Policies

“The Therapeutic Tutors CIC” whether trading directly or under the name “The Therapeutic Tutors” is committed to ensuring the protection of children (under 18 years of age) and vulnerable adults at risk of abuse through the development and implementation of effective policies and best practice.

This Safeguarding Policy, with the associated procedures, provides guidance for all members of The Therapeutic Tutors who may have any safeguarding concerns within the context of their work. Types of relevant activity include: coaching or training directly provided by The Therapeutic Tutors or on behalf of another supplier; provision of consultancy services to education or care organisations that work with children or adults at risk; access to either personal or confidential data/information that relates to children or adults at risk.

Members of The Therapeutic Tutors including staff, contractors, suppliers and volunteers, recognise and accept the responsibility to develop and raise awareness of the issues involved in working with children (under 18 years of age) and vulnerable adults.

Definitions for Children and Vulnerable Adults

The Department for Education (DfE) ‘Keeping children safe in education’ guidance, Part 1, describes safeguarding as including:protecting children from maltreatment; preventing impairment of children’s health or d evelopment; where a child is suffering significant harm, or is likely to do so, action should be taken to protect that child. Action should also be taken to promote the welfare of a child in need of additional support, even if they are not suffering harm or are at immediate risk.

The Counter-Terrorism and Security Act 2015 is about preventing people from being drawn into radicalisation and must also be considered within the scope of this policy. Section 26 of this Act places a duty on certain bodies (“specified authorities” listed in Schedule 6 to the Act), in the exercise of their functions, to have “due regard to the need to prevent people from being drawn into terrorism”. An adult at risk of abuse is any person who is aged 18 years or over and at risk of abuse or neglect because of their needs for care and or support. The Care Act 2014 states “Safeguarding adults means protecting a person’s right to live in safety, free from abuse and neglect”.

The broad definition of a vulnerable adult is a person ‘who is eighteen years of age or over, and who may be in need of community care services by reason of mental or other disability, age or illness, and who is or may be unable to take care of him/herself, or unable to protect him/herself against significant harm or exploitation.’ (“Who Decides‟:1997, Lord Chancellor‟s department).

The Therapeutic Tutors shall:

• provide an environment in which children and vulnerable adults feel safe and valued;

• ensure that members of The Therapeutic Tutors including staff and volunteers take responsibility to protect children and vulnerable adults from harm at all times;

• elect a member of The Therapeutic Tutors as the designated representative for all children and vulnerable adult matters, and to identify appropriate training opportunities;

• develop and adopt a set of guidelines/code of conduct for working with children and vulnerable adults, which all members of The Therapeutic Tutors including staff and volunteers are aware of and adhere to;

• exercise a Duty of Care and, when necessary, share information and/or concerns in a confidential manner with the appropriate outside agency e.g. Social Services, emergency services if there is immediate danger of harm;

• ensure that all staff and volunteers who work with, or have responsibility for, children or vulnerable adults undergo a Disclosure and Barring Service check (DBS);

• ensure recruitment of volunteers is thorough and includes a minimum of two character references to support an application;

• develop a time specific induction period when all new staff and volunteers are introduced to guidelines for working with children and vulnerable adults and policy and procedures;

• ensure volunteers are supervised during a designated probationary period with ongoing regular supervision opportunities;

• review and update this policy and practice annually.

The Therapeutic Tutors Policy Statement

All staff, including contractors and suppliers instructed by and acting for and on behalf of the The Therapeutic Tutors should not have any unsupervised contact with children or adults at risk during visits to Training Centres and/or Recognised Training Centres or in any other situation as part of their work for us unless they have a current DBS check and clearance. We require everyone to declare unspent and exempt convictions at recruitment and appointment. We would not knowingly place anyone in a position that caused them to come into contact with children or adults at risk where unsuitable. The Safeguarding Officer has responsibility for reviewing and updating the Safeguarding Policy and Procedures annually or sooner in the event of any “safeguarding alert” (see under Procedures below). We promote our approach to Safeguarding and that the Safeguarding Officer is the first point of contact for anyone with concerns for either a child or an adult at risk.

Procedure: All members, staff, third party, trustees and other Executive Committee Members who suspects there is abuse of an adult at risk or child, or to whom another has confided such abuse, should report this as soon as possible to the Safeguarding Officer. This is described as a “safeguarding alert”. If there is a concern that the child or adult is at immediate risk of harm the emergency services should also be called immediately.

The Safeguarding Officer will contact the relevant local authority Adult Helpdesk or Safeguarding Adults Service and act in accordance with their guidance in relation to an adult, or contact the relevant local authority Children and Families Helpdesk, or the Safeguarding Children Service for advice on action to be taken in relation to a child.

In the event that there is a safeguarding alert about a member, staff, third party of The Therapeutic Tutors, the Safeguarding Officer who will liaise with the relevant local servicess (see the details below under the heading Additional Support & Advice regarding further action). . These will advise about making a referral to the Local Authority Designated Officer (LADO) who is responsible for dealing with such allegations. If the individual raising an alert regarding a child or adult at risk feels that the Safeguarding Officer has not responded appropriately, or where they have a disagreement with the Safeguarding Officer as to the appropriateness of a referral, it is their right and duty as a citizen to make a direct referral to the local authority designated safeguarding service. If there is an alert implicating the Safeguarding Coordinator, the person contacted with that concern should inform another appropriate representative of The Therapeutic Tutors, who will follow the procedure above.

We are aware that anyone having a concern or receiving a disclosure that some kind of abuse has taken place may feel uncomfortable, hesitant or anxious about voicing it to someone else. It is important to report any concern to the Safeguarding Officer, without trying to make a judgement or assess its validity. It is the role of others to assess the risk. The Therapeutic Tutors members, staff or consultants must simply ensure that they report any concern or disclosure. If a disclosure is made, the person first being confided in should allow the discloser to talk without rush or interruption; showing acceptance of what they say (however unlikely the story may sound) by reflecting back words or short phrases they have used. They should try to remain calm, even if on the inside they are feeling something different.

The Therapeutic Tutors shall follow these guidelines:

• ensure that the adult or child at risk is and feels safe, calling emergency services if there is immediate danger of harm;

• show that we take what they are saying seriously;

• reassure and stress that they are not to blame;

• be honest and explain that we will have to tell someone else (e.g. Safeguarding Officer);

• inform them that we will make a record of what has been said as soon as possible after the event;

• if the discloser decides not to tell you after all, accept their decision but let them know that you are always ready to listen and that you will still need to tell the Safeguarding Officer that a conversation was initiated;

• use language that is age appropriate; and

• for those with a communication difficulty such as hearing or sight impairment, learning difficulty or where English is not their first language, try to ensure there is someone available who can interpret appropriately.

• A person who is confided in should not carry out their own investigation into an allegation or suspicion of abuse. Instead, they should report what they have been told and/or any concerns as soon as possible to the Safeguarding Officer. It is then the role of the Safeguarding Officer to collect and clarify the details of the concern, using the template provided herein under Annex A, and pass these on to statutory agencies with the legal duty to investigate.

Abuse may be defined as the wrongful application of power by someone in a dominant position. This can be in a family, institution or community setting and very often the abuser is known often in a trusted relationship with either the child or adult. It involves an imbalance of power and exploitation without full and informed consent. It is the violation of an individual’s human and civil rights by any other person or persons. Abuse might be unintentional, the important factor is whether the person is harmed or not.

Abuse can take several different forms and may be a single act or repeated acts of: Physical abuse: includes hitting, slapping, kicking, pushing, withholding or misuse of medication;

Sexual abuse: includes sexual assault and rape, or sexual acts where the vulnerable person has not (or could not give) given consent or was forced into consenting;

Psychological abuse: includes threats of harm, emotional abuse, humiliation, verbal abuse, intimidation, coercion, harassment, withdrawal of support, isolation and deprivation (physical and sensory);

Material / financial abuse: includes fraud, theft, exploitation, financial transactions, misappropriation e.g. willed inheritance, property, benefits and possessions;

Neglect & Acts of Omission: includes ignoring physical care and medical needs, withholding basic living requirements e.g. adequate nutrition, safe and warm environment, withholding necessary medication and failure to provide access to appropriate health and social care services and / or educational services;

Discrimination: includes harassment and/or exclusion because of race, creed, culture, ability, gender and any slur deemed offensive and abusive.

Bullying may be defined as deliberately hurtful behaviour, usually repeated over a period of time, where it is difficult for those bullied to defend themselves. It can take many forms, but the three main types are physical (e.g. hitting, kicking, theft), verbal (e.g. racist or homophobic remarks, threats, name calling) and emotional (e.g. isolating an individual from the activities and social acceptance of their peer group). The damage inflicted by bullying can frequently be underestimated. It can cause considerable distress to children to the extent that it affects their health and development or, at the extreme, cause them significant harm (including self-harm). All settings in which children are provided with services or are living away from home should have in place rigorously enforced anti- bullying strategies.

Other kinds of abuse

Can include spiritual abuse (such as when an intimidating leader imposes his/her will on other people, causing them to be fearful to challenge or disagree, believing they will lose the leader's or God's acceptance and approval). In recent years definitions of domestic violence have broadened from that which may occur between two adults who are intimate partners, to threatening behaviour (psychological, physical, sexual, financial or emotional) between adults, aged 18 and over, who are or have been intimate partners or family members, regardless of gender and sexuality - mother, father, son, daughter, brother, sister and grandparents, in-laws or step-family. Children can suffer all forms of abuse in a situation of domestic violence and will also suffer from witnessing domestic violence.

Modern Slavery encompasses slavery, human trafficking, forced labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment.

Organisational Abuse includes neglect and poor care practice within an institution or specific care setting such as a hospital or care home, for example, or in relation to care provided in one’s own home. This may range from one off incidents to on-going ill-treatment. It can be through neglect or poor professional practice as a result of the structure, policies, processes and practices within an organization.

Self-Neglect covers a wide range of behaviour neglecting to care for one’s personal hygiene, health or surroundings and includes behaviour such as hoarding.

Possible indicators of abuse may include a child:

speaking directly or more indirectly about it;

showing unexpected changes in mood or behaviour;

nervousness;

persistent tiredness;

running away;

stealing;

lying.

Categories of adult abuse:

exploitation (includes radicalisation)

Spiritual abuse

Multiple forms of abuse

Inappropriate restraint

Hate crime

Human trafficking

Forced Marriage

Female Genital Mutilation (FGM)

Possible indicators of abuse in relation to an adult

Whilst we do not expect members, staff and consultants, trustees to diagnose abuse, it is also important to be aware, recognise and be alert to signs that all is not well also with an adult:

Disclosing partially or fully;

Frequent or unexplained minor injuries or bruising;

Signs of depression or stress which may happen suddenly or gradually emerge;

Neglected personal care;

Weight loss;

Dramatic change of behaviour /personality – this can happen very suddenly and unexpectedly and is often associated with fear;

Confusion;

Persistent financial hardship;

Denial that anything is wrong and an emphasis that all is extremely well;

Seeking help from numerous sources/people – this may be a direct request for help or attention seeking behaviour;

Acceptance or resignation of a situation as being part of being old and/or disabled;

Deference or submission to a suspected abuser;

Not getting to medical appointments.

Abuse can happen in any setting where people are dependent on the care of others for their well-being.

Code of Conduct

all members, staff, contractors, volunteers etc treat all children and/or vulnerable adults with respect and sensitivity at all times;

all members, staff, contractors, volunteers etc must ensure that the safety and dignity of those children and/or vulnerable adults in their care is maintained at all times;

all members, staff, contractors, volunteers etc have a duty to ensure that any children and/or vulnerable adults in their care are aware that there are designated members of staff to help them with any worries and/or difficulties;

all members, staff, contractors, volunteers etc should be made aware of this Safeguarding Policy, and Duty of Care, during induction and follow the The Therapeutic Tutors procedures for reporting possible / alleged cases of abuse or harm.

Sharing Information

If volunteers have concerns about the possible abuse of a vulnerable adult, or where a disclosure has been made, this must be reported to a member of staff as a Duty of Care responsibility.

An accurate written dated record of concerns, disclosures and any related incident(s) must be made by the volunteer.

The designated staff member will liaise with the relevant agencies and forward the record of concern for information. A copy should be kept on file to which designated staff members only have access.

It is important for staff and volunteers to avoid making assumptions and discussing concerns indiscriminately. Confidentiality, and respect for the vulnerable adult(s) involved, is of the utmost importance.

Volunteer recruitment

Volunteers who wish to work with either children or vulnerable adults are required to obtain a Disclosure and Barring Service (DBS) check, which is valid for three years;

As part of the recruitment process, volunteers will be required to complete an application form, supply two character references and attend for interview (to be interviewed by two or more people, which includes a The Therapeutic Tutors Director or their appointed individual);

Volunteers will have a supervised probationary period of three months with regular supervision thereafter.

Induction & Training

Volunteers will complete an induction period that will include training in:

Guidelines, where applicable, for working with children and vulnerable adults;

recognising different forms of abuse;

guidelines on the process for recording concerns / disclosures (see attached Annex A);

policies and procedures.

Monitoring

This policy will be reviewed annually by The Therapeutic Tutors to ensure it remains fit for purpose.

The designated Safeguarding Officer is Serena Hemmings.

Additional Support & Advice

First point of contact for all local (Surrey County Council) social care calls information and advice:

During the day and in office hours:

CHILDREN

https://www.surreycc.gov.uk/children/contact-childrens-services

Children's Single Point of Access (C-SPA)

If you are a child or young person being abused or neglected, or an adult who is concerned about a child or young person's safety and wellbeing, you can contact the Children's Services 'Single Point of Access' between 9am to 5pm on Monday to Friday.

Phone: 0300 470 9100

Email: cspa@surreycc.gov.uk

ADULTS

contact the Multi Agency Safeguarding Hub (MASH):

Availability: 9am to 5pm, Monday to Friday

Telephone: 0300 470 9100

Online: Adult Safeguarding Referral online form. If you would like a Microsoft Word version of this form, please email us using the following address:

Email: ascmash@surreycc.gov.uk

Client Safety Agreement

Safety Aspects of Horse-related Activities

SECTION A. Protective Attire

I understand that I should always wear hard-soled, fully enclosed shoes

or boots and socks to protect feet, and long trousers to protect legs

while working around or interacting with horses.

SECTION B. The Nature and Physical Character of the Horse

Domesticated, well-trained horses are usually obedient, docile and

affectionate; however, it is important to understand that their innate

survival instincts. The following information has been collated with your

safety in mind:

1. I am advised that all horses at The Therapeutic Tutors CIC run as a

herd. The Therapeutic Tutors CIC believes in the promotion of natural

herd behaviour such as mutual grooming, playing and companionship.

2. I am advised that horses involve risk and can be unpredictable by

nature, with minds of their own, as are all animals both domestic and

wild. The horse can be very responsive to your energy so be aware of

how you are feeling.

3. I am advised that when a horse is frightened, angry, under stress or

feels threatened, it is the horse’s instinct to move forward or sideways,

to run away from danger or gallop to safety. Please be aware of your

position / where you are standing when around theThe Therapeutic

Tutors CIC. I am advised not to stand between multiple horses. I am

advised to stand out of the way of the horses flight path.

4. I am advised that if a horse is frightened or feels threatened from

behind, the horse may kick. Please be aware of your distance.

5. I am advised that a human must always approach a horse calmly and

quietly with caution, preferably to the horse’s shoulder or lower neck.

6. I am advised that loud and/or sudden unexpected movements, such as

dropping an object near a horse, can provoke a domesticated horse to

react according to natural, protective instincts as described above.

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6. I am advised that the first signs of anger or fear in a horse are the

sudden tensing of the muscles of the body, possibly laying the ears flat

back against the head, or quickly tossing or raising the head. I

understand that the person taking responsibility for my time with the

herd will manage any of these signs should they be evident.

7. I am advised that a horse can see independently with each eye,

actually looking in one direction with one eye and another direction with

the other eye. The horse can also focus both eyes on one object

somewhere in front of him/her. Typically the direction in which the ear is

pointing will tell an observer where the eye is looking on the same side

and what the horse is listening to.

8. I am advised that a horse has two blind areas around which he/she

cannot see. Those areas are directly behind the horse and directly in

front. When a horse has his/her head lowered to the ground, the spot

directly at the end of the nostrils is a blind area. This is the reason it is

best to approach a horse close to the shoulder, and never to surprise a

horse from the rear, or to reach first for the horse’s mouth, muzzle area.

9. I am advised that while a horse is very sure-footed by nature, horses

may accidentally step on an object such as a human’s foot when they are

balancing or turning around. When a horse is worked on unstable ground

or slippery grass or footing, the horse could fall down and be injured.

10. In pursuing activities with the The Therapeutic Tutors CIC and being

around the The Therapeutic Tutors CIC herd of horses the Participant

understands and accepts the unavoidable risks inherent in herd and

horse related activities including but not limited to bodily injury, physical

harm, loss of property, damage or loss of lives. The Therapeutic Tutors

CIC cannot accept any liability in relation to the same. The Participant

knowingly and voluntarily engages in the same organised byThe

Therapeutic Tutors CIC.

SECTION C. Physical and Mental Wellbeing

I acknowledge that practices such as mindfulness, experiential and

equine facilitated learning are also recognised as having therapeutic

value but note that the exercises in this workshop have no therapeutic

intention and warrant that I will remain responsible for my own personal

emotional well-being at all times during and after these sessions.

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I have read and understand the above concerning protective attire,

the nature and physical character of the horse and physical and

mental wellbeing.

Registration on the Accredited Practitioner Register™ or Organisational Membership of Athena Herd Foundation recognises alignment to the Athena Herd Foundation Ethos of Ethical Treatment of Horses. These are standards of equine care which build upon Friends, Freedom and Forage as published in The Horse’s Manifesto (2012) by the International Association of Animal Behaviour Consultants (IAABC), and the Five Domains model (2016). The Five Domains represent an update of the Five Freedoms (1965) produced by Professor David Mellor at Massey University in New Zealand. This means a focus on positive experiences rather than minimising exposure to negative ones.

This means:

focus on the physical and mental health and wellbeing of the horse(s)

to provide conditions which align to the themes of the Five Domains:

Nutrition

Environment

Health

Behaviour

Mental state

The Athena Herd Foundation Framework of Professional Standards have been defined to ensure that registered practitioners create and maintain appropriate and effective standards in the delivery of the service.

It aims to ensure that the service users are free to engage safely and freely, and so to work towards effective progress towards their personal goals and aspirations. Therefore, members of the Accredited Practitioner Register™ are charged with acting in such a way that facilitates feelings of safety and trust for the service user.

Membership of the Register is a serious ethical commitment and as such, a registered practitioner shall:

act at all times with sound ethics and morals at all times;

ensure that all decisions made with regard to the service users support or treatment are made ethically;

recognise in practice the foundational motivations of acting to alleviate individual distress and suffering, minimise risk to service users, enhance individual wellbeing and resilience, and facilitate an individual sense of self-worth and value;

in delivery recognise the uniqueness of individual human experience and so respecting the personal feelings and emotions of each service user;

at all times prioritise and acknowledge the needs of our service users;

maintain a physically safe space for service users in their interaction with horses, as well as generally whenever they are onsite;

ensure appropriate levels of privacy are maintained for service users throughout the duration of their session(s);

maintain appropriate care and attention for the equines being worked with;

properly contract sessions or groups of sessions, establishing clear and bounded framework of understanding for the service user about how the sessions will be carried out, how they will be engaged, what will be in scope and what will not;

ensure that service users have clear expectations of what activities can be provided and what outcomes might be achievable;

maintain service user focus throughout sessions and maintain respect for the service user and their feelings and experiences;

recognition and appropriate respect for all protected characteristics as defined within Equality Act 2010;

work at all times within the bounds and limitations of their professional competencies and publicly offered services;

protecting general service user confidentiality and privacy, including their personal details and information;

monitor service use progress throughout period of treatment;

maintain clear and appropriate record keeping, and keep these notes appropriately private and secure location;

monitoring and recording service user experience throughout and acting where necessary to better or improve that experience;

sustain a regular practice of professional supervision;

maintain appropriate and current personal legal checks and searches;

sustain and keep up to date levels of professional practice, including personal learning and development, and self-care and practice;

provide a clear and accessible process of recourse should the service user need to raise a complaint or concern;

maintain a list of appropriate sign-posting options that can be shared with the service user should it become necessary

Data Protection Policy

“The Therapeutic Tutors CIC” is committed to protecting all personal data. Therefore, when you contact Us (for whatever reason) you can be confident about how personal data will be looked after and used. It needs to retain and process certain data to enable the efficient running of the business.

In developing relationships with horses and learning new skills, participants gain increased self-confidence, self-awareness, improved communication skills, learning responsibility and empathy. These are factors linked to resilience said to be essential in achieving positive life outcomes (“Services”).

Please read this Data Protection Policy carefully to understand Our views and practices regarding your personal data and how We will treat it.

“The Therapeutic Tutors CIC” owns and operates “www.thetherapeutictutors.co.uk” (the "Website").

For the purpose of the Data Protection Act 2018 and the General Data Protection Regulation (Regulation (EU) 2016/679) and/or any relevant law implemented as a result of General Data Protection Regulation and E Privacy Law (together, "Data Protection Laws"), We are a:

data controller in respect of any personal data that You share with Us, or that We collect, through Our Website (including any personal data that you provide to Us, or that We collect, during your registration for, and subscription to, the Services we provide) or otherwise in Your communications with Us; and

data processor in respect of personal data that You share with Us as part of Your use of the Services that We provide, and in respect of which You are the data controller. Our and Your respective obligations in relation to that personal data are set out in this Data Protection Policy and Our Terms and Conditions.

You can contact Us directly, at the above address, by email at info@therapeutictutor.org, or through our Website.

This Data Protection Policy applies to all use of Our Website and the provision of Services to You, and any other communications You have with Us from time to time.

For the purposes of Data Protection Laws and paragraph b. above only, We process "Personal Data " (as defined in Our Terms and Conditions) in accordance with the following scope, nature and purposes:

Nature and purpose of the processing of personal data: necessary for the provision of our Services to You in accordance with our Terms and Conditions.

Subject matter of the Processing of Personal Data: for Our provision of Services to You, as set out in Our Terms and Conditions.

Duration of the Processing of Personal Data: the Term of Our Agreement with you in accordance with our Terms and Conditions entered into under the same, until We delete that data in accordance with the Agreement between Us.

Categories of Personal Data being shared between You and Us: personal data relating to individuals provided to Us by You (or at Your direction) during Our provision of the Services.

Types of Data Subject in respect of whom We Process Personal Data: the Data Subjects in respect of whom use Our Services and data is sent (or provided) to Us by You or at Your direction. For the avoidance of doubt, this does not relate to Our processing of Your personal data otherwise than in accordance with paragraph b. above.

Fair processing: We will only use Your personal data in the manner set out in this Data Protection Policy. We will only use Your personal data in a way that is fair to You. We will only collect personal data where it is necessary for Us to do so and where it is relevant to Our dealings with You. We will only keep your personal data for as long as it is relevant to the purpose for which it was collected or for as long as we are required to keep it by law.

Other than as set out in this Data Protection Policy, We shall NOT sell or disclose your personal data to third parties without obtaining Your prior consent unless this is necessary for the purposes set out in this Data Protection Policy or unless We are required to do so by law.

Collection and processing of your personal data: We collect:

Your title and name:

By You filling in an application form at the time you subscribe to receive the Services we provide either directly or through the Website (including newsletters and other communications).

When You fill in forms available on the Website to get in touch with Us or get in touch with Us directly for example to inform Us of a particular issue, to make a complaint, to request access to additional services, or register for an event.

When You contact Us in any other way for any reason.

Your address:

By You filling in an application form at the time you subscribe to receive the Services we provide either directly or through the Website.

Your email address:

By You filling in an application form at the time you subscribe to receive the Services we provide either directly or through the Website (including newsletters and other communications).

When You fill in forms available on the Website or get in touch with Us directly, for example to inform Us of a particular issue, to make a complaint, to request access to additional services, or sign-up for an event.

When You contact Us in any other way for any reason.

Your contact telephone number(s)

By You filling in an application form at the time you subscribe to receive the Services We provide either directly or through the Website (including newsletters and other communications).

When You fill in forms available on the Website to get in touch with Us or directly, for example to inform Us of a particular issue, to make a complaint, to request access to additional services, or register for an event.

When You contact Us in any other way for any reason.

Your username and password for accessing the restricted areas of the Website

By You filling in an application form at the time you subscribe to receive the Services we provide through the Website or contacting Us directly.

Your business name (if applicable)

By You filling in an application form at the time You subscribe to receive the Services We provide through the Website or directly (including newsletters and other communications).

Special Category Data

Owing to the Services that We offer, We need to collect, store and process special category data about You. Special category data is information about an individual that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and/or information concerning health. We collect and process information concerning your health (health data) for the purpose of assessing the suitability of our Services. Where We collect such information, We will only request and process the minimum necessary for specified purposes. The legal basis for this processing is the compliance with our legal obligations, to protect your vital interests and consent.

Why do We use the personal data?

We use the personal data You provide to Us for the following purposes:

To provide You with billing information in relation to any Services that We provide to You. This is necessary for the performance of the contract We have in place with You.

To manage the Website, detect fraud or Website abuses, send You information relevant to the Website and in case We have any queries. This is in our legitimate interest.

To carry out Our obligations arising from any Agreement entered into between You and Us. This is necessary for the performance of the Agreement We have in place with You.

To notify You about changes to Our Services. This is necessary for the performance of the Agreement We have in place with You.

To allow You to register for a Training Programme or event through Our Website, which may include sending an email to You to confirm your details. This is necessary for the performance of the Agreement We have in place with You.

To give You a new password if You have forgotten it. This is necessary for the performance of the Agreement We have in place with you.

To provide learner/customer support. This is necessary for the performance of the Agreement We have in place with You.

To prevent or investigate prohibited activity. This is in our legitimate interest.

To enforce Terms and Conditions and/or any Agreement entered into between Us. This is in our legitimate interest.

How long do We hold the personal data for?

If We are providing Services to You, we will keep your personal data for as long as We have an Agreement with You to provide Services to You through the Website.

We will keep personal data after We stop providing Services to You through the Website, to see if you would like to start using those Services again. After that, We will delete Your personal data, except where We need to keep it for legal, regulatory or audit reasons, in which case we may do so for 6 (six) years after You cease to be Our customer.

In some circumstances You can ask Us to delete your data (see below for further information).

In some circumstances We may anonymise Your personal data (so that it can no longer be associated with You) for research or statistical purposes in which case We may use this information indefinitely without further notice to You.

Otherwise, We will only retain Your personal data for as long as is necessary for the reason We collected it. In making this decision, We consider the amount, nature and sensitivity of the data, the reason We process it and, whether We can achieve that purpose without processing Your data, legal requirements, and the potential risks to You from Us processing Your data. You can contact Us for more information about how long We hold your data for.

Information You provide to Us when enquiring about, or applying for, jobs listed on the Website or through such other media as We may use for such purposes from time to time. Please see "Recruitment" below.

Recruitment

We are the data controller for any information You give to us during a job or volunteer enquiry or application process.

We will only collect the information that We need for recruitment purposes as part of the job or volunteer application process, such as your name, address, email address, phone number, employment history, salary history and referees (together, "Recruitment Data"). We will retain Recruitment Data for as long as is necessary, and in any event for no longer than 2 (two) years, and, if we employ you, for the duration of your employment with us and for a period after your employment ends, in accordance with our internal policies of which you will be informed if you join us.

We will use Recruitment Data only for the purpose of dealing with Your enquiry or application, or to fulfil our legal and/or regulatory obligations. This might include contacting You to keep your application moving and assessing your suitability for the particular role We have available.

We will not share Recruitment Data with any third parties for marketing purposes, and We will not transfer it outside of the European Economic Area.

You do not have to provide personal data to us when We ask for it, but it may impact Your application if you do not give Us all of the information We need to assess your suitability for the role We have available.

If We make you a conditional offer of employment, We will ask you for further information, such as proof of your qualifications and identity, and information about Your health. If We then make you a final offer of employment, We will ask you for details of Your bank account (so we can pay your salary), emergency contact details, and details of any pension scheme of which you are a member.

Making sure the Personal Data We hold is accurate and up-to-date

You should only submit to Us or the Website information which is accurate and not misleading.

By submitting Your or anyone else's data to Us or the Website, You must ensure that You have full authority and consent to supply Us with that data on their behalf and You warrant to Us that You do have that authority.

IP addresses

We may collect information about Your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our Users' browsing actions and patterns and does not identify any individual.

We use this data to ensure that content from the Website is presented in the most effective manner for You and for Your computer. We hold this data for 2 (two) years.

Cookies

You can set Your browser to refuse all or some browser cookies, or to alert You when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. For more information about the cookies We use, please see Our Cookie Policy.

Where We store your Personal Data

All information You provide to Us is stored on Our secure servers. We use industry standard security and firewalls on Our servers. Where We have given You (or where You have chosen) a password which enables You to access certain parts of the Website, You are responsible for keeping that password confidential. We ask You not to share a password with anyone.

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of Your information. Our security procedures mean that We may occasionally request proof of identity before We disclose personal information to You.

Unfortunately, the transmission of information via the Internet is not completely secure. Although We do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website. Any transmission is at Your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Security

We hold all personal data securely, whether the personal data is in physical or electronic format. We have put in place appropriate security measures to prevent Your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to Your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process Your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify You and any applicable regulator of a breach where We are legally required to do so.

Sharing Personal Data with third parties

In providing Our Services or otherwise running our business, We use third parties which assist Us in operating Our business, and which process certain personal data on Our behalf. We share personal data with those third parties only to the extent it is necessary for Us to provide the Services, and where it is in Our legitimate interest to do so. We have contracts with those third parties in which they are obligated to process personal data in compliance with Data Protection Laws. All third parties are based in European Economic Area (EEA). See Our Terms and Conditions for information about third parties that We use in providing our Services.

Other third parties that We use in operating the Website, other than for providing our Services, are as set out below:

Third party: Google, Inc. (Google Analytics)

Purpose: We use this provider to supply information about Your usage of the website.

In most circumstances We will not disclose personal data without consent. However, when We receive a complaint or communication from, for example, the Information Commissioner's Office or another regulator or relevant body (such as the Police), We may be under an obligation to share personal information.

Other websites

The Website may, from time to time, contain links to and from the websites. If you follow a link to any of these websites, please note that these websites have their own data protection/privacy policies and We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Your rights under Data Protection Laws

If You would like to:

- correct or update the Personal Data that We hold about You

- ask that We delete Your personal data;

- get a copy of the personal data that We hold about You;

- access the personal data We hold about You;

- restrict the uses for which We use your personal data;

- transfer the personal data We hold about You to a third-party data controller;

- object to Our processing of Your personal data for particular purposes; or

- withdraw Your consent to Our use of your personal data (where relevant);

Please contact Us promptly directly or through our Website or by post sent to Our registered address. When contacting Us, please include your name, email address and customer reference so that we can be sure that it is You that is contacting Us and not somebody else.

Usually, You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if Your request is clearly unfounded, repetitive or excessive. Alternatively, We may refuse to comply with Your request in these circumstances.

You can unsubscribe from receiving marketing communications from Us by contacting Us directly or through Our Website or by post sent to Our registered address.

We may need to request specific information from You to help Us confirm Your identity and ensure Your right to access Your personal data (or to exercise any of Your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact You to ask You for further information in relation to Your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if Your request is particularly complex or You have made a number of requests. In this case, We will notify you and keep you updated.

Changes to Our Data Protection Policy

Any changes We make to this Data Protection Policy will be posted on Our Website and, where appropriate, notified to You by e-mail. Each time you enter the Website, you agree that the Terms and Conditions and this Data Protection Policy current at that time shall apply to all personal data held by Us.

Contact

Questions, comments and requests regarding the Terms and Conditions and/or this Data Protection Policy are welcomed and should be sent to us directly or through our Website, email or by post sent to our registered address.

The Therapeutic Tutors Terms and Conditions

Refunds and cancellation policy 

When you book an appointment with us, we commit to making that time available for you, and close that time to anyone else. If you are late for your appointment, the session will end at the scheduled time, meaning your session will unfortunately be shorter. We have reserved this time for you and only you and have other people scheduled after your time. In turn, we promise to honour our appointments and be on time as well. Your time is valuable and so is ours and our equine and canine colleagues. If you cancel after the 24 hour limit or fail to turn up for any reason you will be charged in full. If you need to cancel your appointment please alert us by email at the earliest opportunity. Equine Facilitated Learning (EFL) is a collaborative process in which client and EFL Practitioner work together as a team to help develop self awareness and develop interpersonal skills. The number of sessions varies depending on the individual and the reason for seeking this type of self development. Our aim is to provide a brief but comprehensive programme using evidence-based techniques and approaches, with the intention of giving you the best chance of achieving the changes you are looking for. You will gain skills which will help you stay feeling good. As with all therapeutic, educational or medical interventions, success cannot be guaranteed, as progress depends in part upon the motivation and active participation of the client. The EFL Practitioner provides the rationale and programme for EFL following discussion and initial consultation. 

Protecting your personal information 

Your personal details will not be shared with anyone for any purpose, other than with your express permission. Under the GDPR, we cannot keep information when the original purpose has come to an end. To send you information from time to time that we feel will be of interest to you, we keep a record of your email in the Cloud. You can unsubscribe from this at any time. Once you have completed EFL or Canine Assisted Interventions with us, which we define as when we have not heard from you for 2 months, all information and notes taken during the course of therapy will be shredded to protect your privacy. Some moral and legal limitations apply to confidentiality. An EFL Practitioner has a responsibility both to the client and to the community at large. These limitations mainly concern risk of serious self-harm, harm to others and child protection. If a situation arises in which the moral or legal limits of confidentiality are exceeded, this will be explained and discussed with you. Trained, qualified, nationally registered and insured for your safety and protection we hold full professional indemnity and public liability insurance. Our Practitioners are registered with the ACCPH and abide by their code of ethics. You have the right to access their official procedures in circumstances where an issue cannot be satisfactorily resolved within the bounds of the client/practitioner relationship.

This Compliments and Complaints Policy covers:

This policy covers those directly receiving the provision of any service by the “The Therapeutic Tutors CIC”. (“Company”)

The Company:

strives to provide excellent Service and Training;

values and encourages any concerns to be raised as early as possible with an The Company;

takes all Compliments and Complaints seriously and reaches out to all parties involved;

values the time taken to bring Compliments and/or Complaints to our attention and uses such Compliments and Complaints and feedback as a mechanism for continuous improvement;

is committed to carrying out a thorough investigation and working through amicable solutions;

records and maintains a record of all Compliments and Complaints;

Making a Compliment

If you wish to formally Compliment The Company on any aspect, please contact The Company in writing either by post or email.

Making a Complaint

If you wish to raise a Complaint against The Company on any aspect of same’s business, please contact The Company in writing either by post or email, as follows:

duly complete the Compliments and Complaints Form and submit to The Company or an appropriate other person in the case that anything raised is in relation to the same either by email or post (see below);

this must be done within one (1) calendar month of the date of the event that the complaint relates to;

we will look to acknowledge your Complaint as soon as is reasonably possible and in any event within five (5) working days from receipt of the same;

we will keep you informed at each stage of the Complaints process;

the duration of the Complaints process is dependent on the nature and complexity of the Complaint and the availability of associated documentation. Having said this, a Complaint will normally be either responded to or a progress update given at 10 working day intervals thereafter until the Complaint has reached a satisfactory conclusion. In cases where a complaint cannot be resolved to the satisfaction of all parties concerned, the final decision will rest with the Company’s Directors;

we do not charge any fees to cover the administrative and member costs involved in dealing with Complaints.

Contact us:

Please send the Company your duly completed Compliments and Complaints Form marked for the attention of Director either by:

Post: 9 Woodlands Grove, Coulsdon, Surrey CR5 3AN

Email: info@therapeutictutor.org

Please note that the Company Mindset will not accept anonymous complaints.

Legal Advice:

If, at any point, any of the parties involved wish to place the matter in the hands of their solicitors, The Company will only continue to communicate through the respective solicitors. This does not prevent any of the parties seeking legal advice.

Feedback or Opportunity to Improve

The Company is committed to ensuring all our members, learners, service users have a positive experience with us. However, we recognise that there may be an occasion where you consider there is some feedback or an opportunity for The Company to improve and wish to bring this to our attention. We welcome all feedback which will help us improve our service.

Please contact The Company through the email address info@therapeutictutor.org with your feedback.

Handling of Your Personal Data

Please note that our Data Protection Policy can be found at “www.thetherapeutictutors.co.uk” around how we use and protect this information.