PRIVACY POLICY

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This privacy policy sets out how Athena uses and protects any information that is collected when you use this website.

 

Athena is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

 

Athena may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 23rdApril 2018.

 

Your Rights

As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

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• The right to be informed about our collection and use of personal data;

• The right of access to the personal data we hold about you;

• The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us);

• The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (We only hold your personal data for a limited time but if you would like us to delete it sooner, please contact us using the details in the 'contact us' section);

• The right to restrict (i.e. prevent) the processing of your personal data;

• The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

• The right to object to Us using your personal data for particular purposes; and

• Rights with respect to automated decision making and profiling.

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If you have any cause for complaint about Our use of your personal data, please contact us using the details provided in the 'contact us' section and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

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For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

 

Lawful, Fair, and Transparent Data Processing

The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:

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• The data subject has given consent to the processing of their personal data for one or more specific purposes;

• The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;

• The processing is necessary for compliance with a legal obligation to which the data controller is subject;

• The processing is necessary to protect the vital interests of the data subject or of another natural person;

• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or

• The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

 

What we collect

We may collect the following information:

• name and job title

• contact information including email address

• demographic information such as local authority making an enquiry

• other information relevant to customer surveys and/or offers

 

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• Internal record keeping.

• We may use the information to improve our products and services.

• We may periodically send promotional emails about our availability or other information which we think you may find interesting using the email address which you have provided.

• From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail.

• We may use the information to customise the website according to your interests.

 

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

 

How we use cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

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Athena do not use cookies at this stage.

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Controlling your personal information

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you information about our services which we think you may find interesting if you tell us that you wish this to happen.

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You may request details of personal information which we hold about you under the Data Protection Act 1998. If you would like a copy of the information held on you please write to Athena , Bedford Heights, Manton Lane, Bedford, MK41 7PH.

 

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

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MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

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This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It describes the steps taken by Athena Housing and Support Limited and Athena Children’s Services Limited to prevent slavery and human trafficking within their businesses and supply chains.

 

Our organisation, business and supply chains

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Athena provides supported accommodation and related services to children, young people and families. Our services are delivered primarily by directly employed staff and supported by external suppliers.

Our supply chain includes staffing agencies, landlords, property-maintenance contractors, utilities, IT and communications providers, training organisations, professional advisers, transport providers and suppliers of furniture, equipment, food and household products.

Responsibility for modern slavery compliance rests with the Director, supported by senior managers and those responsible for recruitment, safeguarding and procurement.

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Policies

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Athena does not tolerate slavery, forced labour, human trafficking or exploitation within its business or supply chain.

Our approach is supported by policies covering:

• modern slavery and human trafficking;

• safeguarding;

• safer recruitment;

• whistleblowing;

• equality, diversity and inclusion;

• employee conduct;

• procurement and contractor management; and

• reporting allegations and concerns.

These policies apply to employees, agency workers, contractors and suppliers where relevant and are reviewed regularly.

 

Due diligence

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Before appointing employees, agency workers, contractors or key suppliers, Athena carries out checks proportionate to the level of risk. These may include:

• identity and right-to-work checks;

• employment history, references and enhanced DBS checks;

• supplier ownership and business checks;

• confirmation of employment, safeguarding and ethical-working practices;

• review of relevant policies, insurance and accreditations;

• contractual requirements to comply with applicable legislation; and

• assessment using the Government Modern Slavery Assessment Tool where appropriate.

Concerns or inconsistencies are investigated before an appointment is approved. Suppliers must cooperate with enquiries and take corrective action where weaknesses are identified. Athena may suspend or terminate an arrangement where a supplier fails to address serious concerns.

 

Risk assessment and management

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We assess modern slavery risk by considering the sector, location, workforce model, use of temporary or migrant labour, subcontracting arrangements and the nature of the goods or services supplied.

Areas of potentially increased risk include agency staffing, construction and property maintenance, cleaning and supply chains involving low-paid, temporary, migrant or outsourced labour.

Risk controls include safer recruitment, checks on staffing agencies, supplier due diligence, clear contractual expectations, management oversight and routes for staff and young people to report concerns.

As Athena supports young people who may be vulnerable to criminal or sexual exploitation, staff are also trained to recognise possible indicators of trafficking and modern slavery. Any concern is immediately referred through safeguarding procedures and, where necessary, reported to the police, local authority or other appropriate agency.

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Measuring effectiveness

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Athena monitors the effectiveness of its arrangements using indicators including:

• the proportion of staff completing required training;

• the number of suppliers assessed for modern slavery risk;

• completion of due diligence before supplier approval;

• concerns raised through safeguarding and whistleblowing procedures;

• identified breaches and corrective actions;

• supplier compliance reviews; and

• lessons learned from incidents, audits and complaints.

Senior management reviews these indicators and ensures that identified improvements are recorded, allocated and monitored to completion.

 

Training and capacity building

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Relevant staff receive training on modern slavery and human trafficking through induction, safeguarding training and periodic refresher training. Training includes recognising indicators of exploitation, responding to disclosures, recording concerns and following internal and external reporting procedures.

Managers and staff involved in recruitment, procurement or supplier management receive additional guidance appropriate to their responsibilities. Training completion is recorded and monitored, and further learning is provided where audits, incidents or changes in guidance identify a need.

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Reporting concerns

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Employees, contractors, suppliers and other stakeholders are encouraged to report concerns to a manager, the Designated Safeguarding Lead or through Athena’s whistleblowing procedure. Reports will be taken seriously, handled sensitively and investigated appropriately. No person raising a genuine concern in good faith will suffer detrimental treatment.