Modern Slavery Policy

CPL Learning is committed to preventing acts of modern slavery and human trafficking from occurring within its business and to communicate this policy throughout its supply chain. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

The Purpose of the Organisation

The commercial activities of the business are principally the delivery of vocational training and qualifications (offline and online), learning activities, software development, licensing services related to the sectors which we service.

Scope of the Modern Slavery Act 2015

The Act defines modern slavery as “slavery, servitude and forced or compulsory labour” and “human trafficking” (Modern Slavery). The Act requires commercial organisations operating in the UK (i.e. that supply goods or services from or to the UK) and have a global turnover above £36 million, to publish a statement each financial year, which sets out the steps they have taken to ensure there is no Modern Slavery in their business or supply chains. CPL Learning’s turnover is below this limit, but we nevertheless published this Modern Slavery Policy and commit to review it annually.

CPL Learning has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. CPL Learning is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners and, as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

Our Due Diligence Processes

Because of the skilled nature of the employment positions we offer, we consider the risk of Modern Slavery existing within our business to be low. Our focus is therefore on ensuring that people we recruit to our organisation have a right to work here and are doing so of their own volition. We operate a right to work check system, as detailed below:

Right to Work Check

• Any person who applies for employment with us is subject to a right to work check before a job offer is made to that person.
• This check ensures that we are compliant with the Immigration Act 2016, but also reduces the risk of employing a person who is the victim of forced or compulsory labour.

Our Supply Chain

To deliver its services, the business works with a small range of suppliers, all of whom are based in a low risk jurisdiction, i.e., the United Kingdom.

The contractual terms and conditions that we put in place with our suppliers are being updated to include clauses that forbid the use of slavery and human trafficking.

Training

General awareness training is to be provided via an e-learning course available online and this training will form part of every new employee’s induction process. We will inform and highlight the steps that our staff can take if they are concerned about any such type of behaviour and we will also take steps to ensure that our suppliers are aware of our policy. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

Whistleblowing

The business has a Whistleblowing Policy and all staff are informed of their responsibility to voice any concerns to our HR department, which will deal with these concerns in the strictest confidentiality. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

Executive Approvals

This Policy will be reviewed by the CPL Learning Limited Executive Team on an annual basis.

Responsibility for Policy:

Executive Team

Responsibility for Implementation:

All employees at CPL Learning Limited

Data Privacy Policy

Collecting your personal data

CPL Learning Ltd needs to use and store certain information about its employees, clients and others to allow it to effectively carry out its business operation. For example, we monitor performance and learning to ensure our courses are fit for purpose. We also record health data to ensure that we can make the required adjustments to fully support our delegates in their learning experiences.

We may also collect information from you as a result of your relationship with one or more of our clients or other service providers.

We may also automatically collect certain non-personally identifiable information when you visit our website - for further details on this please see our Cookie Policy.

The information we process includes personal data. We must process personal data according to the General Data Protection Regulation (GDPR).

The GDPR is a new EU legal framework for data protection. The GDPR will apply to all member states from the 25th May 2018.

Protection of your information

CPL Learning has developed its Privacy Policy to ensure that everyone associated with us understands their rights and responsibilities. We have has also drawn up a series of detailed guidelines to help deal with the everyday implications of the policy in practice.

We apply the highest standards of security when it comes to hosting and protecting your information.

We have the necessary policies and technical measures in place to protect your Personal Data against unauthorised access, accidental loss, improper use and disclosure. All our employees and any third parties we engage to process your personal information are obliged to respect the confidentiality of your information.

We do not sell, rent, distribute or otherwise make personal information commercially available to any third party, except as described in our Privacy Policy or with your prior permission.

However, the internet is not completely secure and, although we deploy the most relevant measures best to protect your Personal Data, the transmission of your data to use is done at your own risk.

Marketing

We may provide you from time to time with information that we think may be of interest to you such as service and product updates, new services, details of events or competitions hosted by us. If you prefer not to receive promotional material from us, please email us at data.protection@cpltraining.co.uk

In compliance with data protection and electronic communication rules, we may provide you from time to time with information that we think may be of interest to you. This information may be service and product updates, new services, details of events or competitions hosted by us. If you prefer not to receive promotional material from us, please click the unsubscribe link in the email or drop us an email at data.protection@cpltraining.co.uk

Breach reporting

We have appointed David Dasher, Chief Technical Officer, as our Data Protection Lead.

Suspected or actual compromises of data must be reported to us immediately using the Information Security Incident Reporting Form, which will be escalated to our DP Lead and other relevant internal parties immediately.

This is a requirement of our Information Security Policy which contains further details of our response procedures.

Completed forms should be submitted to data.protection@cpltraining.co.uk

For advice, support and assistance in the event of a suspected breach, please contact us on 01509 279169.

Your rights

You have a right of access to Personal Data that we may hold about you, to have inaccurate information about you corrected and to request that we stop using your Personal Data for marketing purposes. Access requests should be put in writing and addressed to the Data Protection Lead at the address shown below. Please help us to keep your information up to date by informing us of any changes.

Revisions to our polices

We may change our policies from time to time, including information contained on this page. You should check this page from time to time to ensure that you are happy with any changes.

Contact Information

If you have any comments or questions about our data protection and privacy practices, please contact the Data Protection Lead by email data.protection@cpltraining.co.uk or by letter at CPL Learning Limited, Bridge Court, 110 Canning Street, Birkenhead, CH41 1EW.

Cookies Policy

Our website uses cookies to allow the website to function correctly and to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and it also allows us to improve the functionality. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.

Cookies contain information that is transferred to your computer’s hard drive. We use the following categories of cookies:

Strictly necessary cookies

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical/performance cookies

They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies

These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

All data or information which is collected by the setting of a cookie is anonymous, and cannot identify you or your use of the website personally. You can find more information about the individual cookies we use and the purposes for which we use them below:

Cookies

If you do not consent to our use of cookies, we will not be able to display our web pages properly and your experience of our website will be greatly affected.

Remove consent

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.