Policies

Policies

Safeguarding Policy

. Introduction

More Positive Me C.I.C. is committed to empowering people impacted by domestic abuse who have received safeguarding, MARAC, IDVA, ISVA and/or Outreach Support, who are no longer in an abusive relationship and are ready to move forward. 

2. Additional Needs 
This could include people with learning disabilities, mental or physical health problems, older people and people with a physical disability or impairment. Their need for additional support to protect themselves may be increased when complicated by additional factors such as physical frailty or chronic illness, sensory impairment, challenging behaviour, drug or alcohol dependency, social or emotional problems, poverty or homelessness. This policy relates to adults of 18 years or older. All clients coming to More Positive Me are with additional needs will be encouraged to access further support via organisation within our working alliance. We recognise PTSD, cPTSD, Anxiety & Depression as the impact of domestic abuse.    

3. Definition of Domestic Abuse 
The government definition of domestic violence and abuse is:
“Any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members regardless of gender or sexuality.”
Section 3 of the Domestic Abuse Act 2021 came into force on 31 January 2022 and specifically provides that a child (under 18 years old) who sees, hears, or experiences the effects of domestic abuse and is related to the victim or the suspect is also to be regarded as a victim.
Psychological abuse - Physical abuse - Sexual abuse - Economical abuse - Emotional abuse - Coercive control. 


4. Whole team awareness
All involved with More Positive Me C.I.C, including directors, contractors, employees and volunteers need to be aware of the prevalence of abuse within our society and its institutions and be able to identify and address matters of concern.

Safeguarding Adults Code of Conduct 

All directors, staff, contractors and volunteers must abide by the principles set out in the Team Safeguarding Agreement below.

More Positive Me Team Safeguarding Agreement 
          
More Positive Me provides peer support groups and signposting for adult survivors of domestic abuse. 

Our purpose is to meet as equals, to support one another, to talk openly and honestly about abuse and the effects that abuse has had on us and society. We do this in order to gain a better understanding of ourselves and one another, through the framework of our Empowerment Course and Rediscovering You Self Care Toolkit.

Anyone working with us must be working towards completing the DASST level 1, 2 & 3 training to grow awareness of domestic abuse and its traits. Team Members can ask Jeanette Brown, Director, for access to this.
Trauma awareness training & Domestic Abuse Champions training alongside DASH risk assessment training and MARAC understandability must be completed within the first 6 months of enrolment.
Further training will always be offered and encouraged. 

In order to create a safe and supportive recovery environment we mutually agree to: 
No alcohol 
No drugs 
No sexual contact 
No physical violence/aggressive behaviour/aggressive language 
No discriminatory language or behaviour based on ethnicity, gender, sexual orientation, religion or disability
Non judgemental approach
Group agreement for confidentiality

In order to protect the identity and honour the confidentiality of group members, we agree not to say anything that would reveal their identity to others outside of the group, and ahere at all times to the Confidentiality Policy. 

We do not rush to rescue or fix, we allow people to feel their feelings in a safe and supportive space. 

If a group member needs to leave the room, a More Positive Me CIC Team Member will follow them to offer support.

More Positive Me CIC aims to work in a manner which protects clients from being abused.

Initial contact with a client will always be via the safe email address provided within their referral form, unless another preference has been stated, and always adhering to any safety requirements the client or referrer have specified.

To maintain safety of all members, attendees will only be admitted to a group once a confidentiality form has been completed and eligibility has been ascertained.

Any face to face meeting with a client outside of a scheduled group to which they have registered must be authorised by a Director of More Positive Me CIC.

Safeguarding Procedure
If a client or Team Member shares some information that makes you suspect a high risk to the safety of the client, immediately complete a DASH risk assessment and offer client access to the J9 Folder. Team Members can ask for support from a Director to complete this.
Before completing the DASH, explain the following to the at-risk individual:
Information shared will be treated as confidential within More Positive Me, in line with our Confidentiality Policy, unless the risk is high, when you have a duty of care to complete the MARAC referral (Multi Agency Risk Assessment Conference).  
A MARAC referral would only be made to safeguard them and their family when we believe they are at high risk of harm, and that while we would ideally have their consent for this, a referral may take place even in the absence of their consent.
Individuals with a medium-low risk result can only be referred with consent.
Make suitable adaptations to communication and check the individual has understood.
If the DASH scores above 14, or you feel the risk is imminent, then a Director of More Positive Me must be informed and a MARAC form completed and submitted that day. 
Respond sensitively and coherently to reported incidents of self-
       neglect and abuse, in a consistent manner, recording the actual
      words where possible, checking your understanding with the client.
Take every precaution to prevent putting yourself or a client in a position that increases the risk of emotional or physical harm to yourself or them. If unsure what to do, ask a director for guidance.
If you feel there is an imminent risk to the safety (including risk of suicide) of any More Positive Me CIC Team Member, group member or yourself, dial 999 and ask for the police.
Adhere to all More Positive Me policies and flag any instances where changes may be needed.
Agree to undertake Safeguarding training as advised by the Directors and to ask if you feel you need further training or support.

5. Statement of Intent 
More Positive Me C.I.C. will: 
  •  Provide an abuse-free environment. At the beginning of every group session, the group agreement will be made visible, and a  reminder of the agreement will be made when necessary.
  • Recognise internal and external abuse. 
  • Always inform a Director if there are any issues. 
  • Take action against Directors, staff, associates, students and volunteers who are proved to have abused others. 
  • Ensure that Directors, staff, associates, volunteers who work with our clients have appropriate training and undertake a DBS.

6. Responsibilities 
A. More Positive Me C.I.C. will adopt and review the
     implementation of this policy.

B. The Directors are Safeguarding Leads, will retain overall
     responsibility and will make all final decisions which relate to
     this policy.

C. More Positive Me C.I.C. are responsible for reviewing and
      updating this policy and will keep those involved with
     More Positive Me C.I.C. informed of any changes in the law. 

D. All Directors, staff, volunteers and associates are
     responsible for the implementation of this policy within their
     workplace.

E. You are required to adhere to this policy.


7. Be Alert 
Think about what you see and hear. 
Take seriously what you are told and take prompt action. 
Be aware that the client may not understand they have been abused and so do not realise the significance of what they are telling you. 

8. Checks and Training 
All staff, associates and volunteers who work with our clients will be required to complete the appropriate training and undertake an Enhanced Disclosure and Barring Service check.

Individual clients will be risk assessed, when appropriate.

9. What you should do 
If you suspect that an adult is being treated in a way that may be harmful to their physical or emotional well-being you should follow the Safeguarding Procedure, raise your concerns, and pass on any information you have to a Director immediately; 

Jeanette Brown, Director jeanette@morepositiveme.co.uk
Hannah Hill, Director hannah@morepositiveme.co.uk

If a Director is unavailable, you should contact Devon Domestic Abuse Support Service (currently FEARFREE), who will be able to advise: Phone 03451551074, retaining a note of what has happened in line with the Data Protection Policy. 

A confidential written record will be made and kept by the Director who will discuss the matter with the staff, associate or volunteer as soon as possible, and decide how to progress the matter.

You will be expected to provide details of your concerns and any evidence you have. You may be asked, at a later stage, to join in a joint discussion with the appropriate agencies to clarify the concerns. You will be provided with support through this process.

Please follow the instructions below 

DO:
 
 Stay calm and try not to react in a way that may cause anxiety to the 
  •   Vulnerable Adult.
  •  Listen carefully.
  •  Be empathetic.
  •  Explain you must tell one of the Directors and that if there is a high risk information may be passed to MARAC (Multi             Agency Risk Assessment Collaboration) with the full intention of supporting their risk. 
  • Make notes of what the person said using their words and store in line with the Data Protection Policy.
  • Tell the person that: - 
  • They did the right thing by telling you. 
  • You will treat the information seriously.
  • It is not their fault. 
  • Inform the Director the same day of your concerns and actions. 

DO NOT: 
  • press for more details, 
  • promise to keep it secret,
  • discuss with anyone else apart from the Directors or the Devon Domestic Abuse Helpline 0345 1551 074 for support                   and advice. 
  • be judgemental e.g. Why didn't you run away? 
  • stop someone telling you or ignore them. They may never disclose again.

What a Director of More Positive Me C.I.C. should do:

Directors of More Positive Me C.I.C. are responsible for ensuring that staff are aware of the Company’s policies and of the relevant non-policy procedural documents. 

When an alert is raised by a member of the staff, associate or volunteer regarding a client, colleague or member of the public, a Director of More Positive Me CIC will:- 
  • support their member of staff in following the objectives of the policy.
  • safeguard the rights of a Whistle-blower,   
  • take responsibility for making an initial decision with their member of staff, associate or volunteer as to whether         this incident falls within the Safeguarding policy. 
  • If in doubt it should be included, a discussion with a Director must take place the same day to make a safeguarding decision, 
  • make an incident report on the clients section on the database, store it in line with the Data Protection Policy, and follow the procedure above, 
  • if there is any possibility that a crime has been committed, contact the Police Safeguarding Team by phone Tel: 08456051166 
  • take steps to ensure that any evidence is protected and is available for a MARAC referral/ meeting. 
  • ensure that the client that disclosed is kept informed of the 'progress' of the alert and steps being taken. 

Please note: The Directors of More Positive Me C.I.C. and/or staff will usually be invited to attend the MARAC meeting. They may also make a request to attend.

More Positive Me C.I.C. agree to adhere to and follow the Multi —agency safeguarding protection procedures which require More Positive Me C.I.C. to work in full cooperation with partner agencies, usually through a MARAC meeting. It is important to take an open and non-defensive approach to allegations and to ensure there is a measure of independence within the safeguarding process.

Please also note that complaints made about any members of More Positive Me C.I.C. are covered in our Whistle-blower, Complaints, and Grievance policies and procedures. 

It is important that a Director of More Positive Me C.I.C. takes 'ownership' of the whole process as the ‘responsible manager’. The key elements of this, for clarity are: 
the responsibility for overseeing the investigation, action plan and outcome communication.

Marac forms https://www.devon.gov.uk/dsva/information-for-professionals/marac/

DASH forms https://safelives.org.uk/sites/default/files/resources/Dash%20for%20IDVAs%20FINAL_0.pdf

This policy should be read in conjunction with Appendices A & B.  

Devon County Council have centralised the three-locality based Safeguarding Adult Hubs, creating one Devon Safeguarding Adults Service. 

Centralisation enables a single point of contact for all Safeguarding Adult Concern referrals made to Devon County Council. The intention is to deliver an equitable and timely response to Safeguarding Adult Concerns referrals and timely decision making and communications in relation to Section 42 of the Care Act (2014). 
The service will consist of a single management and leadership structure operating across the County. The newly appointment service manager for the Devon Safeguarding Adults Service is Carly Stanton.

How to make a Safeguarding Adult Concern Referral to Devon County Council:

All Safeguarding Adult Concern referrals can now be made direct to: adultsc.safeguardingadultservices-mailbox@devon.gov.uk   

To ensure that referrals in progress are not compromised, the mailboxes for the previous locality hubs will remain open until 5th May 2024
(Auto responses have also been set up providing the new shared mailbox address) 
The generic telephone contact details for the Devon Safeguarding Adults Service will be confirmed via further email in due course.

As per current process:
If you feel that you need an urgent response to your email, please telephone the existing locality telephone number, which have not changed, and chose from the list of options 

• Exeter, East and Mid Devon 01392 381206
• South and West Devon 01392 381211
• North Devon 01392 381208 

If you are emailing outside of normal working office hours and the matter is urgent, involving the safety of an adult, please contact our Emergency Duty Service on 0345 6000 388. 

If your concern is for the immediate protection and safety of an adult, please consider the need to call the appropriate emergency service.


This policy will be reviewed every two years.
 
Date Reviewed: 02/04/2024 Next review: 02/04/2026 

Domestic Abuse Policy
Introduction
This policy covers the internal and external support available to employees experiencing, or involved in, domestic abuse. Everyone has the right to live free from abuse in any form and the responsibility for abuse lies with the perpetrator. There is an increased awareness of the prevalence of domestic abuse in society and the Company understands that there may be colleagues who are experiencing domestic abuse, or who want to support friends, colleagues or family members who are going through it.

About this policy
This policy applies to all Team Members of More Positive Me CIC, whether temporary or permanent, and includes Directors, employees, consultants, workers, volunteers, self employed associates and interns.  
The policy will refer to ‘Team’ or ‘Team Member’ throughout, and by this, we are referring to all the people indicated above.

The aims of this policy are to:
· Support all Team Members experiencing domestic abuse and promote their health, safety and well-being at work.
· Recognise that a Team Member’s ability to work may be impacted both directly by the perpetrator of domestic abuse, but also indirectly owing to the physical and mental impacts of domestic abuse.
· Enable Team Members experiencing domestic abuse to remain productive, efficient and at work.
· Aid Directors seeking to help Team Members who are experiencing domestic abuse.
· Assist colleagues of Team Members who are experiencing domestic abuse.
· Reinforce the Company's zero tolerance attitude towards domestic violence.
· Where appropriate, signpost to specialist services perpetrators who voluntarily wish to seek advice and support to address their behaviour.

What is domestic abuse?
Domestic abuse is legally defined as abusive behaviour by one person to another, where they are both 16 or over and they are personally connected. The abusive behaviour can be a single incident or a course of conduct. Behaviour is considered abusive if it consists of any of the following:

• physical or sexual abuse.
• violent or threatening behaviour.
• controlling or coercive behaviour.
• economic abuse; and
• psychological, emotional, or other abuse.

Company support (See also ‘Reasonable Adjustments’ Below)
It is the More Positive Me CIC's intention to deal constructively, compassionately, and sympathetically with cases of domestic abuse. The Company will support all those who endure and/or witness domestic abuse, regardless of any protected characteristics. If you are concerned about your own personal situation or that of a colleague, you are encouraged to seek support.
You can speak in confidence to the Directors, who can provide initial support, signpost you to resources and help you with any disclosure conversations you would like to have with colleagues and, if you have not done so already, with your HR contact, Nicola Brown, nic@br-hr.co.uk, 07752 194837. The Directors or HR contact will work with you to formulate a response including:
(a) Discussing and agreeing ways to help you stay safe in the workplace.
(b) Signposting you to the appropriate domestic abuse resources; and
(c) Facilitating referrals.
Please refer to the paragraph below relating to confidentiality.
Directors have a role to play in enabling Team Members experiencing domestic abuse to seek help and support. 
The role of the Director is to:
· Identify Team Members who may be experiencing difficulties because of domestic abuse, for example, Team Members coming to work with unexplained injuries, who appear distressed, have unexplained periods of time off work, or show an uncharacteristic deterioration in work performance.
· Provide initial help and support, including advice on the options available for the Team Member, and referrals to appropriate sources of professional help, whilst supporting the Team Member to make their own decisions.
· Protect confidentiality as far as possible (see the paragraph on confidentiality below).
· Refer the individual to the appropriate sources of help, both internal and external, with the consent of the Team Member where possible (see the paragraph on confidentiality below).
· Discuss measures to prioritise safety at work and ensure that the health and safety of all Team Members are protected.
· Support the Team Member to remain productive, efficient and at work.

Confidentiality
Where a Team Member has discussions with the Directors, or HR contact, that they are experiencing domestic abuse, confidentiality will be maintained as far as possible in line with Company procedures. There are, however, some circumstances where confidentiality cannot be assured. 
These circumstances occur when:
There are concerns about children or vulnerable adults, where high risk to safety has been identified or;
Where we need to act to protect the safety of members of the public, including other colleagues.
Where we believe an individual or family members are in genuine danger this may be reported to the police. This will be subject to prior discussion with the Team Member wherever it is reasonably practicable to do so.
Personal data will be stored in accordance with the company’s data protection policy.

Safety at work
We acknowledge our duty to protect the health, safety and well-being of all Team Members at work, including those affected by domestic abuse. This includes situations where the perpetrator of the abuse is harassing a Team Member at work, for example, turning up at the workplace unannounced, constantly telephoning/e-mailing/texting the Team Member during the working day or harassing the Team Member’s work colleagues.
Team Members need to disclose to the Company that they are at risk from domestic abuse in order to receive this protection, and the Company therefore actively encourages Team Members to disclose when they are experiencing domestic abuse or are worried about behaviour of a current or former partner or family member towards them. Other Team Members should also disclose to the Company if they are being harassed by a work colleague’s current or former partner or family member.  

Perpetrators of domestic abuse
The Company will not tolerate or condone domestic abuse, regardless of the identity or seniority of the perpetrator. If the Company becomes aware that an employee is or may be perpetrating domestic abuse, it will take appropriate action, which could include disciplinary action under the organisation’s disciplinary policy. 

Any domestic abuse perpetrated by a Team Member that endangers another Team Member, or uses company equipment to inflict that abuse, such as mobile phones or laptops, may result in disciplinary action under the organisation’s disciplinary policy up to and including dismissal for Gross Misconduct. The Company takes a zero tolerance approach to domestic abuse and therefore, disciplinary action may be appropriate in some circumstances even where the perpetrator’s behaviour takes place outside work.

The Company recognises that in some cases it may be appropriate to signpost to specialist services Team Members who disclose that they themselves are perpetrators of domestic abuse and who genuinely want to change their behaviour. This will be decided on a case-by-case basis.

Reasonable adjustments
Where a Team Member needs time off to access support, manage any legal issues or family requirements, the Company will provide a reasonable amount of time off per year. Team Members who need time off should discuss this with the Directors to agree how much leave is required, how and when it will be taken, and whether leave will be paid or unpaid. 
More Positive Me CIC is a supportive organisation whose aims reflect their commitment to ensuring all Team Members feel safe and supported in the workplace regardless of their background, experiences and home life.  
The Company welcomes any discussion or request regarding Flexible Working Hours, and whilst it cannot guarantee to grant these, does commit to giving full consideration to any such request with empathy and respect.
 More Positive Me CIC encourages Team Members to speak to the Directors about proposed reasonable adjustments to their work/hours at any time, to enable the Company to support them to live a safer, more fulfilled and positive life as a valued Team Member.

This policy will be reviewed every two years.
 
Date Reviewed: 02/04/2024 Next review: 02/04/2026 

 Grievance Policy

Areas of Grievances 

Grievances normally arise within the following areas: 
 terms and conditions of employment
 health & safety
 bullying and harassment
 working environment
 organisational change
 discrimination or
 personality conflict 

Dealing with grievances informally 

More Positive Me C.I.C. is a small organisation and different combinations of staff and directors will work together at different times. If you have a grievance or complaint to do with your work or the people you work with you should, wherever possible, start by talking it over with the director who is supervising you. You may be able to agree a solution informally between you.

Formal grievance 
If the matter is serious and/or you wish to raise the matter formally you should set out the grievance in writing to the director who is supervising you. You should stick to the facts and avoid language that is insulting or abusive. Where your grievance is against the director who is supervising you and you feel unable to approach them, you should write to another director of More Positive Me C.I.C. using the following email addresses:
Jeanette Brown, Director - jeanette@morepositiveme.co.uk
Hannah Hill, Director - hannah@morepositiveme.co.uk

Grievance hearing 

The director who is supervising you, will call you to a meeting, normally within ten working days, to discuss your grievance. You have the right to be accompanied by a colleague or trade union representative at this meeting if you make a reasonable written request at least 12 hours in advance (although reasonable discretion will be exercised if the timescales are short). 
More Positive Me CIC may arrange for someone not involved in the grievance to observe the meeting to take notes and act as a witness to what is said by all parties. This may be another More Positive Me director or staff member, or a director or staff member of another organisation. We will notify you at least 12 hours in advance of who this will be (although reasonable discretion should be exercised if timescales are short).
Where the grievance is against the director that is supervising you, the meeting will be with the director with whom you have raised the grievance. 
The purpose of the meeting will be to ascertain the details of the grievance and identify any points requiring further investigation.
 After the meeting, the director with whom you have raised the grievance will investigate your grievance as necessary, and give you a decision in writing, normally within five working days. This will outline how they have investigated the grievance and what, if any, action they have decided to take.


Appeal 

If you are unhappy with the director's decision and you wish to appeal you should let them know in writing at the email address above. You will be invited to an appeal meeting normally within ten working days, and your appeal will be heard by the Clinical Lead of More Positive Me C.I.C. You have the right to be accompanied by a colleague or trade union representative at this meeting if you make a reasonable written request at least 12 hours in advance. 
More Positive Me CIC may arrange for someone not involved in the grievance to observe the meeting to take notes and act as a witness to what is said by all parties. This may be another More Positive Me director or staff member, or a director or staff member of another organisation. We will notify you at least 12 hours in advance of who this will be .
After the meeting the Clinical Lead will give you a decision, normally within five working days. 
The Clinical Lead’s decision will be final. 
If you wish to speak to the HR Department about anything involving a Grievance, you can contact:
       Nicola Brown, nic@br-hr.co.uk, 07752 194837



This policy will be reviewed every two years.
 
Date Reviewed: 02/04/2024 Next review: 02/04/2026   

 

Worker Health & Safety Policy

More Positive Me C.I.C. workers are based in buildings belonging to other organisations where room space has been rented for group meetings and other similar activities and vary from week to week and month to month. This policy has been designed to ensure the safety of both staff and clients in premises that, usually, are not the responsibility of either the client or the team. It is therefore the primary aim of this organisation to prevent or avoid any incidents and create a safe working environment for both workers and clients.

While it is our overall responsibility to ensure as safe and healthy an environment as possible is provided for our staff and clients to operate from, it is also a legal duty of staff to take reasonable care to avoid injury to themselves or to others by their work activities.

Any accident or incident involving a member of staff or a member of the public should be reported immediately to a Director of More Positive Me C.I.C. A record will be kept and an incident report will be undertaken by the organisation. This will be in the form of a factual statement covering to the fullest possible extent all the circumstances of the accident/incident and as far as possible to ascertain the cause in order to prevent its recurrence. The incident report will be held by More Positive Me C.I.C. and the lead of any other service which is the main user of a premises in which we might work.


Policy For Maintaining Worker Safety

It is each team member’s responsibility to ensure that a risk assessment of their working environment is conducted prior to meeting with clients on premises owned and/or managed by another organisation. They should also ask to see the health & safety policy for each of the premises they operate from before commencing work there. Team members should familiarise themselves with the procedures in case of a fire in all buildings used by More Positive Me and should ensure on every occasion that clients know how to exit safely in the case of a fire or other incident.

Guidelines to Avoid Risky or Threatening Situations

Each individual team member will need to develop their own strategy regarding their safety when on properties managed by external organisations. These are the guidelines that More Positive Me C.I.C. individuals, volunteers, and all other workers in the organisation are advised to follow to ensure their health and safety when working in premises owned and managed by other agencies:

 a) All workers will be inducted into the use of alarms (where appropriate), and where to sit with clients in counselling rooms.

 b) Counsellors will request that any prior knowledge of a potentially violent client must be made available to the counsellor.

 c) At least one member of staff should be present in the building if clients are on the premises.

 d) Counsellors working in other public buildings must always inform staff which room they are seeing a client in using agreed procedures.

e) All counsellors should familiarise themselves with layout of each building they work in, including the position of alarms and how they work.

f) Counsellors must not reveal their home details or home telephone number to clients and should give serious consideration to being ex-directory.

g) More Positive Me C I C workers are not covered by an insurance which allows them to work in client's homes.

 

h) All workers working from another organisation’s base must carry I.D.

i) Mobile telephones must be taken during all working hours. It is the worker's responsibility to ensure phones are working and charged. Employees will be provided with a company mobile, self-employed workers must provide their own.

j) Counsellors are advised to carry personal alarms with them at all times when working with clients.

k) Workers should not work in a building in which they are the sole worker.

 

I) All workers will have access to training for potentially violent or abusive situations.


This policy will be reviewed every two years.

 

Date Reviewed: 02/04/2024 Next review: 02/04/2026

Whistleblower Policy

More Positive Me C.I.C. is committed to creating an open and transparent culture where concerns can be raised with directors and where directors, staff, students and volunteers who raise concerns are supported and treated fairly.

1. Policy statement

 1.1 This policy aims to enable and encourage staff to raise concerns within More Positive me C.I.C. It recognises a worker's legal rights to make a protected disclosure to certain prescribed persons or bodies under the Public Interest Disclosure Act 1998 and any subsequent legislation, as incorporated into the Employment Rights Act 1996.

 1.2 More Positive Me C.I.C. is committed to creating a safe, open and transparent workplace culture where employees are encouraged to raise concerns at the earliest opportunity. More Positive Me C.I.C. recognises that employees are often the first to realise that there may be something seriously wrong within an organisation.

 1.3 It is important to More Positive Me C.I.C. that any fraud misconduct or wrongdoing by workers or officers of the

 organisation is reported and properly dealt with. More Positive Me C.I.C. is committed to tackling malpractice and wrongdoing. Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. If any cases of wrongdoing are upheld, they will be seriously dealt with.

 1.4 More Positive Me C.I.C. encourages directors and staff to use internal mechanisms for reporting malpractice or illegal acts or omissions by other directors and staff. Whistle-blowers will be listened to and serious concerns will be investigated. More Positive Me C.I.C. aims to reassure staff that they will be protected from harassment or victimisation from co-workers or from More Positive Me C.I.C. for raising concerns.

 1.5 More Positive Me C.I.C. will ensure all directors and staff are sent a copy of this policy on joining More Positive Me C.I.C. The policy will be reviewed annually and a copy will be sent to all staff who will be required to read it.

 1.6 This policy allows staff to take the matter further if they are dissatisfied with the director's response.


 2. Definitions and scope

 

 2.1 This policy applies to all directors and staff of More Positive Me C.I.C. Former staff, volunteers, the self-employed and

 contractors are also encouraged to use it.

 2.2 For the purpose of this policy, More Positive Me C.I.C. recognises that whistleblowing is the passing on of information about wrongdoing at work. The Whistle-blower must reasonably believe that they are acting in the public interest.

 2.3 The statutory categories for wrongdoing are 

 • a criminal offence (such as insurance fraud or illegal tax evasion)

 • a breach of any legal obligation

 • a miscarriage of justice

 • endangering an individual’s health and safety

 • damage to the environment

 • deliberate concealment of information about any of the above


 Examples of wrongdoing might include (but are not restricted to):

 • abuse of a director, staff, student or volunteer by another director, staff, student or volunteer

 • unsafe working conditions e g being asked to go to a survivor's home

 • lack of, or poor response to a reported safety incident

 • inadequate training for staff

 • Inadequate supervision of directors, staff, students or volunteers

 • suspicions of fraud or bullying culture


2.4 It is not necessary for the member of staff, to have proof that wrongdoing is being, has been, or is likely to be committed. A reasonable belief is sufficient to disclose the concern. The member of staff has no responsibility for investigating the wrongdoing. It is the organisation's responsibility to ensure that an investigation takes place.

 2.5 member of staff who makes such a protected disclosure has the right not to be dismissed, subjected to any other detriment, or victimised because they have made a disclosure.

 2.6 More Positive Me C.I.C. will not make 'gagging or confidentiality clause’ settlement agreements or non-disclosure agreements with individuals.

 2.7 This policy is not for staff with concerns about their employment that affects only them — that type of concern is better suited to the separate Grievance Policy.

 2.8 More Positive Me C.I.C. recognises employees may wish to seek advice and be represented by their trade union(s) officers when using the provisions in this policy.

 2.9 This policy will be reviewed annually from date of issue by the designated officer/s (see section 4 below). Where review is necessary due to legislative change, this will happen immediately.

 

3. Roles and Responsibilities

 3.1 The senior management team consisting of the Directors and Director/Clinical Lead are responsible and accountable for this Whistleblowing Policy and Procedure.

  3.2 All staff have a duty to report wrongdoing (whistleblowing) under the circumstances set out in section 2 of this policy.

 3.3 Directors are responsible for;

 • ensuring all staff are aware of this policy and procedure and their responsibilities.

 • investigating issues raised promptly and thoroughly.

 • fostering an open culture within their teams.

 • ensuring any Whistleblower is not subject to detriment.

 • escalating issues where required. 

 3.4 More Positive Me C.I.C. recognises that it is a small mutual support organisation and that Whistleblowers may find it

 difficult to report an issue due to staff and directors working closely together. Different directors will act as line managers for staff and volunteers at different times for specific work. This is in line with More Positive Me C.I.C.’s core purpose of mutual support. Volunteers will already be part of the More Positive Me C.I.C. community, receiving and offering mutual support in group sessions. Students will normally have a designated mentor for their time with More Positive Me C.I.C.

 3.5 Any of the directors (below) may be approached confidentially and will oversee reporting the concern to another Director or the Clinical lead as appropriate. When a member of staff, student or volunteer approaches a director with a concern, that director becomes the designated officer who will investigate the concern. Senior management will jointly ensure the process is monitored and improved where required.

 3.6 Designated officers

 Concerns under this procedure may be reported to:

 Jeanette Brown Director  Jeanette@morepositiveme.co.uk

 Hannah Hill Director  Hannah@morepositiveme.co.uk


  They will;

 

 • treat the concern confidentially unless otherwise agreed.

 • ensure the staff member/volunteer/student receives timely support to progress their concern.

 • give the staff member/volunteer/student timely feedback on how their concern is being dealt with.

 • ensure the staff member/volunteer/student has access to personal support as it is recognised that raising such a

 concern may be stressful.

 • provide advice and support to staff, students and volunteers.

 • ensure learning from whistleblowing cases is fed back to other directors and staff.

 • investigate issues raised with them directly promptly and thoroughly.

 • inform all reported disclosures to the Clinical Lead and the actions being taken.

 

 

 3.6 Senior management will jointly ensure the process is monitored and improved where required.

 3.5 Any of the directors (above) may be approached confidentially

 

 4. How to raise a concern

 4.1 The easiest way a member of staff/volunteer/student can get their concern resolved will be to raise it formally or informally with the director acting as their line manager. If this is not appropriate as the concern relates to the director acting as line manager in this instance, or if the member of staff does not feel able to raise it with them or if raising it with the director does not resolve matters the staff/volunteer/student can approach another director directly. The designated officer (director) will then confirm how the matter will be investigated.


 Any member of staff who wants to raise a concern that is potentially of public interest, is encouraged to get legal advice

 where appropriate such as through their trade union or through the charity Protect https://protect-advice.org.uk.

 4.3 If, for any reason, the member of staff does not feel comfortable raising their concern internally, they can raise

 concerns externally with https://www.gov.uk/government/organisations/office-of- the-regulator-of-community-interest-companies

 4.4 Concerns should be raised in writing (including email). The letter should set out the background and history of the

 concerns, giving names, dates and places where possible, and the reason why the member of staff is making the disclosure. If the individual does not feel able to make the disclosure in writing an interview will be arranged.

 4.5 The employee raising concerns does not have to prove the allegation but they must demonstrate that there are sufficient grounds for concern.

 4.6 It is best to raise a concern openly, because that makes it easier for More Positive me C.I.C. to follow it up. More Positive Me C.I.C. will not disclose the Whistleblower's identity without their consent unless there are legal reasons that require them to do so.

 4.7 Staff, volunteers or students may, if they wish, disclose information anonymously. However it should be noted that in

 such circumstances, More Positive Me will not be able to contact them to discuss their concern or ask them for further

 information, nor will they normally be able to give any feedback about any action it takes, although anonymous Whistleblowers may seek feedback through a telephone appointment or by using an anonymised email address.


 5. How More Positive Me C.I.C. will respond

 5.1 Promptly and confidentially.

 5.2 Any approach to line manager/designated officers will be treated with the strictest confidence and the member of

 staff’s identity will not be disclosed without their prior consent. All members of staff will be treated with respect at all times and the person raising the concern will be thanked.

 5.3 There may be a meeting with the member of staff raising the concern to ensure More Positive Me C.I.C. understands

 exactly the worry.

 5.4 When any meetings are arranged with an employee who has made a protected disclosure, they have a right to be

 accompanied by a trade union representative.

 5.5 When an individual makes a disclosure, the organisation will process any personal data collected as part of the

 investigation in line with More Positive Me C.I.C.’s data protection policy ensuring the data is stored securely and only

 accessed by those individuals essential for dealing with the disclosure.

 5.6 Within 5 working days of the person to whom the concern is raised. As we are a small organisation with some directors operating on a part time basis, this may be up to 21 days, but will always be dealt with in as timely a manner as possible, the director who received the disclosure will write to the member of staff setting out the following:

 • Acknowledgement that the concern has been received the date it has been received, whether the person who raised the concern has requested confidentiality, and a summary of the concern.

  • Indicating how the matter will be dealt with and by whom and how they can be contacted.

 • Telling the member of staff when an investigation has or is to be started, if further assistance will be needed from

 them and that they will be kept up to date.

 • The investigation will be objective and evidence-based and the result will produce a report that focuses on identifying and rectifying any issues and learning lessons to prevent problems recurring.

 5.7 In the event that misconduct is discovered as a result of any investigation under this policy the senior management team will meet to decide the outcome. The member of staff/volunteer/student will be told the outcome of the

 investigation and what More Positive me C.I.C. has done, or proposes to do, about it. If no action is to be taken, the reason

 for this will be explained.

 5.8 If an individual is not satisfied with the response received and any subsequent action taken they should put their concerns in writing to the Board of Directors, More Positive Me C.I.C. 45 Park Street Park Street, Crediton, EX17 3EH who will send a written response to the individual concerned.

6. Harassment and victimisation

 6.1 More Positive Me C.I.C. understands that raising a concern can be difficult for staff, especially if they fear reprisal from those responsible for the malpractice. More Positive Me C.I.C. will not tolerate harassment and victimisation of anyone raising a concern, and there should be no impact on the continued employment or promotion of anyone raising a concern. Any such behaviour is a serious breach of our values as an organisation and, if upheld following investigation, could result in disciplinary action potentially leading to dismissal.


6.2 Nor will More Positive Me C.I.C. tolerate any attempt to bully anyone into not raising any such concern. Any such behaviour is a breach of our values as an organisation and, if upheld following investigation could result in disciplinary action potentially leading to dismissal.

 6.3 This policy encourages members of staff to put their name to their concerns. Concerns expressed anonymously are harder to follow up and have an effective outcome.

 6.4 If a member of staff makes an allegation in good faith but the allegation is not confirmed by the investigation no action will be taken against that member of staff. They will not be at risk of losing their job or suffering any form of reprisal as a result.  Provided the member of staff is acting honestly it does not matter if they are mistaken or if there is an innocent  explanation for their concerns.


 7. Reporting a concern to an external body 

 7.1 This policy is intended to provide a route by which members of staff can raise concerns internally However, if an employee is unhappy with the outcome of an investigation or if, for any reason they do not feel comfortable raising their concern internally, they are free to take the matter outside of the organisation to a prescribed person or body or to their Member of Parliament (MP).

 7.2 The full list of prescribed persons and bodies can be found on

 the UK government website at

 https://www.gov.uk/government/publications/blowing-the-whistle-list-of-prescribed-people-and-bodies--2.

 They include HM Revenue & Customs, the Controller and Auditor General, the Director of the Serious Fraud Office,

 the Information Commissioner, the Equality and Human Rights Commission the Health and Safety Executive.


 More information and support

 8.1 Protect is the UK's whistleblowing charity that aims to stop harm by encouraging safe whistleblowing They provide a legal advice service we offering free expert and confidential advice on how best to raise a concern and protection as Whistleblower.

 Https://protect-advice.org.uk

 Protect Advice Line: whistle@protect-advice.org.uk

 Protect Advice Line: 020 3117 2520 (* option 1)

 8.2 UK government advice on Whistleblowing for employees’ www.gov.uk/whistleblowing.


This policy will be reviewed every two years.

 

Date Reviewed: 02/04/2024 Next review: 02/04/2026


Complaints Policy

More Positive Me C.I.C. exists to provide support for adults recovering from the impact of domestic abuse. Directors, staff and volunteers are expected to hold themselves to account against the highest standards of respect and behaviour towards the staff, volunteers and clients that More Positive Me supports. Due to the nature of work with people who have been impacted by domestic abuse, More Positive Me supports people with the protected characteristics of adults over the age of 18. This is because adult survivors recovering from domestic abuse face specific issues with continued control from their abuser, trauma impact and low self belief. Children need different specialist support that More Positive Me may support in the future with courses available under license from NDADA Grow Together & Side By Side. More Positive Me C.I.C. is a mutual support community. We will support survivors and help them make choices in their healing from trauma. Survivors can opt in and out of support that is not time limited.


1.1 We aim to minimise the occurrance of any actions or omissions leading to complaints by Directors, staff, students and volunteers listening to and treating colleagues and survivors fairly and with respect at all times.

 1.2 Directors, staff and volunteers should not use discriminatory language towards others based on gender, sexual orientation, religion, ethnicity, age or disability.

 1.3 Necessary adaptations should be made in meetings and to communications to be inclusive to all survivors e.g. choose a meeting place that meets access needs; communicate information about events in person or by phone if written communication is not appropriate for a survivor.

 1.4 Directors and staff should acknowledge a complaint promptly and arrange a meeting to resolve the complaint if possible. If it is not resolved by staff, the complaint should be escalated to a director and/or the Clinical lead.

 1.5 Copies of the complaints procedure below should be available for survivors at group and individual meetings.


How to make a complaint

More Positive Me C.I.C. is a community, and we want everyone to feel it is a safe and welcoming space. We want you to feel able to tell us if something is not right and we will try to resolve it with you at the time. We encourage you to approach a member of staff, director, volunteer or supervisor at the time if you feel comfortable doing so. We always aim to be available to listen with empathy and care, to any concerns you have about the service we have provided privately after a meeting you are attending if you ask us to. If this is not possible on the day, we will make an appointment to do so within the next seven working days.

If your complaint cannot be resolved at the time and you need to make a formal complaint, in the first instance please contact one of the directors below, stating that you wish to make a formal complaint and giving the details of the complaint that you wish to be considered (please indicate ‘Urgent - Formal Complaint’ in the subject line of any email):

Jeanette Brown, Director jeanette@morepositiveme.co.uk

Hannah Hill, Director hannah@morepositiveme.co.uk

 One of the directors will arrange to meet with you to investigate your complaint within seven working days of receiving your message.

If the complaint is not resolved, you may ask for your complaint to be escalated to the Clinical Lead who will contact you to arrange a time to discuss it with you. They will respond to you in writing, usually within fourteen days of the meeting. You may ask staff or a director for help to put your complaint in writing.

Please note that any incidents or disputes between survivors that did not happen during a More Positive Me meeting or joint event with a partner organisation, will not be considered within the scope of the complaints procedure.

If you are not happy with the outcome of the complaint you may refer your complaint to:

Complaints and appeals

CIC Regulator

1st Floor

Companies House

Crown Way

Cardiff

CF14 3UZ

Email cicconcerns@companieshouse.gov.uk

 24-hour voicemail service 029 2150 7420

Date Reviewed: 02/04/2024 Next review: 02/04/2026


Equality, Diversity & Inclusion Policy

Introduction

More Positive Me C.I.C. is an organisation set up for the purpose of providing mutual support to adults who are impacted by domestic abuse. More Positive Me is deeply committed to promoting equality, diversity, and inclusion (EDI) within our organisation, while keeping the protected characteristic of the purpose of the organisation of supporting adults who have been impacted by domestic abuse. We strive to eliminate unlawful discrimination and create an inclusive and respectful environment where all individuals, including staff and clients, are treated fairly and with dignity.


Policy Purpose

The purpose of this policy is to:

 1. Ensure equality, fairness, and respect for all staff and clients.

 2. Prohibit unlawful discrimination based on the protected characteristics defined in the Equality Act 2010, including age,

 disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex, and sexual orientation.

 3. Oppose and prevent all forms of unlawful discrimination within the organisation.


Our Commitments

More Positive Me commits to the following principles:

 1. Promoting EDI: We encourage and promote equality, diversity, and inclusion in our organisation.

 2. Safe and Respectful Environment: We are dedicated to creating a working environment that is free of bullying, harassment, victimisation, and unlawful discrimination. We value individual differences and recognize and appreciate the contributions of all staff.

  • All staff are expected to conduct themselves in a manner that supports equal opportunities and prevents bullying, harassment, victimisation, and unlawful discrimination.
  • Clients attending groups facilitated by More Positive Me CIC are expected to adhere to the principles of the More Positive Me mutual group agreement.

  3. Handling Complaints: More Positive Me takes complaints of bullying, harassment, victimisation, and unlawful discrimination seriously, regardless of the source. Such acts will be treated as misconduct and addressed through our grievance and/or disciplinary procedures, with appropriate actions taken. Serious complaints may result in gross misconduct and lead to dismissal.

  • Sexual harassment may have legal and criminal implications, and we will respond appropriately, including reporting such incidents to relevant authorities when necessary.

 4. Equal Opportunities for Development: We provide opportunities for training, development, and career progression to all staff, helping and encouraging them to reach their full potential. We aim to utilise their talents and resources to maximize organisational efficiency.

  5. Merit-Based Decisions: Decisions concerning staff, including recruitment, promotion, and other employment matters, are made based on merit. We adhere to the principles of equality, diversity, and inclusion, with limited exceptions allowed under the Equality Act.

6. Continuous Review and Updates: We will regularly review our employment practices and procedures to ensure fairness and compliance with changing laws and regulations. Our policy will be updated as necessary to reflect these changes.

7. Monitoring and Assessment: As we expand, More Positive Me will monitor the composition of our workforce regarding age, sex, ethnic background, sexual orientation, religion or belief, and disability. This monitoring will help us promote EDI and assess the effectiveness of our policies and action plans. We will review and take action to address any issues identified during this process. This policy will be reviewed every two years.

 

Date Reviewed: 02/04/2024 Next review: 02/04/2026

Data Protection Policy

Introduction

1. More Positive Me C.I.C. needs to collect and use certain types of information, including personal information about clients, staff, and other individuals who come into contact with our organisation. This personal information must be dealt with properly however it is collected, recorded and used — whether on paper, in a computer, or recorded on other material - and there are safeguards to ensure this in the Data Protection Act 1998.

2. More Positive Me C.I.C. regards the lawful and correct treatment of personal information as very important. It endorses fully and adheres to the Government’s Information Commissioner's Office for the Principles of Data Protection, as detailed in the Data Protection Act 1998.

 Principles

3. The Principles of Data Protection, as detailed in the Data Protection Act 1998 require that personal information;

 a. shall be processed fairly and lawfully and in particular, shall not be processed unless specific conditions are met.

 b. shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner

 incompatible with that purpose or those purposes.

 c. shall be adequate, relevant and not excessive in relation to those purpose(s).

 d. shall be accurate and, where necessary, kept up to date.

 e. shall not be kept for longer than is necessary.

 f. shall be processed in accordance with the rights of data subjects under the Act.

 g. shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of or damage to, personal information.


Responsibilities

 4. The Directors of More Positive Me C.I.C. recognise their overall responsibility for ensuring compliance with the requirements of the Data Protection Act 1998.

 5. The Data Protection Officers are responsible for day to management of the arrangements for data protection. The duties of Data Protection Officer are shared by the Directors of More Positive Me.

 6. More Positive Me C.I.C. will, through appropriate management, strict application of criteria, and controls;

 a. observe fully conditions regarding the fair collection and use of information.

 b. meet its legal obligations to specify the purposes for which information is used.

 c. collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to

 comply with any legal requirements.

 d. ensure the quality of information used.

 e. ensure that the rights of people about whom information is held, can be fully exercised under the Act These include;

 (i) the right to be informed that processing is being undertaken

 (ii) the right of access to one's personal information.

 (iii) the right to prevent processing in certain circumstances.

 (iv) the right to correct, rectify, block or erase information which is regarded as wrong information.

 f. take appropriate technical and organisational security measures to safeguard personal information.

 g. ensure that personal information is not transferred abroad.

 f. treat people justly and fairly whatever their age, religion, disability, gender sexual orientation or ethnicity when dealing with requests for information

 h. set out clear procedures for responding to requests for information.


Confidentiality

7. More Positive Me C.I.C. is committed to ensuring that information concerning the Company and its directors, staff, volunteers and clients, is protected from unauthorised or inappropriate disclosure to third parties either within or outside the organisation.

8. Details of More Positive Me C.I.C. Confidentiality Policy are contained in a separate document that should be read in conjunction with this policy.


Processing of sensitive information

9. The following elements of information about individuals are defined as sensitive and their processing is subject to specific regulations.

 a. racial or ethnic origin.

 b. political opinions

 c. religious beliefs or other beliefs of a similar nature.

 d. trade union membership.

 e. physical or mental health or condition.

 f. sexual life.

 g. commission or alleged commission of any offence.

 h. proceedings for any offence committed, disposal of such proceedings or the sentence of any court in such proceedings.


10. More Positive Me C.I.C. will process only the following elements of sensitive information.

 a. for equality and diversity monitoring in employment - elements of sensitive information relating to racial or ethnic

 origin.

 b. for recruitment — physical or mental health conditions and information relating to offences.

 c. for delivery of therapeutic services — physical or mental health condition.


Security

11. More Positive Me C.I.C. policy for maintaining the security of information is contained in a separate Information Security Policy that should be read in conjunction with this policy.

12. More Positive Me C.I.C. will review regularly its procedures for ensuring that records containing personal data remain accurate and consistent and in particular that;

  • Data kept for employment purposes will be held by Jeanette Brown, Director.
  • Information about clients will be shared within More Positive Me on a need-to-know basis only.
  • Minimal and necessary information only, given by clients or referrers will be recorded after contact. It will be kept for no longer than five years after the last contact.
  • Codes will be used on records of survivor information with identifiers kept in a separate place.


Retention of data

13. The requirement to ensure that personal data is not held for longer than necessary must be balanced against statutory and advisory retention periods for documents containing personal and company data. Clients may resume contact with More Positive Me after a long absence, sometimes of several years.

Subject access

14. Subject access is the process whereby the subjects of personal data that is held by an organisation may request access to that data. Subject access requests must be in writing. All staff are required to pass on anything which might be a subject access request to the Director of Services without delay.

15. Individuals making a subject access request will be asked to identify any counsellors or members of staff who may also hold information about them, so that this data can be retrieved.

16. All subject access requests will be handled by a Director In order to ensure that any requirements in relation to the disclosure of third party data are met a minimum of 3 working days notice is required for an access request to be processed.

17. Where the individual making a subject access request is not personally known to a Director, their identity will be verified before any information is provided.

18. The required information will be provided in permanent form unless the applicant makes a specific request to be given supervised access in person.

19. More Positive Me C.I.C. will make no charge for providing subject access.


Transparency

20. More Positive Me C.I.C. is committed to ensuring that clients are aware that their data is being processed and;

 a. for what purpose it is being processed.

 b. what types of disclosure are likely.

 c. how to exercise their rights in relation to the data.

21. People on whom More Positive Me hold data will generally be informed about processing of their personal data in the following ways;

 a. Staff: via personal letter or in their contract agreement.

 b. Volunteers: in the volunteer support pack.

 c. Clients: through information supplied to them at first meeting.


Consent

23. Staff details will only be disclosed for purposes unrelated to their work for More Positive Me C.I.C. (e.g. references)and with their consent.

24. Information about volunteer’s consent will be sought for the means of contact they prefer to be made public e.g. email address for any publication of information which is not essential for their role.

25. Information about clients will only be made public with their consent. (This includes photographs).

26. Sensitive data about clients (including health information) will be held only with the knowledge and consent of the individual.

27. Where consent is sought for the processing or release of personal data, this will be done in writing. Consent can be withdrawn after it has been given, but not retrospectively. There may be occasions where More Positive Me C.I.C. is required to retain data for a certain length of time, even though consent for using it has been withdrawn.


Staff training & acceptance of responsibilities

28. All workers who have access to any kind of personal data will have their responsibilities outlined during their induction procedures. Further training and updates will be provided through training in team meetings and via direct supervision.


This policy will be reviewed every two years.

 

Date Reviewed: 02/04/2024 Next review: 02/04/2026

Confidentiality Policy

Introduction

1. The purpose of this policy is to provide guidance to More Positive Me CIC’s directors, staff, counsellors, volunteers and students on requirements for the safeguarding of confidential material and the circumstances under which confidentiality may be broken.

2 All new staff, volunteers and Directors are to be made aware of the contents of this policy and are required to sign a confidentiality statement (Appendix A) as part of their induction.

3. This policy must be read in conjunction with the More Positive Me CIC policy covering Data Protection.

Commitments

4. More Positive Me CIC undertakes to: -

  • a. treat all personal and sensitive organisational information as confidential.
  • b. comply with the law regarding the protection and disclosure of information.
  • c. not disclose personal information either orally or in writing without the prior informed consent of the individual concerned, except in the circumstances outlined in the section on disclosure below.
  • d. not to gain or attempt to gain access to information to which it is not authorised to have access.


5. In line with the principles in the Data Protection Act 1998, and GDPR, all personal information relating to applicants, clients, staff, volunteers and Directors that is not a matter of public record will be: -

  • a. obtained fairly.
  • b. held for specific purposes and used only for those purposes.
  • c. relevant, accurate and kept up to date.
  • d. corrected if shown to be inaccurate.
  • e. kept no longer than necessary and destroyed when no longer required.
  • f. protected against loss or disclosure.
  • g. treated as confidential at all times.

Disclosure

6. Disclosure of personal information to outside agencies will only be made with the informed consent of the individual concerned except: -

  • a. to comply with the law (e.g. the police Inland Revenue and Council Tax Registration Officer) or a court order.
  • b. where there is a clear health or safety risk or risk to children or vulnerable adults.
  • c. in connection with court proceedings or statutory action to enforce compliance with
  • d. tenancy conditions (e.g. applications for possession, health and safety, fire and building regulations).
  • e. anonymously for bona fide statistical or research purposes provided it is not possible to identify the individuals to whom the information relates.

7. The decision to disclose information without the express consent of the individual concerned will normally be taken by the Directors of the company.


Handling of Confidential Information

8. The following categories of information are to be treated as confidential: -

  • a. Personal information about survivors collected for assessment, monitoring and evaluation purposes.
  • b. Notes and records about survivors.
  • c. Payroll records.
  • d. Personnel records including recruitment documents CRB documents and any other files relating to individual people.
  • e. Home address, telephone number and personal e-mail address.
  • f. Health records of individuals.
  • g. More Positive Me CIC financial records.
  • h. Matters discussed at More Positive Me CIC Directors level.
  • i. More Positive Me CIC documents and resources, including existing course materials and ideas, both physical and digital, and any new work created by directors, staff, counsellors, volunteers as part of their work for More Positive Me CIC (unless specifically agreed in writing by the Directors)

 

9. The storage and handling of Confidential documents is to comply with the following requirements: -

  • a. Confidential documents and magnetic media containing confidential information are to be stored in locked containers when not in use.
  • b. Confidential documents are not to be left unattended in places of work during the working day If there is a need to vacate the room, documents should be locked away.
  • c. If confidential documents are dispatched from More Positive Me CIC to external agencies they must be sent by appropriately secure means and a record of the documents dispatched is to be retained.
  • d. Personal computers used to process confidential information must be password protected and arrangements made to change passwords at regular intervals.
  • e. Codes should be used on records rather than names with the identifiers kept separately.

10. Discretion must be exercised when discussing More Positive Me CIC business to ensure that no personal information or information that may bring the organisation or any member of staff, counsellor, volunteer or Director into disrepute is divulged inadvertently.


11. Intentional or negligent disclosure of personal information may amount to misconduct and be dealt with through More Positive Me CIC disciplinary procedures.



This policy will be reviewed every two years.

Date Reviewed: 02/04/2024 Next review: 02/04/2026


Reserves Policy

1. Introduction

As a CIC, a percentage of our income is allocated to specific projects. This does not provide us with a contingency fund for unexpected expenses that fall outside of the scope of these funding streams.

Income which falls outside of this includes profit made on retail sales, including our workbooks, eCourses and other publications. We intend, through this policy, to specify how we will use this income.

This reserves policy is designed to safeguard the company from such expenses and to support both the people who work for us and our clients. It is designed to reinforce and safeguard More Positive Me CIC’s mission and objectives.

2. Primary Reserve Tier

  • Amount: £6,000
  • Spending Guidelines: Reserved for core running costs in the event of funding shortfall or unexpected drops in income
  • Review Frequency: This amount will be reviewed annually

3. Secondary Reserve Tier

  • Amount: £3,000
  • Spending Guidelines: Reserved for wellbeing and health needs of staff and directors. This may include, but is not limited to: long term sick pay, therapeutic interventions.
  • Review Frequency: This amount will be reviewed annually

4. Tertiary Reserve Tier

  • Amount: Anything above the Primary and Secondary reserves
  • Spending Guidelines: Reserved to support clients with the cost of living. This may include, but is not limited to: covering referral costs for those experiencing financial hardship and unable to pay the minimum donation, applications for assistance with buying essential furniture or household items after fleeing domestic abuse.
  • Review Frequency: This amount will be reviewed annually

5. Shortfall Plan

  • In the event of the reserves falling below £6000 we have a contingency plan as follows:
  • Facilitator Bank not offered any new work after the project they are currently working on.
  • Focus on funding before any other project or course started.
  • Closure of office, working from home.
  • Volunteer support for fundraising, support delivering courses and J9 training.

 

This policy will be reviewed every two years.

 

Date Reviewed: 02/04/2024 Next review: 02/04/2026



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