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Our Commitment to Ethical, Legal, and Transparent Practices

Explore our key policies that reflect our dedication to compliance, responsibility, and continuous improvement.

Policy Contact

Harminder Ghataaura

Date Issued

1st October 2021

Amended

1st July 2024

Next Review Date

1st July 2025

Approved by

Harminder Ghataaura

Oakwood 24 Ltd (“the Company”) is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out our commitment to data protection, and individual’s rights and obligations in relation to personal data. This policy applies to the personal data of job applicants, employees, workers, contractors, volunteers, interns, apprentices, and former employees, referred to as personal data. This policy does not apply to the personal data of clients or other personal data processed for business purposes. This policy does not form part of an employee's contract of employment and may be amended at any time without prior notice. If you consider that the policy has not been followed in respect of either your own personal data or that of others, you should raise the matter with your manager.

Definitions

"Personal data" is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing, or destroying it.

"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.

"Criminal records data" means information about an individual's criminal convictions and offences, and information relating to criminal allegations and proceedings.

Data Protections Principals

The Company processes personal data in accordance with the following data protection principles:

We process personal data lawfully, fairly and in a transparent manner.
We collect personal data only for specified, explicit and legitimate purposes.
We process personal data only where it is adequate, relevant, and limited to what is necessary for the purposes of processing.
We keep accurate personal data and take all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
We keep personal data only for the period necessary for processing.
We adopt appropriate measures to make sure that personal data is secure and protected against unauthorised or unlawful processing, accidental loss, destruction, or damage.

We inform individuals of the reasons for processing their personal data, how we use such data and the legal basis for processing in the Company’s privacy notices. We will not process personal data of individuals for other reasons.

We will update personal data promptly if an individual advises that his/her information has changed or is inaccurate.

Personal data gathered during the employment, worker, contractor or volunteer relationship, or apprenticeship or internship, is held in the individual's personnel file (in hard copy or electronic format, or both), and on HR systems. The periods for which the Company holds personal data are contained in its privacy notices to individuals.

We keep a record of our processing activities in respect of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

Individual Rights

As a data subject, individuals have a number of rights in relation to their personal data.

Individuals have the right to make a subject access request. If an individual makes a subject access request, the Company will tell him/her:

Whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual.
To whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers.
For how long his/her personal data is stored (or how that period is decided).
His/her rights to rectification or erasure of data, or to restrict or object to processing.
His/her right to complain to the Information Commissioner if he/she thinks the organisation has failed to comply with his/her data protection rights; and
Whether or not the organisation carries out automated decision-making and the logic involved in any such decision-making.

We will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically unless he/she agrees otherwise.

If the individual wants additional copies, we will charge a fee, which will be based on the administrative cost to the Company of providing the additional copies.

To make a subject access request, the individual should send their request to the Data Protection Officer. In some cases, the Company may need to ask for proof of identification before the request can be processed. We will inform the individual if we need to verify his/her identity and the documents we require.

The Company will normally respond to a request within a period of one month from the date it is received.

In some cases, such as where the Company processes large amounts of the individual's data, we may respond within three months of the date the request is received. We will write to the individual within one month of receiving the original request to tell him/her if this is the case.

If a subject access request is manifestly unfounded or excessive, the Company is not obliged to comply with it. Alternatively, the Company can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which the Company has already responded. If an individual submits a request that is unfounded or excessive, we will notify him/her that this is the case and whether we will respond to it.

Other Rights

Individuals have a few other rights in relation to their personal data. They can require the Company to:

Rectify inaccurate data.
Stop processing or erase data that is no longer necessary for the purposes of processing.
Stop processing or erase data if the individual's interests override the organisation's legitimate grounds for processing data (where the organisation relies on its legitimate interests as a reason for processing data);
Stop processing or erase data if processing is unlawful; and
Stop processing data for a period if data is inaccurate or if there is a dispute about whether the individual's interests override the organisation's legitimate grounds for processing data.
To ask the Company to take any of these steps, the individual should send the request to their Line Manager.

Data Security

We take the security of personal data seriously. We have internal policies and controls in place to protect personal data against loss, accidental destruction, misuse, or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.

Where the Company engages third parties to process personal data on its behalf, such parties do so based on written instructions and are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

Impact Assessments

Some of the processing that the Company carries out may result in risks to privacy. Where processing would result in a high risk to individual's rights and freedoms, we will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

Data Breaches

If the Company discovers that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. We will record all data breaches regardless of their effect.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, we will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

Personal data may be transferred to countries outside the EEA for references purposes. Data is transferred outside the EEA on the basis of compliance with this policy.

Individual Responsibilities

Individuals are responsible for helping the Company keep their personal data up to date. Individuals should let us know if data provided to us changes, for example if an individual moves to a new house or changes his/her bank details.

Individuals may have access to the personal data of other individuals and of our customers and clients in the course of their employment, contract, volunteer period, internship, or apprenticeship. Where this is the case, the Company relies on individuals to help meet our data protection obligations to staff, customers, and clients.

Individuals who have access to personal data are required:

To access only data that they have authority to access and only for authorised purposes.
To not disclose data except to individuals (whether inside or outside the organisation) who have appropriate authorisation.
To keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
To not remove personal data, or devices containing or that can be used to access personal data, from the organisation's premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device; and
To not store personal data on local drives or on personal devices that are used for work purposes.

Further details about the Company's security procedures can be found in our Data Security policy.

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under our Disciplinary Procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to summary dismissal.

Policy Contact

Harminder Ghataaura

Date Issued

1st October 2021

Amended

1st July 2024

Next Review Date

1st July 2025

Approved by

Harminder Ghataaura

Oakwood 24 is committed to providing a high level of service to all of its customers, and as such, a robust Complaints process has been implemented, ensuring that all complaints, regardless of their nature and severity are dealt with in a timely and acceptable manner. At all times, the complaints procedure will comply with the requirements of the Local Authority Social Services and National Health Service Complaints (England) Regulations 2009.

Oakwood 24 ensures that the below written COMPLAINTS PROCEDURE - FOR HANDLING COMPLAINTS, OMISSIONS AND OVERSIGHTS IS MADE READILY AVAILABLE TO ALL RELEVANT PARTIES, INCLUDING (BUT NOT LIMITED TO):

Authorities
Participating Authorities
Temporary Workers
Internal Staff
Work Seekers

Ensuring that Oakwood 24 handle complaints well:

Demonstrates their commitment to the clients, staff, temporary workers and/or patients
Demonstrates their commitment to providing the best possible service
Assists Oakwood 24 in identifying issues within the business so they can be addressed
Prevention

Oakwood 24 view complaints as an opportunity to learn and improve for the future, as well as addressing the complaint with the complaintive in order to rectify. The policy followed is:

To provide a fair complaints procedure which is clear and easy to use for anyone wishing to make a complaint
To publicise the existence of our complaints procedure so that people know how to contact us to make a complaint
To make sure everyone at Oakwood 24 knows what to do if a complaint is received
To make sure all complaints are investigated fairly and in a timely way
To make sure that complaints are, wherever possible, resolved and that relationships are repaired
To gather information which helps us to improve what we do

Complaints can be received via email, phone or fax alert. In all instances the same process is followed throughout to ensure consistency throughout the business.

The following process followed is:

Complaint recorded on the central register within a day of receiving it. If it can be resolved informally over the phone, then it will.
Written complaints acknowledged within 2 business days.
Investigation opened into complaint received.
Relevant parties contacted for statements.
Member of staff may be required to speak to the complaintive.
Complaintive will be invited to meet, discuss and resolve the complaint. This will be done within 5 days.
Within 2 days of the meeting, Oakwood 24 will write to the complaintive to confirm what took place and agreed solutions.
If no meeting is possible, a detailed reply will be sent to the complaintive. This will include any suggestions for resolving the matter, done within 5 days of completing his investigation.
At this stage, if not satisfied, the complaintive will be directed towards other bodies such as the REC or the relevant professional body (NMC, HCPC, GMC etc)
Where patient safety is questioned, appropriate action will be taken in order to reduce risk. This may include removing temporary workers from assignment until such time as a complaint has been resolved.
Where necessary, any complaints and its findings will be escalated to the relevant professional & regulatory body.
Complaints are resolved within 10 business days; however, if this is not possible, all relevant parties will be kept informed, with an audit trail documented on the recruiter system.

Complaints will be recorded & reviewed during monthly/yearly meetings in order to highlight trends. Any areas of improvement are quickly identified, with necessary changes implemented and communicated in order to reduce any further risk or dissatisfaction.

As part of the Oakwood 24 process, Temporary Workers supplied in the provision of the Services will be promptly and fully informed of complaints relating to them and Oakwood 24 will (and will use all reasonable endeavours to ensure that the Temporary Worker will) take demonstrable action to ensure there is no recurrence of the action complained of.

How to raise a complaint

All complaints can be raised to the Oakwood 24 Complaints Team:

Contact Name: Harminder Ghataaura
Contact number: 0204 518 1778
Address: 3, Sutherland House, Lloyd's Avenue, London, United Kingdom, EC3N 3DS

Escalation

Where a complaint cannot be resolved satisfactorily, Oakwood 24 will escalate accordingly, or provide escalation details to those appropriate, as follows:

NMC

Address: 23 Portland Pl, London W1B 1PZ

Phone: 020 33076802

Email: complaints@nmc-uk.org / newreferrals@nmc-uk.org GMC

Address: 350 Euston Rd, London NW1 3JN

Phone: 0161 923 6602

Email: gmc@gmc-uk.org

HCPC

Address: Park House, 184 Kennington Park Road, London SE11 4BU

Phone: 0207 840 9814 / 0800 328 4218

Email: ftp@hcpc-uk.org

NHS Counter Fraud Authority (NHS CFA)

Address: NHS CFA, 7th Floor, HM Government Hub, 10 South Colonnade, Canary Wharf, London, E14 4PU

Phone: 0800 028 4060

Email: complaints@nhsfcfa.gov.uk

The Care Inspectorate

Address: Care Inspectorate, Compass House, 11 Riverside Drive, Dundee DD1 4NY

Phone: 0345 600 9527

Email: enquiries@careinspectorate.gov.scot / concerns@careinspectorate.gov.scot

Home Office

Immigration Enforcement Hotline: 0300 123 7000

Crimestoppers: 0800 555 111

Fraud Hotline (Action Fraud): 0300 123 2040

Website: https://www.gov.uk/report-immigration-crime

Should a complaint be escalated, Oakwood 24 will ensure that the details of how the complaint has been resolved should is notified to the Authority in writing as soon as possible thereafter.

Furthermore, we will upon request at any time from the Authority provide the Authority with anupdate as to the progress of the resolution of the complaint.

Where Oakwood 24 receive poor reports of a Temporary Worker's performance in a Confidential Reference written to us by, or on behalf of, the Authority, shall not supply that Temporary Worker to the Authority, until the Authority is satisfied that the issues identified have been resolved, will not recur and has confirmed this in writing to us.

Full records are retained on file of any and all complaints received. This is crucial as part of our ongoing commitment to continuous improvement, as well as part of our Quality Assurance Policy.

Oakwood 24 provide a copy of our complaint’s procedure to each Temporary Worker at recruitment. Each Temporary Worker signs and dates a declaration confirming receipt of such procedure and this declaration is retained in a way that cannot be altered, with the personnel records for that Temporary Worker.

Review

This policy statement will be reviewed annually as part of our commitment to upholding professional standards. It may be altered from time to time in the light of legislative changes, operational procedures or other prevailing circumstances.

Policy Contact

Harminder Ghataaura

Date Issued

1st October 2021

Amended

1st July 2024

Next Review Date

1st July 2025

Approved by

Harminder Ghataaura

Effective October 1, 2011, the Agency Worker Regulations 2010 (AWR) were enacted into law in the UK, signifying a crucial piece of legislation. We strongly advise all temporary agency workers under Oakwood 24 to familiarize themselves with these guidelines. Despite the intricate nature of AWR rules, the overarching goal is clear: to ensure equal treatment for temporary agency workers in terms of basic working and employment conditions.

This regulation delineates responsibilities among three parties: the agency worker (you), Oakwood 24 as the temporary work agency, and our clients referred to as hirers. The hirer, whether an individual, company, partnership, sole trader, or public body, is responsible for overseeing and directing your activities during your shift.

Under the AWR, you have the right to the same basic working and employment conditions as comparable employees directly employed by the hirers where Oakwood 24 places you. Equal treatment covers basic rates of pay, overtime or anti-social uplifts (evenings, Saturdays, Sundays, bank holidays, etc.), bonus and incentive schemes, holiday pay, and day one benefits.

Certain benefits applicable only to permanent employees, such as sick pay, pensions, maternity/paternity leave, and redundancy, are not extended to temporary agency workers.

The 12-week qualifying period is crucial for equal treatment. This period applies when you work in the same role (referred to as an "assignment") with the same hirer for 12 continuous weeks. Various circumstances are outlined in the regulations, detailing breaks that do not impede the 12-week qualifying period.

The 12-week qualifying period is akin to a clock that can reset, pause, or continue ticking based on specific breaks between assignments. Breaks that reset the clock to zero include starting a new job role with a new hirer or remaining with the same hirer but with a substantively changed job role. Pauses occur with breaks of no longer than six weeks where you return to the same job role with the same hirer. The clock continues ticking during breaks due to childbirth, pregnancy, maternity, or related leave.

Immediate entitlements for temporary agency workers include "day one" benefits, such as access to collective facilities and amenities of the hirer (including canteens, transport services, and childcare facilities) and the right to be informed of any relevant vacant posts and internal training resources.

The AWR is not applied retrospectively, and qualifying weeks start accruing from October 1, 2011. To ensure you receive these benefits, it is imperative to inform Oakwood 24 of your work at the same hirer through third-party agencies and any breaks you take, such as annual leave, sickness, or other

interruptions. This information is crucial for accurate tracking and equal treatment after the 12-week qualifying period.

For instance, if you work as a carer at a hospital for 10 weeks and then take a break for 6 weeks or less before returning to the same job role, you will resume on qualifying week 11. If your job role changes, the qualifying clock resets to week 1, and if the break exceeds 6 weeks, you start anew on qualifying week 1 upon return.

To further ensure accurate tracking, it is essential to inform Oakwood 24 of any work at a hirer through another third-party agency. Additionally, notify us of annual leave, sickness, or other breaks by emailing the details to payroll@newsite.oakwood24.co.uk, attaching relevant proof for verification. This proactive communication helps us uphold our responsibility to track and record your work accurately and ensures equal treatment after the 12-week qualifying period.

Signed on behalf of Supplier

Harminder Ghataaura

Date Issued

1st January 2025

Next Review Date

1st January 2026

Approved by

Harminder Ghataaura

Commitment to achieving Net Zero

Oakwood 24 Ltd is committed to achieving Net Zero emissions by 2040.

Baseline Emissions Footprint

Baseline emissions are a record of the greenhouse gases that have been produced in the past and were produced prior to the introduction of any strategies to reduce emissions. Baseline emissions are the reference point against which emissions reduction can be measured.

Baseline Year: 2024

Additional Details relating to the Baseline Emissions calculations.

This is the first year of assessing carbon emissions for Oakwood 24 Ltd and therefore we have selected 2024 as the foundation for our baseline emissions, recognising that it provides a more complete and contemporary picture of our organisation’s operations and carbon footprint. Prior to this, our emissions reporting was limited and did not fully encompass the breadth of categories now included within our measurement framework.

Baseline year emissions:

EMISSIONS

TOTAL (tCO2e)

Scope 1

52.34

Scope 2

7.85

Scope 3

(Included Sources)

17.09

The sources we included in our Scope 3 emissions are:

· Water and Waste

· Waste Generated

· Employee Commuting (Estimated based on ONS data, average employee numbers and assumed that all employees are using an average sized car)

Total Emissions

77.28

Current Emissions Reporting

Reporting Year: 2024

EMISSIONS

TOTAL (tCO2e)

Scope 1

52.34

Scope 2

7.85

Scope 3

(Included Sources)

17.09

The sources we included in our Scope 3 emissions are:

Water and Waste
Waste Generated
Employee Commuting (Estimated based on ONS data, average employee numbers and assumed that all employees are using an average sized car)

Total Emissions

77.28

Emissions reduction targets

In order to continue our progress to achieving Net Zero, we have adopted the following carbon reduction targets. We project that carbon emissions will decrease over the next five years to 45.46 tCO2e by 2030. This is a reduction of 41.18%.

Carbon Reduction Projects

In the short term, (next five years to 2030) we will be implementing the below measures to achieve our carbon reduction target.

Transition to electric vehicles: Replace petrol and diesel vehicles with electric or hybrid models, taking advantage of government grants and subsidies for EV purchases and charging infrastructure installation.

Carpooling or ride-sharing: Organise shared travel for health care workers operating in the same geographic area, using route-optimisation technology to group client visits effectively.

Transition to remote operations: Adopting online platforms for candidate interviews and client meetings, significantly reducing travel-related emissions.

Energy-efficient office equipment: Upgrading to energy-efficient computers, printers, and lighting systems, decreasing electricity consumption.

Paperless processes: Implementing digital documentation and e-signatures, reducing paper usage and associated waste.

Waste management programmes: Establishing comprehensive recycling systems within the office to minimise landfill contributions.

Flexible working policies: Introducing flexible working arrangements, allowing staff to work from home, thereby reducing commuting emissions.

Sustainable office supplies: Sourcing office materials from environmentally friendly suppliers to lower the carbon footprint of procurement activities.

Employee training and awareness: Conducting regular training sessions to educate staff on best practices for reducing carbon footprints both professionally and personally.

Beyond 2030, we hope to implement further measures such as those outline below to reach net zero carbon emissions by 2040:

Renewable energy procurement: Plan to switch to 100% renewable energy sources for office operations by 2035, aiming to reduce Scope 2 emissions.

Green certifications: Seek certifications such as ISO 14001 to formalise environmental management systems and demonstrate commitment to sustainability.

Eco-friendly office spaces: Relocate to or retrofit existing offices with energy-efficient infrastructure, including improved insulation and sustainable building materials.

Sustainable transportation incentives: Encourage the use of public transport, cycling, or electric vehicles among employees through incentive programs.

Carbon offsetting programs: Invest in verified carbon offset projects, such as tree planting initiatives, to compensate for unavoidable emissions.

Supply chain engagement: Collaborate with suppliers and partners to ensure they adhere to sustainable practices, amplifying the impact across the value chain.

Digital platform optimisation: Enhance the efficiency of digital platforms and servers to reduce energy consumption associated with online operations.

Regular carbon footprint assessments: Commit to annual assessments of the agency's carbon footprint to monitor progress and identify areas for further improvement.

Declaration and Sign Off

This Carbon Reduction Plan has been completed in accordance with PPN 06/21 and associated guidance and reporting standard for Carbon Reduction Plans.

Emissions have been reported and recorded in accordance with the published reporting standard for Carbon Reduction Plans and the GHG Reporting Protocol corporate standard[1] and uses the appropriate Government emission conversion factors for greenhouse gas company reporting[2].

Scope 1 and Scope 2 emissions have been reported in accordance with SECR requirements, and the required subset of Scope 3 emissions have been reported in accordance with the published reporting standard for Carbon Reduction Plans and the Corporate Value Chain (Scope 3) Standard[3].

This Carbon Reduction Plan has been reviewed and signed off by the board of directors (or equivalent management body).

[1]https://ghgprotocol.org/corporate-standard

[2]https://www.gov.uk/government/collections/government-conversion-factors-for-company-reporting

[3]https://ghgprotocol.org/standards/scope-3-standard

Our Commitment to Ethical, Legal, and Transparent Practices

GDPR Policy

GDPR Policy

Policy Contact

Date Issued

Amended

Next Review Date

Approved by

Definitions

Data Protections Principals

Individual Rights

Other Rights

Data Security

Impact Assessments

Data Breaches

Individual Responsibilities

Modern Slavery Policy

Modern Slavery Policy

Policy Contact

Date Issued

Amended

Next Review Date

Approved by

Complaints Policy

Complaints Policy

Policy Contact

Date Issued

Amended

Next Review Date

Approved by

How to raise a complaint

Escalation

Review

Agency Worker Regulations Policy

Agency Worker Regulations Policy

Policy Contact

Date Issued

Amended

Next Review Date

Approved by

Carbon Reduction Plan

Carbon Reduction Plan

Signed on behalf of Supplier

Date Issued

Next Review Date

Approved by

Commitment to achieving Net Zero

Baseline Emissions Footprint

Baseline Year: 2024

Emissions reduction targets

Carbon Reduction Projects

Declaration and Sign Off

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