Our policies

Privacy policy

At Curamcare, we respect your privacy and are committed to protecting your personal information. This policy explains how we collect information, what we do with it and what controls you have over your personal information.

Please also refer to our Terms and Conditions for more information.

Your privacy

We take our duty to process your personal information very seriously.

We may change this document from time to time to reflect the latest view of what we do with your personal information. Please check back frequently; you will be able to see if changes have been made by the date it was last updated at the end of the document.

Refer to the sections below for more details on how and why we use your personal information:

Website usage

When you are browsing our website, we have cookies in place to ensure that the website works well and provide information on how you navigate the site and the pages you visit. You will be given the option to agree to these cookies when you visit the website. To view our website you are not asked to provide any personal information.

Facebook adverts (sponsored posts)

Occasionally we run Facebook adverts to promote the visibility of our services. When you click on our advert you are consenting to finding out more about us. Our Facebook Adverts use the Facebook Pixel Service of Facebook Inc. 1601 S.California Avenue, Palo Alto, CA94304. USA (Facebook). This tool allows us to find out more about the actions of users after they are redirected to our website. It also allows us to measure the efficiency of our Facebook adverts for statistical and market research purposes. Using this information allows us to improve our advertising for a better experience to our users and provide you with further advertising on Facebook and the use of Custom Audiences. You can find out more about this and withdraw your consent here: https://www.facebook.com/ads/website_custom_audiences/

When you create an account (individual)

When you create an account to provide care for yourself or someone else, we will require some information about the account holder and the cared for person. If the cared for person is under 18, then we shall need to ensure that you have parental responsibility for that child. Creating an online account facilitates the ability to search for care and send messages, schedule visits, make payments etc. To find out more about how we use your personal information in these circumstances, please see our Client Privacy policy which can be found here.

When you use or create an account (Organisation/business)

When you use or create an online account to establish care for someone else, we will require some information about the cared for person. If the cared for person is under 18, then we shall need to ensure that you have parental responsibility or parental consent to seek care for that child. Creating an online account facilitates the ability to search for care and send messages, schedule visits, make payments etc. To find out more about how we use your personal information in these circumstances, please see our client privacy policy which can be found here.

When you become a carer on Curam

When you become a carer on the Curam platform you will be provided with an online account. You should ensure that you do not share the login information for this account with anyone else. The online account facilitates your creation of a carer profile, the ability to apply for work and send and receive messages. Curamcare will also undertake Disclosure and Barring Service (DBS) checks and Protection of Vulnerable Groups (PVG) assessments as part of our assurance processes

When you contact us by ‘phone

When you contact us by ‘phone, our system will log the number you are calling from. If we get disconnected we may call you back to continue the conversation. If we are unavailable to take your call, there is the facility to leave a voicemail message and we will return your call as soon as possible, this may be the next day depending on the time you contact us.

When you contact us via email

When you make an enquiry via email, the information in the email will only be used to respond to your request or question. We try to respond to email queries as promptly as possible, but it can take the team up to 48 hours to respond to email queries especially at busy times or on a Sunday, so please be patient with us.

When you take part in online research or surveys

Occasionally, we ask for feedback on your interaction with the website, our services and your client experience. We will use a secure online platform to gather your responses which may include your name and contact details in case we need to contact you to follow up on your answers.

Links to other websites

In order to be able to provide you additional information about services we may provide links to other websites.

We suggest that you review the privacy policies for any third-party websites you visit as we cannot accept any liability for the way they manage your personal information.

The information we need.

Curam is what’s known as the ‘data controller’ of the personal information you provide to us. Your relationship with us determines how much information we collect from you. We will only ever collect the information needed to provide you with advice and services.

We will be very clear with you about the reason for collecting information and how we intend to use, share and store that information at the point we collect it.

Collecting your personal information

We collect personal information about you through a variety of different methods including when you:

Ask for more information
Share your care needs
Become a carer
Send us correspondence via email
Contact us by telephone
Give us feedback

Children

The Curamcare website is not intended for use by anyone under 16. If you are under 16, please arrange for a parent/guardian to manage an account on your behalf before sending any personal information to us.

Where is your information stored?

Wherever possible, all the personal information we process is processed within the UK or European Economic Area (EEA).

If we transfer your personal information outside of the EEA, we do our best to make sure a similar degree of security of personal information by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission; or
Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal information the same protection it has in Europe.

Sharing your information

In order to provide you with the services requested, we may need to share your information with service providers. We have agreements in place to protect your information and ensure that it is kept securely and confidentially and only used for the purposes of a consultation.

Other than in the following circumstances, we do not share your information with any other organisations or individuals unless we are obliged to by law, for purposes of national security or criminal investigations:

If you have agreed that we may do so
If we sell the business - the new owner may obtain client and carer information. This information would only be used for the same purposes for which it was originally obtained.
If we run an event in partnership with other named organisations, your details may need to be shared. We will be very clear what will happen to your personal information when you register.
And we will never sell or rent your personal information to other organisations.

Retaining your information

We hold your information only as long as necessary for each reason that we use it. For example, when you become a client, we will retain invoicing information for up to seven years for accounting purposes. During the retention period we ensure the security and integrity of the information.

What are your rights?

You have a number of rights about how the personal information you provide can be used. These are:

Transparency over how we use your personal information (right to be informed).
The ability to request a copy of the information we hold about you, which will be provided to you within one month (right of access).
Update or amend the information we hold about you if it is wrong (right of rectification).
Ask us to stop using your information (right to restrict processing).
Ask us to remove your personal information from our records (right to be 'forgotten').
Object to the processing of your information for marketing purposes (right to object).
Obtain and reuse your personal information for your own purposes (right to data portability).
Not be subject to a decision when it is based on automated processing (automated decision making and profiling).

If you wish to raise a complaint about how we have handled your personal information, you can contact us, and we will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal information in accordance with the law, you may complain to the Information Commissioner’s Office (ICO).

If you would like to know more about your rights under data protection law, you can find out more at the Information Commissioner’s Office website.

How to contact us

If you wish to talk through anything in our privacy policy, find out more about your rights or obtain a copy of the information we hold about you, please contact us by emailing client@curamcare.com and we will be happy to help.

About Us

Curamcare Ltd is registered with the Information Commissioner’s Office as a Data Controller. Our registration number is ZA513355.

Curamcare Ltd is a company registered in England and Wales. Registered company number: 11274500 whose registered office is Richmond House, Walkern Road, Stevenage, United Kingdom, SG1 3QP.

Carer Privacy Notice

1. INTRODUCTION

Ecare Group/ Curamcare Ltd (“Curam”, “we” or “us”) take the privacy and security of your personal information very seriously.

In this privacy notice, we set out how we collect and use your personal information before, during and after your working relationship with us, in accordance with data protection legislation.

We may update this notice at any time and we may provide you with additional privacy notices from time to time.

2. PERSONAL INFORMATION THAT WE PROCESS

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

There are “special categories” of more sensitive personal information which require a higher level of protection such as health information, ethnicity or religious beliefs.

We may collect, store, and use the following categories of personal information about you:

Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
Photo for your profile
Skills, work history and experience provided as part of your application and building your profile.
Gender
Disclosure and Barring Service (DBS) and Protecting Vulnerable groups (PVG) Scheme checks.
Passport, driving licence or other form of identification.
Payment information
Information about your use of our information and communications systems including any notes or chats or app usage information.

We may also collect, store and use the following “special categories” of more sensitive personal information:

Information about health, including any medical condition, health and sickness.

If you decide not to provide us with certain personal information that we have requested, we may not be able to perform the services requested. We may from time to time use your personal information without your knowledge or consent where this is required or permitted by law.

3. HOW WE COLLECT PERSONAL INFORMATION

We collect personal information through the signup process directly from you.

We may collect further personal information during the course of providing our services.

4. HOW WE USE YOUR PERSONAL INFORMATION

We will only process your personal information if we have a lawful ground for processing such information. Most commonly, we will use your personal information in the following circumstances:

Where you have freely provided information (consent).
Where we need the information to perform the contract between us or any other contract between us.
Where we need the information to comply with a legal obligation.
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.

We may also use your personal information in the following situations, but these are not likely:

Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest or for official purposes.

5. PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL INFORMATION

We will process your personal information for the following purposes:

Registering you on the platform and creating your profile
Confirming your identity
Ensuring you have access to your account area for scheduling visits, making notes and selecting clients.
Invoicing you or your organisation for the care provided
To prevent fraud.
To monitor your use of our information and communication systems.
Enabling you to send and receive messages.
Enabling you to schedule, reschedule and cancel visit to clients.
Enabling you to report on the work that you have undertaken.
Enabling you to respond to potential clients.
Ensuring safeguarding for the benefit of clients or the person who is receiving the care.
Addressing complaints, questions and feedback.
Investigating disputes and other issues.
Troubleshooting technical problems.
Communicating with you by email, telephone, or text messages.
Improving our services.
Identifying and preventing privacy breaches.
Informing you of changes to our privacy policy.
If you wish to opt-out of promotional e-mails, text messages, or other communications, you may opt-out by following the unsubscribe link or by contacting Curam directly.

6. HOW WE USE SPECIAL CATEGORY INFORMATION

“Special categories” of sensitive personal information require higher levels of protection than non-sensitive information. We will only process special category information such as health information when we specifically obtain consent from you.

7. TRANSFERS TO THIRD PARTIES

We may have to share your personal information with third parties, including third-party service providers for example because it is necessary to administer the relationship with you or where we have another legitimate interest in doing so.

Third party providers may carry out the following services: invoicing, call centre, online platform.

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

We require third parties to respect the security of your information and to treat it in accordance with the law. They must act only in accordance with our instructions and they agree to keep your personal information confidential and secure.

8. TRANSFERS OUTSIDE OF THE UK/EEA

We may transfer your personal information outside the UK/EEA. If we do, you can expect a similar degree of protection in respect of your personal information.

Where we transfer your personal information to countries where there is no adequacy decision in respect of that country, we will put in place certain measures to ensure that your personal information does receive an adequate level of protection, such as contractual clauses that have been approved by the Information Commissioner’s Office.

9. INFORMATION SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

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

10. INFORMATION RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

We delete information about you, where required to by law and on your direct request. We also remove information that we consider inappropriate or no longer relevant, at our sole discretion.

11. WHAT ARE YOUR RIGHTS?

You have a number of rights about how the personal information you provide can be used. These are:

Transparency over how we use your personal information (right to be informed).
The ability to request a copy of the information we hold about you, which will be provided to you within one month (right of access).
Update or amend the information we hold about you if it is wrong (right of rectification).
Ask us to stop using your information (right to restrict processing).
Ask us to remove your personal information from our records (right to be 'forgotten').
Object to the processing of your information for marketing purposes (right to object).
Obtain and reuse your personal information for your own purposes (right to data portability).
Not be subject to a decision when it is based on automated processing (automated decision making and profiling).

If you would like to know more about your rights under data protection law, you can find out more at the Information Commissioner’s Office website.

Client Privacy Notice

12. INTRODUCTION

Curamcare Ltd (“Curamc”, “we” or “us”) take the privacy and security of your personal information very seriously.

In this privacy notice, we set out how we collect and use your personal information before, during and after your client relationship with us, in accordance with data protection legislation.

We may update this notice at any time and we may provide you with additional privacy notices from time to time.

13. PERSONAL INFORMATION THAT WE PROCESS

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

There are “special categories” of more sensitive personal information which require a higher level of protection such as health information, ethnicity or religious beliefs.

We may collect, store, and use the following categories of personal information about you and/or the cared for person:

Personal contact details such as name, title, job title (organisational accounts) addresses, telephone numbers, and personal email addresses
Payment information
Information about your use of our information and communications systems including any notes or chats or usage of the app.
Gender of cared for person.
Age of cared for person.
Usage notes or reports
Communications you have with carers and potential carers.

We may also collect, store and use the following “special categories” of more sensitive personal information:

Information about health, including any medical condition, health and sickness records for the cared for person.

14. HOW WE COLLECT PERSONAL INFORMATION

We collect personal information through the signup process either directly from you or where the care is for another individual from the individual or organisation with responsibility for seeking care on their behalf.

We may collect further personal information during the course of providing our services.

15. HOW WE USE YOUR PERSONAL INFORMATION

We will only process your personal information if we have a lawful ground for processing such information. Most commonly, we will use your personal information in the following circumstances:

Where you have freely provided the information (consent).
Where we need the information to perform the contract between us or any other contract between us.
Where we need the information to comply with a legal obligation.
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.

We may also use your personal information in the following situations, but these are not likely:

Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest or for official purposes.

16. PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL INFORMATION

We will process your personal information for the following purposes:

Registering you on the platform and creating a profile for the cared for person
Ensuring you have access to your account area for scheduling visits, making notes and selecting carers.
Invoicing you or your organisation for the care provided
To prevent fraud.
To monitor your use of our information and communication systems
Enabling you to send and receive messages.
Enabling you to schedule, reschedule and cancel services.
Enabling you to rate and review the service.
Enabling you to report on the work that has been done.
Enabling you to recruit carers.
Ensuring safeguarding for the benefit of clients or the cared for person.
Addressing complaints, questions and feedback.
Investigating disputes and other issues.
Troubleshooting technical problems.
Communicating with you by email, telephone, or text messages.
Improving our services.
Identifying and preventing privacy breaches.
Informing you of changes to our privacy policy
If you wish to opt-out of promotional e-mails, text messages, or other communications, you may opt-out by following the unsubscribe link or by contacting Curam directly.

17. HOW WE USE SPECIAL CATEGORY INFORMATION

18. TRANSFERS TO THIRD PARTIES

Third party providers may carry out the following services: invoicing, carer duties.

19. TRANSFERS OUTSIDE OF THE UK/EEA

We may transfer your personal information outside the UK/EEA. If we do, you can expect a similar degree of protection in respect of your personal information.

20. INFORMATION SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

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

21. INFORMATION RETENTION

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

We delete information about you, where required to by law and on your direct request. We also remove information that we consider inappropriate or no longer relevant, at our sole discretion.

22. WHAT ARE YOUR RIGHTS?

You have a number of rights about how the personal information you provide can be used. These are:

Transparency over how we use your personal information (right to be informed).
The ability to request a copy of the information we hold about you, which will be provided to you within one month (right of access).
Update or amend the information we hold about you if it is wrong (right of rectification).
Ask us to stop using your information (right to restrict processing).
Ask us to remove your personal information from our records (right to be 'forgotten').
Object to the processing of your information for marketing purposes (right to object).
Obtain and reuse your personal information for your own purposes (right to data portability).
Not be subject to a decision when it is based on automated processing (automated decision making and profiling).

If you would like to know more about your rights under data protection law, you can find out more at the Information Commissioner’s Office website.

Adult Safeguarding Policy

The policy is based on national guidance and The Care Act 2014

Introduction:

This policy is to make sure that Curam has all the right things in place to protect and safeguard adults.

Curam believes in protecting an adult’s right to live in safety, free from abuse and neglect. This policy sets out the roles and responsibilities of Curam in working together in promoting the adult’s welfare and safeguarding them from abuse and neglect. Curam employees and approved Curam carers should be made aware of how this policy can be accessed.

This policy and related procedures are applicable employees and Curam carers. Failure to comply with the policy and related procedures will be addressed without delay and may ultimately result in dismissal/exclusion from the organisation.

Care Act 2014 Definition of an Adult at Risk of Abuse:

Where a local authority has reasonable cause to suspect that an adult in its area (whether or not ordinarily resident there)

(a) has needs for care and support (whether or not the authority is meeting any of those needs),

(b) is experiencing, or is at risk of, abuse or neglect, and

Safeguarding as Part of the Deal:

In safeguarding adults, Curam is committed to the principles of the Care Act 2014

Key Principles of Adult Safeguarding:

In the safeguarding of adults, Curam is guided by the six key principles set out in The Care Act 2014 and Making Safeguarding Personal. Curam aims to demonstrate and promote these six principles in our work:

Empowerment – People being supported and encouraged to make their own decisions and informed consent.
Prevention – It is better to take action before harm occurs.
Proportionality – The least intrusive response appropriate to the risk presented.
Protection – Support and representation for those in greatest need.
Partnership – Local solutions through services working with their communities. Communities have a part to play in preventing, detecting and reporting neglect and abuse.
Accountability – Accountability and transparency in delivering safeguarding.

Recognising the signs of abuse:

Employees and carers are well-placed to identify abuse the adult may say or do things that let you know something is wrong. It may come in the form of a disclosure, complaint, or an expression of concern. Everyone within the organisation should understand what to do, and where to go to get help, support and advice.

Types of Abuse:

The Care Act 2014 defines the following ten areas of abuse. Curam also includes self-neglect as an additional category. These are not exhaustive but are a guide to behaviour that may lead to a safeguarding enquiry. This includes:

Physical abuse - Including assault, hitting, slapping, pushing, misuse of medication, restraint or inappropriate physical sanctions.
Domestic Violence/ Domestic Abuse - Including psychological, physical, sexual, financial, emotional abuse; so called ‘honour’ based violence.
Exploitation- Including sexual and/or criminal exploitation.
Sexual abuse - Including rape, indecent exposure, sexual harassment, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, subjection to pornography. Witnessing sexual acts, indecent exposure and sexual assault or sexual acts to which the adult has not consented or was pressured into consenting.
Psychological abuse - Including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, cyber bullying, isolation or unreasonable and unjustified withdrawal of services or supportive networks.
Financial or material abuse - Including theft, fraud, internet scamming, coercion in relation to an adult’s financial affairs or arrangements, including in connection with wills, property, inheritance or financial transactions, or the misuse of misappropriation of property, possessions or benefits.
Modern slavery - Encompasses slavery, human trafficking, forced labour and domestic servitude. Traffickers and those who coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment.
Discriminatory abuse - Including forms of harassment, slurs or similar treatment because you are, or are perceived to be different due to race, gender and gender identity, age, disability, sexual orientation or religion.
Organisational abuse - Including neglect and poor care practice within an institution or specific care setting such as a hospital or care home, for example or in relation to care provided in one’s own home. This may range from one off incidents to long-term ill treatment. It can be through neglect or poor professional practice because of the structure, policies, processes or practices within an organisation.
Neglect and acts of omission - Including ignoring medical, emotional or physical care needs, failure to provide access to appropriate health, care and support or educational services, the withholding of the necessities of life, such as medication, adequate nutrition and heating.
Self-neglect - This covers a wide range of behaviour neglecting to care for one’s personal hygiene, health or surroundings and includes behaviour such as hoarding.

Radicalisation to Terrorism:

The Government through its PREVENT programme has highlighted how some adults may be vulnerable to exploitation and radicalisation and involvement in terrorism. Signs and indicators of radicalisation may include:

Being in contact with extremist recruiters.
Articulating support for violent extremist causes or leaders.
Accessing violent extremist websites, especially those with a social networking element.
Possessing violent extremist literature.
Using extremist narratives to explain personal disadvantage.
Justifying the use of violence to solve societal issues.
Joining extremist organisations.
Significant changes to appearance and/or behaviour.

Reporting Concerns:

Any Curam employee or Curam carer who becomes aware that an adult is or is at risk of, being abused must raise the matter immediately with Curam’s head office on 01387 730766. If the adult requires immediate protection from harm, they should immediately contact the police and the appropriate adult social care department of the appropriate local authority.

Early sharing of information is the key to providing an effective response where there are emerging concerns. To ensure effective safeguarding arrangements no one should assume that someone else will do it.

Safe Recruitment & Selection:

Curam is committed to safe employment and safe recruitment practices, that reduce the risk of harm to adults with care and support needs from people unsuitable to work with them.

Curam has policies and procedures that cover the recruitment of all employees and Curam carers. See Curam carer recruitment internal guidelines document.

Is there a Person in a Position of Trust Involved?

In any instance of safeguarding, consideration must be given as to whether an allegation has been made against a person in a position of trust (PiPoT) and who may be a risk to others. This can be anyone from a formal employee or approved Curam carer to an informal carer.

Training and Awareness:

Curam will ensure an appropriate level of safeguarding training is available to all its employees, approved Curam carers and any relevant persons linked to the organisation who requires it (e.g., contractors).

For all employees or Curam carers who are working with adults at risk this requires them as a minimum to have awareness training that enables them to:

Understand what safeguarding is and their role in Safeguarding Adults.
Recognise an adult potential in need of safeguarding and act.
Understand how to report a safeguarding Alert.
Understand dignity and respect when working with individuals.
Have knowledge of the Safeguarding Adults Policy.

Similarly, employees and Curam carers may encounter concerns about the safety and wellbeing of children/young people. For more information about children’s safeguarding, refer to Curam Children and Young People’s Safeguarding Policy.

Mental Capacity:

The MCA defines someone is lacking capacity, because of an illness or disability such as a mental health problem, dementia or a learning disability, who cannot do one or more of the following four things:

Understand information given to them about a particular decision.
Retain that information long enough to be able to make the decision.
Weigh up the information available to make the decision.
Communicate their decision. Refer to the Mental Capacity Act Code of Practice, https://www.gov.uk/government/publications/mental-capacity-act-code-of-practice. Curam will seek to involve an advocate if the person lacks capacity to make decisions about a safeguarding concern.

Confidentiality and Information Sharing:

Curam expects all employees and approved Curam carers to maintain confidentiality. Information will only be shared in line with the General Data Protection Regulations (GDPR) and Data Protection.

However, information should be shared with the Local Authority if an adult is deemed to be at risk of harm or contact the police if they are in immediate danger, or a crime has been committed. For further guidance on information sharing and safeguarding please contact the Curam head office.

Recording and Record Keeping:

A written record must be kept about any concern regarding an adult with safeguarding needs. This must include details of the person involved, the nature of the concern and the actions taken, decision made and why they were made.

All Curam records are securely and confidentially stored in line with General Data Protection Regulations (GDPR).

Whistleblowing:

Curam is committed to ensuring that employees and approved Curam carers who in good faith whistle-blow in the public interest, will be protected from reprisals and victimisation.

Important Contacts:

Senior Lead for Safeguarding

Name: Gemma Stokes

Email address: gemma@curamcare.com

Telephone number: 01387 730766

Deputy Lead for Safeguarding

Name: Jessica Huntley

Email address: jessica@curamcare.com

Telephone number: 01387 730766

Police

Emergency – 999

Non-emergency – 101

Telephone: 0808 2000 247

https://www.nationaldahelpline.org.uk/

Modern Slavery Statement

Ecare Group Ltd and its trading subsidiaries Curamcare Ltd, Curam.io Ltd and Curam PAYE Ltd (Curam) is committed to the highest standards when dealing with employees, customers, and suppliers, aiming to conduct every aspect of our business with honesty, integrity and openness. We will continue to review and seek feedback on our practices, to meet these standards.

Key elements that we consider:

Our policy

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business. We have a defined clear policy for our staff and expect this to be adhered to, always. The policy is communicated to all staff, through onboarding and inductions, to encourage them to act responsibly. In particular our focus is on our carers and how they are approved.

Risk management

We have identified that our greatest potential risks in relation to modern slavery exist in our carer recruitment and possibly in parts of our supply chain. A risk management approach has been taken to help us identify and understand the potential risks and to ensure we can respond appropriately to any challenges. We will continue to review this approach and seek to strengthen our processes.

Awareness

At Curam, we recognise our responsibility to ensure staff are aware of the reality of modern slavery in the UK and worldwide. We provide online and induction training that enables staff to recognise and respond to any instances of modern slavery - during work time or otherwise. The Curam Modern Slavery Statement will be reviewed annually.

This Statement has been approved by the Executive Board and is signed on their behalf by Jody O’Neill, CEO.

30th April 2023

2021 Introduction

Modern Slavery can take place in a wide range of employment sectors, including social and healthcare. In addition to the potential risk to employees, people using our services may also be victims of modern slavery or human trafficking.

Our modern slavery Statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business or our supply chains.

Our Policies

We have policies that ensure we are conducting business in an ethical and transparent manner.

We have a Modern Slavery Policy which is reviewed on an annual basis.
Whistleblowing Policy – we encourage our customers, suppliers, and employees to use our whistle blowing policy to report any concerns, including issues regarding modern slavery, to the board. We have a process in place and clear steps to take if modern slavery was to be discovered in our business. This includes escalation to line management in the first instance, or contacting police if we believe someone is in immediate danger.

Complaints Policy: Whilst aimed at receiving complaints or concerns about any care provision or carer conduct, all complaints received will be fully investigated and appropriate remedial actions taken. We will work collaboratively with our social care and health partners to ensure our safeguarding policies and procedures dovetail with local procedures and best practice.

Recruitment policy: Our robust recruitment practices always respect human rights by ensuring equal opportunities and fair treatment for all. New employees and carers are screened in compliance with right to work checks. All employees have agreed terms and conditions which accord with employment law and we have a commitment to all carers on the platform and all our employees that everyone earns the national living wage regardless of age. We have a zero-tolerance approach to slavery, trafficking or forced labour.

An Anti-Corruption and Bribery Policy: It is our policy to promote our business being conducted in an honest and ethical manner. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

Training

We have incorporated training on modern slavery into the induction programme for all new employees. The training aims to increase awareness on modern slavery and human trafficking, explaining how to identify if this type of abuse is happening and what to do if you think it may be taking place. We will ensure that all employees are made aware of our Modern Slavery Policy and their obligations within it.

Our Supply Chain

The main way of mitigating the risks posed by modern day slavery is to fully understand how, and on what we spend money, and the country of origin for each area of our supply chain. Our main areas of expenditure are currently:

Recruitment
Technology development
Marketing Analytics
IT Support Services
Financial services

Our Risk Assessment identifies that our priorities with respect to Modern Slavery should be in the recruitment of carers.

We work with several sub-contractors in India. Where possible the sub-contractors are directly hired by Curam and have a clear understanding of our zero-tolerance policy to modern day slavery. Where direct employment is not possible, we work with reputable partners and agencies who share our approach and commitment to ensuring modern slavery is not present in our organisation or our supply chain.

Progress and Future Actions

Curam recognises that addressing the risk of modern slavery within our business and the supply chain is an ongoing process and we are committed to continual review to ensure that we uphold the commitments set out in this statement.

As no reports have been received from employees, the public, law enforcement agencies or local safeguarding teams we are confident that the steps we are taking to ensure slavery is not taking place within our business are effective.

This document constitutes our Modern Slavery Statement for the financial year ending 31st March 2023 and has been created in accordance with the Modern Slavery Act 2015.

Diversity and Inclusion Policy

EQUALITY AND DIVERSITY POLICY

Curam aims to demonstrate excellence in encouraging equality and diversity. We strive to be inclusive through respecting one another, promoting and achieving equality of opportunity, and valuing diversity, and providing an accessible, responsive service to our customers.

PURPOSE AND SCOPE OF POLICY

The purpose of this policy is to ensure that our commitment to equality of opportunity and valuing diversity is reflected in all employment processes. The policy covers all Curam employees, including those on fixed-term contracts and those on secondment from other organisations plus all our approved Curam carers active on our platform.

The term ‘discrimination’ is used throughout this policy to mean unfair and unlawful discrimination.

PRINCIPLES

Equality and diversity are central to our daily working life at Curam. We aim to prevent and remove unfair discrimination, harassment and victimisation wherever we encounter it in our work, to promote equality of opportunity in all that we do, and to value and respect differences.
All employees have a responsibility to challenge, report and/or directly dealing with discriminatory behaviour, unfair treatment, harassment or bullying at Curam.
We recognise that people have preferences in relation to the world around them, however every employee has a responsibility to ensure that decisions made at work are not affected by bias or prejudice. The Equality Act (2010), states that there are nine protected characteristics and that it is unlawful to discriminate against people because of those characteristics.
Discrimination, harassment and victimisation are disciplinary offences which may lead to dismissal.
Our policy will comply with the statutory requirements of the Equality Act 2010, as appropriate and in accordance with current good practice.
Curam is committed to becoming an organisation which understands the effects of disability and provides effective support so that disabled employees can perform to the best of their ability. This means ensuring that they can discuss and request reasonable adjustments, and that managers will ensure that any agreed adjustments are put in place promptly. When considering reasonable adjustments, Curam will consider how best to prevent substantial disadvantage.

OUTCOMES

The outcomes of this policy are that:

Curam acts in compliance with relevant statutory requirements, specifically the Equality Act
The Curam workforce better reflects the community we serve, and the working populations around our sites, at all levels.
Curam employees understand and respond effectively to the diverse needs of the communities we serve to promote equal access to our services.

MONITORING AND REVIEW

Curam will monitor the effectiveness of this policy to ensure we are achieving the stated outcomes above by reviewing:
A formal review of this policy will occur every three years unless there is a significant change in relevant legislation which triggers a review before then.

Curam’s commitment to equality and diversity

Curam will be an exemplar organisation, demonstrating excellence in equality and diversity issues across all areas of policy and practice, and influencing others through the high standards that we set.

In all aspects of our work, we will be:

· accessible · inclusive

· responsive · fair

Curam’s Vision Statement will be realised through all our staff working together to achieve:

An understanding of the different needs of Curam customers so that we can provide an accessible and responsive service to all who need it
At Curam we have a workforce that includes a diverse range of people at all levels, reflecting the community we serve and the working populations around our sites
An open and inclusive culture within Curam
A good reputation for understanding and managing equality and diversity effectively.

Curam’s Diversity Value and E&D Rights and Responsibilities

Our diversity values state:

We value people and their diversity and strive to be inclusive:

We respect others, regardless of personal differences.
We listen to people to understand their needs and tailor our service accordingly, and
We promote equal access to our service for all members of the community.

It is important that people understand their rights, and their responsibilities to achieve our vision for E&D and to put our values into action. To do this effectively we expect the following behaviours:

Valuing diversity through treating customers and people at Curam as individuals.
Constructively challenging or praising others to ensure the Curam values are lived out as well as recognising unacceptable behaviour and taking appropriate action.
Demonstrating an understanding of the E&D Policy and participating in developmental activities relating to E&D

Glossary of terms stated in the Equality Act (2010)

Age

The Act protects people of all ages. However, different treatment because of age is not unlawful direct or indirect discrimination if the employee can justify it, ie if the person can demonstrate that it is a proportionate means of meeting a legitimate aim.

Disability

Under the Act, a person is disabled if they have a physical or mental impairment which has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities.

Gender reassignment

The Act provides protection for transsexual people. A transsexual person is someone who proposes to, starts or has completed a process to change his or her gender.

Marriage and civil partnership

The Act protects employees who are married or in a civil partnership against discrimination. Single people are not protected.

Pregnancy and maternity

A woman is protected against discrimination on the grounds of pregnancy and maternity during the period of her pregnancy and any statutory maternity leave to which she is entitled.

Race

For the purposes of the Act ‘race’ includes colour, nationality and ethnic or national origins.

Religion or belief

In the Equality Act, religion includes any religion. It also includes a lack of religion, in other words those that do not follow a certain religion or have no religion at all. Additionally, a religion must have a clear structure and belief system. Belief means any religious or philosophical belief or a lack of such belief. To be protected, a belief must satisfy various criteria, including that it is a weighty and substantial aspect of human life and behaviour.

Sex

Both men and women are protected under the Act.

Sexual orientation

The Act protects bisexual, gay, heterosexual and lesbian people.

Direct discrimination

Direct discrimination occurs when someone is treated less favourably than another because of a protected characteristic they have or are thought to have (see perception discrimination below), or because they associate with someone who has a protected characteristic (see discrimination by association below).

Discrimination by association

This is direct discrimination against someone because they associate with another person who possesses a protected characteristic.

Perception discrimination

This is direct discrimination against an individual because others think they possess a particular protected characteristic. It applies even if the person does not actually possess that characteristic but are perceived as doing so.

Indirect discrimination

Indirect discrimination can occur when you have a condition, rule, policy or even a practice that applies to everyone but particularly disadvantages people who share a protected characteristic. Indirect discrimination can be justified if the employee can show that you acted reasonably in managing your business, ie that it is ‘a proportionate means of achieving a legitimate aim’.

Harassment

Harassment is “unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual”. Employees are also protected from harassment because of perception and association.

Third party harassment

The Equality Act makes you potentially liable for harassment of your employees by people (third parties) who are not employees of your company, such as customers or clients. You will only be liable when harassment has occurred on at least two previous occasions, you are aware that it has taken place, and have not taken reasonable steps to prevent it from happening.

Victimisation

Victimisation occurs when an employee is treated badly because they have made or supported a complaint or raised a grievance under the Equality Act; or because they are suspected of doing so.

Discrimination arising from a disability.

The Act says that treatment of a disabled person amounts to discrimination where:

An employer treats the disabled person unfavourably.
This treatment is because of something arising in consequence of the disabled person’s disability; and
The employer cannot show that this treatment is a proportionate means of achieving a legitimate aim, unless the employer does not know, and could not reasonably be expected to know, that the person has the disability.

Discrimination through failure to provide reasonable adjustments.

Discrimination against a disabled person occurs where an employer fails to comply with a duty to make reasonable adjustments imposed on them in relation to that disabled person, the employer must:

Avoid the substantial disadvantage where a practice applied by or on behalf of the employer puts a disabled person at a substantial disadvantage compared to those who are not disabled.
Remove or alter a physical feature or provide a reasonable means of avoiding such a feature where it puts a disabled person at a substantial disadvantage compared to those who are not disabled.
Provide an auxiliary aid where a disabled person would, but for the provision of that auxiliary aid, be put at a substantial disadvantage compared to those employees who are not disabled.

Updated 28th Feb 2024

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