organisation’s designated safeguarding lead (see above) 3. Record – We will create a safeguarding reporting form to ensure that we receive all the information we need for accurate and useful reporting. – As far as possible, records should be written contemporaneously, dated and signed. – Keep records about safeguarding concerns confidential and in a location where the alleged abuser will not have access to the record. Access should not be given to any unauthorised personnel for accessing confidential information including the sharing of passwords. 4. Refer In making a decision whether to refer or not, the designated safeguarding lead should take into account: (1) the adult’s wishes and preferred outcome (2) whether the adult has mental capacity to make an informed decision about their own and others’ safety (3) the safety or wellbeing of children or other adults with care and support needs (4) whether there is a person in a position of trust involved (5) whether a crime has been committed This should inform the decision whether to notify the concern to the following people: o the police if a crime has been committed and/or o Islington’s Access & Advice Team (part of adult social services) for possible safeguarding enquiry o relevant regulatory bodies such as Care Quality Commission, Ofsted, Charities commission o service commissioning teams o family/relatives as appropriate (seek advice from adult social services) The designated safeguarding lead should keep a record of the reasons for referring the concern or reasons for not referring. Incidents of abuse may be one-off or multiple and may affect one person or more. Staff and volunteers should look beyond single incidents to identify patterns of harm. Accurate recording of information will also assist in recognising any patterns. As soon as Adult Social Services becomes involved, a 4-stage safeguarding adults process is followed. For more information about this 4-stage safeguarding adults process, refer to the London Safeguarding Adults Procedures. What are your roles and responsibilities? All staff, management, trustees and volunteers at Foundation Coeur D’amour are expected to report any concerns to the named person for safeguarding. If the allegation is against one of Foundation Coeur D’amour’s members, volunteers, trustees or directors, seek advice from Foundation Coeur D’amour safeguarding lead Foundation Coeur D’amourIf the allegation is against the safeguarding lead, seek advice from Islington’s Access & Advice Team. [If your organisation has a separate policy on Person’s in Positions of Trust, include a link to it]. The designated safeguarding adult lead should be responsible for providing acknowledgement of the referral and brief feedback to the person raising the original concern. Feedback should be given in a way that will not make the situation worse or breach the Data Protection Act. If the police are involved, they should be consulted prior to giving feedback to the referrer to ensure any criminal investigation is not affected. The local authority will decide on who will lead on a safeguarding enquiry should it progress to that stage. The named organisation should not conduct its own safeguarding enquiry unless instructed to do so by the local authority. Staff and volunteers should ensure that the adult with care and support needs is involved at all stages of their safeguarding enquiry ensuring a person-centred approach is adopted. Complaints procedure Foundation Coeur D’amour promotes transparency and honesty when things go wrong. All staff and volunteers should apologise and be honest with service users and other relevant people when things go wrong. Foundation Coeur D’amour is registered with the Charity Commission and therefore all staff and volunteers have a legal Duty of Candour to give a full and honest explanation to people about when things go wrong. If a staff or volunteer or any other member of the organisation is unhappy with Foundation Coeur D’amour decision about the safeguarding concern, refer them to Foundation Coeur D’amour is committed to ensuring that staff and volunteers who in good faith whistle-blow in the public interest, will be protected from reprisals and victimisation. The Mental Capacity Act 2005 is to be used when decisions on behalf of those adults with care and support needs who are unable to make some decisions for themselves. Refer to the Mental Capacity Act Code of Practice, https://www.gov.uk/government/publications/mental-capacity-act-code-of-practice. You will need to involve an advocate if the person lacks capacity to make decisions about the safeguarding concern. Why is it important to take action? It may be difficult for adults with care and support needs to protect themselves and to report abuse. They rely on you to help them. Confidentiality and information sharing
Foundation Coeur D’amour expects all staff, volunteers, and trustees to maintain confidentiality at all times. In line with Data Protection law, LA JULIETTE does not share information if not required.

It should however be noted that information should be shared with authorities if an adult is deemed to be at risk of immediate harm. Sharing the right information, at the right time, with the right people can make all the difference to preventing harm. For further guidance on information sharing and safeguarding see: https://www.scie.org.uk/care-act-2014/safeguarding-adults/sharing-information/keymessages.asp

Foundation Coeur D’amour is signed up to the Islington Safeguarding Adults Board information sharing agreement. Recruitment and selection Foundation Coeur D’amour is committed to safe employment. Safe recruitment practices, such as Disclosure and Barring checks reduce the risk of exposing adults with care and support needs to people unsuitable to work with them. Refer to the council’s guidance on Safer Recruitment (please note this guidance is currently being updated). Training, awareness raising and supervision? Foundation Coeur D’amour ensures that all staff and volunteers receive basic awareness training on safeguarding adults as they may come across adults with care and support needs who may be at risk of abuse. Those adults may report things of concern to staff or volunteers who should be equipped with the basic knowledge around safeguarding adults and be confident to identify that abuse is taking place and action is required. All staff and volunteers should be clear about the core values of Foundation Coeur D’amour and commitment to safeguarding adults. It is also useful to discuss training with staff who have attended training sessions to ensure they are embedding this in practice. Voluntary organisations (including volunteers) who support adults with care and support needs can access the basic awareness safeguarding adults training provided by Islington Council. Free online training is also available. See: https://www.islington.gov.uk/social-care-and-health/support-for-professionals/courses-for-professionals Similarly, staff and volunteers may encounter concerns about the safety and well-being of children. For more information about children’s safeguarding, refer to LA JULIETTE Children’s safeguarding policy [insert link to your internal policy]

Prevent

Radicalisation and extremism of adults with care and support needs is a form of emotional/psychological exploitation. Radicalisation can take place through direct personal contact, or indirectly through social media. If staff are concerned that an adult with care and support needs is at risk of being radicalised and drawn into terrorism, they should treat it in the same way as any other safeguarding concern. For more information about Prevent see: https://www.gov.uk/government/publications/prevent-duty-guidance

Useful contacts

Foundation Coeur D’amour. 7 BELL YARD
LONDON WC2A 2JR – Tel: 07904 395293 Email: contact.amour.trust@gmail.com

Useful links:

London Safeguarding adults policy and procedures- http://londonadass.org.uk/wp-content/uploads/2015/02/LONDON-MULTI-AGENCY-ADULT-SAFEGUARDING-POLICY-AND-PROCEDURES.pdf Safer recruitment- http://www.islingtonscb.org.uk/SiteCollectionDocuments/Safer%20recruitment%20-%20safeguarding%20children%20and%20adults%205%20August%2013.pdf Carer and support statutory guidance-https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/506202/23902777_Care_Act_Book.pdf Prevent- https://www.gov.uk/government/publications/prevent-duty-guidance Information sharing- https://www.scie.org.uk/care-act-2014/safeguarding-adults/sharing-information/keymessages.asp Appendix 1 What are the types of safeguarding adults abuse? The Care and Support statutory guidance sets out the 10 main types of abuse: • Physical abuse • Neglect • Sexual abuse • Psychological • Financial abuse • Discriminatory • Organisational • Domestic violence • Modern Slavery • Self-neglect However, you should keep an open mind about what constitutes abuse or neglect as it can take many forms and the circumstances of the individual case should always be considered. For more information, read section 14.17 of the Care and Support Statutory Guidance. What are the possible signs of abuse? Abuse and neglect can be difficult to spot. You should be alert to the following possible signs of abuse and neglect: • Depression, self-harm or suicide attempts • Difficulty making friends. • Fear or anxiety • The person looks dirty or is not dressed properly, • The person never seems to have money, • The person has an injury that is difficult to explain (such as bruises, finger marks, ‘non-accidental’ injury, neck, shoulders, chest and arms), • The person has signs of a pressure ulcer, • The person is experiencing insomnia. • The person seems frightened or frightened of physical contact. • Inappropriate sexual awareness or sexually explicit behaviour • The person is withdrawn, and changes in behaviour. You should ask the person if you are unsure about their well-being as there may be other explanations to the above presentation. Who abuses and neglects adults?

Abuse can happen anywhere, even in somebody’s own home. Most often abuse takes place by others who are in a position of trust and power. It can take place whether an adult lives alone or with others. Anyone can carry out abuse or neglect, including:
• partners;
• other family members;
• neighbours;
• friends;
• acquaintances;
• local residents;
• people who deliberately exploit adults they perceive as vulnerable to abuse;
• paid staff or professionals; and
• volunteers and strangers