Your Policies

1.                Maintaining appropriate standard of dress code

1.1              We encourage everyone to maintain an appropriate standard of dress and personal appearance at work.

1.2              Failure to comply with the dress code may result in action under our Disciplinary Procedure.

1.3              We will review our dress code periodically to ensure that it reflects appropriate standards and continues to meet our needs.

1.4              This policy does not form part of any employee's contract of employment and we may amend it at any time.

2.                Appearance

2.1              While working for us you represent us with customers, clients and the public. Your appearance contributes to our reputation and the development of our business.

2.2              It is important that you appear clean at all times when at work.

2.3              Footwear must be safe and clean and take account of health and safety considerations.

2.4              Where we provide safety clothing and equipment, including protective footwear, it should be worn or used as appropriate and directed.

2.5              You should not wear clothing or jewellery that could present a health and safety risk.

3.                Religious and cultural dress

3.1              You may wear appropriate religious and cultural dress (including clerical collars, head scarves, skullcaps and turbans) unless it creates a health and safety risk to you or any other person or otherwise breaches this policy.

3.2              Priority is at all times given to health and safety requirements.

See also: Expenses - 'How to claim' 

1.                Reimbursement of expenses

1.1              We will reimburse expenses properly incurred in accordance with this policy. Any attempt to claim expenses fraudulently or otherwise in breach of this policy may result in disciplinary action.

1.2              Expenses will only be reimbursed if they are:

(a)           submitted on the appropriate claim form;

(b)          submitted within 7 days of being incurred;

(c)           supported by relevant documents (for example, VAT receipts, tickets, and credit or debit card slips); and

(d)          authorised in advance where required.

1.3              Claims for authorised expenses submitted in accordance with this policy will be paid directly into your bank/building society account via payroll.

1.4              Any questions about the reimbursement of expenses should be put to your manager before you incur the relevant costs.

1.                Equal opportunities statement

1.1              Billing Better Limited is committed to promoting equal opportunities in employment. You and any job applicants will receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (Protected Characteristics).

2.                Discrimination

2.1              You must not unlawfully discriminate against or harass other people including current and former employees, job applicants, clients, customers, suppliers and visitors. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts), and on work events including social events.

3.                Recruitment and selection

3.1              Recruitment, promotion and other selection exercises such as redundancy selection will be conducted on the basis of merit, against objective criteria that avoid discrimination. Shortlisting should be done by more than one person if possible.

3.2              Vacancies should generally be advertised to a diverse section of the labour market. Advertisements should avoid stereotyping or using wording that may discourage particular groups from applying.

3.3              Job applicants should not be asked questions which might suggest an intention to discriminate on grounds of a Protected Characteristic. For example, applicants should not be asked whether they are pregnant or planning to have children.

3.4              Job applicants should not be asked about health or disability before a job offer is made.

4.                Disabilities

4.1              If you are disabled or become disabled, we encourage you to tell us about your condition so that we can consider what reasonable adjustments or support may be appropriate.

5.                Part-time and fixed-term work

5.1              Part-time and fixed-term employees should be treated the same as comparable full-time or permanent employees and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate), unless different treatment is justified.

1.                What is harassment?

1.1              Billing Better Limited is committed to providing a working environment free from harassment and bullying and ensuring all staff are treated, and treat others, with dignity and respect.

1.2              Harassment is any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment.

1.3              It also includes treating someone less favourably because they have submitted or refused to submit to such behaviour in the past.

1.4              Unlawful harassment may involve conduct of a sexual nature (sexual harassment), or it may be related to age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. Harassment is unacceptable even if it does not fall within any of these categories.

1.5              Harassment may include, for example:

(a)           unwanted physical conduct or "horseplay", including touching, pinching, pushing and grabbing;

(b)          unwelcome sexual advances or suggestive behaviour (which the harasser may perceive as harmless);

(c)           offensive e-mails, text messages or social media content;

(d)          mocking, mimicking or belittling a person's disability.

1.6              A person may be harassed even if they were not the intended "target". For example, a person may be harassed by racist jokes about a different ethnic group if the jokes create an offensive environment.

2.                What is bullying?

2.1              Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined or threatened. Power does not always mean being in a position of authority, but can include both personal strength and the power to coerce through fear or intimidation.

2.2              Bullying can take the form of physical, verbal and non-verbal conduct. Bullying may include, by way of example:

(a)           physical or psychological threats;

(b)          overbearing and intimidating levels of supervision;

(c)           inappropriate derogatory remarks about someone's performance;

2.3              Legitimate, reasonable and constructive criticism of a worker's performance or behaviour, or reasonable instructions given to workers in the course of their employment, will not amount to bullying on their own.

3.                If you are being harassed or bullied

3.1              If you are being harassed or bullied, consider whether you feel able to raise the problem informally with the person responsible. You should explain clearly to them that their behaviour is not welcome or makes you uncomfortable. If this is too difficult or embarrassing, you should speak to your manager, who can provide confidential advice and assistance in resolving the issue formally or informally.

3.2              If informal steps are not appropriate, or have not been successful, you should raise the matter formally under our Grievance Procedure.

3.3              We will investigate complaints in a timely and confidential manner.

3.4              Once the investigation is complete, we will inform you of our decision. If we consider you have been harassed or bullied by an employee the matter will be dealt with under the Disciplinary Procedure as a case of possible misconduct or gross misconduct. If the harasser or bully is a third party such as a customer or other visitor, we will consider what action would be appropriate to deal with the problem. Whether or not your complaint is upheld, we will consider how best to manage any ongoing working relationship between you and the person concerned.

4.                Protection and support for those involved

4.1              Staff who make complaints or who participate in good faith in any investigation must not suffer any form of retaliation or victimisation as a result. Anyone found to have retaliated against or victimised someone in this way will be subject to disciplinary action under our Disciplinary Procedure.

5.                Record-keeping

5.1              Information about a complaint by or about an employee may be placed on the employee's personnel file, along with a record of the outcome and of any notes or other documents compiled during the process.

1.                What is bribery?

1.1              Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

1.2              Bribery includes offering, promising, giving, accepting or seeking a bribe.

1.3              All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your manager.

1.4              Specifically, you must not:

(a)           give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;

(b)          accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;

(c)           give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure.

1.5              You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

2.                Gifts and hospitality

2.1              This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services. You must declare to your manager, and keep a written record of all hospitality or gifts given or received.

1.                What is whistleblowing?

1.1              We are committed to conducting our business with honesty and integrity and we expect all staff to maintain high standards. Any suspected wrongdoing should be reported as soon as possible.

1.2              Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. This includes bribery, facilitation of tax evasion, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations.

2.                How to raise a concern

2.1              We hope that in many cases you will be able to raise any concerns with your manager. However, where you prefer not to raise it with your manager for any reason, you should contact any member of the management team.

2.2              We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.

3.                Confidentiality

3.1              We hope that staff will feel able to voice whistleblowing concerns openly under this policy. Completely anonymous disclosures are difficult to investigate. If you want to raise your concern confidentially, we will make every effort to keep your identity secret and only reveal it where necessary to those involved in investigating your concern.

4.                External disclosures

4.1              The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice before reporting a concern to anyone external. Protect (Independent Whistleblowing charity) operates a confidential helpline Helpline: 0203 117 2520, whistle@pcaw.co.uk and www.pcaw.co.uk.

5.                Protection and support for whistleblowers

5.1              We aim to encourage openness and will support whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken. Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform your manager immediately.

5.2              However, if we conclude that a whistleblower has made false allegations maliciously, the whistleblower may be subject to disciplinary action.

See also Time Off

1.                Your holiday entitlement

1.1              The company's holiday year runs from 1 January to 31 December. If your employment starts or finishes part way through the holiday year, your holiday entitlement during that year shall be calculated on a pro-rata basis rounded up to the nearest half day.

1.2              Unless otherwise set out in your employment contract, you are entitled to 25 days' paid holiday in each holiday year, or the pro rata equivalent if you work part-time. This does not include the usual public holidays as observed in England and Wales.

1.3              Except as set out in this policy, holiday entitlement must be taken during the holiday year in which it accrues. Any holiday not taken by the end of the holiday year will be lost and you will not receive any payment in lieu.

1.4              Unused holiday can only be carried over to another holiday year:

(a)           By special arrangement with your manager (up to 5 days only);

(b)          in cases involving long term sickness absence;

(c)           in cases of maternity, paternity, adoption, parental or shared parental leave; and

(d)          if otherwise required by law.

2.                Taking holiday

2.1              All holiday must be approved in advance by your manager. You should normally give at least four weeks' notice of holiday requests to allow planning of work schedules where necessary. You must not make travel bookings until approval has been given.

2.2              We may require you to take (or not to take) holiday on particular dates, including when the business is closed, particularly busy, or during your notice period.

3.                Sickness during periods of holiday

3.1              If you are sick or injured during a holiday period and would have been incapable of work, you may choose to treat the period of incapacity as sick leave and reclaim the affected days of holiday.

3.2              Employees already on sick leave before a pre-arranged period of holiday may choose to cancel any days of holiday that coincide with the period of incapacity and treat them as sick leave.

3.3              Dishonest claims or other abuse of this policy will be treated as misconduct under our disciplinary procedure.

4.                Long-term sickness absence and holiday entitlement

4.1              Holiday entitlement continues to accrue during periods of sick leave.

4.2              If you are on a period of sick leave which spans two holiday years, or if you return to work after sick leave so close to the end of the holiday year that you cannot reasonably take your remaining holiday, you may carry over unused holiday to the following leave year.

4.3              Any holiday that is carried over under this rule but is not taken within 18 months of the end of the holiday year in which it accrued will be lost.

4.4              Alternatively you can choose to take your paid holiday during your sick leave, in which case you will be paid at your normal rate.

5.                Family leave and holiday entitlement

5.1              Holiday entitlement continues to accrue during periods of maternity, paternity, adoption, parental or shared parental leave (referred to collectively in this policy as family leave).

5.2              If you are planning a period of family leave that is likely to last beyond the end of the holiday year, you should discuss your holiday plans with your manager in good time before starting your family leave. Any holiday entitlement for the year that cannot reasonably be taken before starting your family leave can be carried over to the next holiday year.

5.3              For the avoidance of doubt this covers your full holiday entitlement.

5.4              Any holiday carried over should be taken immediately before returning to work or within three months of returning to work after the family leave.

6.                Arrangements on termination

6.1              On termination of employment you may be required to use any remaining holiday entitlement during your notice period. Alternatively, you will be paid in lieu of any accrued but untaken holiday entitlement for the current holiday year to date, plus any holiday permitted to be carried over from previous years under this policy or as required by law.

1.                Our procedure

1.1              Minor conduct or performance issues can usually be resolved informally with your manager. This procedure sets out formal steps to be taken if the matter is more serious or cannot be resolved informally.

2.                Investigations

2.1              Before any disciplinary hearing is held, the matter will be investigated. Any meetings and discussions as part of an investigation are solely for the purpose of fact-finding and no disciplinary action will be taken without a disciplinary hearing.

2.2              In some cases of alleged misconduct, we may need to suspend you from work while we carry out the investigation or disciplinary procedure (or both). While suspended, you should not visit our premises or contact any of our customers, suppliers, contractors or staff, unless authorised to do so. Suspension is not considered to be disciplinary action.

3.                The hearing

3.1              We will give you written notice of the hearing, including sufficient information about the alleged misconduct or poor performance and its possible consequences to enable you to prepare. You will normally be given copies of relevant documents and witness statements.

3.2              You may be accompanied at the hearing by a trade union representative or a colleague, who will be allowed reasonable paid time off to act as your companion.

3.3              You should let us know as early as possible if there are any relevant witnesses you would like to attend the hearing or any documents or other evidence you wish to be considered.

3.4              We will inform you in writing of our decision, usually within one week of the hearing.

4.                Disciplinary action and dismissal

4.1              The usual penalties for misconduct or poor performance are:

(a)          Stage 1: First written warning. Where there are no other active written warnings on your disciplinary record, you will usually receive a first written warning. It will usually remain active for six months.

(b)          Stage 2: Final written warning. In case of further misconduct or failure to improve where there is an active first written warning on your record, you will usually receive a final written warning. This may also be used without a first written warning for serious cases of misconduct or poor performance. The warning will usually remain active for 12 months.

(c)           Stage 3: Dismissal or other action. You may be dismissed for further misconduct or failure to improve where there is an active final written warning on your record, or for any act of gross misconduct. Examples of gross misconduct are given below (paragraph 6). You may also be dismissed without a warning for any act of misconduct or unsatisfactory performance during your probationary period.

We may consider other sanctions short of dismissal, including demotion or redeployment to another role (where permitted by your contract), and/or extension of a final written warning with a further review period.

5.                Appeals

5.1              You may appeal in writing within one week of being told of the decision.

5.2              The appeal hearing will, where possible, be held by someone senior to the person who held the original hearing. You may bring a colleague or trade union representative with you to the appeal hearing.

5.3              We will inform you in writing of our final decision as soon as possible, usually within one week of the appeal hearing. There is no further right of appeal.

6.                Gross misconduct

6.1              Gross misconduct will usually result in dismissal without warning, with no notice or payment in lieu of notice (summary dismissal).

6.2              Gross misconduct is a serious breach of contract and includes misconduct which, in our opinion, is likely to prejudice our business or reputation or irreparably damage the working relationship and trust between us. This may include misconduct committed outside of work. The following are examples of matters that are normally regarded as gross misconduct (this list is intended as a guide and is not exhaustive):

(a)           theft or fraud;

(b)          physical violence or bullying;

(c)           deliberate and serious damage to property;

(d)          serious misuse of the organisation's property or name;

(e)          deliberately accessing internet sites containing pornographic, offensive or obscene material;

(f)           serious insubordination;

(g)           unlawful discrimination, victimisation or harassment;

(h)          bringing the organisation into serious disrepute;

(i)            serious incapability at work brought on by alcohol or illegal drugs;

(j)            causing loss, damage or injury through serious negligence;

(k)           a serious breach of health and safety rules;

(l)            a serious breach of confidence.

1.                Our  procedure

1.1              Most grievances can be resolved quickly and informally through discussion with your manager. If this does not resolve the problem you should initiate the formal procedure set out below.

2.                Step 1: written grievance

2.1              You should put your grievance in writing and submit it to your manager. If your grievance concerns your manager you may submit it to another manager or a member of the management team. Your grievance should set out the nature of the complaint, including any relevant facts, dates, and names of individuals involved so that we can investigate it.

3.                Step 2: meeting

3.1              We will arrange a grievance meeting, normally within one week of receiving your written grievance. You should make every effort to attend.

3.2              You may bring a companion to the grievance meeting if you make a reasonable request in advance and tell us the name of your chosen companion. The companion may be either a trade union representative or a colleague, who will be allowed reasonable paid time off from duties to act as your companion.

3.3              If you or your companion cannot attend at the time specified you should let us know as soon as possible and we will try, within reason, to agree an alternative time.

3.4              We may adjourn the meeting if we need to carry out further investigations, after which the meeting will usually be reconvened.

3.5              We will write to you, usually within one week of the last grievance meeting, to confirm our decision and notify you of any further action that we intend to take to resolve the grievance. We will also advise you of your right of appeal.

4.                Step 3: appeals

4.1              If the grievance has not been resolved to your satisfaction you may appeal in writing, stating your full grounds of appeal, within one week of the date on which the decision was sent or given to you.

4.2              We will hold an appeal meeting, normally within two weeks of receiving the appeal. This will be dealt with impartially by a manager who has not previously been involved in the case. You will have a right to bring a companion (see paragraph 3.2).

4.3              We will confirm our final decision in writing, usually within one week of the appeal hearing. There is no further right of appeal.

See also Time Off

1.                Our procedure

1.1              Abuse of sickness absence, including failing to report absence or falsely claiming sick pay will be treated as misconduct under our Disciplinary Procedure.

2.                Reporting when you are sick

2.1              If you cannot attend work because you are sick or injured you should telephone your manager as early as possible.

3.                Evidence of incapacity

3.1              You must complete a self-certification form for sickness absence of up to seven calendar days.

3.2              For absence of more than a week you must obtain a certificate from your doctor stating that you are not fit for work, giving the reason. You must also complete a self-certification form to cover the first seven days. If absence continues beyond the expiry of a certificate, a further certificate must be provided.

3.3              If your doctor provides a certificate stating that you "may be fit for work" you must inform your manager immediately. We will hold a discussion with you about how to facilitate your return to work, taking account of your doctor's advice. If appropriate measures cannot be taken, you will remain on sick leave and we will set a date for review.

4.                Statutory sick pay

4.1              You may be entitled to Statutory Sick Pay (SSP) if you satisfy the relevant statutory requirements. Qualifying days for SSP are Monday to Friday, or as set out in your employment contract. The rate of SSP is set by the government in April each year. No SSP is payable for the first three consecutive days of absence. It starts on the fourth day of absence and may be payable for up to 28 weeks.

5.                Return-to-work interviews

5.1              After a period of sick leave your manager may hold a return-to-work interview with you. The purposes may include:

(a)           ensuring you are fit for work and agreeing any actions necessary to facilitate your return;

(b)          confirming you have submitted the necessary certificates;

(c)           updating you on anything that may have happened during your absence;

(d)          raising any other concerns regarding your absence record or your return to work.

6.                Managing long-term or persistent absence

6.1              The following paragraphs set out our procedure for dealing with long-term absence or where your level or frequency of short-term absence has given us cause for concern. The purpose of the procedure is to investigate and discuss the reasons for your absence, whether it is likely to continue or recur, and whether there are any measures that could improve your health and/or attendance. We may decide that medical evidence, or further medical evidence, is required before deciding on a course of action.

6.2              We will notify you in writing of the time, date and place of any meeting, and why it is being held. We will usually give you a week's notice of the meeting.

6.3              Meetings will be conducted by your manager.

6.4              If you cannot attend at the time specified you should let us know as soon as possible and we will try, within reason, to agree an alternative time.

6.5              If you have a disability, we will consider whether reasonable adjustments may need to be made to the sickness absence meetings procedure, or to your role or working arrangements.

7.                Medical examinations

7.1              We may ask you to consent to a medical examination by a doctor or occupational health professional or other specialist nominated by us (at our expense).

7.2              You will be asked to agree that any medical report produced may be disclosed to us and that we may discuss the contents of the report with the specialist and with our advisers. All medical reports will be kept confidential and held in accordance with our Data Protection Policy.

8.                Initial sickness absence meeting

8.1              The purposes of a sickness absence meeting or meetings will be to discuss the reasons for your absence, how long it is likely to continue, whether it is likely to recur, whether to obtain a medical report, and whether there are any measures that could improve your health and/or attendance.

8.2              In cases of long-term absence, we may seek to agree a return-to-work programme, possibly on a phased basis.

8.3              In cases of short-term, intermittent absence, we may set a target for improved attendance within a certain timescale.

9.                If matters do not improve

9.1              If, after a reasonable time, you have not been able to return to work or if your attendance has not improved within the agreed timescale, we will hold a further meeting or meetings. We will seek to establish whether the situation is likely to change, and may consider redeployment opportunities at that stage. If it is considered unlikely that you will return to work or that your attendance will improve within a short time, we may give you a written warning that you are at risk of dismissal. We may also set a further date for review.

10.              Final sickness absence meeting

10.1           Where you have been warned that you are at risk of dismissal, and the situation has not changed significantly, we will hold a meeting to consider the possible termination of your employment. Before we make a decision, we will consider any matters you wish to raise and whether there have been any changes since the last meeting.

11.              Appeals

11.1           You may appeal against the outcome of any stage of this procedure. If you wish to appeal you should set out your appeal in writing, stating your grounds of appeal, within one week of the date on which the decision was sent or given to you.

11.2           If you are appealing against a decision to dismiss you, we will hold an appeal meeting, normally within two weeks of receiving the appeal. This will be dealt with impartially.

11.3           We will confirm our final decision in writing, usually within one week of the appeal hearing. There is no further right of appeal.

11.4           The date that any dismissal takes effect will not be delayed pending the outcome of an appeal. However, if the appeal is successful, the decision to dismiss will be revoked with no loss of continuity or pay.

Under review - pending improved terms! Please check in with HR :)

1.                Entitlement to maternity leave

1.1              If you are pregnant you may take reasonable paid time off during working hours for antenatal appointments. You should try to give us as much notice as possible of the appointment. Unless it is your first appointment, we may ask to see a certificate confirming your pregnancy and an appointment card. The other parent may take unpaid time off to accompany a pregnant woman to an antenatal appointment. You should try to give us as much notice as possible of the appointment.

1.2              All employees are entitled to up to 52 weeks' maternity leave, consisting of 26 weeks' ordinary maternity leave (OML) and 26 weeks' additional maternity leave (AML).

2.                Notification

2.1              Please inform us as soon as possible that you are pregnant. This is important as there may be health and safety considerations.

2.2              Before the end of the fifteenth week before the week that you expect to give birth (Qualifying Week), or as soon as reasonably practical afterwards, you must tell us:

(a)           the week in which your doctor or midwife expects you to give birth (Expected Week of Childbirth); and

(b)          the date on which you would like to start your maternity leave (Intended Start Date).

2.3              We will write to you within 28 days to tell you the date we will expect you to return to work if you take your full maternity leave entitlement (Expected Return Date).

2.4              Once you receive a certificate from a doctor or midwife confirming your Expected Week of Childbirth (MATB1), you must provide us with a copy.

3.                Starting maternity leave

3.1              The earliest you can start maternity leave is 11 weeks before the Expected Week of Childbirth (unless your child is born prematurely before that date).

3.2              If you want to change your Intended Start Date please tell us in writing. You should give us as much notice as you can, but wherever possible you must tell us at least 28 days before the original Intended Start Date (or the new start date if you are bringing the date forward). We will then write to you within 28 days to tell you your new expected return date.

3.3              Your maternity leave should normally start on the Intended Start Date. However, it may start earlier if you give birth before your Intended Start Date, or if you are absent for a pregnancy-related reason in the last four weeks before your Expected Week of Childbirth. In either of those cases, maternity leave will start on the following day.

3.4              Shortly before your maternity leave is due to start we will discuss with you the arrangements for covering your work and the opportunities for you to remain in contact, should you wish to do so, during your leave. Unless you request otherwise, you will remain on circulation lists for internal news, job vacancies, training and work-related social events.

3.5              The law says that we cannot allow you to work during the two weeks following childbirth.

4.                Maternity pay

4.1              Statutory maternity pay (SMP) is payable for up to 39 weeks provided you have at least 26 weeks' continuous employment with us at the end of the Qualifying Week and your average earnings are not less than the lower earnings limit set by the government each tax year. The first six weeks SMP are paid at 90% of your average earnings and the remaining 33 weeks are at a rate set by the government each year.

5.                During maternity leave

5.1              With the exception of terms relating to pay, your terms and conditions of employment remain in force during OML and AML.

5.2              Holiday entitlement will continue to accrue during maternity leave. If your maternity leave will continue into the next holiday year, any holiday entitlement that is not taken before starting your maternity leave can be carried over and must be taken immediately before returning to work or within three months of returning to work unless your manager agrees otherwise. Please discuss your holiday plans with your manager in good time before starting your maternity leave. All holiday dates are subject to approval by your manager.

5.3              If you are a member of the pension scheme, we shall make employer pension contributions during OML and any period of paid AML, based on your normal salary, in accordance with the pension scheme rules. Any employee contributions you make will be based on the amount of any maternity pay you are receiving, unless you inform the Pensions Administrator that you wish to make up any shortfall.

6.                Keeping in touch

6.1              We may make reasonable contact with you from time to time during your maternity leave although we will keep this to a minimum. This may include contacting you to discuss arrangements for your return to work.

6.2              You may work (including attending training) on up to ten "keeping-in-touch" days during your maternity leave. This is not compulsory and must be discussed and agreed with your manager.

6.3              You will be paid at your normal basic rate of pay for time spent working on a keeping-in-touch day and this will be inclusive of any maternity pay entitlement.

7.                Returning to work

7.1              You must return to work on the Expected Return Date unless you tell us otherwise. If you wish to return to work earlier than the Expected Return Date, you must give us eight weeks' prior notice of the date. It is helpful if you give this notice in writing. You may be able to return later than the Expected Return Date if you request annual leave or parental leave, which will be at our discretion.

7.2              You are normally entitled to return to work in the position you held before starting maternity leave, and on the same terms of employment. However, if you have taken AML and it is not reasonably practicable for us to allow you to return into the same position, we may give you another suitable and appropriate job on terms and conditions that are not less favourable.

7.3              If you want to change your hours or other working arrangements on return from maternity leave you should make a request under our Flexible Working Policy. It is helpful if such requests are made as early as possible.

7.4              If you decide you do not want to return to work you should give notice of resignation in accordance with your contract of employment.

1.                Entitlement to adoption leave

1.1              If you are the primary adopter or adopting a child alone, you may take reasonable paid time off to attend an adoption appointment during working hours, once the agency has notified you that a child is to be placed with you for adoption but before the child is actually placed with you. If you are a secondary adopter, you may take unpaid time off to attend the appointment. You should try to give us as much notice as possible of the appointment.

1.2              You are entitled to adoption leave if you meet all the following conditions:

(a)           You are adopting a child through a UK or overseas adoption agency.

(b)          The adoption agency has given you written notice that it has matched you with a child for adoption and tells you the date the child is expected to be placed into your care with a view to adoption (Expected Placement Date).

(c)           You have notified the agency that you agree to the child being placed with you on the Expected Placement Date.

(d)          Your spouse or partner will not be taking adoption leave with their employer (although they may be entitled to take paternity leave).

1.3              The maximum adoption leave entitlement is 52 weeks, consisting of 26 weeks' Ordinary Adoption Leave (OAL) and 26 weeks' Additional Adoption Leave (AAL).

2.                Notification requirements

2.1              Not more than seven days after the agency notifies you in writing that it has matched you with a child (or where that is not reasonably practicable, as soon as reasonably practicable), you must give us notice in writing of the Expected Placement Date, and your intended start date for adoption leave (Intended Start Date).

2.2              We will then write to you within 28 days to inform you of your expected return date assuming you take your full entitlement to adoption leave.

2.3              Once you receive the matching certificate issued by the adoption agency, you must provide us with a copy.

3.                Starting adoption leave

3.1              OAL may start on a predetermined date no more than 14 days before the Expected Placement Date, or on the date of placement itself, but no later.

3.2              If you want to change your Intended Start Date please tell us in writing. You should give us as much notice as you can, but wherever possible you must tell us at least 28 days before the original Intended Start Date (or the new start date if you are bringing the date forward). We will then write to you within 28 days to tell you your new expected return date.

4.                Adoption pay

4.1              Statutory adoption pay (SAP) is payable for up to 39 weeks provided you have at least 26 weeks' continuous employment with us at the end of the Qualifying Week and your average earnings are not less than the lower earnings limit set by the government each tax year. The first six weeks SAP are paid at 90% of your average earnings and the remaining 33 weeks are at a rate set by the government each year. For further information please speak to your manager.

5.                During adoption leave

5.1              All the terms and conditions of your employment remain in force during OAL and AAL, except for the terms relating to pay.

5.2              Holiday entitlement will continue to accrue at the rate provided under your contract. If your adoption leave will continue into the next holiday year, any holiday entitlement that is not taken or cannot reasonably be taken before starting your adoption leave can be carried over and must be taken immediately before returning to work or within three months of returning to work, unless your manager agrees otherwise. Please discuss your holiday plans with your manager in good time before starting your adoption leave. All holiday dates are subject to approval by your manager.

5.3              If you are a member of the pension scheme, we shall make employer pension contributions during OAL and any further period of paid adoption leave based on your normal salary, in accordance with the pension scheme rules. Any employee contributions you make will be based on the amount of any adoption pay you are receiving, unless you inform the Pensions Administrator that you wish to make up any shortfall.

6.                Keeping in touch

6.1              We may make reasonable contact with you from time to time during your adoption leave although we will keep this to a minimum. This may include contacting you to discuss arrangements for your return to work.

6.2              You may work (including attending training) on up to ten "keeping-in-touch" days during your adoption leave. This is not compulsory and must be discussed and agreed with your manager.

6.3              You will be paid at your normal basic rate of pay for time spent working on a keeping-in-touch day and this will be inclusive of any adoption pay entitlement.

7.                Returning to work

7.1              You must return to work on the expected return date unless you tell us otherwise. If you wish to return to work early, you must give us at least eight weeks' notice of the date. It is helpful if you give this notice in writing. You may be able to return later than the expected return date if you request annual leave or parental leave, which will be at our discretion.

7.2              You are normally entitled to return to work in the position you held before starting adoption leave, on the same terms of employment. However, if you have taken AAL and it is not reasonably practicable for us to allow you to return to the same position, we may give you another suitable and appropriate job on terms and conditions that are not less favourable.

7.3              If you want to change your hours or other working arrangements on return from adoption leave you should make a request under our Flexible Working Policy. It is helpful if such requests are made as early as possible.

7.4              If you decide you do not want to return to work you should give notice of resignation in accordance with your contract of employment.

1.                Entitlement to paternity leave

1.1              Paternity leave is available on the birth of a child if you have been continuously employed by us for at least 26 weeks ending with the 15th week before the Expected Week of Childbirth and either:

(a)           you are the biological father and will have some responsibility for the child's upbringing; or

(b)          you are the partner (that is, spouse, civil partner or cohabiting partner) of the mother, and will have the main responsibility (with the mother) for the child's upbringing; or

(c)           the child is born to a surrogate mother where you are, or your partner is, one of the child's biological parents, and you expect to obtain a parental order giving you and your partner legal responsibility for the child.

1.2              Paternity leave is available where a child is placed with you for adoption by an adoption agency, if you have been continuously employed by us for at least 26 weeks ending with the week in which the agency notifies you that you have been matched with a child.

1.3              In adoption or surrogacy cases you may be entitled to take adoption leave instead (see our Adoption Policy). However, adoption leave may only be taken by one parent. Paternity leave is available to the other parent (of either sex).

2.                Taking paternity leave

2.1              Paternity leave is a period of one or two weeks' consecutive leave taken when a child is born or placed with you for adoption. You can start your leave on the date of birth or placement, or later, provided it is taken within eight weeks (56 days) of the birth or placement. (If the baby is premature the period ends eight weeks after the start of the Expected Week of Childbirth.)

2.2              To take paternity leave you must give us written notice by the end of the 15th week before the Expected Week of Childbirth (or no more than seven days after the adoption agency notified you of being matched with a child), or as soon as you reasonably can, stating:

(a)           the Expected Week of Childbirth;

(b)          whether you intend to take one week or two weeks' leave; and

(c)           when you would like your leave to start.

2.3              You can change the intended start date by giving us 28 days' notice or, if this is not possible, as much notice as you can.

3.                Paternity pay

3.1              Statutory paternity pay (SPP) is payable during paternity leave provided you have at least 26 weeks' continuous employment ending with the Qualifying Week (the 15th week before the Expected Week of Childbirth or the week in which the adoption agency notified you of a match) and your average earnings are not less than the lower earnings limit set by the government each tax year. The rate of SPP is set by the government each tax year.

4.                During paternity leave

4.1              All the usual terms and conditions of your employment remain in force during paternity leave, except for the terms relating to pay.

4.2              Holiday entitlement will continue to accrue during paternity leave. If your paternity leave continues into the next holiday year, any remaining holiday that is not taken or cannot reasonably be taken before your paternity leave can be carried over to the next holiday year and must be taken immediately before returning to work or within three months of returning to work unless your manager agrees otherwise.

4.3              If you are a member of our pension scheme, we will make employer pension contributions during paternity leave, based on your normal salary, in accordance with the scheme rules. Any employee contributions you make will be based on the amount of any paternity pay you are receiving, unless you inform the Pensions Administrator that you wish to make up any shortfall.

1.                Frequently used terms

1.1              The definitions in this paragraph apply in this policy.

                    Expected week of childbirth (EWC): the week, beginning on a Sunday, in which the doctor or midwife expects your child to be born.

                    Parent: One of two people who will share the main responsibility for the child's upbringing (and who may be either the mother, the father, or the mother's partner if not the father).

                    Partner: your spouse, civil partner or someone living with you in an enduring family relationship, but not your sibling, child, parent, grandparent, grandchild, aunt, uncle, niece or nephew.

                    Qualifying Week: the fifteenth week before the EWC.

2.                What is shared parental leave?

2.1              Shared parental leave (SPL) is a form of leave that may be available if your child is expected to be born on or after 5 April 2015.

2.2              It gives you and your partner more flexibility in how to share the care of your child in the first year after birth than simply taking maternity and paternity leave. Assuming you are both eligible, you will be able to choose how to split the available leave between you, and can decide to be off work at the same time or at different times. You may be able to take leave in more than one block.

3.                Entitlement to SPL

3.1              You are entitled to SPL in relation to the birth of a child if:

(a)           you are the child's mother, and share the main responsibility for the care of the child with the child's father or with your partner;

(b)          you are the child's father and share the main responsibility for the care of the child with the child's mother; or

(c)           you are the mother's partner and share the main responsibility for the care of the child with the mother (where the child's father does not share the main responsibility with the mother).

3.2              The following conditions must also be fulfilled:

(a)           you must have at least 26 weeks continuous employment with us by the end of the Qualifying Week, and still be employed by us in the week before the leave is to be taken;

(b)          the other parent must have worked (in an employed or self-employed capacity) in at least 26 of the 66 weeks before the EWC and had average weekly earnings of at least £30 during 13 of those weeks; and

(c)           you and the other parent must give the necessary statutory notices and declarations as summarised below, including notice to end any maternity leave, statutory maternity pay (SMP) or maternity allowance (MA) periods.

3.3              The total amount of SPL available is 52 weeks, less the weeks spent by the child's mother on maternity leave (or the weeks in which the mother has been in receipt of SMP or MA if she is not entitled to maternity leave).

3.4              If you are the mother you cannot start SPL until after the compulsory maternity leave period, which lasts until two weeks after birth.

3.5              If you are the child's father or the mother's partner, you should consider using your two weeks' paternity leave before taking SPL. Once you start SPL you will lose any untaken paternity leave entitlement. SPL entitlement is additional to your paternity leave entitlement.

4.                Opting in to shared parental leave and pay

4.1              Not less than eight weeks before the date you intend your SPL to start, you must give us a written opt-in notice giving:

(a)           your name and the name of the other parent;

(b)          if you are the child's mother, the start and end dates of your maternity leave;

(c)           if you are the child's father or the mother's partner, the start and end dates of the mother's maternity leave, or if she is not entitled to maternity leave, the start and end dates of any SMP or MA period;

(d)          the total SPL available, which is 52 weeks minus the number of weeks' maternity leave, SMP or MA period taken or to be taken;

(e)          how many weeks of the available SPL will be allocated to you and how many to the other parent (you can change the allocation by giving us a further written notice, and you do not have to use your full allocation);

(f)           if you are claiming statutory shared parental pay (ShPP), the total ShPP available, which is 39 weeks minus the number of weeks of the SMP or MA period taken or to be taken);

(g)           how many weeks of available ShPP will be allocated to you and how much to the other parent. (You can change the allocation by giving us a further written notice, and you do not have to use your full allocation);

(h)          an indication of the pattern of leave you are thinking of taking, including suggested start and end dates for each period of leave (see paragraph 9 and paragraph 10 for information on taking leave). This indication will not be binding at this stage, but please give as much information as you can about your future intentions; and

(i)            declarations by you and the other parent that you both meet the statutory conditions to enable you to take SPL and ShPP.

5.                Ending your maternity leave

5.1              If you are the child's mother and want to opt into the SPL scheme, you must give us at least eight weeks' written notice to end your maternity leave (a curtailment notice) before you can take SPL. The notice must state the date your maternity leave will end. You can give the notice before or after you give birth, but you cannot end your maternity leave until at least two weeks after birth.

5.2              You must also give us, at the same time as the curtailment notice, a notice to opt into the SPL scheme (see paragraph 5) or a written declaration that the other parent has given their employer an opt-in notice and that you have given the necessary declarations in that notice.

5.3              The other parent may be eligible to take SPL from their employer before your maternity leave ends, provided you have given the curtailment notice.

5.4              The curtailment notice is binding and cannot usually be revoked. You can only revoke a curtailment notice if maternity leave has not yet ended and one of the following applies:

(a)           if you realise that neither you nor the other parent are in fact eligible for SPL or ShPP, in which case you can revoke the curtailment notice in writing up to eight weeks after it was given;

(b)          if you gave the curtailment notice before giving birth, you can revoke it in writing up to eight weeks after it was given, or up to six weeks after birth, whichever is later; or

(c)           if the other parent has died.

5.5              Once you have revoked a curtailment notice you will be unable to opt back into the SPL scheme, unless paragraph 6.4(b) applies.

6.                Ending your partner's maternity leave or pay

6.1              If you are not the mother, but the mother is still on maternity leave or claiming SMP or MA, you will only be able to take SPL once she has either:

(a)           returned to work;

(b)          given her employer a curtailment notice to end her maternity leave;

(c)           given her employer a curtailment notice to end her SMP (if she is entitled to SMP but not maternity leave); or

(d)          given the benefits office a curtailment notice to end her MA (if she is not entitled to maternity leave or SMP).

7.                Booking your SPL dates

7.1              Having opted into the SPL system, you must book your leave by giving us a period of leave notice. This may be given at the same time as the opt-in notice or later, provided it is at least eight weeks before the start of SPL.

7.2              The period of leave notice can either give the dates you want to take leave or, if the child has not been born yet, it can state the number of days after birth that you want the leave to start and end. This may be particularly useful if you intend to take paternity leave starting on the date of birth and wish to take SPL straight afterwards.

7.3              Leave must be taken in blocks of at least one week.

7.4              If your period of leave notice gives a single continuous block of SPL you will be entitled to take the leave set out in the notice.

7.5              If your period of leave notice requests split periods of SPL, with periods of work in between, we will consider your request as set out in paragraph 10, below.

7.6              You can give up to three period of leave notices. This may enable you to take up to three separate blocks of SPL (although if you give a notice to vary or cancel a period of leave this will in most cases count as a further period of leave notice; see paragraph 11) . In exceptional circumstances we may allow you to give more than three period of leave notices but there is no obligation for us to do so.

8.                Procedure for requesting split periods of SPL

8.1              In general, a period of leave notice should set out a single continuous block of leave. We may be willing to consider a period of leave notice where the SPL is split into shorter periods with periods of work in between. It is best to discuss this with your manager and HR in good time before formally submitting your period of leave notice. This will give us more time to consider the request and hopefully agree a pattern of leave with you from the start.

8.2              If you want to request split periods of SPL, you must set out the requested pattern of leave in your period of leave notice. We will either agree to the request or start a two-week discussion period. At the end of that period, we will confirm any agreed arrangements in writing. If we have not reached agreement, you will be entitled to take the full amount of requested SPL as one continuous block, starting on the start date given in your notice (for example, if you requested three separate periods of four weeks each, they will be combined into one 12-week period of leave). Alternatively, you may:

(a)           choose a new start date (which must be at least eight weeks after your original period of leave notice was given), and tell us within five days of the end of the two-week discussion period; or

(b)          withdraw your period of leave notice within two days of the end of the two-week discussion period (in which case the notice will not be counted and you may submit a new one if you choose).

9.                Changing the dates or cancelling your SPL

9.1              You can cancel a period of leave by notifying us in writing at least eight weeks before the start date in the period of leave notice.

9.2              You can change the start date for a period of leave by notifying us in writing at least eight weeks before the original start date or the new start date, whichever is earlier.

9.3              You can change the end date for a period of leave by notifying us in writing at least eight weeks before the original end date or the new end date, whichever is earlier.

9.4              You can combine discontinuous periods of leave into a single continuous period of leave. Since this will involve a change to the start date or end date of a period of leave, see paragraph 11.2 and paragraph 11.3 above which set out how much notice is required.

9.5              You can request that a continuous period of leave be split into two or more discontinuous periods of leave, with periods of work in between. Since this will involve a change to the start date or end date, see paragraph 11.2 and paragraph 11.3 above which set out how much notice is required for the request. We do not have to grant your request but will consider it as set out in paragraph 10.

9.6              A notice to change or cancel a period of leave will count as one of your three period of leave notices, unless:

(a)           it is a result of your child being born earlier or later than the EWC;

(b)          you are cancelling a request for discontinuous leave within two days of the end of the two-week discussion period under paragraph 10.2.

(c)           it is at our request; or

(d)          we agree otherwise.

10.              Premature birth

10.1           Where the child is born early (before the beginning of the EWC), you may be able to start SPL in the eight weeks following birth even though you cannot give eight weeks’ notice. The following rules apply:

(a)           If you have given a period of leave notice to start SPL on a set date in the eight weeks following the EWC, but your child is born early, you can move the SPL start date forward by the same number of days, provided you notify us in writing of the change as soon as you can. (If your period of leave notice already contained a start date which was a set number of days after birth, rather than a set date, then no notice of change is necessary.)

(b)          If your child is born more than eight weeks early and you want to take SPL in the eight weeks following birth, please submit your opt-in notice and your period of leave notice as soon as you can.

11.              Shared parental pay

11.1           You may be able to claim Statutory Shared Parental Pay (ShPP) of up to 39 weeks (less any weeks of SMP or MA claimed by you or your partner) if you have at least 26 weeks' continuous employment with us at the end of the Qualifying Week and your average earnings are not less than the lower earnings limit set by the government each tax year. ShPP is paid by employers at a rate set by the government each year.

11.2           You should tell us in your period of leave notice(s) whether you intend to claim ShPP during your leave (and if applicable, for what period). If it is not in your period of leave notice you can tell us in writing, at least eight weeks before you want ShPP to start.

12.              Other terms during shared parental leave

12.1           Your terms and conditions of employment remain in force during SPL, except for the terms relating to pay.

12.2           Holiday entitlement will continue to accrue at the rate provided under your contract. If your SPL will continue into the next holiday year, any holiday entitlement that is not taken or cannot reasonably be taken before starting your leave can be carried over, and must be taken immediately before returning to work or within three months of returning to work unless your manager agrees otherwise. Please discuss your holiday plans with your manager in good time before starting SPL. All holiday dates are subject to approval by your manager.

12.3           If you are a member of the pension scheme, we will make employer pension contributions during any period of paid SPL, based on your normal salary, in accordance with the pension scheme rules. Any employee contributions you make will be based on the amount of any shared parental pay you are receiving, unless you inform the Pensions Administrator that you wish to make up any shortfall.

13.              Keeping in touch

13.1           We may make reasonable contact with you from time to time during your SPL although we will keep this to a minimum. This may include contacting you to discuss arrangements for your return to work.

13.2           You may ask or be asked to work (including attending training) on up to 10 "keeping-in-touch" days (KIT days) during your SPL. This is in addition to any KIT days that you may have taken during maternity leave. KIT days are not compulsory and must be discussed and agreed with your manager.

13.3           You will be paid at your normal basic rate of pay for time spent working on a KIT day and this will be inclusive of any shared parental pay entitlement.

14.              Returning to work

14.1           If you want to end a period of SPL early, you must give us eight weeks' written notice of the new return date. If you have already given us three period of leave notices you will not be able to end your SPL early without our agreement.

14.2           If you want to extend your SPL, assuming you still have unused SPL entitlement remaining, you must give us a written period of leave notice at least eight weeks before the date you were due to return to work. If you have already given us three period of leave notices you will not be able to extend your SPL without our agreement. You may instead be able to request annual leave or ordinary parental leave (see our Parental Leave Policy), subject to the needs of the business.

14.3           You are normally entitled to return to work in the position you held before starting SPL, and on the same terms of employment. However, if it is not reasonably practicable for us to allow you to return into the same position, we may give you another suitable and appropriate job on terms and conditions that are not less favourable, but only in the following circumstances:

(a)           if your SPL and any maternity or paternity leave you have taken adds up to more than 26 weeks in total (whether or not taken consecutively); or

(b)          if you took SPL consecutively with more than four weeks of ordinary parental leave.

14.4           If you want to change your hours or other working arrangements on return from SPL you should make a request under our Flexible Working Policy. It is helpful if such requests are made as early as possible.

14.5           If you decide you do not want to return to work you should give notice of resignation in accordance with your contract of employment.

1.                Frequently used terms

1.1              The definitions in this paragraph apply in this policy.

                    Partner: your spouse, civil partner or someone living with you in an enduring family relationship at the time the child is placed for adoption, but not your sibling, child, parent, grandparent, grandchild, aunt, uncle, niece or nephew.

                    Qualifying Week: the week the adoption agency notifies you that you have been matched with a child for adoption.

2.                What is shared parental leave?

2.1              Shared parental leave (SPL) is a form of leave that may be available where a child is placed with you and/or your partner for adoption on or after 5 April 2015.

2.2              It gives you and your partner more flexibility in how to share the care of your child in the first year after birth than simply taking maternity and paternity leave. Assuming you are both eligible, you will be able to choose how to split the available leave between you, and can decide to be off work at the same time or at different times. You may be able to take leave in more than one block.

3.                Entitlement

3.1              You may be entitled to SPL if an adoption agency has placed a child with you and/or your partner for adoption, or where a child is placed with you and/or your partner as foster parents under a "fostering for adoption" or "concurrent planning" scheme. You must intend to share the main responsibility for the care of the child with your partner.

3.2              The following conditions must be fulfilled:

(a)           you must have at least 26 weeks continuous employment with us by the end of the Qualifying Week, and still be employed by us in the week before the leave is to be taken;

(b)          your partner must have worked (in an employed or self-employed capacity) in at least 26 of the 66 weeks before the Qualifying Week and had average weekly earnings of at least £30 during 13 of those weeks; and

(c)           you and your partner must give the necessary statutory notices and declarations as summarised below, including notice to end adoption leave or statutory adoption pay (SAP).

3.3              Either you or your partner must qualify for statutory adoption leave and/or SAP and must take at least two weeks of adoption leave and/or pay.

3.4              If your partner is taking adoption leave and/or claiming SAP, you may be entitled to two weeks' paternity leave and pay (see our Paternity Leave Policy). You should consider using this before taking SPL. Paternity leave is additional to any SPL entitlement you may have, but you will lose any untaken paternity leave entitlement once you start a period of SPL.

3.5              The total amount of SPL available is 52 weeks, less the weeks of adoption leave taken by either you or partner (or the weeks in which your partner has been in receipt of SAP if they were not entitled to adoption leave).

4.                Opting in to shared parental leave and pay

4.1              Not less than eight weeks before the date you intend your SPL to start, you must give us a written opt-in notice which includes:

(a)           your name and your partner's name;

(b)          if you are taking adoption leave, your adoption leave start and end dates;

(c)           if you are not taking adoption leave, your partner's adoption leave start and end dates, or if your partner is not entitled to adoption leave, the start and end dates of their SAP;

(d)          the total SPL available, which is 52 weeks minus the number of weeks' adoption leave or SAP taken or to be taken by you or your partner;

(e)          how many weeks of the available SPL will be allocated to you and how many to your partner (you can change the allocation by giving us a further written notice, and you do not have to use your full allocation);

(f)           if you are claiming statutory shared parental pay (ShPP), the total ShPP available, which is 39 weeks minus the number of weeks of SAP taken or to be taken);

(g)           how many weeks of the available ShPP will be allocated to you and how many to your partner (you can change the allocation by giving us a further written notice, and you do not have to use your full allocation);

(h)          an indication of the pattern of leave you are thinking of taking, including suggested start and end dates for each period of leave (see paragraph 9 and paragraph 10 for information on taking leave). This indication will not be binding at this stage, but please give as much information as you can about your future intentions; and

(i)            declarations by you and your partner that you both meet the statutory conditions to enable you to take SPL and ShPP.

5.                Ending your adoption leave

5.1              If you are taking or intend to take adoption leave and want to opt into the SPL scheme, you must give us at least eight weeks' written notice to end your adoption leave (a curtailment notice). The notice must state the date your adoption leave will end. You can give the notice before or after adoption leave starts, but you must take at least two weeks' adoption leave.

5.2              You must also give us, at the same time as the curtailment notice, a notice to opt into the SPL scheme (see paragraph 5) or a written declaration that your partner has given their employer an opt-in notice and that you have given the necessary declarations in that notice.

5.3              If your partner is eligible to take SPL from their employer they cannot start it until you have given us your curtailment notice.

5.4              The curtailment notice is binding on you and cannot usually be revoked. You can only revoke a curtailment notice if your adoption leave has not yet ended and one of the following applies:

(a)           if you realise that neither you nor your partner are in fact eligible for SPL or ShPP, in which case you can revoke the curtailment notice in writing up to eight weeks after it was given;

(b)          if your partner has died.

5.5              Once you have revoked a curtailment notice you will be unable to opt back in to the SPL scheme.

6.                Ending your partner's adoption leave or pay

6.1              If your partner is taking adoption leave or claiming SAP from their employer, you will only be able to take SPL once your partner has either:

(a)           returned to work;

(b)          given their employer a curtailment notice to end adoption leave; or

(c)           given their employer a curtailment notice to end SAP (if they are entitled to SAP but not adoption leave).

7.                Booking your SPL dates

7.1              Having opted into the SPL system, you must book your leave by giving us a period of leave notice. This may be given at the same time as the opt-in notice or later, provided it is at least eight weeks before the start of SPL.

7.2              The period of leave notice can either give the dates you want to take SPL or, if the child has not been placed with you yet, it can state the number of days after the placement that you want the SPL to start and end. This may be particularly useful if you intend to take paternity leave starting on the date of placement and wish to take SPL straight afterwards.

7.3              Leave must be taken in blocks of at least one week.

7.4              If your period of leave notice gives dates for a single continuous block of SPL you will be entitled to take the leave set out in the notice.

7.5              If your period of leave notice requests split periods of SPL, with periods of work in between, we will consider your request as set out in paragraph 10, below.

7.6              You can give up to three period of leave notices. This may enable you to take up to three separate blocks of SPL (although if you give a notice to vary or cancel a period of leave this will in most cases count as a further period of leave notice; see paragraph 11). In exceptional circumstances we may allow you to give more than three period of leave notices but there is no obligation for us to do so.

8.                Procedure for requesting split periods of SPL

8.1              In general, a period of leave notice should set out a single continuous block of leave. We may be willing to consider a period of leave notice where the SPL is split into shorter periods with periods of work in between. It is best to discuss this with your manager and HR in good time before formally submitting your period of leave notice. This will give us more time to consider the request and hopefully agree on a pattern of leave with you from the start.

8.2              If you want to request split periods of SPL, you must set out the requested pattern of leave in your period of leave notice. We will either agree to the request or start a two-week discussion period. At the end of that period, we will confirm any agreed arrangements in writing. If we have not reached agreement, you will be entitled to take the full amount of requested SPL as one continuous block, starting on the start date given in your notice (for example, if you requested three separate periods of four weeks each, they will be combined into one 12-week period of leave). Alternatively, you may:

(a)           choose a new start date (which must be at least eight weeks after your original period of leave notice was given), and tell us within five days of the end of the two-week discussion period; or

(b)          withdraw your period of leave notice within two days of the end of the two-week discussion period (in which case it will not be counted and you may submit a new one if you choose).

9.                Changing the dates or cancelling your SPL

9.1              You can cancel a period of leave by notifying us in writing at least eight weeks before the start date in the period of leave notice.

9.2              You can change the start date for a period of leave by notifying us in writing at least eight weeks before the original start date or the new start date, whichever is earlier.

9.3              You can change the end date for a period of leave by notifying us in writing at least eight weeks before the original end date or the new end date, whichever is earlier.

9.4              You can combine discontinuous periods of leave into a single continuous period of leave. Since this will involve a change to the start date or end date of a period of leave, see paragraph 9.2 and paragraph 9.3 above which set out how much notice is required.

9.5              You can request that a continuous period of leave be split into two or more discontinuous periods of leave, with periods of work in between. Since this will involve a change to the start date or end date, see paragraph 9.2 and paragraph 9.3 above which set out how much notice is required for the request. We do not have to grant your request but will consider it as set out in paragraph 9.

9.6              A notice to change or cancel a period of leave will count as one of your three period of leave notices, unless:

(a)           the variation is a result of the child being placed with you earlier or later than the expected placement date;

(b)          you are cancelling a request for discontinuous leave within two days of the end of the two-week discussion period under paragraph 8.2.

(c)           the variation is at our request; or

(d)          we agree otherwise.

10.              Shared parental pay

10.1           You may be able to claim Statutory Shared Parental Pay (ShPP) of up to 39 weeks (less any weeks of SAP claimed by you or your partner) provided you have at least 26 weeks' continuous employment with us at the end of the Qualifying Week and your average earnings are not less than the lower earnings limit set by the government each tax year. ShPP is paid at a rate set by the government each year.

10.2           You should tell us in your period of leave notice(s) whether you intend to claim ShPP during your leave (and if applicable, for what period). If it is not in your period of leave notice you can tell us in writing, at least eight weeks before you want ShPP to start.

11.              Other terms during shared parental leave

11.1           Your terms and conditions of employment remain in force during SPL, except for the terms relating to pay.

11.2           Holiday entitlement will continue to accrue at the rate provided under your contract. If your SPL will continue into the next holiday year, any holiday entitlement that is not taken or cannot reasonably be taken before starting your leave can be carried over and must be taken immediately before returning to work, within three months of returning to work unless your manager agrees otherwise. You should try to limit carry over to one week's holiday or less. Carry over of more than one week is at your manager's discretion. Please discuss your holiday plans with your manager in good time before starting SPL. All holiday dates are subject to approval by your manager.

11.3           If you are a member of the pension scheme, we will make employer pension contributions during any period of paid SPL, based on your normal salary, in accordance with the pension scheme rules. Any employee contributions you make will be based on the amount of any shared parental pay you are receiving, unless you inform the Pensions Administrator that you wish to make up any shortfall.

12.              Keeping in touch

12.1           We may make reasonable contact with you from time to time during your SPL although we will keep this to a minimum. This may include contacting you to discuss arrangements for your return to work.

12.2           You may ask or be asked to work (including attending training) on up to 10 "keeping-in-touch" days (KIT days) during your SPL. This is in addition to any KIT days that you may have taken during adoption leave. KIT days are not compulsory and must be discussed and agreed with your manager.

12.3           You will be paid at your normal basic rate of pay for time spent working on a KIT day and this will be inclusive of any shared parental pay entitlement.

13.              Returning to work

13.1           If you want to end a period of SPL early, you must give us eight weeks' written notice of the new return date. If you have already given us three period of leave notices you will not be able to end your SPL early without our agreement.

13.2           If you want to extend your SPL, assuming you still have unused SPL entitlement remaining, you must give us a written notice at least eight weeks before the date you were due to return to work. If you have already given us three period of leave notices you will not be able to extend your SPL without our agreement. You may instead be able to request annual leave or ordinary parental leave (see our Parental Leave Policy), subject to the needs of our business.

13.3           You are normally entitled to return to work in the position you held before starting SPL, and on the same terms of employment. However, if it is not reasonably practicable for us to allow you to return into the same position, we may give you another suitable and appropriate job on terms and conditions that are not less favourable, but only in the following circumstances:

(a)           if your SPL and any adoption or paternity leave you have taken adds up to more than 26 weeks in total (whether or not taken consecutively); or

(b)          if you took SPL consecutively with more than four weeks of ordinary parental leave.

13.4           If you want to change your hours or other working arrangements on return from SPL you should make a request under our Flexible Working Policy. It is helpful if such requests are made as early as possible.

13.5           If you decide you do not want to return to work you should give notice of resignation in accordance with your contract. This may have an impact on your entitlement to company shared parental pay.

1.                Statutory right

1.1              This policy summarises the statutory right of employees with at least one year's continuous service to take up to 18 weeks' unpaid parental leave in respect of each child.

2.                Entitlement to parental leave

2.1              To be eligible for parental leave, you must:

(a)           have at least one year's continuous employment with us;

(b)          have or expect to have responsibility for a child; and

(c)           be taking the leave to spend time with or otherwise care for the child.

2.2              You have responsibility for a child if you are the biological or adoptive parent or have legal parental responsibility in some other way, for example under a court order.

2.3              Eligible employees are entitled to take up to 18 weeks' parental leave in relation to each child.

2.4              You must tell us of any parental leave you have taken while working for another employer as this counts towards your 18-week entitlement.

3.                Taking parental leave

3.1              In most cases, parental leave can only be taken in blocks of a week or a whole number of weeks, and you may not take more than four weeks' parental leave a year in relation to each child. Parental leave can be taken up to the child's 18th birthday.

3.2              Special rules apply where your child is disabled, which for these purposes means entitled to a disability living allowance, armed forces independence allowance or personal independence payment. You can take parental leave in respect of that child in blocks of less than one week. However, there is still a limit of 4 weeks a year for each child and 18 weeks in total for each child.

4.                Notification requirements

4.1              You must notify your manager of your intention to take parental leave at least 21 days in advance. It would be helpful if you can give this notice in writing. Your notification should include the start and end dates of the requested period of leave.

4.2              If you wish to start parental leave immediately on the birth of a child, you must give notice at least 21 days before the expected week of childbirth.

4.3              If you wish to start parental leave immediately on having a child placed with you for adoption, you should give notice at least 21 days before the expected week of placement, or if this is not possible, give as much notice as you can.

5.                Evidence of entitlement

5.1              We may ask to see evidence of:

(a)           your responsibility or expected responsibility for the child such as birth certificate, adoption or matching certificate, parental responsibility agreement or court order.

(b)          the child's date of birth or date of adoption placement.

6.                Our right to postpone parental leave

6.1              Although we will try to accommodate your request for parental leave, we may postpone your requested leave where it would unduly disrupt our business (for example, if it would leave us short-staffed or unable to complete work on time).

6.2              We will discuss alternative dates with you, and notify you in writing of the reason for postponement and the new start and end dates, within seven days of receiving your request for parental leave.

6.3              We cannot postpone parental leave if you have requested it to start immediately on the birth or adoption of a child.

6.4              We cannot postpone parental leave for more than six months, or beyond the child's 18th birthday (if sooner).

7.                Terms and conditions during parental leave

7.1              Parental leave is unpaid. You will not be entitled to employer pension contributions in respect of the period of leave.

7.2              Your employment contract will remain in force, and holiday entitlement will continue to accrue. You will remain bound by your duties of good faith and confidentiality, and any contractual restrictions on accepting gifts and benefits, or working for another business.

1.                Statutory right

1.1              The law recognises that there may be occasions when you need to take time off work to deal with unexpected events involving one of your dependants.

1.2              This time off for dependants policy gives all employees the right to take a reasonable amount of unpaid time off work to deal with certain situations affecting their dependants.

1.3              No-one who takes time off in accordance with this policy will be subjected to any detriment.

2.                Reasonable unpaid time off

2.1              You have a right to take a reasonable amount of unpaid time off work when it is necessary to:

(a)           provide assistance when a dependant falls ill, gives birth, is injured or assaulted;

(b)          make longer-term care arrangements for a dependant who is ill or injured;

(c)           take action required in consequence of the death of a dependant;

(d)          deal with the unexpected disruption, termination or breakdown of arrangements for the care of a dependant (such as a child-minder falling ill); and/or

(e)          deal with an unexpected incident involving your child while a school or another educational establishment is responsible for them.

2.2              A dependant for the purposes of this policy is:

(a)           Your spouse, civil partner, parent or child;

(b)          a person who lives in the same household as you, but who is not your tenant, lodger, boarder or employee; or

(c)           anyone else who reasonably relies on you to provide assistance, make arrangements or take action of the kind referred to in paragraph 2.1.

2.3              This policy applies to time off to take action which is necessary because of an immediate or unexpected crisis. This policy does not apply where you need to take planned time off or provide longer-term care for a dependant. If this is the case, you should take advice from your manager.

2.4              Whether action is considered necessary will depend on the circumstances, including nature of the problem, the closeness of the relationship between you and the dependant, and whether anyone else is available to assist. Action is unlikely to be considered necessary if you knew of a problem in advance but did not try to make alternative care arrangements.

2.5              Reasonable time off in relation to a particular problem will not normally be more than two days. However, we will always consider each set of circumstances based on its own facts.

3.                Exercising the right to time off

3.1              You will only be entitled to time off under this policy if, as soon as is reasonably practicable, you tell your manager:

(a)           the reason for your absence; and

(b)          how long you expect to be away from work.

3.2              If you fail to notify us as set out above, you may be subject to disciplinary proceedings under our Disciplinary Procedure for taking unauthorised time off.

3.3              We may in some cases ask you to provide evidence for your reasons for taking the time off, either in advance or on your return to work. Suspected abuse of this policy will be dealt with as a disciplinary issue under our Disciplinary Procedure.

1.                When compassionate leave may be available

1.1              Compassionate leave is designed to help you deal with traumatic personal circumstances such as the death of a close relative or where a close relative has a life-threatening illness or injury.

1.2              You may take unpaid compassionate leave of up to 3 days in any 12-month period where a close relative has died, is critically ill with a life-threatening illness, or has suffered a life-threatening injury.

1.3              In the event of the death of a child, including a stillbirth, please see our Parental Bereavement Leave Policy which applies instead of this policy. We may grant further unpaid compassionate leave in this situation at our discretion.

1.4              We will consider requests for compassionate leave due to other traumatic events or difficult personal circumstances on a case by case basis.

1.5              If you are still unable to return to work following compassionate leave you should contact your manager. We may at our discretion grant you further unpaid compassionate leave in those circumstances. Alternatively, you may be able to take a period of annual leave, subject to your manager's approval.

2.                Requesting compassionate leave

2.1              We recognise that it may not always be possible to request compassionate leave in advance. However, where it is possible, you should make a request to your manager. You should tell them the reasons for your request and the number of days leave you would like to take.

2.2              Where it is not possible to request leave in advance you should contact your manager as soon as possible to tell them the reason for your absence and the number of days you expect to be absent. Someone can do this on your behalf if necessary.

1.                Entitlement to parental bereavement leave

1.1              This policy sets out the arrangements for parental bereavement leave, which is a type of compassionate leave intended to help employees deal with the death of a child or a stillbirth after at least 24 weeks of pregnancy.

1.2              Parental bereavement leave can be one week, two consecutive weeks, or two separate weeks. It can be taken at any time during the first 56 weeks after the child's death.

1.3              Further unpaid compassionate leave may be available under our Compassionate Leave Policy at our discretion. Please speak to your manager if you require further time off in addition to parental bereavement leave.

2.                Parental bereavement pay

2.1              You may qualify for statutory parental bereavement pay (SPBP) during parental bereavement leave if:

(a)           you have at least 26 weeks' continuous employment ending on the Saturday before the child died; and

(b)          you earn at least the lower earnings limit for class 1 national insurance contributions.

2.2              SPBP is only payable in respect of whole weeks of leave, at the same rate as statutory paternity pay. The rate is set by the government each tax year.

3.                Leave in the first eight weeks

3.1              In the first eight weeks after a child has died, there is no need to give advance notice to take parental bereavement leave. Please notify your manager as soon as you can on the day you want your leave to start, preferably before the time you would normally start work, where possible. Someone can do this on your behalf if necessary.

3.2              If you have already started work, then your parental bereavement leave period will start on the following day. We would usually allow you to take the rest of the day off as compassionate leave.

3.3              You can cancel any planned parental bereavement leave in the first eight weeks by telling us at any time before the leave starts, and no later than the time you would normally start work on the first day of the leave period. You cannot cancel leave once it has started.

4.                Leave after more than eight weeks

4.1              To take parental bereavement leave more than eight weeks after the child has died, please give your manager at least a week's written notice.

4.2              Parental bereavement leave can be cancelled with a week's written notice, and can be re-booked by giving a week's written notice.

5.                Written confirmation

5.1              We will ask you to confirm the following information in writing within 28 days of starting any period of parental bereavement leave:

(a)           your name;

(b)          the date the child died or was stillborn;

(c)           the dates of paid or unpaid parental bereavement leave taken; and

(d)          your relationship to the child.

1.                Eligibility

1.1              This flexible working policy gives eligible employees an opportunity to request a change to their working pattern. The time between making a request and notifying you of a final decision (including the outcome of any appeal) will be less than three months unless we have agreed a longer period with you.

1.2              To be eligible to make a flexible working request, you must:

(a)           be an employee;

(b)          have worked for us continuously for at least 26 weeks at the date your request is made; and

(c)           not have made a flexible working request during the last 12 months (even if you withdrew that request).

2.                What is a flexible working request?

2.1              A flexible working request under this policy means a request to do any or all of the following:

(a)           to reduce or vary your working hours;

(b)          to reduce or vary the days you work;

(c)           to work from a different location (for example, from home).

3.                Making a flexible working request

3.1              Your flexible working request should be submitted to us in writing and dated. It should:

(a)           state that it is a flexible working request;

(b)          explain the change being requested and propose a start date;

(c)           identify the impact the change would have on the business and how that might be dealt with; and

(d)          state whether you have made any previous flexible working requests.

4.                Meeting

4.1              We will arrange a meeting at a convenient time and place to discuss your request. You may be accompanied at the meeting by a colleague of your choice. They will be entitled to speak and confer privately with you, but may not answer questions on your behalf.

4.2              We may decide to grant your request in full without a meeting, in which case we will write to you with our decision.

5.                Decision

5.1              We will inform you in writing of our decision as soon as possible after the meeting.

5.2              If your request is accepted, we will write to you with details of the new working arrangements and the date on which they will commence. You will be asked to sign and return a copy of the letter.

5.3              If we cannot immediately accept your request we may require you to undertake a trial period before reaching a final decision on your request.

5.4              Unless otherwise agreed, changes to your terms of employment will be permanent.

5.5              We may reject your request for one or more of the following business reasons:

(a)           the burden of additional costs;

(b)          detrimental effect on ability to meet customer demand;

(c)           inability to reorganise work among existing staff;

(d)          inability to recruit additional staff;

(e)          detrimental impact on quality;

(f)           detrimental impact on performance;

(g)           insufficiency of work during the periods that you propose to work; or

(h)          planned changes.

5.6              If we are unable to agree to your request, we will write to tell you which of those reasons applies in your case. We will also set out the appeal procedure.

6.                Appeal

6.1              You may appeal in writing within 14 days of receiving our written decision.

6.2              Your appeal must be dated and must set out the grounds on which you are appealing.

6.3              We will hold a meeting with you to discuss your appeal. You may bring a colleague to the meeting.

6.4              We will tell you in writing of our final decision as soon as possible after the appeal meeting, including reasons. There is no further right of appeal.

1.                Jury service

1.1              You should tell your manager as soon as you are summoned for jury service and provide a copy of your summons if requested.

1.2              Depending on the demands of our business we may request that you apply to be excused from or defer your jury service.

1.3              We are not required by law to pay you while you are absent on jury service. You will be advised at court of the expenses and loss of earnings that you can claim.  

2.                Voluntary public duties

2.1              Employees are entitled to a reasonable amount of unpaid time off work to carry out certain public duties, including duties as a tribunal member, magistrate, local councillor, member of an NHS Trust, prison visitor, police station lay visitor or school governor.

2.2              If you are unsure whether a public service that you perform is covered by this policy you should speak to your manager.

2.3              As soon as you are aware that you will require time off for performance of a public service you should notify your manager in writing, providing full details of the time off that is being requested and the reasons for your request. In order that arrangements can be made to cover your duties in your absence you should make your request in good time.

2.4              Each request for time off will be considered on its merits taking account of all the circumstances, including how much time is reasonably required for the activity, how much time you have already taken, and how your absence will affect the business.

3.                Reserve forces duties

3.1              We are aware that employees who are members of the Reserve Forces (the Territorial Army, Royal Navy Reserve, Royal Marines Reserve or Royal Auxiliary Air Force) may be called-up at any time to be deployed on full-time operations, and are expected to attend regular training.

3.2              We are under no obligation to offer leave (either paid or unpaid) for reservists to undertake training and you should use existing holiday entitlement to meet training commitments.

3.3              If we receive notice that you have been called-up for active service we may apply to an adjudication officer for the notice to be deferred or revoked if your absence would cause serious harm to our business (which could not be prevented by the grant of financial assistance).

3.4              Once your military service has ended you may submit a written application for reinstatement to your employment. This should be made by the third Monday following the end of your military service and you should notify us of the date on which you will be available to restart work.

3.5              If it is not reasonable and practicable to reinstate you into your former employment we will offer you the most favourable alternative on the most favourable terms and conditions which are reasonable and practicable.

1.                When it is applicable

1.1              If there is a reduced need for employees to perform work of a particular kind on a temporary or permanent basis, or any other occurrence which affects normal working, we shall be entitled to lay you off or impose short-time working for such period as we shall decide.

2.                Working hours

2.1              While you are laid off you shall not be required to work and shall have no right to remuneration subject to clause 3.2.

2.2              While you are on short-time working your working hours may be reduced as we see fit and your remuneration shall be correspondingly reduced subject to clause 3.2.

3.                Notice and pay

3.1              We shall give you as much notice as is reasonably practicable of lay-off or short-time working. Thereafter we shall give as much notice as is reasonably practicable of any further change to your hours including a return to normal working hours.

3.2              During any period of lay-off or short-time working we shall pay statutory guarantee pay in accordance with legislation in force from time to time.

1.                Your responsibilities

1.1              At Billing Better Limited, we are committed to ensuring the health and safety of staff and anyone affected by our business activities, and to providing a safe and suitable environment for all those attending our premises.

1.2              The purpose of this policy is to set out our arrangements in relation to:

(a)           assessment and control of health and safety risks arising from work activities;

(b)          preventing accidents and work-related ill health;

(c)           consultation with employees on matters affecting their health and safety;

(d)          provision and maintenance of a safe workplace and equipment;

(e)          information, instruction, training and supervision in safe working methods and procedures; and

(f)           emergency procedures in cases of fire or other major incident.

1.3              This policy does not form part of any contract of employment or other contract to provide services and we may amend it at any time.

2.                Who does this policy apply to?

2.1              This policy applies to all employees, officers, consultants, self-employed contractors, casual workers, agency workers, volunteers and interns. It also applies to anyone visiting our premises or using our vehicles.

3.                Who is responsible for this policy?

3.1              The management has overall responsibility for the effective operation of this policy. The management has delegated responsibility for overseeing its implementation to the Health and Safety Manager. Suggestions for changes to this policy should be reported to the Health and Safety Manager. The post of Health and Safety Manager is held by [NAME], and they can be contacted at [INSERT TELEPHONE NUMBER AND EMAIL ADDRESS].

3.2              Any questions you may have about the day-to-day application of this policy should be referred to your manager in the first instance.

3.3              This policy is usually reviewed annually by the Health and Safety Manager.

4.                Your responsibilities

4.1              All staff share responsibility for achieving safe working conditions. You must take care of your own health and safety and that of others, observe applicable safety rules and follow instructions for the safe use of equipment.

4.2              You should report any health and safety concerns immediately to your line manager or the Health and Safety Manager.

4.3              You must co-operate with managers on health and safety matters, including the investigation of any incident.

4.4              Failure to comply with this policy may be treated as misconduct and dealt with under our disciplinary procedure.

5.                Information and consultation

5.1              We will inform and consult directly with all staff or the elected workplace safety representatives regarding health and safety matters.

5.2              We will ensure any health and safety representatives receive the appropriate training to carry out their functions effectively.

5.3              The Health and Safety Manager is responsible for informing and consulting employees about health and safety matters.

6.                Training

6.1              We will ensure that you are given adequate training and supervision to perform your work competently and safely.

6.2              Staff will be given a health and safety induction and provided with appropriate safety training. This may include manual handling, control of substances hazardous to health (COSHH), working at height, asbestos awareness, gas safety, electrical safety and the use of personal protective equipment (PPE).

7.                Equipment

7.1              You must use equipment in accordance with any instructions given to you. Any equipment fault or damage must immediately be reported to your line manager or Health and Safety Manager.

7.2              No member of staff should attempt to repair equipment unless trained to do so.

7.3              The Health and Safety Manager is responsible for ensuring equipment safety and maintenance.

8.                Accidents and first aid

8.1              Details of first aid facilities and the names of trained first aiders are displayed on the notice boards or around the premises.

8.2              All accidents and injuries at work, however minor, should be reported to the Health and Safety Manager and recorded in the Accident Book.

8.3              The Health and Safety Manager is responsible for investigating any injuries or work-related diseases, ensuring that accident records are kept, and for submitting reports to the relevant authorities if required under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (SI 2013/1471) (RIDDOR).

9.                National health alerts

9.1              In the event of an epidemic or pandemic alert we will organise our business operations and provide advice on steps to be taken by staff, in accordance with official guidance, to reduce the risk of infection at work as far as possible. Any questions should be referred to your line manager.

9.2              It is important for the health and safety of all our staff that you comply with instructions issued in these circumstances.

10.              Fire safety

10.1           All staff should familiarise themselves with the fire safety instructions, which are displayed on notice boards and near fire exits in the workplace.

10.2           If you hear a fire alarm, leave the building immediately by the nearest fire exit and go to the fire assembly point shown on the fire safety notices. Do not stop to collect belongings or use any lifts. Fire wardens will assist in the evacuation of the building and you must follow their instructions. Do not re-enter the building until told to do so.

10.3           If you discover a fire do not attempt to tackle it unless it is safe and you have been trained or feel competent to do so. You should operate the nearest fire alarm and, if you have sufficient time, call reception and report the location of the fire.

10.4           Nominated individuals will be trained in the correct use of fire extinguishers.

10.5           You should notify your line manager if there is anything (for example, impaired mobility) that might impede your evacuation in the event of a fire. A personal evacuation plan will be drawn up and brought to the attention of the relevant fire wardens and colleagues working in your vicinity.

10.6           Fire drills will be held at least every [See separate policy] months and must be taken seriously.

10.7           The Health and Safety Manager is responsible for ensuring fire risk assessments are undertaken and implemented, and for ensuring regular checks of fire extinguishers, fire alarms, escape routes and emergency lighting.

11.              Risk assessments and measures to control risk

11.1           We carry out general workplace risk assessments periodically. The purpose is to assess the risks to health and safety of employees, visitors and other third parties as a result of our activities, and to identify any measures that need to be taken to control those risks.

11.2           Measures will be taken to avoid or reduce the need to lift or carry items which could cause injury (manual handling) and to provide training on manual handling as necessary.

11.3           The use of hazardous substances at work will be avoided wherever possible and less hazardous alternatives will be used where available. Training on the control of substances hazardous to health (COSHH) will be provided as necessary.

11.4           Personal protective equipment (PPE) is provided where there are risks that cannot be adequately controlled by other means.

11.5           The Health and Safety Manager is responsible for workplace risk assessments and any measures to control risks.

12.              Computers and display screen equipment

12.1           If you use a computer screen or other display screen equipment (DSE) habitually as a significant part of your work:

(a)           You should try to organise your activity so that you take frequent short breaks from looking at the screen.

(b)          You are entitled to a workstation assessment.

(c)           You are entitled to an eyesight test by an optician at our expense.

12.2           You should contact your line manager to request a workstation assessment or an eye test. Eye tests should be repeated at regular intervals as advised by the optician, usually every two years. However, if you develop eye problems which may be caused by DSE work (such as headaches, eyestrain, or difficulty focusing) you can request a further eye test at any time.

12.3           We will not normally pay for glasses or contact lenses, unless your vision cannot be corrected by normal glasses or contact lenses and you need special glasses designed for the display screen distance. In such cases we will pay the cost of basic corrective appliances only.

12.4           Further information on the use of DSE can also be obtained from your line manager or Health and Safety Manager.

1.                Where is smoking banned?

1.1              Our centre is smoke-free in accordance with the Health Act 2006 and associated regulations. All staff and customers have the right to a smoke-free environment.

1.2              Smoking is not permitted in any enclosed or substantially enclosed premises within our centre. The ban applies to anything that can be smoked and includes, but is not limited to, cigarettes, electronic cigarettes, pipes (including water pipes such as shisha and hookah pipes), cigars and herbal cigarettes.

1.3              Anyone using our vehicles, whether as a driver or passenger, must ensure the vehicles remain smoke-free.

2.                Where is smoking permitted?

2.1              You may only smoke outside in designated areas during breaks. When smoking outside, you must dispose of cigarette butts and other litter appropriately.

3.                Breaches of the policy

3.1              Breaches of this policy by any employee will be dealt with under our Disciplinary Procedure and, in serious cases, may be treated as gross misconduct leading to summary dismissal.

3.2              Smoking in smoke-free premises or vehicles is also a criminal offence and may result in a fixed penalty fine and/or prosecution.

1.                About lone workers

1.1              At Billing Better Limited (the ‘Company’), we are committed to ensuring the health and safety of all staff, in particular those working alone.

1.2              We understand that lone workers face the same hazards at work as anyone else, but there is a greater risk of these hazards causing harm to lone workers as there may be no one available to support them if things go wrong.

1.3              The purpose of this policy is to set out our arrangements in relation to lone workers. If you work alone, you must comply with this policy.

1.4              Unless expressly stated otherwise, this policy does not form part of any contract of employment or other contract to provide services and we may amend it at any time.

2.                Who does this policy apply to?

2.1              This policy applies to all employees, officers, consultants, self-employed contractors, casual workers, agency workers, volunteers, interns and anyone else who works on their own.

2.2              This policy should be read in line with our Homeworking and Health and Safety policy.

3.                Who is a lone worker?

3.1              A lone worker is someone who works by themselves without close or direct supervision. This includes but is not limited to staff who:

(a)           work alone at a fixed base

(b)          work separately or away from other staff

(c)           work from home

(d)          work away e.g. abroad. 

4.                Lone worker arrangements

4.1              Any reference to “workplace” in this policy is a reference to the place of work as specified in your contract of employment or, where not specified, your usual place of work when you attend our premises.

4.2              Not all roles and not all jobs are suitable for lone working. If working alone affects your contractual working days and hours then you must speak to your direct line manager.

4.3              When working alone, you should seek medical advice or contact the emergency services in the event of an emergency. You must familiarise yourself with the location of our first-aid equipment and be familiar with how to administer it to yourself. If you require first-aid training, please speak to your line manager before you work alone.

5.                Management and training

5.1              The following procedures are put in place by the Company to protect lone workers:

(a)           line managers will periodically visit and observe those working alone;

(b)          line managers will pre-agree regular contact time with lone workers. This can be by using phones, email or other forms of communication; and

(c)           lone workers must notify their line manager once their work is completed or as agreed from time to time.

5.2              Your line manager will:

(a)           remain responsible for supervising and assessing you in the same way as all other staff, and will agree the best way to appraise your performance and provide ongoing supervision;

(b)          set out the best way to contact them in the event of an emergency. We recommend you keep in touch with them regularly when working alone;

(c)           regularly review your working arrangements and take steps to address any perceived problems; and

(d)          ensure that you are kept up to date with any changes to the workplace or information relevant to your work.

5.3              You will be subject to the same performance measures, processes and objectives that would apply if you did not work alone.

5.4              If you receive an unsatisfactory grade in an appraisal or informal review, or are subject to a (verbal or written) warning for any reason, your lone working arrangements may be terminated immediately, in which case different arrangements may be put in place.

5.5              You will be provided with the same opportunities for training, development and promotion as all other staff. If your lone working arrangement will impact on your ability to apply for certain roles, your line manager will discuss this with you to ensure that you are not denied any opportunity unfairly.

6.                Health and safety

6.1              When working alone, you have the same health and safety duties as other staff. You must take reasonable care of your own health and safety and that of anyone else who might be affected by your actions and omissions. You must attend our usual health and safety training, read the Health and Safety Policy, which is in this Staff Handbook and undertake to use equipment safely.

6.2              To identify any potential health and safety hazards of you working alone and take appropriate steps to minimise risk, we may carry out a health and safety risk assessment before or shortly after you begin working alone. We may contact you to discuss the risk assessment but this will depend on the circumstances, including the nature of the work you undertake.

6.3              When carrying out a risk assessment we would consider:

(a)           consulting you about any potential risks and measures on how to control them;

(b)          taking steps to ensure risks are removed, where possible, or putting in place control measures to ensure you can work safely; and

(c)           instructions, training and supervision.

6.4              You must ensure that your working patterns and levels of work when working alone are not detrimental to your health and wellbeing. If you have concerns about your health or wellbeing arising as a result of your workload or working pattern when working alone, you should inform your line manager without delay so that we can discuss measures to deal with this in line with our Stress and Mental Wellbeing at Work policy.

6.5              You must use your knowledge, experience and training to identify and report any health and safety concerns to your line manager. Your line manager will confirm how to keep in touch and how to share your concerns.

7.                Termination of lone working arrangement

7.1              We reserve the right to terminate your lone working arrangement, for example, due to a change in business needs, performance concerns or if your role changes so that lone working is no longer suitable, at any time.

8.                Misconduct

8.1              Breach of the rules set out in this policy may be treated as a disciplinary matter in accordance with our Disciplinary Procedure. This may result in disciplinary action being taken against you. A serious breach of this policy may amount to gross misconduct resulting in dismissal.

1.                About homeworking

1.1              We support homeworking in appropriate circumstances, either occasionally (to respond to specific circumstances or particular tasks) or on a regular (full or part-time) basis. Homeworking can also be a means of accommodating a disability and can be requested as a means of flexible working under our Flexible Working Policy.

1.2              The purpose of this policy is to set out how we will deal with requests for homeworking, and conditions on which homeworking is allowed. If you are permitted to work from home, you must comply with this policy.

1.1              This policy does not form part of any contract of employment or other contract to provide services and we may amend it at any time.

2.                Who does this policy apply to?

2.1              This policy applies to all employees, officers, consultants, self-employed contractors, casual workers, agency workers, volunteers and interns who have successfully completed any applicable probationary period.                 

3.                Who is responsible for this policy?               

3.1              The Company has overall responsibility for the effective operation of this policy.

3.2              Any questions you may have about the day-to-day application of this policy should be referred to your line manager in the first instance.

3.3              This policy is usually reviewed annually by the Company.

4.                Homeworking arrangements               

4.1              Any reference to "workplace" in this policy is a reference to the place of work as specified in your contract of employment or, where not specified, your usual place of work when you attend our premises.

4.2              We recognise that there are a number of homeworking arrangements that you may request, and that these arrangements may be requested as part of a flexible working application (if eligible), such as:

(a)           working from home as your main place of work;

(b)          working from home on a part-time basis on fixed days of the week; or

(c)           splitting your working time between the workplace and your home subject to business factors and manager approval.

4.3              If you want to vary your working arrangements so that, either permanently or temporarily, you work from home for all or part of your working week, you will need to make a flexible working request (if eligible) in accordance with our Flexible Working Policy. Any request to work from home must meet the needs of our business as well as your needs.

4.4              All homeworking arrangements will be subject to a trial period of 1 month. We may, at our discretion, extend this period for up to a further two months. During the trial period, we will monitor the homeworking arrangements. At the end of the trial period, we will inform you if we consider it appropriate for the homeworking arrangements to continue.

4.5              There are also a number of circumstances in which the ability to work from home on an occasional and temporary basis may benefit you, including illness of a dependant or travel disruption. For these temporary arrangements, you should contact your line manager to seek authorisation on a case-by-case basis.

5.                Conditions necessary for homeworking.               

5.1              Not all roles and not all jobs are suitable for homeworking. You should not assume that, if you are eligible to make a flexible working application to work from home, this will automatically give you the right to amend your working hours or any other aspect of your working arrangements.

5.2              A request for homeworking is unlikely to be approved, on either a temporary or permanent basis, if:

(a)           you need to be present in the workplace to perform your job (for example, because it involves a high degree of personal interaction with colleagues or third parties, or involves equipment that is only available in the workplace);

(b)          your most recent appraisal identifies any aspect of your performance as unsatisfactory;

(c)           your line manager has advised you that your current standard of work or work production is unsatisfactory;

(d)          you have an unexpired warning, whether relating to conduct or performance; or

(e)          you need training or supervision to deliver an acceptable quality or quantity of work.

5.3              If you wish to apply to work from home, you will need to be able to show that you can:

(a)           set up a suitable working environment at your home that enables you to carry out your role effectively;

(b)          continue to work the hours required by your contract of employment;

(c)           work independently, motivate yourself and use your own initiative;

(d)          manage your workload effectively and complete work to set deadlines;

(e)          identify and resolve any new pressures created by working at home;

(f)           adapt to new working practices, including maintaining contact with your line manager and colleagues at work;

(g)           make arrangements for the care of any children or other dependants who rely on you for support or care when you are working from home; and

(h)          determine any resulting home insurance and tax implications for yourself.

6.                Location               

6.1              You will be required to work from your home address for the duration of your homeworking arrangement. If you wish to work from a different location at any time, you will need to agree this with your line manager in advance and that request is subject to their written approval.

6.2              If you wish to work from a location abroad at any time during your homeworking arrangement, this will require separate approval from the Company and there is no guarantee that this will be possible. Working from home from a location abroad is not subject to this policy due to different compliance and legislative requirements.

6.3              If we agree to you working from an address other than your home address, this will be subject to our right to require you to return to your home address on 1 weeks' notice.

7.                Management, training and workplace attendance             

7.1              Your line manager will:

(a)           remain responsible for supervising and assessing you in the same way as staff based in the workplace, and will agree the best way to appraise your performance and provide ongoing supervision in a remote way;

(b)          regularly review your homeworking arrangements and take steps to address any perceived problems; and

(c)           ensure that you are kept up to date with any changes to the workplace or information relevant to your work.

7.2              You will be subject to the same performance measures, processes and objectives that would apply if you worked in the workplace.

7.3              If you receive an unsatisfactory grade in an appraisal or informal review, or are subject to a (verbal or written) warning for any reason, your homeworking arrangements may be terminated immediately, in which case you will be expected to return to work in the workplace.

7.4              You will be provided with the same opportunities for training, development and promotion as staff based in the workplace. If your homeworking arrangement will impact on your ability to apply for certain roles, your line manager will discuss this with you to ensure that you are not denied any opportunity unfairly.

7.5              You agree to attend the workplace or other reasonable location for meetings, training courses or other events which we require you to attend.

7.6              You understand that when you do attend the workplace, you may have to hot desk or share a desk with someone else.

8.                Health and safety               

8.1              When working at home, you have the same health and safety duties as other staff. You must take reasonable care of your own health and safety and that of anyone else who might be affected by your actions and omissions. You must attend our usual health and safety courses, read the Health and Safety Policy, which is in this Staff Handbook and undertake to use equipment safely.

8.2              To identify any potential health and safety hazards in the home and take appropriate steps to minimise risk, we retain the right to carry out a health and safety risk assessment (either remotely or by arranging a home visit) before or shortly after you begin homeworking. We will contact you to arrange completion of the risk assessment. The need for these inspections will depend on the circumstances, including the nature of the work you undertake.

8.3              You must not have in-person meetings in your home with customers or give customers your home address or telephone number.

8.4              You must ensure that your working patterns and levels of work when working at home are not detrimental to your health and wellbeing. If you have concerns about your health or wellbeing arising as a result of your workload or working pattern, you should inform your line manager without delay so that we can discuss measures to deal with this.

8.5              You must use your knowledge, experience and training to identify and report any health and safety concerns to your line manager.

9.                Equipment and suitable workspace               

9.1              We will provide the equipment that we consider you reasonably require to work from home. We will make all necessary arrangements for and bear the cost of installing, maintaining, repairing or replacing (where necessary) the equipment, and removing it from your home. Where any equipment is provided, it remains our property and you must:

(a)           ensure it is only used by you and only for the purposes for which we have provided it;

(b)          take reasonable care of it and use it only in accordance with any operating instructions and our policies and procedures;

(c)           make it available for collection by us or on our behalf when requested to do so; and

(d)          not use any personal device or computer for work.

9.2              When travelling between your remote working location and your workplace, you agree to keep equipment provided by us secure at all times.

9.3              On termination of your homeworking arrangement or on termination of your employment, you must return all equipment provided by us. Where necessary, we may need to arrange a home visit to reclaim equipment.

9.4              It is your responsibility to ensure that you have a suitable workspace at home with adequate lighting for working from home.

9.5              If you have a disability, you should inform us of any equipment you require to work from home comfortably.

9.6              We are not responsible for the associated costs of you working from home, including the costs of heating, lighting, electricity, broadband internet access, mobile or telephone line rental, or calls.

10.              Insurance requirements            

10.1           We are responsible for taking out and maintaining a valid policy of insurance covering any equipment we provide against fire, theft, loss and damage throughout your employment. 

10.2           We are not liable for any loss, injury or damage that may be caused by any equipment that is not provided by us but required by you to work from home.

10.3           You are responsible for ensuring that working from home will not invalidate the terms of your home insurance. Before commencing homeworking, you should ensure that you check your home insurance policy and inform your home and contents insurance provider of your working arrangements as required.

10.4           Before commencing working from home, you should check the terms of your mortgage, lease or rental agreement to ensure this does not breach any of the terms. It is your responsibility to inform your mortgage provider or landlord that you are working from home and seek any necessary approval before commencing homeworking.

10.5           When you are working at or from home, you are covered by our employers' liability insurance policy[LV2] . Any accidents must be reported immediately to your line manager in accordance with our Health and Safety Policy.

11.              Data security and confidentiality            

11.1           Your line manager must be satisfied that you are taking all reasonable precautions to maintain confidentiality in accordance with our requirements.

11.2           You are responsible for ensuring the security of confidential information in your home and when travelling to and from your workplace.

11.3           When working from home, you undertake to:

(a)           change your password frequently and comply with our instructions relating to password security;

(b)          use our designated VPN or multi-factor authentication;

(c)           comply with our instructions relating to software security and to implement all updates to equipment as soon as you are requested to do so;

(d)          send work-related emails and messages through our designated communication facilities;

(e)          share data only through our designated platform;

(f)           make all work-related calls through our designated video-conferencing software;

(g)           maintain a private space for confidential work calls;

(h)          ensure that any display screen equipment is positioned so that only you can see it or a privacy screen is used;

(i)            lock your computer terminal whenever it is left unattended;

(j)            ensure no one else in your home has access to confidential information stored on our equipment;

(k)           ensure any wireless network used is secure;

(l)            change your wireless network passwords frequently and ensure that your wireless network router has software security updates applied;

(m)         keep all papers containing confidential information in filing cabinets that are locked when not in use, and ensure that no one else in your home has access to them; and

(n)          shred or otherwise dispose securely of confidential information when it is no longer required and at all times comply with our instructions on document retention.

11.4           To comply with data protection obligations, you will only store or process company data or personal data on equipment that has been provided by or authorised by us.

11.5           To comply with data protection legislation, we retain the right to conduct a data protection impact assessment (DPIA) to assess the risks involved with data processing in the home. Where this is necessary, we will contact you to arrange the DPIA.

11.6           You confirm that you:

(a)           have read and understood our Data Protection Policy, IT and Communications Policy and any other applicable policies from time to time in force regarding the retention of personal data, electronic communications and data security;

(b)          will regularly keep yourself informed of the most current version of these policies; and

(c)           will attend any training on data protection and confidentiality whether online or in person when requested to do so.

11.7           If you discover or suspect that there has been a data breach or an incident involving the security of information relating to us, our clients, our customers, or anyone working with or for us, you must report it immediately to your line manager.

12.              Termination of homeworking arrangement            

12.1           We reserve the right to terminate your homeworking arrangement, for example, due to a change in business needs, performance concerns or if your role changes so that homeworking is no longer suitable, subject to 1 weeks' notice.

12.2           If you want to terminate your homeworking arrangement, you must give your line manager 1 weeks' notice to allow us to arrange a desk space for you in the workplace and collect any equipment that is no longer required.

13.              Misconduct           

13.1           Breach of the rules set out in this policy is treated as a disciplinary matter in accordance with our Disciplinary Procedure. It may result in disciplinary action being taken against you. A serious breach of this policy may amount to gross misconduct resulting in dismissal.

1.                About this policy

1.1              We are committed to protecting the health, safety and wellbeing of our staff. We recognise the importance of identifying and tackling the causes of work-related stress. We also recognise that personal stress, while unrelated to the workplace, can adversely affect the wellbeing of staff at work.

1.2              The purpose of this policy is to set out the measures we have in place to support the mental wellbeing of all our staff.

1.3              This policy does not form part of any contract of employment or other contract to provide services, and we may amend it at any time.

1.4              Any information you provide to us about your health will be processed in accordance with our Data Protection Policy. We recognise that such data is sensitive and will handle it in a confidential manner.

2.                Who does this policy apply to?               

2.1              This policy applies to all employees, officers, consultants, self-employed contractors, casual workers, agency workers, volunteers and interns.

3.                Who is responsible for this policy?               

3.1              The Company has overall responsibility for the effective operation of this policy.

3.2              Any questions you may have about the day-to-day application of this policy should be referred to your line manager in the first instance.

3.3              This policy is usually reviewed annually by the Company.

4.                Legal obligations               

4.1              We have a legal duty to take reasonable care to ensure that your health is not put at risk by excessive pressures or demands arising from the way work is organised.

4.2              This policy takes account of our obligations under the Health and Safety at Work etc Act 1974, Management of Health and Safety at Work Regulations 1999, Employment Rights Act 1996, Protection from Harassment Act 1997, Working Time Regulations 1998 and Equality Act 2010.

5.                Understanding stress and mental health               

5.1              Stress is the adverse reaction people have to excessive pressures or demands placed on them. Stress is not an illness but, sustained over a period of time, it can lead to mental and/or physical illness.

5.2              Mental health is a term to describe our emotional, psychological and social wellbeing; it affects how we think, feel and act and how we cope with the normal pressures of everyday life. Positive mental health is rarely an absolute state since factors inside and outside work affect mental health, meaning that we move on a spectrum that ranges from being in good to poor mental health.

5.3              There is an important distinction between working under pressure and experiencing stress. Certain levels of pressure are acceptable and normal in every job. They can improve performance, enable individuals to meet their full potential and provide a sense of achievement and job satisfaction. However, when pressure becomes excessive it produces stress and undermines mental health.

5.4              Pressures outside the workplace, whether the result of unexpected or traumatic events such as accidents, illness, bereavement, family breakdown or financial worries, can result in stress and poor mental health. They can also compound normal workplace pressures.

5.5              We recognise that individuals react to similar situations in different ways and that what triggers stress and poor mental health varies from person to person.

6.                Our approach to mental wellbeing in the workplace              

6.1              We will:

(a)           Promote a culture of open communication by providing both formal and informal channels through which staff can raise concerns.

(b)          Take account of stress and mental wellbeing when planning and allocating workloads. We will provide opportunities to discuss these through our appraisal and/or one-to-one supervision processes.

(c)           Monitor working hours and overtime to ensure that staff are not overworking and monitor holidays to ensure that staff are using their entitlement.

(d)          Ensure risk assessments include or specifically address work-related stress.

(e)          Facilitate requests for flexible working where reasonably practicable in accordance with our Flexible Working Policy.

(f)           Ensure that in any workplace reorganisation our change management processes are designed to minimise uncertainty and stress.

(g)           Implement policies and procedures to address factors that can cause or worsen stress in particular so that we can provide a workplace free from harassment, bullying and victimisation and address inappropriate behaviour through disciplinary action.

(h)          Provide training to help all staff understand and recognise the causes of work-related stress and mental ill health, the impact of stress from factors in everyday life and the steps they can take to protect and enhance their own mental wellbeing and that of their colleagues.

(i)            Provide support for staff affected by or absent by reason of stress.

7.                Supporting the implementation of this policy               

7.1              All staff

All staff should ensure that they are familiar with this policy and act in accordance with its aims and objectives. Staff should plan and organise their work to meet personal and organisational objectives and co-operate with support, advice and guidance that may be offered by line managers. Anyone who experiences or is aware of a situation that may result in work-related stress or undermine mental wellbeing at work should speak to a manager.

7.2              Managers

All line managers have a responsibility to recognise potential issues of work-related stress or mental ill health in the staff they manage. They should seek advice from senior management in the event that they have concerns. All managers should provide support to staff by working with the Company. In particular, they need to:

(a)           Promote a culture of open communication.

(b)          Effectively plan and provide feedback on performance.

(c)           Ensure that staff receive necessary training.

(d)          Monitor workloads and reallocate work where necessary.

(e)          Ensure that staff understand the standards of behaviour expected of them and others, and act on behaviour that falls below those standards.

7.3              Help and information can also be obtained from Mind, the mental health charity, www.mind.org.uk or the Samaritans, www.samaritans.org.

7.4              If any member of staff is considered by their line manager or colleagues to be at serious risk of self-harm, or of harming others, action must be taken straight away. The matter should be referred to their line manager who will seek medical advice if that is reasonably practicable. Every effort will be made to contact any person nominated by the member of staff as an emergency contact. Where necessary the emergency services will be called. The wellbeing of the member of staff and those around them will always be our first concern.

8.                Addressing work-related stress               

8.1              If you believe you are suffering from work-related stress you should discuss this with your line manager in the first instance. If you feel unable to do so you should contact senior management.

8.2              Once an issue affecting your health comes to the attention of your line manager or supervisor, we will discuss with you what steps can be taken to address that issue. Those steps may include any of the following:

(a)           A review of your current job role, responsibilities, workload and working hours. Adjustments may be agreed to these, on a temporary basis and subject to further review, where appropriate.

(b)          Where it appears that stress has been caused by bullying or harassment, investigation under our Disciplinary and/or Grievance Procedures.

(c)           Referral for medical advice, treatment and/or a medical report to be provided by our medical advisers or any specialist or GP who has been treating you.

(d)          If you are on sickness absence, discussion of an appropriate return to work programme. Our Sickness Absence Policy may be applied.

9.                Absence due to stress or mental ill health               

9.1              If you are absent due to work-related stress or mental ill health, you should follow the sickness absence reporting procedure contained in your contract and our Sickness Absence Policy.

9.2              In cases of prolonged or repeated absence it may be necessary to apply the procedure set out in our Sickness Absence Policy and Capability Procedure.

10.              Confidentiality            

10.1           Information about stress, mental health and mental wellbeing is highly sensitive. Every member of staff is responsible for observing the high level of confidentiality that is required when dealing with information about stress or mental health whether they are supporting a colleague or because they are otherwise involved in the operation of a workplace policy or procedure.

10.2           Breach of confidentiality may give rise to disciplinary action.

10.3           However, there are occasions when information about stress or mental wellbeing need to be shared with third parties. For example:

(a)           Where steps need to be taken to address work-related stress such as reallocating work within a team.

(b)          Where medical advice is required on how to support a member of staff, address issues raised by work-related stress or address issues raised by mental ill health.

(c)           Where allegations of harassment, bullying or other misconduct require a disciplinary investigation or proceedings to take place.

(d)          Where a member of staff presents an immediate danger to themselves or others.

In these circumstances, wherever possible, matters will be discussed with the member of staff concerned before any action is taken.

11.              Protection for those reporting stress or assisting with an investigation            

11.1           Staff who report that they are suffering from work-related stress or mental ill health, who support a colleague in making such a report or who participate in any investigation connected with this policy in good faith will be protected from any form of intimidation or victimisation.

11.2           If you feel you have been subjected to any such intimidation or victimisation, you should seek support from your line manager. You may also raise a complaint in accordance with our Grievance Procedure.

11.3           If, after investigation, you are found to have provided false information in bad faith, you will be subject to action under our Disciplinary Procedure.

1.                About this policy

1.1              We are committed to providing a safe, healthy and productive working environment. This includes ensuring that all staff are fit to carry out their jobs safely and effectively in an environment which is free from alcohol and drug misuse.

1.2              The purpose of this policy is to increase awareness of the effects of alcohol and drug misuse and its likely symptoms and to ensure that:

(a)           All staff are aware of their responsibilities regarding alcohol and drug misuse and related problems.

(b)          Staff who have an alcohol or drug-related problem are encouraged to seek help, in confidence, at an early stage.

(c)           Staff who have an alcohol or drug-related problem affecting their work are dealt with sympathetically, fairly and consistently.

1.3              This policy is not intended to apply to "one-off" incidents or offences caused by alcohol or drug misuse at or outside work where there is no evidence of an ongoing problem, which may damage our reputation, and which are likely to be dealt with under our Disciplinary Procedure.

1.4              This policy does not form part of any contract of employment or other policy to provide services, and we may amend it at any time.

1.5              Any information you provide to us about your health will be processed in accordance with our Data Protection Policy. We recognise that such data is sensitive and will handle it in a confidential manner.

2.                Who does this policy apply to?

2.1              This policy applies to all employees, officers, consultants, self-employed contractors, casual workers, agency workers, volunteers and interns.

3.                Who is responsible for this policy?

3.1              The Company has overall responsibility for the effective operation of this policy.

3.2              Any questions you may have about the day-to-day application of this policy should be referred to your line manager in the first instance.

3.3              This policy is usually reviewed annually by the Company.

4.                Our approach to alcohol and drug misuse

4.1              We will not accept staff arriving at work under the influence of alcohol or drugs, or whose ability to work is impaired in any way by reason of the consumption of alcohol or drugs, or who consume alcohol or take drugs (other than prescription or over the counter medication, as directed) on our premises.

5.                Identifying a problem

5.1              If you notice a change in a colleague's pattern of behaviour you should encourage them to seek assistance through their line manager. If they will not seek help themselves, you should draw the matter to the attention of your line manager. You should not attempt to cover up for a colleague whose work or behaviour is suffering as a result of an alcohol or drug-related problem.

5.2              If you believe that you have an alcohol or drug-related problem you should seek specialist advice and support as soon as possible.

6.                Alcohol and drugs at work

6.1              Alcohol and drugs can lead to reduced levels of attendance, reduced efficiency and performance, impaired judgement and decision making and increased health and safety risks for you and other people. Irresponsible behaviour or the commission of offences resulting from the use of alcohol or drugs may damage our reputation and, as a result, our business.

6.2              You are expected to arrive at work fit to carry out your job and to be able to perform your duties safely without any limitations due to the use or after-effects of alcohol or drugs. In this policy drug use includes the use of controlled drugs, psychoactive (or mind-altering) substances formerly known as "legal highs", and the misuse of prescribed or over-the-counter medication.

6.3              We expect you to demonstrate responsible behaviour at work, work-related functions and work-related social events and to act in a way that will not have a detrimental effect on our reputation. If you entertain clients or represent us at external events where alcohol is served, you are considered to be "at work" regardless of whether you do so outside normal working hours. Consequently, we will expect you to remain professional and fit for work at all times.

6.4              Managers should act to prevent excessive consumption of alcohol by any member of staff and should take steps to deal with any unacceptable conduct. Any such behaviour may lead to disciplinary action.

6.5              You must comply with drink-driving laws and drug-driving laws at all times. Conviction for drink-driving or drug-driving offence may harm our reputation and, if your job requires you to drive, you may be unable to continue to do your job. Committing a drink-driving or drug-driving offence while working for us or outside working hours may lead to action under our Disciplinary Procedure and could result in dismissal.

6.6              If you are prescribed medication you must seek advice from your GP or pharmacist about the possible effect on your ability to carry out your job and whether your duties should be modified or you should be temporarily reassigned to a different role. If so you must tell your line manager without delay.

7.                Searches

7.1              We reserve the right to conduct searches for alcohol or drugs on our premises, including, but not limited to, searches of lockers, filing cabinets and desks, bags, clothing and packages.

7.2              Any alcohol or drugs found as a result of a search will be confiscated and action may be taken under our Disciplinary Procedure.

8.                Managing suspected substance misuse

8.1              Where a line manager considers that a deterioration in work performance or changes in patterns of behaviour may be due to alcohol or drug misuse they should seek advice and assistance from senior management.

8.2              If your line manager has reason to believe that you are suffering the effects of alcohol or drugs misuse, they will invite you to an investigatory interview. The purpose of the interview is to:

(a)           discuss the reason for the investigation and seek your views on, for example, the deterioration of your work performance or behaviour; and

(b)          where appropriate, offer to refer you to a specialist for medical or specialist advice.

8.3              If you arrive at work and a manager reasonably believes you are under the influence of alcohol or drugs, they shall immediately contact senior management in order that you can be provided with assistance and an investigation can be undertaken.

8.4              If you agree to be referred to a specialist, your line manager will request an urgent appointment and prepare a letter of referral, a copy of which will be provided to you.

8.5              Your line manager may ask for your consent to approach your GP for advice. A report will be sent to your line manager who will then reassess the reasons for their investigatory meeting with you and decide on the way forward.

8.6              If, as the result of the meeting or investigation, your line manager continues to believe that you are suffering the effects of alcohol or drugs misuse and you refuse an offer of referral to a specialist or appropriate treatment provider, the matter may be dealt with under our Disciplinary Procedure.

9.                Providing support

9.1              Alcohol and drug-related problems may develop for a variety of reasons and over a considerable period of time. We are committed, in so far as possible, to treating these problems in a similar way to other health issues. We will provide support where possible with a view to a return to full duties. This may include:

(a)           Referral to appropriate treatment providers, where necessary in conjunction with your GP.

(b)          Time off work to attend treatment.

(c)           Adjusting your duties or other support as recommended by your GP or specialist during treatment and for an agreed period afterwards, subject to operational requirements and feasibility.

9.2              If you do not finish a programme of treatment, or your recovery and return to work does not go as planned, your line manager will meet with you to decide what further action if any should be taken.

10.              Confidentiality

10.1           We aim to ensure that the confidentiality of any member of staff experiencing alcohol or drug-related problems is maintained appropriately. However, it needs to be recognised that, in supporting staff, some degree of information sharing is likely to be necessary.

10.2           If you seek help with an alcohol or drug-related problem directly from the Company and you wish to keep matters confidential from your line manager and colleagues, this will be respected unless there is reason to believe that this could put you, your colleagues or anyone else at risk or carries some other material risk for the business. In those circumstances the Company will encourage you to inform your line manager and will give you sufficient time to do so before discussing the matter with them.

11.              Performance and disciplinary issues

11.1           If you agree to undertake appropriate treatment or rehabilitation for an acknowledged alcohol or drug-related problem, we may decide to suspend any ongoing disciplinary action against you for related misconduct or poor performance, pending the outcome of the treatment.

11.2           Our intention is to support all staff with alcohol or drug-related problems to regain good health. Depending on the progress made on the course of treatment, any disciplinary action may be suspended for a specified period, discontinued or restarted at any time as we see fit.

1.                INTERPRETATION

1.1              Definitions:

Automated Decision-Making (ADM): when a decision is made which is based solely on Automated Processing (including profiling) which produces legal effects or significantly affects an individual. The UK GDPR prohibits Automated Decision-Making (unless certain conditions are met) but not Automated Processing.

Automated Processing: any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.

Company name: Billing Better Limited

Company Personnel: all employees, workers, contractors, agency workers, consultants, directors, members and others.

Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject's wishes by which they, by a statement or by a clear positive action, signify agreement to the Processing of Personal Data relating to them.

Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the UK GDPR. We are the Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.

Criminal Convictions Data: means personal data relating to criminal convictions and offences and includes personal data relating to criminal allegations and proceedings.

Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.

Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programmes involving the Processing of Personal Data.

Data Protection Officer (DPO): the person required to be appointed in specific circumstances under the UK GDPR. Where a mandatory DPO has not been appointed, this term means a data privacy manager or other voluntary appointment of a DPO or refers to the Company data privacy team with responsibility for data protection compliance.

Explicit Consent: consent which requires a very clear and specific statement (that is, not just action).

UK GDPR: the retained EU law version of the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the UK GDPR.

Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person's actions or behaviour.

Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.

Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the UK GDPR.

Privacy Guidelines: the Company privacy and UK GDPR related guidelines provided to assist in interpreting and implementing this Data Protection Policy and Related Policies, available here.

Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies: separate notices setting out information that may be provided to Data Subjects when the Company collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, employee privacy notices or the website privacy policy) or they may be stand-alone, one-time privacy statements covering Processing related to a specific purpose.

Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.

Related Policies: the Company's policies, operating procedures or processes related to this Data Protection Policy and designed to protect Personal Data,.

Special Categories of Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.

2.                Introduction

2.1              This Data Protection Policy sets out how Billing Better Limited ("we", "our", "us", "the Company") handle the Personal Data of our customers, suppliers, employees, workers and other third parties.

2.2              This Data Protection Policy applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject.

2.3              This Data Protection Policy applies to all Company Personnel ("you", "your"). You must read, understand and comply with this Data Protection Policy when Processing Personal Data on our behalf and attend training on its requirements. This Data Protection Policy sets out what we expect from you for the Company to comply with applicable law. Your compliance with this Data Protection Policy is mandatory. Related Policies and Privacy Guidelines are available to help you interpret and act in accordance with this Data Protection Policy. You must also comply with all such Related Policies and Privacy Guidelines. Any breach of this Data Protection Policy may result in disciplinary action.

2.4              Where you have a specific responsibility in connection with Processing such as capturing Consent, reporting a Personal Data Breach, conducting a DPIA as referenced in this Data Protection Policy or otherwise then you must comply with the Related Policies and Privacy Guidelines. 

2.5              This Data Protection Policy (together with Related Policies and Privacy Guidelines) is an internal document and cannot be shared with third parties, customers or regulators without our prior authorisation.

3.                Scope

3.1              We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times. The Company is exposed to potential fines for failure to comply with the provisions of the UK GDPR.

3.2              The CEO, directors and managers are responsible for ensuring all Company Personnel comply with this Data Protection Policy and need to implement appropriate practices, processes, controls and training to ensure that compliance. 

3.3              The DPO/ Data Protection Manager is responsible for overseeing this Data Protection Policy and, as applicable, developing Related Policies and Privacy Guidelines. That post is held by Will Hyde.

3.4              Please contact the DPO with any questions about the operation of this Data Protection Policy or the UK GDPR or if you have any concerns that this Data Protection Policy is not being or has not been followed. In particular, you must always contact the DPO in the following circumstances:

(a)           if you are unsure of the lawful basis which you are relying on to process Personal Data (including the legitimate interests used by the Company) (see paragraph 5.1);

(b)          if you need to rely on Consent and/or need to capture Explicit Consent (see paragraph 6);

(c)           if you need to draft Privacy Notices (see paragraph 7);

(d)          if you are unsure about the retention period for the Personal Data being Processed (see paragraph 11);

(e)          if you are unsure about what security or other measures you need to implement to protect Personal Data (see paragraph 12.1);

(f)           if there has been a Personal Data Breach (paragraph 13);

(g)           if you are unsure on what basis to transfer Personal Data outside the UK (see paragraph 14);

(h)          if you need any assistance dealing with any rights invoked by a Data Subject (see paragraph 15);

(i)            whenever you are engaging in a significant new, or change in, Processing activity which is likely to require a DPIA (see paragraph 19) or plan to use Personal Data for purposes other than what it was collected for;

(j)            if you plan to undertake any activities involving Automated Processing including profiling or Automated Decision-Making (see paragraph 20);

(k)           if you need help complying with applicable law when carrying out direct marketing activities (see paragraph 21); or

(l)            if you need help with any contracts or other areas in relation to sharing Personal Data with third parties (including our vendors) (see paragraph 22).

4.                Personal data protection principles

4.1              We adhere to the principles relating to Processing of Personal Data set out in the UK GDPR which require Personal Data to be:

(a)           Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency);

(b)          collected only for specified, explicit and legitimate purposes (Purpose Limitation);

(c)           adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation);

(d)          accurate and where necessary kept up to date (Accuracy);

(e)          not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation);

(f)           processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality);

(g)           not transferred to another country without appropriate safeguards being in place (Transfer Limitation); and

(h)          made available to Data Subjects and allow Data Subjects to exercise certain rights in relation to their Personal Data (Data Subject's Rights and Requests).

4.2              We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).

5.                Lawfulness, fairness, transparency

5.1              Lawfulness and fairness

5.2              Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject.

5.3              You may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The UK GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.

5.4              The UK GDPR allows Processing for specific purposes, some of which are set out below:

(a)           the Data Subject has given his or her Consent;

(b)          the Processing is necessary for the performance of a contract with the Data Subject;

(c)           to meet our legal compliance obligations;

(d)          to protect the Data Subject's vital interests;

(e)          to pursue our legitimate interests (or those of a third party) for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices.

5.5              You must identify and document the legal ground being relied on for each Processing activity.

6.                Consent

6.1              A Controller must only process Personal Data on the basis of one or more of the lawful bases set out in the UK GDPR, which include Consent.

6.2              A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters. 

6.3              Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured. Consent may need to be refreshed if you intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented. 

6.4              When processing Special Category Data or Criminal Convictions Data, we will usually rely on a legal basis for processing other than Explicit Consent or Consent if possible. Where Explicit Consent is relied on, you must issue a Privacy Notice to the Data Subject to capture Explicit Consent. 

6.5              You will need to evidence Consent captured and keep records of all Consents in accordance with Related Policies and Privacy Guidelines so that the Company can demonstrate compliance with Consent requirements.

7.                Transparency (notifying Data Subjects)

7.1              The UK GDPR requires Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. The information must be provided through appropriate Privacy Notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them.

7.2              Whenever we collect Personal Data directly from Data Subjects, including for HR or employment purposes, we must provide the Data Subject with all the information required by the UK GDPR including the identity of the Controller and DPO, how and why we will use, Process, disclose, protect and retain that Personal Data through a Privacy Notice which must be presented when the Data Subject first provides the Personal Data.

7.3              When Personal Data is collected indirectly (for example, from a third party or publicly available source), we must provide the Data Subject with all the information required by the UK GDPR as soon as possible after collecting or receiving the data. We must also check that the Personal Data was collected by the third party in accordance with the UK GDPR and on a basis which contemplates our proposed Processing of that Personal Data.

7.4              If you are collecting Personal Data from Data Subjects, directly or indirectly, then you must provide Data Subjects with a Privacy Notice in accordance with our Related Policies and Privacy Guidelines.

8.                Purpose limitation

8.1              Personal Data must be collected only for specified, explicit and legitimate purposes. It must not be further Processed in any manner incompatible with those purposes.

8.2              You cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes and they have Consented where necessary.

9.                Data minimisation

9.1              Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.

9.2              You may only Process Personal Data when performing your job duties requires it. You cannot Process Personal Data for any reason unrelated to your job duties.

9.3              You may only collect Personal Data that you require for your job duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes.

9.4              You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company's data retention guidelines.

10.              Accuracy

10.1           Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.

10.2           You will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

11.              Storage limitation

11.1           Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.

11.2           The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires that data to be kept for a minimum time.

11.3           You must not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.

11.4           You will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all the Company's applicable records retention schedules and policies. This includes requiring third parties to delete that data where applicable. 

11.5           You will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice.

12.              Security integrity and confidentiality

12.1           Protecting Personal Data

12.2           Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

12.3           We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. You are responsible for protecting the Personal Data we hold. You must implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data. You must exercise particular care in protecting Special Categories of Personal Data and Criminal Convictions Data from loss and unauthorised access, use or disclosure.

12.4           You must follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.

12.5           You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

(a)           Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it;

(b)          Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed; and

(c)           Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.

12.6           You must comply with and not attempt to circumvent the administrative, physical and technical safeguards we implement and maintain in accordance with the UK GDPR and relevant standards to protect Personal Data.

13.              Reporting a Personal Data Breach

13.1           The UK GDPR requires Controllers to notify any Personal Data Breach to the Information Commissioner and, in certain instances, the Data Subject.

13.2           We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.

13.3           If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the DPO or your manager. You should preserve all evidence relating to the potential Personal Data Breach.

14.              Transfer limitation

14.1           The UK GDPR restricts data transfers to countries outside the UK to ensure that the level of data protection afforded to individuals by the UK GDPR is not undermined. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country.

14.2           You may only transfer Personal Data outside the UK if one of the following conditions applies:

(a)           the UK has issued regulations confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subject's rights and freedoms;

(b)          appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved for use in the UK, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the DPO;

(c)           the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or

(d)          the transfer is necessary for one of the other reasons set out in the UK GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest.

15.              Data Subject's rights and requests

15.1           Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:

(a)           withdraw Consent to Processing at any time;

(b)          receive certain information about the Controller's Processing activities;

(c)           request access to their Personal Data that we hold;

(d)          prevent our use of their Personal Data for direct marketing purposes;

(e)          ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;

(f)           restrict Processing in specific circumstances;

(g)           challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;

(h)          request a copy of an agreement under which Personal Data is transferred outside of the UK;

(i)            object to decisions based solely on Automated Processing, including profiling (ADM);

(j)            prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;

(k)           be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;

(l)            make a complaint to the supervisory authority; and

(m)         in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine-readable format.

15.2           You must verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade you into disclosing Personal Data without proper authorisation).

15.3           You must immediately forward any Data Subject request you receive to your manager and the DPO.

16.              Accountability

16.1           The Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.

16.2           The Company must have adequate resources and controls in place to ensure and to document UK GDPR compliance including:

(a)           appointing a suitably qualified DPO (where necessary) and an executive accountable for data privacy;

(b)          implementing Privacy by Design when Processing Personal Data and completing DPIAs where Processing presents a high risk to rights and freedoms of Data Subjects;

(c)           integrating data protection into internal documents including this Data Protection Policy, Related Policies, Privacy Guidelines or Privacy Notices;

(d)          regularly training Company Personnel on the UK GDPR, this Data Protection Policy, Related Policies and Privacy Guidelines and data protection matters including, for example, Data Subject's rights, Consent, legal basis, DPIA and Personal Data Breaches. The Company must maintain a record of training attendance by Company Personnel; and

(e)          regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort.

17.              Record keeping

17.1           The UK GDPR requires us to keep full and accurate records of all our data Processing activities.

17.2           You must keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects' Consents and procedures for obtaining Consents.

17.3           These records should include, at a minimum, the name and contact details of the Controller and the DPO, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data's retention period and a description of the security measures in place. To create the records, data maps should be created which should include the detail set out above together with appropriate data flows.

18.              Training and audit

18.1           We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.

18.2           You must undergo all mandatory data privacy related training and managers should ensure the team undergo similar mandatory training.

18.3           You must regularly review all the systems and processes under your control to ensure they comply with this Data Protection Policy and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.

19.              Privacy by Design and Data Protection Impact Assessment (DPIA)

19.1           We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles.

19.2           You must assess what Privacy by Design measures can be implemented on all programmes, systems or processes that Process Personal Data by taking into account the following:

(a)           the state of the art;

(b)          the cost of implementation;

(c)           the nature, scope, context and purposes of Processing; and

(d)          the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing.

19.3           Controllers must also conduct DPIAs in respect to high-risk Processing.

19.4           You should conduct a DPIA (and discuss your findings with the DPO) when implementing major system or business change programs involving the Processing of Personal Data including:

(a)           use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes);

(b)          Automated Processing including profiling and ADM;

(c)           large-scale Processing of Special Categories of Personal Data or Criminal Convictions Data; and

(d)          large-scale, systematic monitoring of a publicly accessible area.

19.5           A DPIA must include:

(a)           a description of the Processing, its purposes and the Controller's legitimate interests if appropriate;

(b)          an assessment of the necessity and proportionality of the Processing in relation to its purpose;

(c)           an assessment of the risk to individuals; and

(d)          the risk mitigation measures in place and demonstration of compliance.

20.              Automated Processing (including profiling) and Automated Decision-Making

20.1           Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:

(a)           a Data Subject has Explicitly Consented;

(b)          the Processing is authorised by law; or

(c)           the Processing is necessary for the performance of or entering into a contract.

20.2           If certain types of Special Categories of Personal Data or Criminal Convictions Data are being processed, then grounds (b) or (c) will not be allowed but the Special Categories of Personal Data and Criminal Convictions Data can be Processed where it is necessary (unless less intrusive means can be used) for substantial public interest like fraud prevention.

20.3           If a decision is to be based solely on Automated Processing (including profiling), then Data Subjects must be informed when you first communicate with them of their right to object. This right must be explicitly brought to their attention and presented clearly and separately from other information. Further, suitable measures must be put in place to safeguard the Data Subject's rights and freedoms and legitimate interests.

20.4           We must also inform the Data Subject of the logic involved in the decision making or profiling, the significance and envisaged consequences and give the Data Subject the right to request human intervention, express their point of view or challenge the decision.

20.5           A DPIA must be carried out before any Automated Processing (including profiling) or ADM activities are undertaken.

20.6           Where you are involved in any data Processing activity that involves profiling or ADM, you must comply with the Company's guidelines on profiling or ADM.

21.              Direct marketing

21.1           We are subject to certain rules and privacy laws when marketing to our customers.

21.2           For example, a Data Subject's prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as "soft opt-in" allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.

21.3           The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information.

21.4           A Data Subject's objection to direct marketing must be promptly honoured. If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.

21.5            You must comply with the Company's guidelines on direct marketing to customers.

22.              Sharing Personal Data

22.1           Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.

22.2           You may only share the Personal Data we hold with another employee, agent or representative of our group (which includes our subsidiaries and our ultimate holding company along with its subsidiaries) if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions.

22.3           You may only share the Personal Data we hold with third parties, such as our service providers, if:

(a)           they have a need to know the information for the purposes of providing the contracted services;

(b)          sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject's Consent has been obtained;

(c)           the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;

(d)          the transfer complies with any applicable cross-border transfer restrictions; and

(e)          a fully executed written contract that contains UK GDPR-approved third party clauses has been obtained.

23.              Changes to this Data Protection Policy

23.1           We keep this Data Protection Policy under regular review.

23.2           This Data Protection Policy does not override any applicable national data privacy laws and regulations in countries where the Company operates.

1.                What is the purpose of this document?

Billing Better Limited is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the UK General Data Protection Regulation (UK GDPR).

It applies to all employees, workers and contractors.

1.1              Billing Better Limited is a "controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

1.2              This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

1.3              It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

2.                Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

3.                The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.

3.1              We will collect, store, and use the following categories of personal information about you:

(a)           Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

(b)          Date of birth.

(c)           Gender.

(d)          Marital status and dependants.

(e)          Next of kin and emergency contact information.

(f)           National Insurance number.

(g)           Bank account details, payroll records and tax status information.

(h)          Salary, annual leave, pension and benefits information.

(i)            Start date and, if different, the date of your continuous employment.

(j)            Leaving date and your reason for leaving.

(k)           Location of employment or workplace.

(l)            Copy of driving licence.

(m)         Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).

(n)          Employment records (including job titles, work history, working hours, holidays, training records and professional memberships).

(o)          Compensation history.

(p)          Performance information.

(q)          Disciplinary and grievance information.

(r)           CCTV footage and other information obtained through electronic means such as swipe card records.

(s)           Information about your use of our information and communications systems.

(t)           Photographs.

(u)          Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied.

3.2              We may also collect, store and use the following more sensitive types of personal information:

(a)           Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.

(b)          Trade union membership.

(c)           Information about your health, including any medical condition, health and sickness records, including:

(d)          where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision;

(e)          details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and

(f)           where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.

(g)           Genetic information and biometric data.

(h)          Information about criminal convictions and offences.

4.                How is your personal information collected?

4.1              We collect personal information about employees, workers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.

4.2              We may also collect personal information from the trustees or managers of pension arrangements operated by a group company.

4.3              We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

5.                How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform the contract we have entered into with you.

2. Where we need to comply with a legal obligation.

3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else's interests).

2. Where it is needed in the public interest or for official purposes.

6.                Situations in which we will use your personal information

6.1              We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests , provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

(a)           Making a decision about your recruitment.

(b)          Determining the terms on which you work for us.

(c)           Checking you are legally entitled to work in the UK.

(d)          Paying you and, if you are an employee or deemed employee for tax purposes, deducting tax and National Insurance contributions (NICs).

(e)          Providing workplace benefits to you.

(f)           Enrolling you in a pension arrangement in accordance with our statutory automatic enrolment duties.

(g)           Liaising with the trustees or managers of a pension arrangement operated by a group company, your pension provider and any other provider of employee benefits.

(h)          Administering the contract we have entered into with you.

(i)            Business management and planning, including accounting and auditing.

(j)            Conducting performance reviews, managing performance and determining performance requirements.

(k)           Making decisions about salary reviews and compensation.

(l)            Assessing qualifications for a particular job or task, including decisions about promotions.

(m)         Gathering evidence for possible grievance or disciplinary hearings.

(n)          Making decisions about your continued employment or engagement.

(o)          Making arrangements for the termination of our working relationship.

(p)          Education, training and development requirements.

(q)          Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.

(r)           Ascertaining your fitness to work.

(s)           Managing sickness absence.

(t)           Complying with health and safety obligations.

(u)          To prevent fraud.

(v)           To monitor your use of our information and communication systems, checkout tills and to ensure compliance with our IT policies.

(w)         To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

(x)           To conduct data analytics studies to review and better understand employee retention and attrition rates.

(y)           Equal opportunities monitoring.

6.2              Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

7.                If you fail to provide personal information

7.1              If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

8.                Change of purpose

8.1              We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

8.2              Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9.                How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.

2. Where we need to carry out our legal obligations or exercise rights in connection with employment.

3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

10.              Situations in which we will use your sensitive personal information

10.1           In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process your particularly sensitive personal information are listed below. We have indicated the purpose or purposes for which we are processing or will process your more sensitive personal information.

(a)           We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits including statutory maternity pay, statutory sick pay, pensions and permanent health insurance. We need to process this information to exercise rights and perform obligations in connection with your employment.

(b)          We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

11.              Do we need your consent?

11.1           We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

12.              Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our Data Protection Policy.

12.1           We envisage that we will hold information about criminal convictions.

12.2           We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.

12.3           We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

13.              Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

1. Where we have notified you of the decision and given you 21 days to request a reconsideration.

2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.

3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

13.1           You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

14.              Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the UK.

If we do, you can expect a similar degree of protection in respect of your personal information.

15.              Why might you share my personal information with third parties?

15.1           We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

16.              Which third-party service providers process my personal information?

16.1           "Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT services.

16.2           We will share personal data regarding your participation in any pension arrangement with the trustees or scheme managers of the arrangement in connection with the administration of the arrangements.

17.              How secure is my information with third-party service providers and other entities in our group?

17.1           All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

18.              What about other third parties?

18.1           We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

18.2           We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC.

Transferring information outside the UK

We may transfer the personal information we collect about you to EU countries outside the UK in order to perform our contract with you. There are adequate regulations in respect of those countries. This means that the countries to which we transfer your data are deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measure to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects UK law on data protection: data protection clauses in binding contracts. If you require further information about this protective measure, you can request it from the management.

19.              Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

19.1           We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

19.2           We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

20.              Data retention

21.              How long will you use my information for?

21.1           We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are in the table below. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

21.2           In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention procedure and applicable laws and regulations.

22.              Rights of access, correction, erasure, and restriction

23.              Your duty to inform us of changes

23.1           It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

24.              Your rights in connection with personal information

24.1           Under certain circumstances, by law you have the right to:

(a)           Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

(b)          Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

(c)           Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

(d)          Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

(e)          Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

(f)           Request the transfer of your personal information to another party.

24.2           If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Billing Better Limited in writing.

25.              No fee usually required

25.1           You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

26.              What we may need from you

26.1           We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

26.2           In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact a member of the management team. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data protection officer

26.3           We have a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact Will Hyde. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO).

27.              Changes to this privacy notice

27.1           We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

27.2           Retention Period

·        Recruitment records such as online application form, CV, equal opportunity monitoring forms, assessment exercises/tests, interview notes, pre-employment verifications, criminal record checks (transferred to your employment file and deleted 7 years after the contract ends)

·        Immigration checks (deleted 3 years after termination of employment)

·        Contract of employment, other contracts and letter of change of terms (deleted 7 years after the contract ends)

·        Payroll and wage records including bonuses, expenses, details of overtime etc. (deleted 7 years after employment ends)

·        Current bank details (to be deleted after payment of final salary when employment ends)

·        PAYE records (deleted 7 years after employment ends)

·        Working hours and pay records, including travel and maintenance allowance (deleted 7 years after the working relationship ends)

·        Loans to employees (deleted 7 years after employment ends)

·        Personnel records such as qualifications, references, consents for processing special categories of personal data, annual leave records, disciplinary and grievance file, death benefit forms, resignation, termination and retirement letters/documents (deleted 7 years after employment ends).

·        Records in connection with working time including opt out form, time sheets, health and safety assessment records etc. (deleted 3 years after the relevant period).

·        Maternity and Adoption records (deleted 4 years after the end of the tax year in which the pay period ends)

·        Accident records including death or injury in connection with work (deleted 4 years from the date the report was made)

If you have any questions about this privacy notice, please contact your manager or Will Hyde.

1.                Using the internet

1.1              Where we provide internet access, this is provided solely for business purposes.

1.2              You should not access any web page or download any image or other file from the internet which could be regarded as illegal, offensive, in bad taste or immoral. Even web content that is legal in the UK may be in sufficient bad taste to fall within this prohibition. As a general rule, if any person (whether intended to view the page or not) might be offended by the contents of a page, or if the fact that our software has accessed the page or file might be a source of embarrassment if made public, then viewing it will be a breach of this policy.

1.3              We may block or restrict access to some websites at our discretion.

2.                Personal use of our systems

2.1              We permit the incidental use of our systems to send personal e-mail, browse the internet and make personal telephone calls subject to certain conditions. Personal use is a privilege and not a right. It must not be overused or abused. We may withdraw permission for it at any time or restrict access at our discretion.

2.2              Personal use must meet the following conditions:

(a)           it must be minimal and take place exclusively outside of normal working hours (that is, during your lunch break, and before or after work);

(b)          personal e-mails should be labelled "personal" in the subject header;

(c)           it must not affect your work or interfere with the business;

(d)          it must not commit us to any marginal costs; and

(e)          it must comply with our policies including the Equal Opportunities Policy, Anti-harassment and Bullying Policy, Data Protection Policy and Disciplinary Procedure.

3.                Monitoring

3.1              Our systems enable us to monitor telephone, e-mail, voicemail, internet and other communications. For business reasons, and in order to carry out legal obligations in our role as an employer, your use of our systems including the telephone and computer systems (including any personal use) may be continually monitored by automated software or otherwise.

3.2              We reserve the right to retrieve the contents of e-mail messages or check internet usage (including pages visited and searches made) as reasonably necessary in the interests of the business, including for the following purposes (this list is not exhaustive):

(a)           to monitor whether the use of the e-mail system or the internet is legitimate and in accordance with this policy;

(b)          to find lost messages or to retrieve messages lost due to computer failure;

(c)           to assist in the investigation of alleged wrongdoing; or

(d)          to comply with any legal obligation.

4.                Prohibited use of our systems

4.1              Misuse or excessive personal use of our telephone or e-mail system or inappropriate internet use will be dealt with under our Disciplinary Procedure. Misuse of the internet can in some cases be a criminal offence.

4.2              Creating, viewing, accessing, transmitting or downloading any of the following material will usually amount to gross misconduct (this list is not exhaustive):

(a)           pornographic material (that is, writing, pictures, films and video clips of a sexually explicit or arousing nature);

(b)          offensive, obscene, or criminal material or material which is liable to cause embarrassment to us or to our clients;

(c)           a false and defamatory statement about any person or organisation;

(d)          material which is discriminatory, offensive, derogatory or may cause embarrassment to others (including material which breaches our Equal Opportunities Policy or our Anti-harassment and Bullying Policy);

(e)          confidential information about us or any of our staff or clients (except as authorised in the proper performance of your duties);

(f)           unauthorised software;

(g)           any other statement which is likely to create any criminal or civil liability (for you or us); or

(h)          music or video files or other material in breach of copyright.

1.                Personal use of social media

1.1              Personal use of social media is never permitted during working hours or by means of our computers, networks and other IT resources and communications systems.

2.                Prohibited use

2.1              You must avoid making any social media communications that could damage our business interests or reputation, even indirectly.

2.2              You must not use social media to defame or disparage us, our staff, customers or any third party; to harass, bully or unlawfully discriminate against staff, customers or third parties; to make false or misleading statements; or to impersonate colleagues, customers or third parties.

2.3              You must not express opinions on our behalf via social media, unless expressly authorised to do so by your manager. You may be required to undergo training in order to obtain such authorisation.

2.4              You must not post comments about sensitive business-related topics, such as our performance, or do anything to jeopardise our trade secrets, confidential information and intellectual property. You must not include our logos or other trademarks in any social media posting or in your profile on any social media.

2.5              You are not permitted to add customers to personal social networking accounts.

2.6              Any misuse of social media should be reported to a manager.

3.                Guidelines for responsible use of social media

3.1              Be respectful to others when making any statement on social media and be aware that you are personally responsible for all communications which will be published on the internet for anyone to see.

3.2              If you disclose your affiliation with us on your profile or in any social media postings, you must state that your views do not represent those of your employer (unless you have been authorised to speak on our behalf). You should also ensure that your profile and any content you post are consistent with the professional image you present to clients and colleagues.

3.3              If you are uncertain or concerned about the appropriateness of any statement or posting, refrain from posting it until you have discussed it with your manager.

If you see social media content that disparages or reflects poorly on us, you should contact your manager. 

1.                About this policy

1.1              At Billing Better, we welcome dogs to our premises. We understand that dogs can add to the office atmosphere, improve mental health of staff and be helpful to the owners of the dogs to be able to bring them in.

1.2              On balance, any dogs coming into the office must promote the experience of all workers and aid the Company in delivering its aims.

1.3              This policy does not form part of any contract of employment and we may amend or revoke it at any time.

2.                Who does this policy apply to?               

2.1              This policy applies to all employees, officers, casual workers, agency workers, volunteers and interns.

3.                Requesting to bring in your dog               

3.1              Any request to bring in your dog will need to be submitted and approved by your line manager.

4.                Guidelines               

4.1              All dogs will be subject to a 3-strike policy. If any of the behaviours in clause 4.2 are shown, they may count as a strike. Any strikes will be determined and issues by our Leadership team. 

4.2              Upon receiving three strikes, a dog will no longer be allowed onto our premises.

4.3              We will only allow:

(a)           a maximum of 3 dogs on our premises at any one time;

(b)          dogs that are under the owner’s control at all times; and

(c)           dogs that do not:

(i)            bark continuously

(ii)           jump up at people

(iii)          eat staff members food out of bins, desks, their bags or anywhere else on our premises

(iv)          defecate in the office

4.4              The owner of the dog will be entirely responsible for the above and any damage and/or mess caused by the dog, including clearing or cleaning any damage or mess caused by the dog. If any damage or mess caused by the dog is not cleared or cleaned or if this is not possible, we will make arrangements to facilitate this and may pass on any applicable charges to the owner of the dog.

4.5              If anyone working for the Company has an allergy to dogs, a dog has a negative impact on anyone’s health or this interferes with their ability to practice their religion, their needs will be put first and we may prevent dogs coming onto our premises. 

1.                About this policy

1.1              At Billing Better we are committed to conducting business in an ethical and responsible manner, and we have zero tolerance for slavery and human trafficking in any form.

1.2              This policy outlines our commitment to preventing slavery and human trafficking in our organisation and supply chain.

2.                Definitions               

2.1              The term "modern slavery" refers to slavery, servitude, forced labour, and human trafficking, as defined by the United Kingdom's Modern Slavery Act 2015.

2.2              The term "supply chain" refers to all parties involved in the production, processing, and distribution of our products and services, including contractors, suppliers, and sub-contractors.

3.                Scope               

3.1              This policy applies to all parts of our organisation, including our employees, contractors, and other stakeholders.

3.2              This policy also applies to our supply chain, including contractors, suppliers, and sub-contractors.

4.                Commitment               

4.1              We are committed to preventing slavery and human trafficking in all forms and to promoting ethical and responsible business practices.

4.2              We have implemented a range of measures to ensure compliance with this policy, including:

(a)           Conducting due diligence on our supply chain to identify and assess the risk of modern slavery and human trafficking.

(b)          Providing training and awareness programs to educate our employees, contractors, and other stakeholders about modern slavery and human trafficking.

(c)           Establishing a process for reporting any instances or suspected instances of modern slavery and human trafficking.

(d)          Investigating and remedying any incidents of modern slavery and human trafficking that are identified.

(e)          Protecting the confidentiality and safety of anyone who reports such incidents.

5.                Due Diligence               

5.1              We will conduct due diligence on our supply chain to identify and assess the risk of modern slavery and human trafficking.

5.2              This due diligence will include:

(a)           Reviewing our suppliers' policies and practices relating to modern slavery and human trafficking.

(b)          Requiring our suppliers to comply with our Anti-Human Trafficking and Modern Slavery policy and to provide evidence of their compliance upon request.

(c)           Terminating relationships with any suppliers who fail to comply with this policy.

5.3              We will review and update our due diligence processes on an ongoing basis to ensure that they are effective in preventing modern slavery and human trafficking.

6.                Training and Awareness               

6.1              We will provide training and awareness programs to educate our employees, contractors, and other stakeholders about modern slavery and human trafficking.

6.2              These programs will include information on:

(a)           The definitions and signs of modern slavery and human trafficking.

(b)          Our commitment to preventing modern slavery and human trafficking.

(c)           The steps that employees and contractors can take to report any instances or suspected instances of modern slavery and human trafficking.

6.3              We will update and refresh our training and awareness programs on a regular basis to ensure that they remain relevant and effective.

7.                Reporting and Remediation               

7.1              We have established a process for reporting any instances or suspected instances of modern slavery and human trafficking.

7.2              This process includes:

(a)           Providing multiple ways for employees and contractors to report incidents, including anonymous reporting options.

(b)          Protecting the confidentiality and safety of anyone who reports an incident.

(c)           Investigating and remedying any incidents of modern slavery and human trafficking that are identified.

7.3              We will review and update our reporting and remediation processes on an ongoing basis to ensure that they are effective in preventing modern slavery and human trafficking.

8.                Monitoring and review               

8.1              We will regularly monitor and review the effectiveness of this policy and its related policies and procedures to ensure that they are meeting their intended goals.

8.2              We will also review and update this policy on an ongoing basis to ensure that it remains relevant and effective.

8.3              We will regularly assess the risks of modern slavery and human trafficking in our organisation and supply chain, and we will take appropriate action to mitigate any identified risks.

9.                Reporting and Transparency              

9.1              We will report on our efforts to prevent modern slavery and human trafficking in our organisation and supply chain, in accordance with relevant laws and regulations.

9.2              This will include providing information about our due diligence processes, the training and awareness programs that we have in place, and any incidents of modern slavery and human trafficking that we have identified and remediated.

10.              Contact information            

10.1           If you have any questions about this policy or our efforts to prevent modern slavery and human trafficking, please contact the Leadership team.