Policies

Modern Slavery

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Data Protection

Data protection principles:

CCM is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

Processed lawfully, fairly and in a transparent manner in relation to individuals.
Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes are not be considered to be incompatible with the initial purposes.
Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Accurate, and where necessary, kept up to date; every reasonable step to be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals.
Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

General provisions

This policy applies to all personal data processed by CCM.
The Responsible Person shall take responsibility for CCM’s ongoing compliance with this policy.
This policy shall be reviewed at least annually.

Lawful, fair and transparent processing

Individuals have the right to access their personal data and any such requests made to CCM shall be dealt with in a timely manner.

Lawful purposes

All data processed by CCM must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests
Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in CCM’s systems.

Data minimisation

CCM shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Accuracy

CCM shall take reasonable steps to ensure personal data is accurate.
Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

Archiving / removal

To ensure that personal data is kept for no longer than necessary, CCM shall regularly review data.
Archiving requirements shall consider what data should/must be retained, for how long, and why.

Security

CCM shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
When personal data is deleted this should be done safely such that the data is irrecoverable.
Appropriate back-up and disaster recovery solutions shall be in place.

Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, CCM shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Information Commissioners Office (ICO).

Equality and diversity

Our policy

The purpose of this policy is to provide diversity and equality to all in employment, irrespective of their gender, race, ethnic origin, disability, age, nationality, national origin, sexuality, religion or belief, marital status and social class. We oppose all forms of unlawful and unfair discrimination.

All employees, whether part time, full time or temporary, will be treated fairly and equally.

Selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability.

All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the organisation.

Our commitment:

Every employee is entitled to a working environment which promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated.

The commitment to diversity and equality in the workplace is good management practice and makes sound business sense.

Breaches of our diversity and equality policy will be regarded as misconduct and could lead to disciplinary proceedings.

This policy is fully supported by senior management.

The policy will be monitored and reviewed annually.

The senior management will review the policy and its implementation on a regular basis to ensure compliance.

Health and safety

Our general policy statement is:

To provide adequate control of the health and safety risks arising from our work activities;
To consult with our employees on matters affecting their health and safety;
To provide and maintain safe plant and equipment;
To ensure safe handling and use of substances;
To provide information, instruction and supervision for employees;
To ensure all employees are competent to do their tasks, and to give them adequate training;
To prevent accidents and cases of work-related ill health, as far as is reasonably practicable;
To maintain safe and healthy working conditions;
To review and revise this policy as necessary at regular intervals.