Anti-Slavery Policy

Anti-Slavery Policy

  1. What is slavery?
    1. Modern slavery is a complex and multi-faceted crime and tackling it requires all of us to play a part.  You may think this whole subject is irrelevant to us, but it is not.
    1. At a very basic level, of course preventing exploitation and human trafficking, and protecting our workforce and reputation makes good business sense.
    1. The Modern Slavery Act 2015 covers four activities:
SlaveryExercising powers of ownership over a person
ServitudeThe obligation to provide services is imposed by the use of coercion
Forced or compulsory labourWork or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily
Human traffickingArranging or facilitating the travel of another person with a view to their exploitation
  1. This policy covers all four activities.
    1. The Modern Slavery Act 2015 recognises the important part organisations can and should play in tackling slavery.  With this in mind, we need to pay particularly close attention to:
      1. our supply chain;
      1. any outsourced activities, particularly to jurisdictions that may not have adequate safeguards; and
      1. cleaning and catering suppliers.
  2. Responsibilities
    1. The Train2Work Academy, our managers and colleagues have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity.
    1. Everyone must observe this policy and be aware that turning a blind eye is unacceptable.
    1. Train2Work Academy
      1. We will:
        1. maintain clear policies and procedures preventing exploitation and human trafficking, and protecting our workforce and reputation
        1. be clear about our recruitment policy (see Recruitment paragraph 4.3 below)
        1. check our supply chains (see Supply chains paragraph 4.2 below)
        1. lead by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc. to ensure we know who is working for us
        1. ensure we have in place an open and transparent grievance process for all staff
        1. seek to raise awareness so that our colleagues know what we are doing to promote their welfare
        1. make a clear statement that we take our responsibilities to our employees and our clients seriously (see Anti-slavery statement)
      1. The Chair of Train2Work Academy will lead on implementing Train2Work Academy’s responsibilities under this policy.
    1. Managers
      1. Managers will:
        1. listen and be approachable to colleagues
        1. respond appropriately if they are told something that might indicate a colleague is in an exploitative situation;
        1. remain alert to indicators of slavery (see Identifying slavery)
        1. raise the awareness of our colleagues, by discussing issues and providing training, so that everyone can spot the signs of trafficking and exploitation and know what to do
        1. use their experience and professional judgement to gauge situations
    1. Colleagues
      1. We all have responsibilities under this policy. Whatever your role or level of seniority, you must:
        1. keep your eyes and ears open—if you suspect someone (a colleague or someone in our supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting procedure (see Reporting slavery paragraph 6 below)
        1. follow our reporting procedure if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated
        1. tell us if you think there is more we can do to prevent people from being exploited
  3. The risks
    1. The principal areas of risk we face, related to slavery and human trafficking, include:
      1. supply chains
      1. recruitment through agencies
      1. general recruitment
    1. We manage these risk areas through our procedures set out in this policy and elsewhere.
  4. Our procedures
    1. Anti-slavery statement
      1. We make a clear annual statement that we take our responsibilities to our employees, people working within our supply chain and our students seriously.
      1. We make this statement as part of our company reporting.
    1. Supply chains
      1. We will check supply chains to ensure the potential for slavery and human trafficking is significantly reduced.
      1. We tell the companies we do business with that we are not prepared to accept any form of exploitation.
      1. All our standard supplier contracts will contain an anti-slavery clause. This clause prohibits suppliers and their employees from engaging in slavery or human trafficking.
    1. Recruitment
      1. Using agencies
        1. Our HR department and recruiting managers follow Train2Work Academy policy and only use agreed specified reputable recruitment agencies.
        1. To ensure the potential for slavery and human trafficking is reduced as far as possible, we thoroughly check recruitment agencies before adding them to our list of approved agencies. This includes:
          1. conducting background checks
          1. investigating reputation
          1. ensuring the staff it provides have the appropriate paperwork (e.g. work visas)
          1. ensuring the agency provides assurances that the appropriate checks have been made on the person they are supplying
        1. We keep agents on the list under regular review, at least every 3 years.
      1. General recruitment
        1. We always ensure all staff have a written contract of employment.
        1. We always ensure staff are legally able to work in the UK.
        1. We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
    1. If, through our recruitment process, we suspect someone is being exploited, the HR department or recruiting manager will follow our reporting procedures (See Reporting slavery paragraph 6 below).
  5. Identifying slavery
    1. There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support.
    1. However, the following key signs could indicate that someone may be a slavery or trafficking victim.
      1. The person is not in possession of their own passport, identification or travel documents.
      1. The person is acting as though they are being instructed or coached by someone else.
      1. They allow others to speak for them when spoken to directly.
      1. They are dropped off and collected from work.
      1. The person is withdrawn or they appear frightened.
      1. The person does not seem to be able to contact friends or family freely.
      1. The person has limited social interaction or contact with people outside their immediate environment.

This list is not exhaustive.

  • Remember, a person may display a number of the trafficking indicators set out above but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right.
    • If you have a suspicion, report it.
  • Reporting slavery
    • Talking to someone about your concerns may stop someone else from being exploited or abused.
    • If you think that someone is in immediate danger, dial 999.
    • Otherwise, you should discuss your concerns with your line manager or Local Safeguarding Officer who will decide a course of action and provide any further advice in accordance with the Train2Work Academy’s Safeguarding Policy.
    • Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with your Local Safeguarding Officer before taking any further action.
  • Training
    • We provide specialist training to those staff members who are involved in managing recruitment.
    • More general awareness training will be provided to all staff
  • Monitoring our procedures
    • We will review our Anti-slavery Policy regularly, at least annually. We will provide information and/or training on any changes we make.

FUNDING FEE POLICY

Fees Policy

Introduction

Train2Work Academy works in partnership with local authories and colleges. We offer both accredited and tailor learning/community courses that are funded by the local authories which receives grant from the Education Skills Funding Agency (ESFA)/Greater London Authority (GLA). You will be fully supported in completing your application and you will be made completely aware of fees that you may have to pay for your course before you enrol on our courses.

Tailor Learning/Community Course Fees

Our non-accredited courses community courses are free to those who are claiming benefits or those whose total household income is less than £23,302.50 per annum or learners that receive other state benefits and earning less than 16 times the minimum wage per week or earning less than £617 per month. If you do not fall into these categories, there may be a small fee to pay.  

Accredited Course Fees

Our accredited course fees may be free or subsidised by the funder if you meet certain criteria. You will be able to confirm whether or not you qualify before enrolment on our courses.

Subsidised Fees

You will qualify for subsidised fees if you are aged 19 years (as at 31st August 2024) or over and:

  • have been continuously resident in the United Kingdom (UK) for at least the three years before the start of your course;
  • or are a national of any European Union (EU) country or are the spouse, civil partner or child of an EU national and have been continuously resident in the European Economic Area (EEA) for at least the three years before the start of your course.

If you do not meet the above criteria, you may have to pay a higher, non-subsidised fee and will not qualify for benefit claimant discounts. If you think you may fall into this category, please contact the Centre for more information to confirm your fee.

Eligibility to funding does not give you the right to funding. Circumstances such as previous achievement, economic status, age and so on need to be taken into account.

Fully Funded (ZERO FEES)?

If you are in receipt of one of the active benefits below at the time of enrolment and actively looking to get into employment, your course will be free (fully funded). You will need to provide a letter from the Job Centre as proof of receipt of one of the following:

  • Job Seeker’s Allowance (JSA)
  • Employment Support Allowance (ESA) in the Work-Related Activity Group (ESA WRAG)
  • Universal Credit – mandated to undertake skills training

If you are unemployed but not receiving one of the above benefits and are unavailable for work due to unavoidable commitments such as looking after a child or acting as a career, your course may be fully funded.

If you are unemployed or working less than 16 hours per week and or earning less than £617 per month, want to enter employment and are claiming wider benefits such as:

  • Income support
  • Housing Benefit
  • Council Tax Benefit
  • Working Tax Credit
  • Pension Credit
  • Other

How Much to Pay?

If you do not qualify for full funding, you may be eligible to a subsidy of 50% of the basic course fee (co-funded), dependent on your circumstances.

If you require any further advice on our course fees, instalment payments, eligibility for discounts, or other course queries our IAG Course Advisors or Finance Team at our Centre will be happy to help or you can email us at admin@trainworkacademy.org

Additional Fees

You may require to pay additional fees for specialist materials and technical support. This information will be provided during your enrolment stage.

Refund Policy

Unless there are exceptional circumstances, course fees will only be refunded in the following situations:

  • if the course is cancelled or closed prematurely by Train2Work Academy
  • if the date and time are altered and you have to withdraw as a result

Refunds will not be granted if you choose to withdraw part-way through the course.

Advice and Information

Should you have any queries on fees or course information, including deciding on which course/level is right for you, please contact our IAG/Course Advisers on 020 3981 1990 or email us at courses@trainworkacademy.org

Train2Work Academy Privacy Notice (GDPR)

Registration

Train2Work Academy is registered with the Information Commissioner for the processing of personal as a Data Controller on the Data Protection Registration Number: ZA149841

For further details, please visit the ICO register:

https://ico.org.uk/ESDWebPages/Entry/ZA149841

The categories of student information that we collect, hold and share include

  • Personal information (such as name, unique student number and address)
  • Nominated next of kin contact information (name, phone number)
  • Characteristics (such as ethnicity, language, nationality, health and life experiences likely to affect learning, childcare needs, country of birth and nationality)
  • Attendance information (such as sessions attended, number of absences and absence reasons)
  • Educational Performance (such as reports and exam grades)
  • Destinations where students go after leaving us
  • Relevant medical information
  • The categories of parent/Next of kin information that we collect is limited to name and contact information (phone numbers, address and email etc.). Any additional information disclosed to us is held only if it is relevant to the support of their child (16-18 olds).


The categories of parent/Next of kin information that we collect is limited to name and contact information (phone numbers, address and email etc.). Any additional information disclosed to us is held only if it is relevant to the support of their child (16-18 olds).

Why we collect and use this information

We use the student and parent/Next of kin data:

  • to support student learning
  • to monitor and report on student progress
  • to safeguard our students, provide appropriate pastoral care and ensure their safety and wellbeing
  • to assess the quality of our services and ensure continuous improvement
  • to comply with the law regarding data sharing
  • to comply with the funder regulations: Education and Skills Funding Agency(“the ESFA”); Department for Education; Greater London Authority; Home Office; Local Authorities; and others; and claim the necessary funding to keep education free of charge or at a subsidised rate.

The lawful basis on which we use this information

We collect and use student and parent/Next of kin information under Articles 6 and 9 of the General Data Protection Regulation. In particular, we process information where that processing is

  • necessary for compliance with a legal obligation to which   TRAIN2WORK ACADEMY is subject, including the legitimate purpose of ensuring the safety and wellbeing of our students,
  • where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in   TRAIN2WORK ACADEMY,
  • where the data subject has given consent to the processing of his or her personal data for specific purposes or
  • (iv) where processing is necessary in order to protect the vital interests of the data subject or of another natural person.

For special category data we collect and use student information where the processing is necessary for the reasons of substantial public interest, respects the essence of the right to data protection and provides for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

Collecting student information

Whilst the majority of student and parent/Next of kin information you provide to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with the General Data Protection Regulation, we will inform you whether you are required to provide certain student information to us or if you have a choice in this.

Storing student data

We hold student data for the duration of their education at   TRAIN2WORK ACADEMY and afterwards depending on the funding contractual instructions. Parent/Next of kin information is held within the student information. All information is held within a secure filing cabinet or in password protected electronic files in UK.

Why we share student information

We do not share information about our students or parent/Next of kin with anyone without consent unless the law and our policies allow us to do so.

Who we share student information with (with students’ consent)

In specific circumstances, we may share student information with these organisations:

  • Local Authorities (Lambeth Adult Learning, Wandsworth Lifelong Learning and others)
  • Job Centre Plus
  • Providers and Universities that the students attend after leaving us
  • Employers and employment agencies
  • Department for Education (DfE)
  • Greater London Authority (GLA)
  • Home Office
  • HMRC
  • Exam Boards
  • Health Professionals
  • Police
  •   TRAIN2WORK ACADEMY Enrichment Programme Providers

We share information with contractors and suppliers who provide the following services:

Our Funders

We share students’ data with the Department for Education (DfE), ESFA, Home Office, Lottery and Local Authorities on a statutory basis. This data sharing underpins  Train2Work Academy funding and educational attainment policy and monitoring. We are required to share information about our students with the DfE under regulation 5 of The Education (Information About Individual Pupils) (England) Regulations 2013.

Pro-Suite (Management Information System (MIS) provider)

We share student and parent/Next of kin personal data with Pro-Suite when necessary to correct ILR submissions.

Transport For London – TFL (for obtaining Oyster Discount Cards)

We share student personal data with TFL to enable them to obtain travel discounts, at their request.

Exam Boards

We share student personal data with exam boards to facilitate legal obligation to provide examinations.

TRAIN2WORK ACADEMY Enrichment Providers

We share student personal data with   Train2Work Academy enrichment providers engaged in providing school trips / visits in order for them to process travel arrangements and may include sensitive medical information in order to keep students safe whilst on organised trips / visits.

Suppliers of Email, Internet and IT services

We use email and IT services to enable the   Train2Work Academy to administer communication both internally and externally and facilitate the smooth running of the   Train2Work Academy. Where necessary external IT suppliers will access systems to provide support and fix issues. In all instances there will be a data protection agreement in place to safeguard information on the systems they are accessing.

Data collection requirements

To find out more about the data collection requirements placed on us by the Department for Education and ESFA (for adult students) go https://www.gov.uk/government/publications/privacy-information-key-stage-4-and-5-and-adult-education

Youth support services

We will also share certain information about students aged 16+ with our local authority and / or provider of youth support services as they have responsibilities in relation to the education or training of 16-19 year olds under section 507B of the Education Act 1996. This enables them to provide services as follows:

  • post-16 education and training providers
  • youth support services
  • social services
  • careers advisers
  • Institute for Employment Studies on behalf of Youth Futures Foundation

The National Pupil Database (NPD) 16-18 olds

The NPD is owned and managed by the Department for Education and contains information about students in England. It provides evidence on educational performance to inform independent research, as well as studies commissioned by the Department. It is held in electronic format for statistical purposes. This information is securely collected from a range of sources including Train2Work Academy, local authorities and awarding bodies. We are required by law to provide information about our students to the DfE as part of statutory data collections such as the Train2Work Academy. Some of this information is then stored in the NPD. The law that allows this is the Education (Information About Individual Pupils) (England) Regulations 2013.

To find out more about the NPD, go

https://www.gov.uk/guidance/apply-for-department-for-education-dfe-personal-data .

ESFA Processing, Personal data and Data Subjects for adult students

ESFA Description Details

Subject matter of the Processing
The subject matter is the personal data of Learners on education or training programmes administered by the ESFA that are subject to this Agreement as defined in the ESFA privacy notice and ILR specification and its appendices.

https://www.gov.uk/government/collections/individualised-learner-record-ilr

Duration of the Processing

The duration of the Processing covers the academic year data returns to the ESFA as defined in Appendix A of the ILR specification to enable funding and audit of the learning programmes defined in this Agreement.

https://www.gov.uk/government/collections/individualised-learner-record-ilr

Nature and purposes of the Processing

The nature and purposes of the processing is defined in the ESFA privacy notice.

https://www.gov.uk/government/publications/privacy-information-key-stage-4-and-5-and-adult-education

The processor will be required to submit the data to the ESFA as set out in Clause 16 Submission of Learner Data of the Contract.

Type of personal data

The personal data to be processed is defined in the ILR specification.

https://www.gov.uk/government/collections/individualised-learner-record-ilr

Categories of data subject

The data subjects are Learners on education or training programmes administered by the ESFA that are subject to this Agreement.

Description Details

Retention and destruction of the data once the processing is complete UNLESS requirement under union or member state law to preserve that type of data Information on how the data must be supplied to the ESFA is detailed in the ILR specification and its appendices.

https://www.gov.uk/government/collections/individualised-learner-record-ilr

For the purposes of the DfE as a data controller of the data, providers are required to retain the data for the funding and audit purposes 6 years from the end of the financial year in which the last payment is made under the Contract for the specific student.

For the purposes of the Department for Work & Pensions as a data controller, where Learner data is used as match on the 2007-13 ESF programme, the data must be retained securely until at least 31 December 2022 and where Learner data is used as match on the 2014-20 ESF programme, the data must be retained securely until 31st December 2030.

The Contractor (and any other data controller) is responsible for determining any further need to process the data, including its retention, prior to secure destruction.

Requesting access to your personal data

Under data protection legislation, parent/Next of kin and students have the right to request access to information about themselves. To make a request for your personal information, or be given access to your child’s educational record, contact Suad Abdirahman, Data Protection Officer (suadabdirahman@train2workacademy.org).

You also have the right to:

  • object to processing of personal data that is likely to cause, or is causing, damage or distress
  • prevent processing for the purpose of direct marketing
  • object to decisions being taken by automated means
  • in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed; and
  • claim compensation for damages caused by a breach of the Data Protection regulations

Concerns

If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office

https://ico.org.uk/make-a-complaint

Contact

If you would like to discuss anything in this privacy notice, please contact us below:

Review and Update

This privacy notice is reviewed annually.