If you have an urgent safeguarding concern please phone 07855 359 140. To report a non urgent concern please email samuel@creativementornetwork.org.

If someone is in immediate danger phone 999.

REATIVE MENTOR NETWORK SAFEGUARDING CHILDREN AND YOUNG PEOPLE POLICY

We believe that safeguarding and protecting children and young adults is the individual and collective responsibility of everyone working in or visiting the organisation. Our policy recognises that the welfare and interests of children and young adults are paramount in all circumstances. We are committed to ensuring our safeguarding practices reflect statutory responsibilities, government guidance and complies with best practice.

This policy applies for the duration of a young person’s participation on the Creative Mentor Network programme. For the avoidance of doubt, should a mentor and mentee elect to remain in contact following the end of the programme, then they do so at their own risk and outside the scope of Creative Mentor Network’s responsibility.

1. Policy purpose and guidance

This policy states Creative Mentor Network’s commitment in relation to Safeguarding children and young adults and gives guidance on:

What CMN staff or volunteers should do if they think a child/young person they are working with has raised a safeguarding disclosure or a safeguarding incident occurs. [See Appendix 1]

What the organisation will do to ensure that employees, whether paid staff or volunteers, do not pose a risk to children and young adults.

How CMN procedures work alongside other local agencies.

2. Terminology

A child/children is any individual under the age of 18. Young adults are people aged 18 to 27.

Safeguarding and promoting the welfare of children and young adults is:

Protecting children/young adults from maltreatment

Preventing impairment of children’s / young adult’s health or development

Taking action to enable all children/ young adults to have the best outcomes

Promoting the freedom and dignity of the person who has experienced or is experiencing abuse

Promoting the rights of all people to live free from abuse and coercion

Ensuring the safety and well-being of people who do not have the capacity to decide how they want to respond to abuse that they are experiencing

Managing services in a way which promotes safety and prevents abuse

Recruiting staff and volunteers safely, ensuring all necessary checks are made

Providing effective management for staff and volunteers through supervision, support and training

3. Staff Responsibilities

The Designated Safeguarding Lead is the person with the overall responsibility of ensuring the organisation’s Safeguarding Children and Young Adult Policy is implemented and ensures that the Policy and procedures are kept up to date and are applied consistently. The Designated Safeguarding Lead possesses a ‘Designated Safeguarding Lead (Level 3)’ certificate which is to be renewed every 3 years.

The Deputy Safeguarding Lead is the person who will have the role of the Designated Safeguarding Lead when they are not contactable or available. The Deputy Safeguarding Lead possesses a ‘Designated Safeguarding Lead (Level 3)’ certificate which is to be renewed every 3 years.

Creative Mentor Network’s Designated Safeguarding Lead & Deputy are:

Samuel Conley, Designated Safeguarding Lead (DSL)

e-mail: samuel@creativementornetwork.org

Mobile: 07855 359 140

Natasha Khan, Deputy Safeguarding Lead

e-mail: natasha@creativementornetwork.org

Mobile: 07748 720 226

In the absence of the Designated Safeguarding Lead (DSL) or Deputy Designated Safeguarding Lead (or where safeguarding concerns relate to actions by the DSL or Deputy DSL), Trustees can be contacted in regards to a safeguarding incident:

Russ Lidstone, Trustee & Chair

e-mail: safeguarding@creativementornetwork.org

Ryan Johnson, Safeguarding Trustee

e-mail: msgryan@icloud.com

All staff and volunteers have a responsibility to safeguard the welfare of children and young adults with whom they work and to respond to any concerns about safeguarding. All staff and volunteers should study this policy and ensure that they are clear about what they should do if they have any concerns about disclosure of abuse from a child/young adult. See Appendix 1.

4. Relevant Legislation

Creative Mentor Network is committed to the definition ‘safeguarding and promoting the welfare of children and young adults’. This policy is written with regard to the following documents:

Working Together to Safeguard Children (2019)

What to Do If You’re Worried a Child Is Being Abused (2006)

The Children Acts (1989 and 2004)

Care Act (2014)

Counter Terrorism and Security Act (2015)

The Prevent Strategy (2015)

London Multi Agency Adult Safeguarding Policies and Practice (2019)

Keeping Children Safe In Education (2022)

Our policy recognises that the welfare and interests of children and young adults are paramount in all circumstances.

As part of our Safeguarding policy Creative Mentor Network will:

• Promote and prioritise the safety and wellbeing of children and young adults .

• Ensure all adults working with children understand their roles and responsibilities in respect of safeguarding and is provided with appropriate learning opportunities to recognise, identify and respond to signs of abuse, neglect and other safeguarding concerns relating to children and young adults.

• Ensure appropriate action is taken in the event of incidents/concerns of abuse and support is provided to the individual/s who raise or disclose the concern.

• Ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored.

• Prevent the employment of unsuitable staff and volunteers using safer recruitment practices.

• Ensure robust safeguarding arrangements and procedures are used effectively.

5. Procedures

To ensure appropriate recruitment we shall ensure that all safer recruitment procedures are undertaken including appropriate pre-employment, selection, vetting and identity checks.

All adults involved in Creative Mentor Network, who have access to children must be subjected to appropriate vetting DBS checks in respect of their suitability to work with children. Before starting work with children, either in a voluntary or non-voluntary position, a DBS must be in place. Staff and volunteers working with children will receive an Enhanced DBS check.

We have a three-year renewal policy on DBS checks for all staff, volunteers and trustees.

All new members of staff and volunteers are provided with a copy of this policy, the Code of Conduct (contained within Creative Mentor Network’s Mentor Training Booklet) and the Charity Commission Guidance on Safeguarding of Children, linked here.

All new staff and volunteers will have a meeting with the Safeguarding Lead to discuss the Code of Conduct and Creative Mentor Network's procedures for child safeguarding and child protection. All staff and volunteers will be asked to acknowledge their understanding of their obligations in relation to safeguarding by signing a declaration

Staff and volunteers should conduct themselves with children and young adults mindful of this policy.

As a general rule, staff and volunteers should avoid situations where they are on their own with a mentee and, in such situations, plan ahead and signal the arrangement with another member of staff. Avoid last-minute or informal arrangements for one-to-one meetings. Staff and mentors working with children should not give lifts in cars to children, particularly one-to-one, other than in an emergency, where another member of staff, preferably the Safeguarding Lead, should be informed.

In order that staff and volunteers do not place themselves or children at risk of harm or of allegations of harm, staff and volunteers should seek immediate advice from the Safeguarding Lead or Deputy Safeguarding Lead if a child's interaction with you seems inappropriate, out of the ordinary.

Though Trustees are not directly mentioned in the above bullet points (as they are unlikely to interact with children or young adults taking part in Creative Mentor Networks programming), they are nevertheless required to follow the procedures as and when necessary.

These policies and procedures will be widely promoted. Failure to comply with the policy and procedures will be addressed without delay and may ultimately result in disciplinary action, and dismissal/exclusion from the organisation.

6. Entitlement

Creative Mentor Network acknowledges that some children and young adults, including those who are disabled and those from ethnic minority communities, can be particularly vulnerable to abuse and we accept the responsibility to take all reasonable and appropriate steps to ensure their welfare. The Creative Mentor Network policy aims to ensure that regardless of age, gender, race, ethnicity, religion or beliefs, sexual orientation and socio-economic background, all persons are protected appropriately. If there are any concerns contact the Safeguarding Lead immediately.

Adults working with children as part of Creative Mentor Network have a duty to:

• Understand, adopt, adhere to and implement the Safeguarding Children and Young Adults Policy

• Respect and promote the rights, wishes and feelings of all children and young adults

• Safeguard and promote the welfare of all children and young adults

• Conduct themselves in accordance with the Creative Mentor Network Code of Conduct

• Have a positive and enjoyable experience in a safe environment

• Are protected from abuse whilst participating in dealings with Creative Mentor Network

8. Policy and Monitoring Procedures

CMN’s safeguarding policy is reviewed every term and discussed in quarterly trustee board meetings. Trustees are informed of any important incidents or changes to the safeguarding procedures for CMN.

The Designated Safeguarding Lead and Safeguarding Trustee will review the safeguarding policy annually to make sure it complies with UK government guidelines and that of other safeguarding agencies. Once confirmed as accurate, the updated policy will be presented to the board of trustees, and discussed as an agenda item.

The next date for this policy to be reviewed annually is Wednesday 17th April, 2024.

Additionally, the Designated Safeguarding Lead and Safeguarding Trustee will meet monthly to discuss updates and significant incidents and make any necessary changes to CMN's process.

9. Roles and responsibilities

Creative Mentor Network meets its child and young adult protection responsibilities by ensuring that adults working with children are briefed on Safeguarding policies and best practices.

All Creative Mentor Network staff and volunteers are given ample time to read and consider the Safeguarding Children and Young Adults Policy. Deviation from the guidelines or failure to enforce the Safeguarding Children and Young Adults Policy may result in immediate dismissal/exclusion from the organisation

If an issue arises or you have a concern it is important to escalate the matter to a senior member of staff. In some cases, you may feel the need to report issues/concerns directly to the Safeguarding Lead. Concerns shared will be treated with the strictest of confidence and investigated fully. Please see Appendix 1.

10. Code of Conduct

It is important that adults working with children and young adults understand that the nature of their work and the responsibilities related to it, place them in a position of trust. At Creative Mentor Network, we aim to create a safe culture by ensuring adults working with children and young adults follow a Code of Conduct. This Code of Conduct endeavours to:

Assist staff working with children, and young adults to work safely and responsibly and to monitor their own standards and practice

Set clear expectations of behaviour and codes of practice relevant to the age group.

In your role at Creative Mentor Network, you are acting in a position of authority and have a duty of care towards the children and young adults we work with. You are likely to be seen as a role model and are expected to act appropriately. Please see Appendix 2 for the ‘Mentor Code of Conduct"‘ that is included in the mentor handbook.

You are responsible for:

• Prioritising the welfare of children and young adults

• Providing a safe environment for children and young adults

• Having a good awareness of issues to do with safeguarding and taking action when appropriate

• Following our principles, policies and procedures including safeguarding, whistleblowing and online safety

• Staying within the law at all times

• Modelling good behaviour for children and young adults to follow

• Challenging all unacceptable behaviour and reporting any breaches of the behaviour code to the Safeguarding Lead

• Reporting all concerns about abusive behaviour following our safeguarding procedures. This includes behaviour being displayed by an adult/child and directed at anybody of any age. See Appendix 1.

Rights

You should treat children and young adults fairly and without discrimination or prejudice

Understand that children and young adults are individuals with individual needs

Respect differences in gender, sexual orientation, culture, race, ethnicity, disability and religious belief systems and appreciate that all participants bring something different and valuable to the organisation

Challenge discrimination and prejudice

Encourage young adults to speak about attitudes or behaviour that makes them feel uncomfortable

Relationships

Promote relationships that are based on openness, honesty, trust and respect

Be patient with others

Exercise caution when you discuss sensitive issues

Ensure your contact with children and young adults is appropriate and relevant to the project

Ensure that whenever possible there is more than one adult present during activities. If a situation arises where you are alone with a child or young person ensure that you are within sight or hearing of other adults

Only provide personal care in an emergency and make sure there is more than one adult present

Respect

Value and take children and young adult’s contributions seriously actively involving them in planning activities whenever possible

Respect children and young adult’s right to personal privacy as far as possible. If you need to break confidentiality in order to follow safeguarding procedures it is important to explain this at the earliest opportunity

Unacceptable behaviour

When working with children and young adults you must not:

Allow concerns or allegations to go unreported

Take unnecessary risks

Smoke, consume alcohol or use illegal substances

Develop inappropriate relationships with children and young adults

Make inappropriate promises to children and young adults

Engage in behaviour that is in any way abusive including having any form of sexual contact

Let children and young adults have your personal contact details (mobile number, personal email or home address or have contact with them through a personal social media account

Act in a way that can be perceived as threatening or abusive

Make sarcastic, insensitive, derogatory or sexually suggestive comments/gestures

11. Power and Positions of Trust

As a result of their knowledge, position and/or the authority invested in their role, adults working with children and young adults are in positions of trust.

There is potential for exploitation and harm of children and young adults. Where a person aged 18 or over is in a specified position of trust with a child under 18, it is a criminal offence for that person to engage in sexual activity with or in the presence of that child, or to cause or incite that child to engage in or watch sexual activity.

This means that adults should not:

• Use their position to gain access to information for their own or others’ advantage

• Use their position to intimidate, bully, humiliate, threaten, coerce or undermine children and young adults

• Use their status and standing to form or promote relationships which are of a sexual nature, or which may become so.

12. Propriety and Behaviour

There may be times, for example, when a person’s behaviour or actions in their personal life come under scrutiny from the work environment, the local communities or public authorities. This could be because their behaviour is considered to compromise their position or indicate unsuitability to work with children. Misuse of drugs, alcohol or acts of violence would be examples of such behaviour.

People in contact with children should therefore understand and be aware that safe practice also involves using judgement and integrity about behaviours in places other than the work setting.

This means that adults should not:

• Smoke or drink alcohol whilst in the company of, or whilst responsible for, children or young adults

• Behave in an aggressive, violent or forceful manner which would lend any reasonable person to question your suitability to work with children and young adults or act as a role model.

13. Infatuations

Occasionally, a child or young adult may develop an infatuation with an adult. Staff and volunteers should deal with these situations sensitively and appropriately to maintain the dignity and safety of all concerned. They should remain aware, however, that such infatuations carry a high risk of words or actions being misinterpreted and should therefore make every effort to ensure that their own behaviour is above reproach. In this situation a staff member or volunteer who becomes aware that a child/young adult is developing an infatuation should discuss this at the earliest opportunity with a senior member of staff so appropriate action can be taken to avoid any hurt, distress or embarrassment. Please see appendix 1.

This means that staff and volunteers should not:

• Be in a one-to-one situation (there should always be another person nearby and no doors should be closed).

• Encourage the obsession.

• Ignore the signs of infatuation and fail to report them.

14. Sexual Contact

Staff and volunteer mentors should clearly understand the need to maintain appropriate boundaries in their contact with children and young adults. Relationships, whether emotional or sexual between children or young adults and the adults who work with them will be regarded as a grave breach of trust. Allowing or encouraging a relationship to develop in a way which might lead to a sexual relationship or intimate relationship is also unacceptable. Any sexual activity between an adult and the child or young adult with whom they work will be regarded as a criminal offence and reported accordingly. Additionally, this will always be a matter of disciplinary action.

Children are protected by specific legal provisions regardless of whether the child or young person consents or not. The sexual activity referred to does not just involve physical contact including penetrative and non-penetrative acts. It may also include non-contact activities, such as causing children to engage in or watch sexual activity or the production of pornographic material. There are occasions when a person may embark on a course of behaviour known as 'grooming' where the sole purpose is to gain the trust of a child, and manipulate that relationship so sexual abuse can take place. Adults should be aware that consistently conferring inappropriate special attention and favour upon a child/young adult might be construed as being part of a 'grooming' process and as such will give rise to concerns about their behaviour and, in relation to staff and volunteer mentors, could result in disciplinary action.

This means that staff and volunteer mentors should not:

• Have emotional or sexual relations with any child or young adult mentee on the programme.

• Have any communication which could be interpreted as sexually suggestive or provocative – either verbal, letter, notes, email, text, calls or physical contact

• Talk about your own sexual relationships

• Make sexual remarks about children or young adults

Relationships should be professional, healthy and respectful at all times. Your language, demeanour attitudes and conduct all require careful thought when dealing with children and vulnerable adults.

15. Dress and Appearance

Staff and volunteer mentors should dress in ways which are appropriate to their role and this may need to be different to how they dress when not at work.

Staff and volunteer mentors should wear clothing appropriate to the role:

• Not viewed as offensive, revealing or sexually provocative

• Does not distract, cause embarrassment or give rise to misunderstanding

• Is absent of any political or otherwise contentious slogan

• Is not considered discriminatory and is culturally sensitive

16. Behaviour Management

All children and young adults have a right to be treated with respect and dignity even in those circumstances where they display difficult or challenging behaviour.

Staff and volunteer mentors should:

• Not use any form of degrading treatment to punish a child or vulnerable adult

• Not use sarcasm, demeaning or insensitive comments towards children or vulnerable adults. It is not acceptable in any situation.

• Never use corporal punishment.

17. Physical Contact

There are occasions when it is appropriate and proper for staff and volunteer mentors to have physical contact with children or young adults, but it is crucial that they only do so in ways appropriate to their professional role. The general culture of 'limited touch' should be adopted and staff should use their professional judgement at all times.

Physical contact should take place only when it is necessary in relation to a particular situation. Some of these situations are:

• During certain activities such as drama, sports and outdoor activities

• When a child or young adult is in severe distress

• For restraint and physical intervention

Medical and First Aid

This means that staff and volunteer mentors should never:

• Use physical force as a means of punishment and discipline

• Never touch a child or young adult in a way which may be considered indecent

• Indulge in ‘horse-play’.

• The use of unwarranted physical force is likely to constitute a criminal offence.

18. Communication

Communication with children and young adults by whatever method, should take place within clear and explicit professional boundaries. This includes the wider use of technology such as mobile phones, text messaging, e-mails, cameras, and websites. A person should ensure that all communications are transparent and open to scrutiny.

Staff and volunteer mentors should not share any inappropriate or unnecessary personal information with a child or young adult. and all contact should be made only for professional reasons.

This means that staff and volunteer mentors;

• Must use their work email.

• Must use their work phone and mobiles if working with children.

• Ensure that mobile numbers of children are not stored on a personal mobile and children should not have access to staff/mentors personal mobile numbers

• Inform the DSL if contacted by a child on a personal number

• When working with young adults, if there is no access to a work phone or mobile, a personal number can be used.

• Recognise that texting is not a professional means of communication and should not occur between a child and avoided with young adults.

• Never use Whatsapp to communicate with a child.

• Discourage the use of Whatsapp with a young adult, however it is essential to a particular line of work the CMN work phone must be added to the conversation: +447746333402

• Not use internet or web-based communication channels to send personal messages to a child or young adult

• Not use a social network site to complain or criticize children or young adults

• Report any unwanted contact/emails/messages from children to the Designated Safeguarding Lead.

18.1 Online Communication

With the shift to online, we recognise that face-to-face communication will be greatly replaced by online communication. It is imperative that clear boundaries are established so that staff, mentors, children and young adults foster safe professional relationships.

This means that staff and volunteer mentors;

• Set clear boundaries as to when communication can be made within appropriate work hours

• Conduct all video calls in an appropriate setting without distracting backgrounds or noise

• Dress appropriately for video calls

• Ensure permission is granted before sharing any contact details or personal information of anyone in your network with children or young adults

• Be present in all video introductions of members from your network to children

• Be copied into email communication with members of your network to children

18.2 Social Media

Social media is vital to the success of mentoring (particularly now that much working practice takes place work online rather than face to face) but with it are inherent risks. As such certain precautions must be taken.

This means that staff and volunteer mentors:

• Should never connect with a child or young adult on personal social media accounts such as Instagram, Snapchat, TikTok.

• Can connect with children and young adults on professional sites such as Linkedin and The Dots

• Can allow a young adult to follow a merged personal and professional social media account but they must ensure that no inappropriate content is posted

• For safeguarding purposes there must be an audit trail of any and all communications with a child or young adult so that staff or volunteers are protected against any possible allegations.

19. Child and young adult protection guidance

19.1 How to respond to concerns

If you have concerns about a child or young adult’s safety or well-being, discuss your concerns with the Safeguarding Lead who will have the appropriate training and expertise to support you and advise on the next stage. You should act swiftly. There should not be any time delay (see Appendix 1). If you cannot contact this person and you believe that a child or young adult may be in imminent danger of abuse you should contact the Police immediately.

19.2 How to respond to a disclosure

A concern may come to light as a response or something a child or young person says to you. Often, this disclosure can be made during casual conversation. If a disclosure is made to you:

Listen to the information and accept what you hear without passing judgement or dismissing what you hear. Do not dismiss or trivialise what the child or young adult has told you. Stay calm. Be aware of your own reactions. Do not transmit shock, anger or embarrassment

Never enter into a pact of secrecy with the child or young person. Assure them you will try and help but this may involve telling a more senior trained member of staff. Do not promise confidentiality but that the information will be treated with great care but reiterate you may need to share the information with a trained safeguarding person

Reassure and praise them. Tell them you believe them and it is not their fault. Children and young adults rarely lie about abuse but they may have tried to tell others and not been heard or believed

Encourage the child or young person to talk without leading questions. Do not put words into their mouth or make judgemental statements about any person. Keep your own responses short and simple and do not offer new information. Do not interrogate them. Check you have understood what they are telling you. Do not comment on the offender – it may be someone they love

Be aware the child or young person may retract what they have told you, but it is essential to report what you have heard

As soon as possible afterwards (if possible during the conversation) make a detailed record of the conversation, including questions you asked. Do not add your opinion

Immediately after the meeting you should contact the Safeguarding Lead and report the outcome of the meeting, producing the written record of the conversation

Take into account the child or young adult's age, their level of understanding, their culture and level of language

Confidentiality: you must never discuss issues with colleagues, family or friends. The information you have received must remain between yourself and the Safeguarding Lead or Deputy Safeguarding Lead

Any information divulged must be on a need to know basis.

Parents / Guardians of a child will always be informed of allegations of abuse made by a child unless this puts the child or the subsequent investigation at risk (e.g. if they are the subject of the allegation).

19.3 How to record a disclosure and Record-Keeping

Recording a disclosure is an essential part of the safeguarding process. If possible a disclosure should be recorded during the time of the disclosure, or directly afterwards. If this is not possible it should be done as soon as possible after (within 24 hours) by contacting the Designated Safeguarding Lead. This can be done directly via email, or by using the contact form at the top of this page. See Appendix 1 for details.

Why do I need to record a disclosure?

Clarifies the nature and extent of concerns

Provides a clear record of the development of concerns

Identifies patterns of behaviour

Assists any subsequent referrals

Ensures consistency

What needs to be recorded?

Signs and indicators

Disclosures

Relevant contact with parents / guardians

How do I make my record accurate?

Factually - day, date, time place

Give background information

Record words verbatim

Keep any initial notes

Record action taken and the reasons

Secure provision is made for all records produced during any welfare discussions or disclosures. These records are then transferred to Creative Mentor Network server where they are stored for three years in a secure digital safeguarding file. There are copies of all documents and information which may have been sent to any authority regarding any safeguarding issue.

20. Recognising symptoms of abuse/ safeguarding issue

Although a child or young adult may make a disclosure of abuse to you, it is entirely possible that you will become concerned about the welfare of a child or young adult because of their behaviour or because you notice physical symptoms of abuse.

The four areas of abuse are physical, emotional, neglect and sexual (PENS).

There are no absolute criteria on which to rely when judging what constitutes significant harm. Consideration of the severity of ill-treatment may include the degree and extent the duration and frequency of all the four abuses.

20.1 What is abuse and neglect?

These are forms of maltreatment – a person may abuse or neglect a child by inflicting harm, or failing to act to prevent harm. Children and young adults may be abused by a family member or in an institution or residential or community setting; by those known to them or, more rarely, by a stranger.

21. Handling allegations of abuse against staff

If an allegation is made against a member of Creative Mentor Network staff or volunteer mentor, the quick resolution of that allegation is our priority to the benefit of all concerned. At any stage of consideration or investigation, all unnecessary delays should be avoided.

Any allegation of abuse by a member of staff or volunteer mentor should be reported to the Safeguarding Lead or Deputy Safeguarding Lead straight away. In the absence of the Designated Safeguarding Lead (DSL) or Deputy Designated Safeguarding Lead (or where safeguarding concerns relating to actions by the DSL or Deputy DSL), Trustees should be contacted in regards to a safeguarding incident.

The Safeguarding Lead or Deputy Safeguarding Lead will then immediately launch a full investigation and decide on strategy going forward. The Safeguarding Lead or Deputy Safeguarding Lead will inform the accused person about the allegations as soon as possible after completion of investigation.

In response to an allegation, staff or volunteer mentor suspension will be the default option whilst a full investigation is undertaken. If the suspension is deemed appropriate, the reasons and justification should be recorded by the Creative Mentor Network and the individual notified of the reasons.

CMN will investigate allegations of misconduct in good faith, with the assumption that allegations are made in good faith. Allegations made in good faith that cannot be substantiated will nevertheless remain in CMN records as per this policy. Allegations that are found not to have been raised in good faith and are not substantiated, will be removed from personnel records and should not be referred to in employer references.

22. Other safeguarding issues

Safeguarding covers a range of issues. We should do everything possible to ensure that children feel safe at all times.

22.1 Child Sexual Exploitation (CSE)

CSE involves exploitative situations, contexts and relationships where young adults receive something (for example food, accommodation, drugs, alcohol, gifts, money or in some cases simply affection) as a result of engaging in sexual activities. Sexual exploitation can take many forms ranging from the seemingly ‘consensual’ relationship where sex is exchanged for affection or gifts, to serious organised crime by gangs and groups. What marks out exploitation is an imbalance of power in the relationship. The perpetrator always holds some kind of power over the victim which increases as the exploitative relationship develops. Sexual exploitation involves varying degrees of coercion, intimidation or enticement, including unwanted pressure from peers to have sex, sexual bullying including cyberbullying and grooming. However, it is also important to recognise that some young adults who are being sexually exploited do not exhibit any external signs of this abuse.

If you suspect a child is at risk of CSE or that this has already taken place this should be reported to the Safeguarding Lead.

22.2 Female Genital Mutilation. FGM

The UK Government Advice and guidance on FGM states “that FGM is considered child abuse in the UK and a grave violation of the human rights of girls and women.” FGM is a form of abuse that may might effect your mentee. FGM is included in the training of staff and volunteers.

22.3 Prevent

The Creative Mentoring Network is aware that all organisations working with young adults as outlined in the Government’s Prevent Policy have a duty to understand the implications for young adults. Prevent is included in the staff and mentor programme training programme.

22.4 Staff Training

All core CMN staff complete a safeguarding training certificate appropriate to their level of contact with children and young adults. Training will be renewed every three years.

Those on the core team that have regular and direct contact with children and young people and hold a safeguarding role will complete the following:

Introduction to safeguarding children (Level 1)

Advanced safeguarding children (Level 2)

Designated safeguarding lead training (Level 3) certificate.

All other members of the core team will complete the following:

Introduction to safeguarding children (Level 1)

23.1 Complaints Procedure

Any complaints about this policy or procedures should be addressed in writing to the Designated Safeguarding Lead with a copy to the Chair of the Trustees Board of Creative Mentoring Network.

These can be submitted to the below email addresses:

samuel@creativementornetwork.org [Designated Safeguarding Lead - Samuel Conley]

msgryan@icloud.com [Safeguarding Trustee - Ryan Johnson]

3.2 Whistleblowing Policy

Creative Mentor Network is committed to the highest possible standards of openness and accountability. We expect employees and external partners who have any serious concerns about any aspect of the organisation to report their concerns. This applies to all employees and volunteers, external contractors and those providing service to the organisation on a temporary or permanent basis.

The following concerns may be reported:

Conduct which is a breach of the law

Health and Safety risks to the public and employees

Possible fraud and corruption

Sexual or physical abuse of clients

Damage to the environment

Other unethical conduct

Safeguarding concerns

The organisation recognises that the decision to report a concern may be difficult but you will be doing your duty to your employer and for those you provide a service. Creative Mentor Network will not tolerate any harassment or victimisation and will take appropriate action to protect you when you raise a concern in good faith.

24. Local Safeguarding Contacts

Islington Safeguarding Children’s Partnership: Referrals can be made by emailing lado@islington.gov.uk or telephoning 020 7527 8102 to discuss concerns,

Contact the NSPCC helpline: If you're worried about a child, even if you're unsure, contact their professional counsellors for help, advice and support. Call on 0808 800 5000 or email help@nspcc.org.uk.

Childline: You can talk to them about anything. No problem is too big or too small. Call them on 0800 1111 or chat to them online.

APPENDIX

SAFEGUARDING DISCLOSURE AND COMPLAINTS POLICY

CREATIVE MENTOR NETWORK MENTOR CODE OF CONDUCT

As a mentor, it is important that you are aware of the issues surrounding safeguarding. CMN has a duty of care to help protect you and the young adults you will be working with. The following is CMN’s Code of Conduct. Please make sure you read it thoroughly.

A mentor should

• Do what you can to ensure that your mentee is safe.

• Treat everyone equally with the same fairness and respect you would expect to be treated with.

• Respect the participant's background, culture and traditions and be aware certain behaviour may offend his/her beliefs.

• Discourage negative or abusive attitudes or behaviour (e.g. ridicule, racism, swearing, exclusion, bullying).

• Inform young people if their behaviour is inappropriate and escalate this to the programme manager if the behaviour continues

• Be aware that you are a role model for the young people you are working with.

• You should only meet in your designated professional base or an agreed public location (no private residences).

• Always work in open spaces or with the office door open and ensure another member of staff is present nearby

• Avoid unnecessary physical contact with young people.

• The mentor should only contact the mentee with the office/work number. In the absence of a work number, use a personal number but inform Creative Mentor Network you are doing this.

Using Whatsapp with a mentee is discouraged, however if it is essential to your line of work then the CMN mobile should be added to your Whatsapp conversation; 07746 333402

Feel free to connect with your mentee professionally online (LinkedIn etc.), but do not connect on personal accounts (e.g. personal Instagram or Twitter accounts).

Never meet or make contact with a young person outside the designated hours and location of the session.

If there is ever an issue, raise it with the Designated Safeguarding Lead (samuel@creativementornetwork.org) immediately.

CREATIVE MENTOR NETWORK BUSINESS PARTNERSHIP AGREEMENT 30.01.20

This Business Partnership Agreement (Agreement) governs a Partner’s receipt of the Services and participation on the Programme. Capitalised terms have the definitions set forth herein. A Partner shall be bound by these terms by accepting this Agreement by either (i) signing the Proposal Form; or (ii) receiving Services from CMN in line with the terms set out in a Proposal Form.

1.Definitions and interpretation

1.1 In this Agreement:

Fees

means the fees payable by the Partner to participate in the Programme as set out in the Proposal Form.

Initial Term

means the initial term for the Services as set out in the Proposal Form.

Mentee

means a young person selected by CMN to participate in the Programme.

Mentor

an employee or member of the Partner nominated by the Partner to participate in the Programme.

Mentoring Session

means a meeting between a Mentor and a Mentee.

Mentoring Workshops

means the Mentor training workshops which form part of the Programme.

Programme

means the training and/or mentoring programme set out in the Proposal Form.

Proposal Form

means the proposal form specifying the Services to be provided by CMN hereunder, the fees for such Services and any other relevant terms of the engagement.

Safeguarding Policy

means the Creative Mentor Network safeguarding policy located at https://www.creativementornetwork.org/safeguarding (as updated from time to time).

Schemes

means the Spring (February to June) and Summer (July to October) cohorts of the Programme each year, or such other tailored or bespoke course intakes agreed by the parties in the Proposal.

Services

means the services to be provided by CMN to the Partner as set out in the Proposal Form.

1.2 In this Agreement: (i) a reference to this Agreement includes its schedules, appendices and annexes (if any); (ii) a reference to a ‘party’ includes that party’s personal representatives, successors and permitted assigns; (iii) a reference to a ‘person’ includes a natural person, corporate or unincorporated body (in each case whether or not having separate legal personality) and that person’s personal representatives, successors and permitted assigns; (iv) a reference to a gender includes each other gender; (v) words in the singular include the plural and vice versa; (vi) any words that follow 'include', 'includes', 'including', ‘in particular’ or any similar words and expressions shall be construed as illustrative only and shall not limit the sense of any word, phrase, term, definition or description preceding those words; (vii) any clause, schedule or other headings in this Agreement are included for convenience only and shall have no effect on the interpretation of this Agreement; and (viii) a reference to legislation is a reference to that legislation as amended, extended, re-enacted or consolidated from time to time.

2. Term

This Agreement shall commence on the Effective Date and shall continue for the Initial Term.

3. Programme

CMN shall provide the Services and deliver the Programme materially in accordance with the Proposal. CMN shall use reasonable endeavours to deliver the Services in accordance with any timelines and dates set out in the Proposal and Partner acknowledges that the sequencing and timing of any such deliverables may be subject to change from time to time upon reasonable notice from CMN.

4. Mentors

The Partner shall nominate the Mentors for each Scheme and shall notify CMN in writing of the selected Mentors at least 8 weeks prior to the start of the relevant Scheme. The Partner shall nominate Mentors of suitable character who are available to commit for the duration of the Scheme.

The Partner shall give appropriate notice to, and obtain consent from, the Mentors to provide their personal data to CMN pursuant to this Agreement.

The Partner shall ensure that the Mentors shall at all times comply with this Agreement and any policies and procedures supplied to the Partner from time to time during the Programme.

The Partner shall use all reasonable endeavours to procure that the Mentors shall attend all Mentoring Workshops and Mentoring Sessions.

If in CMN’s reasonable opinion at any time: (i) a Mentor engages in any improper or illegal behaviour; or (ii) it believes that the acts or omissions of a Mentor have or could put the wellbeing, health or safety of a Mentee at risk, CMN shall have the right to:

• remove the Mentor from the Programme; and/or

• terminate this Agreement for material breach with immediate effect

The Partner shall use all reasonable endeavours to ensure that each Mentor organises and attends the Mentoring Sessions with their Mentee.

The Partner shall indemnify and hold harmless CMN from and against all actions, liabilities, losses and costs which CMN may suffer or incur or which may be brought against CMN arising, directly or indirectly out of the acts or omissions of the Mentors and/or an employee of the Partner, including, without limitation, any acts or omissions that pose a safeguarding risk to a Mentee.

5. Fees

The Partner will pay the Fees which shall be invoiced and payable in advance and the Partner shall pay the invoice in full within 30 days of the date of the invoice.

6. Safeguarding

The Partner shall, and shall procure that each Mentor shall at all times comply with the Safeguarding Policy.

The Partner shall not, and shall ensure that the Mentors shall not, use the personal data of a Mentee for any reason other than to arrange the Mentoring Sessions and shall not share such data with a third party without the Mentee’s explicit and informed consent.

The Partner shall procure that all Mentoring Sessions shall take place at one of the offices of the Partner, save that a Mentor can meet a Mentee at another location if relevant and appropriate to the project or work. The Partner shall be responsible for providing a safe environment for the Mentees attending the Mentoring Sessions.

7. Promotional Material

The Partner consents to CMN using its logo or other branding on CMN’s website and marketing materials, and to be identified as a "Business Partner of CMN" (or similar).

The Partner shall: (i) consult and comply with CMN’s press briefing pack available at [https://www.creativementornetwork.org/press] in respect of any press release or other external marketing materials which directly or indirectly reference the participation of the Partner and/or its Mentors in the Programme (External Marketing Materials); (ii) reference CMN explicitly by name in any External Marketing Material; and (iii) use the CMN name and logo on any internal communications about the Programme.

8. Intellectual Property and Restrictive Covenant

All intellectual property in the Programme and the Services (including the training content and materials) is exclusively the property of CMN and or its partners and nothing in this Agreement shall be construed as licensing any such intellectual property to the Partner or the Mentors other than as necessary to participate in, and complete, the Programme in accordance with this Agreement.

In order to protect the CMN intellectual property and its business, the Partner agrees that it shall not, for the term of this Agreement and for 6 months thereafter, offer to employ or engage or otherwise endeavour to entice away from CMN any of its employees or consultants involved in the delivery of the Services or which the Partner otherwise engaged with during the course of the Programme.

9. Termination

If a party is in material breach of this Agreement and such material breach is not remedied (if capable of remedy) within 14 days of notice of breach being given, then the non-defaulting party may terminate this Agreement with immediate effect by notice in writing to the defaulting party.

10. Liability

CMN shall have no liability to the Partner for any damage to property (business or personal) caused by a Mentee during a Mentoring Session or any other visit by a Mentee to a place of business of the Partner in connection with the Programme.

CMN assumes no responsibility for any meetings between the Mentor and Mentee outside of the formal Mentoring Sessions and shall not be responsible for the acts or omissions of a Mentee during the Programme.

CMN and its officers, employees and agents shall have no liability to the Partner in respect of any actual or expected loss of profits, loss of revenue, loss of goodwill, loss of opportunity, or loss of business, increased costs or expenses, or special, indirect or consequential loss of any type. For the avoidance of doubt, the foregoing heads of loss include both direct and indirect loss.

The aggregate liability of CMN, its officers, employees and agents to the Partner arising out of any act, omission, event or circumstance or series of acts, omissions, events or circumstances relating to this Agreement or with respect to the matters contemplated herein shall in no circumstances exceed the Fees.

11. Force majeure

Neither party shall be in breach of this Agreement nor liable for delay in performing, or failure to perform, any of its obligations under this Agreement if such delay or failure result from events, circumstances or causes beyond its reasonable control. In such circumstances the affected party shall be entitled to a reasonable extension of the time for performing such obligations. If the period of delay or non-performance continues for 4 weeks, the party not affected may terminate this Agreement by giving five (5) days' written notice to the affected party.

12. Notices

Any notices required to be given under this Agreement may be given by email to the email address set out in the Proposal Form (or to any alternate email address notified to the other party) or by post to the other party’s registered office.

13. Contracts (Rights of Third Parties) Act 1999

With the exception of the right of CMN's officers, employees and agents to enforce the terms of this Agreement, no term of this Agreement is enforceable under the Contract (Rights of Third Parties) Act 1999 by a person who is not a party to the Agreement.

14. No partnership or agency

Nothing in this Agreement or in any document referred to in it or any arrangement contemplated by it shall constitute any of the parties a partner or agent of any other, nor shall the execution, completion and implementation of this Agreement confer on any party any power to bind or impose any obligations to any third parties on any other party or to pledge the credit of any other party.

Each party confirms it is acting on its own behalf and not for the benefit of any other person.

15. Assignment and variation

Neither party may assign (whether absolutely or by way of security and whether in whole or in part), transfer, mortgage, charge, declare itself a trustee for a third party of or otherwise dispose in any manner whatsoever of the benefit of this Agreement or sub-contract or delegate its performance under this Agreement without the prior written consent of the other, except that CMN may sub-contract the delivery of some or all of the Programme without the Partner’s consent.

No variation of this Agreement shall be effective unless it is agreed in writing (email shall suffice). The expression "variation" includes any variation, supplement, deletion or replacement, however effected.

16. Entire agreement and counterparts

If any provision or part of this Agreement is void or unenforceable due to any applicable law, it shall be deemed to be deleted and the remaining provisions of this Agreement shall continue in full force and effect. If any invalid, unenforceable or illegal provision of this Agreement would be valid, enforceable and legal if some part of it were deleted, the provision shall apply with the minimum deletion necessary to make it valid, legal and enforceable.

Each of the parties to this Agreement confirms that this Agreement represents the entire understanding, and constitutes the whole agreement, in relation to its subject matter and supersedes any previous agreement between the parties with respect thereto and, without prejudice to the generality of the foregoing, excludes any warranty, condition or other undertaking implied at law or by custom, usage or course of dealing.

This Agreement may be executed in any number of counterparts and by the parties to it on separate counterparts, each of which when so executed and delivered shall be an original, but all the counterparts shall together constitute one and the same instrument.

17. Governing law and jurisdiction

This Agreement and any dispute or claim arising out of or in connection with it or its subject matter, existence, negotiation, validity, termination or enforceability (including non-contractual disputes or claims) shall be governed by and construed in accordance with English law.

Each party irrevocably agrees that the Courts of England shall have exclusive jurisdiction in relation to any dispute or claim arising out of or in connection with this Agreement or its subject matter, existence, negotiation, validity, termination or enforceability (including non-contractual disputes or claims).

Creative Mentor Network Discrimination, Bullying and Harassment Policy

The Company is committed to ensuring that dignity at work and mutual respect are enshrined in all working practices. We are an equal opportunity employer and do not unlawfully discriminate against employees or job applicants on the basis of race, religion or belief, sex, sexual orientation, national origin, disability, pregnancy or any similar status or condition.

As a company, we do not tolerate discrimination, harassment or bullying and behaviour of this kind is expressly prohibited. Harassment, discrimination and bullying are regarded as unacceptable conduct, which can have long term effects on the morale and well- being of employees. Discrimination, bullying and harassment are regarded as gross misconduct, for which dismissal without notice may be appropriate. The Company is committed to ensuring that the workplace is free from discrimination, harassment and bullying and encourages anyone who thinks they have experienced such behaviour to report incidents for investigation and action. Equally, all employees are expected to be aware of the terms of this policy and to take individual responsibility for ensuring our working environment is free from discrimination, harassment and bullying.

Harassment on grounds of sex, race, religion or belief, sexual orientation, age, disability and gender reassignment (the "Relevant Protected Characteristics") is unlawful discrimination under UK law. If you harass colleagues, you could be personally liable and may have to pay compensation on top of any compensation we might be ordered to pay. In serious cases, harassment may be a criminal offence for which the harasser can be imprisoned. Bullying can also be unlawful, particularly when it leaves the victim with no choice but to resign.

Some behaviour may be both harassment and bullying and the distinctions are not always easy to draw. Whether or not the behaviour is sufficiently serious to be unlawful, we will not tolerate harassment or bullying of any kind. We regard such behaviour as gross misconduct and it is likely to result in dismissal.

This policy covers harassment or bullying which occurs both in and out of the workplace, such as on business trips or at events or work-related social functions. It covers bullying and harassment by staff and also by third parties such as customers, suppliers or visitors to our premises.

1. What is harassment?

Harassment is unwanted conduct based on the Relevant Protected Characteristics, which has the purpose or effect of:

• violating an individual’s dignity

• creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual

In some cases, the conduct might have the effect of violating an individual’s dignity or making an intimidating environment for them, even though that was not the purpose. Such conduct can still count as harassment, unless it is not reasonable, in all the circumstances for the conduct to be recognised as having that effect. Examples of different types of harassment are set out at the end of this policy. Some types of conduct (such as assault) will obviously count as harassment. Other behaviour (like compliments about someone’s appearance and some sorts of teasing or banter amongst colleagues) will not normally be unacceptable to most people but might become harassment if continued once it is made clear that an individual regards it as unwelcome or offensive. Behaviour which falls somewhere in the middle of these examples will have to be judged against the test set out above. However, it is important to remember that how the conduct in question is regarded by the recipient is just as (if not more) important than the motive of the alleged harasser. The fact that the harasser might only have been “joking”, “having a laugh” or “merely being friendly” and meant no offence may provide an explanation but is not necessarily an excuse. It is important to realise that harassment can occur without being targeted at a particular individual. You may not realise that someone is a member of a protected group (for example, you may be “joking” about religion or sexual orientation without knowing the religion or sexual orientation of those present) and you should also bear in mind that people who do not belong to that protected group might nevertheless be offended.

2. What is bullying?

Bullying means intimidating, threatening or humiliating treatment of an individual (usually someone at the same or more junior level). It might include:

• aggressive/excessive unjustified criticism of performance

• whispering or gossiping campaigns

• “picking on” or ostracising a colleague

• criticising a colleague in public;

• shouting

• or repeatedly putting unreasonable pressure on subordinates, such as imposing unachievable deadlines.

Your responsibility

All mentors have a responsibility to ensure that harassment and bullying does not occur and to comply with this policy. Mentors must demonstrate respect for your mentees and mentors whilst working together and must not harass or bully anyone in any way.

CMN have additional responsibilities to ensure that this policy is implemented and, where harassment or bullying does occur, that it is dealt with appropriately.

What should you do if you think you are being harassed or bullied?

If you think that you are being harassed or bullied you may wish to try to resolve the problem in the first instance (either individually or with the support of the CMN team) by explaining to the individual concerned that his/her behaviour is unwelcome and should stop.

If you wish to try to resolve the problem in this informal way you should keep notes or a diary of any incidents of bullying/harassment and your attempts to resolve the matter. These will help us investigate if the problem is not resolved and you decide to take it further.

If you choose the informal route, you may not want us to investigate or raise the matter with the alleged bully/harasser ourselves. We will normally try to ensure that your wishes are complied with and that the matter will go no further while you are trying to handle matters informally. However, if we consider that the welfare, health or safety of others are at risk or that there are overriding reasons why we should do so, we may have to approach the alleged bully/harasser and/or conduct further investigations.

If you or we regard attempts at informal resolution as inappropriate, or where the outcome has been unsatisfactory, the formal procedure may be appropriate. To bring a formal complaint of harassment or bullying, please notify CMN. Any investigations necessary will be carried out with sensitivity and due respect for the rights of both of you (the person complaining) and the alleged harasser. The importance of confidentiality will be stressed to all those interviewed or involved.

Information about a complaint by or about a mentee/mentor may be placed on the employee’s personnel file, along with a record of the outcome and of any notes or other documents compiled during the process. These will be processed in accordance with our Data Protection Policy.

If it would not be appropriate for the alleged harasser/bully and the complainant to work together during the investigation, we will consider moving the alleged harasser/bully or suspending him/her while the investigation is ongoing.

Any complaint that is unfounded and not made in good faith, for example a malicious complaint, will be treated as a disciplinary offence. However, complainants should not be penalised for bringing a complaint in good faith. Victimisation and retaliation against such complainants will not be tolerated and will be treated as gross misconduct in the same way as harassment and bullying.

Examples of harassment

Harassment can take a number of forms. The examples of harassment listed below are intended to be illustrative and are not an exhaustive list.

Harassment based on sex is often sexual in nature but is sometimes not. Harassment based on sex might include:

• derogatory comments about gender or matters associated with gender

• ostracism on grounds of gender (whether the recipient is of the same or different gender)

• degrading comments about appearance or dress

Sexual harassment is a type of harassment based on sex which involves unwanted conduct of sexual nature and may include:

• physical conduct of a sexual nature ranging from unnecessary touching, patting, pinching or brushing against some other person’s body to sexual assault

• unwelcome sexual advances, flirtations or suggestive remarks, leering, whistling or sexually suggestive gestures

• display of pornographic or sexually suggestive pictures, objects or written materials

• repeated requests to go on a date or to socialise outside of work when this is unwanted

• invading someone else’s personal space

• pressure for sexual behaviour/favours in return for avoiding detrimental treatment; or

• detrimental treatment following the rejection of a sexual advance

Racial or religious harassment might include:

• derogatory or degrading abuse or insults and offensive comments about race or religion

• display, circulation or discussion of racist pictures, objects or written materials

• unreasonably and repeatedly dismissing or not taking seriously a person’s request for their religious practices to be accommodated

• unjustified display of emblems that have sectarian or religious significance

• “jokes” based on race or religion and abuse of a racial or religious nature

Harassment on grounds of disability might include:

• mimicry and imitation of the disabled person

• “jokes” based on disability

• offensive comments about disability or matters associated with disability

Harassment on grounds of sexual orientation might include:

• teasing or name calling about an individual’s sexual orientation (real or perceived)

  homophobic “jokes” or derogatory stereotyping based on sexual orientation

• “outing” a person (i.e. revealing their sexual orientation) against their wishes

Harassment on grounds of age might include:

• “jokes” based on age or the perceived effect of age

• derogatory stereotyping based on age

• “talking down to” and humiliating younger workers

Creative Mentor Network is the controller and responsible for your personal data (collectively referred to as the CMN, Company, "we", "us" or "our" in this privacy notice).

The purpose of this Privacy Policy is to inform you of the types of personal information which we collect from you and how we use your personal information.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 7th July 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Our policy

It is important that you read this privacy notice together with any other privacy notice, fair processing notice or privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

We collect personal information from:

Potential Clients

Clients

Course Participants

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions.

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

avail of our products or services;

create an account on our website;

subscribe to our service or publications;

request marketing to be sent to you;

enter a competition, promotion or survey; or

give us some feedback.

Automated technologies or interactions.

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources.

We may receive personal data about you from various third parties and public sources.

Technical Data from the following parties:

analytics providers;

advertising networks; and

search information providers.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

Identity and Contact Data from data brokers or aggregators.

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, products and services. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Special categories of personal data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health and genetic and biometric data. In limited circumstances, we collect special categories of personal data (mostly about your health) about you if you provide this information to us which allows us assess your dietary needs.

How we use your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

When someone visits https://www.creativementornetwork.org/ we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Potential Clients

When we receive an enquiry from you about our courses, we record your contact details including name, job title, business telephone number, email and postal address. We record this personal information in an electronic database and / or manual files in order to provide you with the information which you are seeking and also to follow up with you to enquire as to whether you have any questions or if you require any further information from us. Each time we contact you, we record a brief note on the file of the status of you enquiry.

We will make contact with you at monthly intervals unless we are asked not to make contact again. In such a case, we will record this information on our system and ensure that your wishes are respected. Occasionally, we may send you newsletters unless you request us not to send you such communications.

Clients

Once a potential client becomes a client, we will use your personal information on the client record for the purposes of managing the business relationship with you. This may also include us contacting you on a monthly basis and making a record of such contact on our systems. Occasionally, we may send you newsletters unless you request us not to send you such communications.

You can ask us to stop sending you marketing messages and/or newsletters at any time by contacting us at any time.

Where you opt out of receiving marketing messages and/or newsletters, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Course Participants

Once a course has been booked, we collect personal information on the participants(s) from the client representative making the booking or from the participants directly. This includes technical, profile, and usage data for the training course.

In some circumstances, depending on agreements made between us and our clients and / or participants, feedback (written or oral) may be provided to the participant directly and / or to the client.

Under no circumstances, unless required by law or regulatory body, will we pass your personal information to any third parties, with the exception of our contractors who need such personal information to assist us in performing our contracts with our clients. We have contractual protections in place to protect any of your personal information which we need to disclose to our contractors.

We take our obligations to protect your personal information seriously. Should you have any questions about privacy at CMN, please contact us.

Why does CMN need to collect and store personal data?

In order for us to provide you with information about our services, we need to collect personal data for correspondence purposes and/or detailed service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

In terms of being contacted for marketing purposes CMN would contact you for additional consent.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide these when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Will CMN share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to CMN in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with our procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

How will CMN use the personal data it collects about me?

CMN will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. CMN is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

In some circumstances you can ask us to delete your data and in some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under what circumstances will CMN contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that the organisation holds about me?

CMN at your request, can confirm what information we hold about you and how it is processed. If CMN does hold personal data about you, you can request the following information:

Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.

Contact details of the data protection officer, where applicable.

The purpose of the processing as well as the legal basis for processing.

If the processing is based on the legitimate interests of CMN or a third party, information about those interests.

The categories of personal data collected, stored and processed.

Recipient(s) or categories of recipients that the data is/will be disclosed to.

How long the data will be stored.

Request transfer of your personal data

Details of your rights to correct, erase, restrict or object to such processing.

Information about your right to withdraw consent at any time.

How to lodge a complaint with the supervisory authority.

Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

The source of personal data if it wasn’t collected directly from you.

Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

If you wish to exercise any of the rights set out above, please contact us.

What forms of ID will I need to provide in order to access this?

CMN will need two of the following forms of ID when information on your personal data is requested:

Passport, driving licence, birth certificate, utility bill or bank statement from the last 3 months, rent book.

This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

International transfers

Some of our third parties may be based outside the European Economic Area (EEA) so the processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 7th July 2020 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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Necessary cookies

These are essential for the website to function properly. This category only includes cookies that ensure basic functionalities and security features of the website. These do not store any personal information.

Non-essential cookies

These may not be necessary for the website to function and are used specifically to collect user personal data via analytics, ads, other embedded contents are termed as non-necessary cookies. It is mandatory to procure user consent prior to running these cookies on your website.