Our Policies

This promise outlines the commitment made to donors and the public by fundraising organisations which register with the Fundraising Regulator. Those who register with the regulator agree to ensure their fundraising is legal, open, honest and respectful. The standards for fundraising are set out in the Code of Fundraising Practice.

WE WILL COMMIT TO HIGH STANDARDS

• We will adhere to the Fundraising Code of Practice. 
• We will monitor fundraisers, volunteers and third parties working with us to raise funds, to ensure that they comply with the Code of Fundraising Practice and with this Promise. 
• We will comply with the law as it applies to charities and fundraising. 
• We will display the Fundraising Regulator badge on our fundraising material to show we are committed to good practice.

WE WILL BE CLEAR, HONEST AND OPEN

• We will tell the truth and we will not exaggerate. 
• We will do what we say we are going to do with donations we receive. 
• We will be clear about who we are and what we do. 
• We will give a clear explanation of how you can make a gift and change a regular donation. 
• Where we ask a third party to fundraise on our behalf, we will make this relationship and the financial arrangement transparent. 
• We will be able to explain our fundraising costs and show how they are in the best interests of our cause if challenged. 
• We will ensure our complaints process is clear and easily accessible. 
• We will provide clear and evidence based reasons for our decisions on complaints. 

WE WILL BE RESPECTFUL

• We will respect your rights and privacy. 
• We will not put undue pressure on you to make a gift. If you do not want to give or wish to cease giving, we will respect your decision. 
• We will have a procedure for dealing with people in vulnerable circumstances and it will be available on request. 
• Where the law requires, we will get your consent before we contact you to fundraise. 
• If you tell us that you don’t want us to contact you in a particular way we will not do so. We will work with the Telephone, Mail and Fundraising Preference Services to ensure that those who choose not to receive specific types of communication don’t have to. 

WE WILL BE FAIR AND ACCESSIBLE

• We will treat donors and the public fairly, showing sensitivity and adapting our approach depending on your needs. 
• We will take care not to use any images or words that intentionally cause distress or anxiety. 
• We will take care not to cause nuisance or disruption to the public.

WE WILL BE ACCOUNTABLE AND RESPONSIBLE

• We will manage our resources responsibly and consider the impact of our fundraising on our donors, supporters and the wider public. 
• If you are unhappy with anything we’ve done whilst fundraising, you can contact us to make a complaint. We will listen to feedback and respond appropriately to compliments and criticism we receive. 
• We will have a complaints procedure, a copy of which will be available on our website or available on request. 
• Our complaints procedure will let you know how to contact the Fundraising Regulator in the event that you feel our response is unsatisfactory. 
• We will monitor and record the number of complaints we receive each year and share this data with the Fundraising Regulator on request. 

INTRODUCTION 

Hospital Rooms seeks to raise funds actively and effectively whilst guarding against potential reputational risk, and ensuring that donors are aligned with Hospital Rooms’ values and ethical framework. This policy is designed to ensure that due diligence for potential donors is efficient, effective, ethical, appropriately documented, and carried out in a timely fashion. This policy applies to donations of cash and securities received by Hospital Rooms, the sponsorship of exhibitions, in-kind support and where relevant, the donation of artworks by artists, their representatives and/or collectors to generate funds for Hospital Rooms. 

RESPONSIBILITIES 

Control and coordination of all fundraising activities will be the responsibility of Hospital Rooms SMT acting on delegated authority from the Board of Trustees, who retain overall responsibility for all decisions regarding the acceptance and refusal of donations. Legal or other advice may be sought in matters relating to the acceptance of gifts where, for example, a donation is proposed which may provide a benefit to a donor or a person or business connected to the donor. 

RESEARCH 

Recognising that the objective is to achieve success through energetic fundraising and that the tendency will be towards acceptance rather than rejection, research undertaken by the Hospital Rooms SMT will be as robust as circumstances reasonably permit. Where additional investigations are deemed appropriate, the Hospital Rooms SMT will engage freelance support and/or professional search firms and international due diligence providers. The confidential advice and opinions of individuals who have knowledge of the specific funders and/or context in which they operate, commercially or personally, may also be sought.  

For contributions of over £10,000, all potential funders will be subject to an initial screening comprising a search of publicly available material, designed to highlight potential areas of controversy or concern. Wherever practical this process will take place before a donation is secured, to avoid the potential reputational damage of refusing or returning a donation.  

The initial screening will normally involve a combination of adverse news searches on Google (or a similar web search engine), and a registry check (with Companies House data and/or reasonably accessible international registries). For donations of more than £10,000 but less than £50,000, Hospital Rooms SMT in consultation with the Chair of the Board of Trustees will decide if more detailed research is required and/or if a full review should be undertaken including referring the matter to the Board of Trustees who will be required to consider the results of such research dispassionately and express any findings and conclusions objectively. Donations exceeding £50,000 will automatically be referred to the Board of Trustees. 

CORPORATE SPONSORS AND PARTNERS 

All corporate sponsors and partners providing support of £5,000 or more will be subject to the same initial screening of publicly available information mentioned above. This screening will be focused on the company and its activities, with reference to any activity that might be a source of reputational or ethical risk, such as pending major court cases and prominent allegations. Standard checks will be made in relation to the company’s sector, its corporate register and listed company details in country of origin and of its parent or associated companies, if relevant, and more generally in relation to its regulatory jurisdiction. 

DISTINCTION BETWEEN ALLEGATION AND FACT 

The Hospital Rooms SMT and Board of Trustees should distinguish between mere allegation or rumour or speculation on the one hand and confirmed fact or legal finding on the other, treating the former with caution although not disregarding the same if they consider that public perception alone carries a significant reputational risk for Hospital Rooms irrespective of the underlying truth. 

RECORDS 

All advice and research material received in respect of individual donors, institutional funders, and corporate sponsors as well as any conclusions or views as to the prudence of accepting the potential funding expressed by the Executive and/or Board of Trustees and all information concerning countries, or their regimes gathered in the context of this donations policy will be retained on file. Notes will be made and retained if discussions have been oral and not in writing. 

REFERRALS TO THE BOARD OF TRUSTEES 

The Board of Trustees retain overall responsibility for decisions regarding the acceptance and refusal of donations. As such, where the Executive feels that the results of the initial screening for donations of less than £50,000 should be further reviewed, the Executive should consult with the majority of Trustees before taking decisions. 

In the case of donations above £50,000, either from individual donors, institutional funders, or corporate sponsors and partners, these must be reviewed and discussed by the full Board of Trustees at a board meeting, with decisions recorded in the minutes of the meeting. 

The Board of Trustees shall consider all potential donations referred to it by the Executive in accordance with the following principles of ethical fundraising. Hospital Rooms will not accept funds in circumstances when: 

• The donation is made anonymously, through an intermediary who is not prepared to identify the donor to anyone at Hospital Rooms; 
• The donor has acted, or is believed to have acted, illegally in the acquisition of funds, for example when funds are tainted through being the proceeds of criminal conduct; or, 
• When acceptance of the funds would, in the judgement of the Board of Trustees, significantly damage the effective operation of Hospital Rooms in delivering its mission, whether because such acceptance would:

1. Harm Hospital Rooms’ relationship with other donors, partners, or stakeholders;
2. Create unacceptable conflicts of interest; 
3. Materially damage the reputation of Hospital Rooms; or, 
4. Detrimentally affect the ability of Hospital Rooms to fulfil its mission in any other way than is mentioned above. 

The Board of Trustees will act and rely on the material put before it by the Executive but may require further research to be conducted before it takes a decision.

Minutes will be kept of its discussions and key points, together with the research material and reports and supporting documents. These will be stored electronically. 

DONATIONS FROM CHARITABLE FOUNDATIONS 

Donations and grants of any size from charitable foundations registered with the regulatory authorities in the UK, North America, and European Foundation Centre (EFC) affiliated organisations, will not normally be subject to a full review by the Board of Trustees and can be progressed on the signing of an appropriate agreement with the funder. For the United Kingdom this means charities regulated and scrutinised by the Charity Commission for England and Wales, the Office of the Scottish Charity Regulator, and the Charity Commission for Northern Ireland. For the United States of America this means tax- exempt, non-profit corporations or associations recognised under section 501(c) regulated and scrutinised by the Internal Revenue Service (IRS) and the relevant state Attorney General. For Canada this means charities regulated and scrutinised by the Canada Revenue Agency (CRA). In the absence of any equivalent regulatory framework covering Europe, the (EFC) has openly published its principles of good practice to which all affiliated organisations have to adhere. Exceptionally, the Executive may refer a registered charitable foundation to the Board of Trustees where the results of the initial screening suggest to the Executive that there is a possible ethical or reputational risk to Hospital Rooms which ought to receive the attention of the Board, in particular, any area of risk associated with any founder or trustee of such a foundation. 

GIFTS OF ARTWORKS 

Hospital Rooms will only accept gifts of artworks from donors who have undergone the same due diligence checks as mentioned above and in cases where the artwork provenance is clear, and ownership of the artwork is undisputed. Any monies accruing by virtue of the sale of donated artworks will be used solely to support the activities of Hospital Rooms. Arrangements for the sale of donated artworks will need to be agreed on a case-by- case basis with the artist and/or their representatives and the Board of Trustees. 

RESTRICTED GIFTS 

Subject to the provisions of this policy, Hospital Rooms: 

• May accept unrestricted gifts, including those made with an expression of wishes that the gift be used for a particular purpose within Hospital Rooms Objects; 
• May accept gifts restricted for particular projects including specific exhibitions, research trips, staff salaries or to support students from particular backgrounds, provided those purposes are in line with Hospital Rooms core values, within the organisation’s charitable objects and capable of being carried out; 
• Will not accept gifts that are too difficult or costly to administer or gifts that are restricted for purposes outside the objects of Hospital Rooms. Where a gift is proposed to be made for restricted purposes, the Executive will consider, prior to accepting such a donation, whether the proposed project would be an appropriate project for Hospital Rooms in the circumstances including: 
• Whether the proposed project is an effective way of furthering Hospital Rooms’ Objects; 
• The intended impact of the proposed project; 
• The anticipated financial cost of involvement in the proposed project; 
• The impact the proposed project would have on Hospital Rooms’ reputation; 
• Whether the proposed project could be carried out in a manner that is lawful and consistent with relevant guidance; and 
• The means by which useful results of any research will be disseminated. If the Board of Trustees is satisfied that the project proposed is eligible, it will consider whether in all the circumstances accepting such a restricted donation would be in the best interests of Hospital Rooms.

1. If a complaint about fundraising is received from a member of the public (the “complainant”), Hospital Rooms will acknowledge the complaint in writing within 14 days of receipt of the complaint and provide them with a copy of Hospital Rooms’s complaints procedure and the Fundraising Promise or, if they have access to the internet, with details of Hospital Rooms’s website. The acknowledgement will also confirm that Hospital Rooms will seek to resolve the complaint within 30 days. 
2. Hospital Rooms will investigate the complaint and will advise the complainant of the outcome of the investigation within 30 days of receipt of the complaint. In exceptional circumstances, Hospital Rooms may need more than 30 days to gather all the information required for its investigation (for example, if a key member of staff is on annual leave or sick). If this happens, Hospital Rooms will contact the complainant in writing with a copy to the Fundraising Regulator (“the regulator”) outlining the situation. 
3. If the complainant is dissatisfied with the outcome of Hospital Rooms’s investigation, the complainant may refer the complaint to the regulator within two months of receiving Hospital Rooms’s response. 
4. Once the regulator has received the complaint, it will contact Hospital Rooms to let it know and to get background information about the complaint, and the regulator will investigate the complaint and seek a resolution with all parties concerned within 30 days. If the complainant is still not satisfied, they can seek adjudication by the regulator. 

Contact the Fundraising Regulator: 

Online: https://www.fundraisingregulator.org.uk/

By Email: complaints@fundraisingregulator.org.uk 

By Post: Fundraising Regulator, Eagle House, 167 City Road, London, EC1V 1AW 

By Phone: Call 0300 999 3407 (Monday to Friday, 09.30 am – 4.30 pm) 

Contact Us: Ania Patla, Head of Partnerships & Special Projects, Hospital Rooms, Unit 404 Lock Studios, 7 Corsican Square, London E3 3YD

Email: ania@hospital-rooms.com 

INTRODUCTION 

This document sets out the policy and procedures of Hospital Rooms against fraud and other forms of dishonesty. 

It applies to Directors, staff, contractors, trustees and volunteers. Anybody associated with Hospital Rooms who commits fraud, theft or any other dishonesty, or who becomes aware of it and does not report it, will be subject to appropriate disciplinary action. 

 

STATEMENT OF INTENT  

Hospital Rooms will continually strive to ensure that all its financial and administrative processes are carried out and reported honestly, accurately, transparently and accountably and that all decisions are taken objectively and free from personal interest. We will not condone any behaviour that falls short of these principles. 

All members of Hospital Rooms have a responsibility for putting these principles into practice and for reporting any breaches they discover. 

 

DEFINITIONS 

1. Fraud: A deliberate intent to acquire money or goods dishonestly through the falsification of records or documents. The deliberate changing of financial statements or other records by either; a member of the public, someone who works or is a volunteer for Hospital Rooms. The criminal act is the attempt to deceive and attempted fraud is therefore treated as seriously as accomplished fraud 
2. Theft: Dishonestly acquiring, using or disposing of physical or intellectual property belong- ing to Hospital Rooms or to individual members of the organisation. 
3. Misuse of equipment: Deliberately misusing materials or equipment belonging to Hospital Rooms for financial or material benefit. 
4. Abuse of position: Exploiting a position of trust within the organisation for financial or material benefit. 

CULTURE

Hospital Rooms expects honesty and integrity in its entire staff. Directors, staff and volunteers are expected to lead by example in adhering to policies, procedures and practices. Equally, members of the public, service users and external organisations (such as suppliers and contractors) are expected to act with integrity and without intent to commit fraud against the Charity. 

As part of this, Hospital Rooms will provide clear routes by which concerns may be raised by Directors, staff and volunteers. Details of this can be found in the Hospital Rooms Staff Handbook. 

Senior management are expected to deal promptly, firmly and fairly with suspicions and allegations of fraud or corrupt practice 

 

RESPONSIBILITIES 

In relation to the prevention of fraud, theft, misuse of equipment and abuse of position, specific responsibilities are as follows: 

Trustee and Non-Executive Directors:

The Directors are responsible for establishing and maintaining a sound system of internal control that supports the achievement of the Charity’s policies, aims and objectives. 

The system of internal control is designed to respond to and manage the whole range of risks which the Charity faces. 

The system of internal control is based on an on-going process designed to identify the principal risks, to evaluate the nature and extent of those risks and to manage them effectively. Managing fraud risk is seen in the context of the management of this wider range of risks. 

 

The Chief Executive Officer (CEO): 

Overall responsibility for managing the risk of fraud has been delegated to the CEO, Tim A Shaw, The day to day responsibility has been delegated to the COO, Natalie Carter, to act on behalf of the CEO. 

Their responsibilities include: 

• Undertaking a regular review of the fraud risks associated with each of the key organisational objectives. 
• Establishing an effective anti-fraud response plan, in proportion to the level of fraud risk identified. 
• The design of an effective control environment to prevent fraud. 
• Establishing appropriate mechanisms for: 
• reporting fraud risk issues 
• reporting significant incidents of fraud or attempted fraud to the Board of Trustees; 
• Liaising with the Charity’s appointed Auditors. 
• Making sure that all staff are aware of the Charity’s Anti-Fraud Policy and know what their responsibilities are in relation to combating fraud; 
• Ensuring that appropriate anti-fraud training is made available to Directors, staff and volunteers as required; and 
• Ensuring that appropriate action is taken to minimise the risk of previous frauds occurring in future. 

Senior Management Team 

The Senior Management Team is responsible for: 

• Ensuring that an adequate system of internal control exists within their areas of responsibility and that controls operate effectively; 
• Preventing and detecting fraud as far as possible; 
• Assessing the types of risk involved in the operations for which they are responsible; 
• Reviewing the control systems for which they are responsible regularly; 
• Ensuring that controls are being complied with and their systems continue to operate effectively; 
• Implementing new controls to reduce the risk of similar fraud occurring where frauds have taken place. 

Staff 

Every member of staff is responsible for: 

• Acting with propriety in the use of Charity’s resources and the handling and use of funds whether they are involved with cash, receipts, payments or dealing with suppliers; 
• Conducting themselves with selflessness, integrity, objectivity, accountability, openness, honesty and leadership; 
• Being alert to the possibility that unusual events or transactions could be indicators of fraud; 
• Alerting their manager when they believe the opportunity for fraud exists e.g. because of poor procedures or lack of effective oversight; 
• Reporting details immediately if they suspect that a fraud has been committed or see any suspicious acts or events; and 
• Cooperating fully with whoever is conducting internal checks or reviews or fraud investigations. 

Volunteers 

Every volunteer is responsible for: 

• Acting with propriety in the use of the Charity’s resources and the handling and use of funds whether they are involved with cash, receipts, payments or dealing with suppliers; 
• Conducting themselves with selflessness, integrity, objectivity, accountability, openness, honesty and leadership; 
• Being alert to the possibility that unusual events or transactions could be indicators of fraud; 
• Alerting their manager when they believe the opportunity for fraud exists e.g. because of poor procedures or lack of effective oversight; 
• Reporting details immediately if they suspect that a fraud has been committed or see any suspicious acts or events; and 
• Cooperating fully with whoever is conducting internal checks or reviews or fraud investigations.

1. All members of staff are entitled to be treated with dignity and respect in their place of work. This means freedom from behaviour by colleagues that can be interpreted as bullying or harassment or that causes offense, and access to redress if such behaviour does arise. It also means standards of everyday behaviour that contribute to a working environment in which mutual respect and individual dignity are maintained.
2. Personal harassment takes many forms but whatever form it takes, it is unlawful under the Equality Act 2010 and will not be tolerated. https://www.gov.uk/guidance/equality-act-2010-guidance
3. This policy will be reviewed regularly to ensure it remains up to date and in order to monitor its effectiveness.

BULLYING AND HARASSMENT

Behaviour can constitute bullying or harassment where: it violates the dignity of a member of staff on the grounds of their age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation (the protected characteristics); or where it creates an intimidating, hostile and degrading, humiliating or offensive environment. Individual or accumulative acts can seriously undermine the dignity, confidence, and work satisfaction to such an extent that it has an effect on job performance, and general happiness both inside and outside work.

Conduct becomes harassment if it persists and it has been made clear that it is regarded as offensive by the recipient or a witness to the conduct, although a single offensive act can amount to harassment if it is sufficiently serious.

 

SCOPE

We deplore all forms of personal harassment and seek to ensure that the working environment is sympathetic to all those who work for us. This includes employees, workers, agency workers, volunteers and contractors in all areas of our Company, including any overseas sites.

 

DEFINITIONS

Harassment

This is unwanted conduct related to a relevant protected characteristic that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person.

Unwanted conduct can include:

1. spoken words;
2. banter;
3. written words;
4. posts or contact on social media;
5. imagery;
6. graffiti;
7. physical gestures;
8. facial expressions;
9. mimicry;
10. jokes or pranks;
11. acts affecting a person’s surroundings;
12. aggression;
13. physical behaviour towards a person or their property.

 

Sexual Harassment

This is unwanted conduct of a sexual nature which has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person.

1. sexual comments or jokes;
2. displaying sexually graphic pictures, posters or photos;
3. suggestive looks, staring or leering;
4. propositions and sexual advances;
5. making promises in return for sexual favours;
6. sexual gestures;
7. intrusive questions about a person’s private or sex life or a person discussing their own sex life;
8. sexual posts or contact on social media;
9. spreading sexual rumours about a person;
10. sending sexually explicit emails or text messages, and
11. unwelcome touching;
12. hugging, massaging or kissing.

Less favourable treatment for rejecting or submitting to unwanted conduct

This occurs when:

someone is subjected to unwanted conduct:

1. of a sexual nature;
2. related to sex, or
3. related to gender reassignment;

the unwanted conduct has the purpose or effect of:

1. violating their dignity, or
2. creating an intimidating, hostile degrading, humiliating or offensive environment for them, and
3. they are treated less favourably because they submitted to, or rejected the unwanted conduct.

DETRIMENTAL BEHAVIOUR BECAUSE OF AN ASSOCIATION WITH A PROTECTED CHARACTERISTIC

Bullying and harassment may not be based on the fact that a colleague belongs to a particular group, but simply because the individual has been singled out for such treatment or associates with someone of a protected characteristic. For example, this would include claiming someone is gay when they are not or making fun of someone who has a disabled relative. The bullying and harassment may take the following forms, though again this is not intended as an exhaustive list:

• Limiting or withdrawing verbal communication.
• Isolating a colleague by unfriendly or unwelcoming behaviour.
• Behaviour designed to belittle or produce anxiety in a colleague.
• Unreasonable scrutiny of work.
• Unreasonable criticism of work, and adopting double standards in expectations of work performance.
• Unreasonable denial of leave and/or special leave requests.
• Unreasonable denial of requests for flexible working.
• Work or staff social activities that deliberately exclude a colleague.
• Jokes or inappropriate humour at the expense of a colleague.

 

STANDARDS OF WORK BEHAVIOUR

• Courtesy towards colleagues.
• Consideration and understanding of the work demands of colleagues.
• Maintaining a temperate tone, and temperate language, in all verbal and written communication with colleagues.
• Avoidance of the use of foul language.
• Awareness of language and conduct which have the potential to offend a colleague.
• Obtaining the express or implied permission of a colleague before adopting familiarity in conduct or language.

 

CIRCUMSTANCES WHICH ARE COVERED

This policy covers behaviour which occurs in the following situations:

1. a work situation
2. a situation occurring outside of the normal workplace or normal working hours which is related to work, for example, a working lunch or social event with colleagues;
3. outside of a work situation but against a colleague or other person connected to the Company, including on social media;
4. against anyone outside of a work situation where the incident is relevant to their suitability to carry out the role.

 

WHAT TO DO IF YOU OR A COLLEAGUE IS SUBJECT TO BULLYING OR HARASSMENT

The company is committed to ensuring that there is no harassment or bullying in the workplace. Allegations of harassment will be treated as a disciplinary matter, although every situation will be considered on an individual basis and in accordance with the principles of the grievance and disciplinary procedures, a copy of which is available from the COO.

• Informal complaint

We recognise that complaints of personal harassment, and particularly of sexual harassment, can sometimes be of a sensitive or intimate nature and that it may not be appropriate for you to raise the issue through our normal grievance procedure. In these circumstances you are encouraged to raise such issues with a senior colleague of your choice (whether or not that person has a direct supervisory responsibility for you) as a confidential helper. This person will not be the same person who will be responsible for investigating the matter if it becomes a formal complaint.

If you are the victim of minor harassment you should make it clear to the harasser on an informal basis that their behaviour is unwelcome and ask the harasser to stop. If you feel unable to do this verbally then you

should hand a written request to the harasser, and your confidential helper can assist you in this.

• Formal complaint

Where the informal approach fails or if the harassment is more serious, you should bring the matter to the attention of the COO or CEO as a formal written complaint and again your confidential helper can assist you in this. If possible, you should keep notes of the harassment so that the written complaint can include:

1. the name of the alleged harasser;
2. the nature of the alleged harassment;
3. the dates and times when the alleged harassment occurred;
4. the names of any witnesses; and
5. any action already taken by you to stop the alleged harassment.

On receipt of a formal complaint we will take action to separate you from the alleged harasser to enable an uninterrupted investigation to take place. This may involve a temporary transfer of the alleged harasser to another work area or suspension with contractual pay until the matter has been resolved.

The person dealing with the complaint will invite you to attend a meeting, at a reasonable time and location, to discuss the matter and carry out a thorough investigation. You have the right to be accompanied at such a meeting by your confidential helper or another work colleague of your choice and you must take all reasonable steps to attend. Those involved in the investigation will be expected to act in confidence and any breach of confidence will be a disciplinary matter.

On conclusion of the investigation, which will normally be within ten working days of the meeting with you, the decision of the investigator, detailing the findings, will be sent in writing to you.

You have the right to appeal against the findings of the investigator in accordance with the appeal provisions of the grievance procedure.

 

DISCIPLINARY ACTION

1. If the decision is that the allegation is well founded, the harasser will be liable to disciplinary action in accordance with our disciplinary procedure. An employee who receives a formal warning or who is dismissed for harassment may appeal by using our capability/disciplinary appeal procedure.
2. When deciding on the level of disciplinary sanction to be applied, we will take into consideration aggravating factors such as abuse of power over a more junior colleague.
3. If you bring a complaint of harassment you will not be victimised for having brought the complaint. However if it is concluded that the complaint is both untrue and has been brought with malicious intent, disciplinary action will be taken against you.

THIRD PARTY HARASSMENT

1. Third party harassment occurs when one of our workforce is subjected to harassment by someone who is not part of our workforce but who is encountered in connection with work. This includes our customers, supplier, members of the public. Third party harassment of our workforce will not be tolerated.
2. Should a stakeholder or service user harass a member of our workforce, they will be warned that continued provision of our service to them will cease if they are to act in a similar way again. Should their behaviour recur, they will be informed that our service to them will cease. Any criminal acts will be reported to the police, and we will share information relating to the incident with our other branches to ensure that we maintain a consistent approach to the cessation of our services.

INTRODUCTION 

Hospital Rooms is responsible for the safety of their staff and artists working on its Projects on NHS Wards and must ensure robust systems are in place for recognising, reporting, and responding to Serious Incidents that take place in NHS trusts involving Hospital Rooms staff or artists. This should be done in partnership with the NHS Trust where the work is taking place. 

NHS mental health wards can sometimes be unpredictable environments, caring for people who are experiencing severe mental health problems and may be aggressive or violent. As a consequence Hospital Rooms must work closely with the lead NHS contact (usually ward manager) for each project to ensure they are conscious of the safety of the environment they are working in. 

When an incident occurs, the immediate effects, and the aftermath, should be managed promptly and efficiently to protect life, prevent suffering and reduce damage. Then an appropriate investigation carried out to identify the causative factors, and plans put in place to prevent or reduce the likelihood of a reoccurrence. 

This policy applies to all artists and staff working on a Hospital Rooms project. 

 LEGAL RESPONSIBILITIES 

NHS Trusts have a legal obligation to provide a record of all accidents, and work –related illnesses, which affect staff and visitors to Trust premises, including patients. Also all NHS organisations are required to have a centralised system for collecting data on safety incidents. 

 

DUTIES 

The Hospital Rooms Board of Trustees is responsible for ensuring that Hospital Rooms has policies in place and complies with its legal and regulatory obligations. It is also responsible for ensuring policies are communicated to those working with Hospital Rooms, they are also responsible for monitoring incidents reporting. 

 AIMS 

• To give clear instructions to people working with service users through Hospital Rooms projects on their duties associated reporting and learning from incidents . 
• To clarify expectations in relation to the reporting of incidents and processes that follow after a concern has been raised. 
• To clarify the expectations in relation to training. 
• To outline the process in which Hospital Rooms monitors the effectiveness of the incident policies and procedures. 

DEFINITIONS 

WHAT IS AN INCIDENT? 

An incident is described as “any event which has given rise to potential or actual harm or injury, to patient dissatisfaction or to damage/ loss of property” (Ref: NHS Executive). 

This definition includes patient/service user injury, fire, theft, vandalism, assault and employee accident and near misses. It includes incidents resulting from negligent acts, deliberate or unforeseen. Also an unplanned or unexpected event in which a member of staff/contractor or the public has been, or could have been injured, killed, or suffer mental trauma, or led to loss or damage to equipment or property, or other financial loss. 

For example: 

• Unexpected / unexplained death 
• Absconsion by a detained patient 
• A member of staff or artist hurts his/her back 
• A member of staff or artist is subject to verbal or physical abuse 
• Fire on work premise 
• Theft, loss or damage to organisation or personal property 

WHAT IS A SERIOUS INCIDENT? 

• A serious incident that requires investigation could be defined as acts and/or omissions that have resulted in: 
• Unexpected or avoidable death, 
• Unexpected or avoidable injury that has resulted in serious harm or requires further treatment to prevent death or serious harm 
• Actual or alleged abuse 

WHAT IS A NEAR MISS? 

Any incident that had the potential to cause harm but was prevented or avoided, resulting in no harm to person or property. 

REPORTING 

Hospital Rooms staff must immediately report any incidents to the NHS Trust manager in charge of the area or service in which the incident occurred. The NHS manager is responsible for ensuring that an incident report (IR1) has been completed, and for more significant incidents a senior manager has been informed. Hospital Rooms staff member must also inform Niamh White and Tim A Shaw verbally or by email of the incident and the name of the NHS manager whom they have reported the incident to. This will then be reported to the board by the CEO. 

 

PROCEDURE 

1. Prior to starting a Hospital Rooms project with a trust, Hospital Rooms will ensure that a trust lead for incidents has been identified and that there is a named contact in the trust for staff on a project to raise concerns to. this will usually be the ward manager for the area where the project Is taking place 
2. All Hospital Rooms projects will be risk assessed via the application process prior to starting the project by the CEO. This will include identification of lead and ensuring the Trust has a visitors/contractor/ volunteers policy to cover artists and staff from hospital rooms 
3. All artists will be asked to read Safeguarding and Incidents leaflets provided by the trust and confirm they have done so. 
4. All artists will be expected to comply with trust policy and procedures around incidents, health and safety, safeguarding and risk. They will also be expected to comply with any advice from staff in relation to their safety and risk from patients 
5. Hospital Rooms will provide artists with induction information around incidents, safeguarding and health and safety through the policies. 
6. If an Incident occurs it must be immediately raised with Tim and Niamh who will inform the Board of Trustees. 
7. The incident or ‘near miss’ should be logged and recorded on the Bright Safe portal. 
8. A meeting to review should be held within 7 days of the incident occurring to investigate, identify any failings and devise and implement any new working practices to avoid recurrence. 
9. The Hospital Rooms leads will meet with the artists and named trust contacts at the end of each project to confirm if any incidents have been raised, and request feedback on the actions and learning from this from the Trust named link 
10. An Incident report will be included in the quarterly board papers & Trustees will review any incidents, learnings and actions at the Trustee meeting. 

TRAINING & SUPPORT 

All Hospital Rooms staff and artists will be required to undertake a DBS check before any contract commences. Hospital Rooms staff are required to have passed Safeguarding for Adult Awareness training and Safeguarding Children Awareness where appropriate during onboarding. 

Site Leads will have undergone further training in ‘Incident and Accident Reporting’ before attending site. All staff will be encouraged to report incidents where they feel comfortable. 

Where any additional training is required this will be assigned appropriately. 

Following any incident Hospital Rooms will provide counselling and support to staff, contractors and volunteers via the Health Assured program. 

Hospital Rooms (“We”) understands how important it is to protect your personal data and privacy. We use the information that we collect about you in accordance with the Data Protection Act 2018 (DPA 2018), the UK General Data Protection Regulation (UK GDPR) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR). 

Our full privacy notice is explained below, but our key data principles are: 

• We will only ever ask you for information that we really need to know. 
• We will provide clear, honest and open information about how we use your data. 
• We will give you choice about how we use your data. 
• We will use your data appropriately and in a way that you would reasonably expect. 
• We will never sell your data. 
• We will not share your data with third parties without your consent, or unless required in order to fulfil our contract with you, or allowed by law. 
• We will be accountable and responsible, and will ensure that the appropriate security measures are in place to protect any data you share. 
• We will ensure that our staff, volunteers, partners and artists understand these principles and their responsibilities in delivery them. 

WHO WE ARE 

Hospital Rooms is an arts and mental health charity that commissions world-class artists to create artworks for NHS mental health inpatient units across the UK. 

Our vision is for all people in mental health wards to have access to have the freedom to experience extraordinary artworks. We believe in the power of art to provide joy and dignity and to stimulate and heal. 

Hospital Rooms, Unit 404 Lock Studios, 7 Corsican Square, London E3 3YD  is a registered charity in England and Wales (charity number 1168101). 

 

OUR CONTACT DETAILS 

There are many ways you can contact us, including by post, email, and telephone. Our postal address: 

Hospital Rooms 

Unit 404 Lock Studios 7 Corsican SquareLondon 

E3 3YD 

Telephone Number: 07564639216

Email: info@hospital-rooms.com 

If you have any questions about how your data is used, data retention periods, or wish to be removed from any communications or data processing activities, please contact us using the details above.

THE TYPE OF PERSONAL INFORMATION WE COLLECT

We only collect the information that is necessary to carry out normal business operations and to provide any goods or services you’ve asked for.

Examples of the types of personal information that we collect and process include:

• Name, Title
• Contact details including postal address, email address and contact telephone number(s)
• Date of Birth
• Transaction history – we never store your credit card number (although we do keep a record of the last four digits to help us identify transactions)
• Taxpayer status (for Gift Aid purposes)
• Bank details (for regular giving)
• Technical information gathered when you visit our website, including, but not limited to, the Internet Protocol address (IP address) used to connect your device to the Internet, browser type and device type.

SPECIAL CATEGORY DATA

The UK GDPR singles out some types of personal data as likely to be more sensitive. We only collect sensitive data where we have gained your explicit consent.

Examples of the types of Special Category Data that we collect and process include as part of our Equal Opportunities recruitment:

• personal data revealing racial or ethnic origin;
• personal data revealing political opinions;
• personal data revealing religious or philosophical beliefs;
• data concerning health;
• data concerning a person’s sexual orientation.

Hospital Rooms uses the Disclosure and Barring Service (DBS) to help make safer recruitment decisions.

Special Category Data and Criminal Offence Data is subject to enhanced security measures, used only for the purposes agreed, and erased when no longer necessary.

HOW WE GET THE PERSONAL INFORMATION AND WHY WE HAVE IT

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• You want to volunteer for us.
• You wish to attend, or have attended, an event.
• You have made a donation or legacy pledge to us.
• You have purchased merchandise from our website or at an event 
• You have made a complaint or enquiry to us. 
• You have made an information request to us. 
• You enter research. 
• You apply to undertake a project with us on behalf of a mental health service provider. 

WHAT WE USE YOUR PERSONAL INFORMATION FOR 

We will only collect the personal data that we need and use it on relevant lawful purposes as permitted by current data protection legislation (DPA 2018, UK GDPR & PECR). 

We will use the information to: 

• Maintain our records and accounts. 
• Manage our volunteers. 
• Provide our services to the public. 
• Send you information about Hospital Rooms, keeping you informed about our work, campaigns (including fundraising activities), and events. 
• Process donations and payments made to us. 
• Fulfil orders and dispatch merchandise purchased from us. 
• Keep in touch about any legacy pledges you have made to us. 
• Make safer recruitment decisions. 
• Report to funders. 
• Engage with our supporters. 
• Carry our research and evaluation. 
• Process job applications. 

EMAIL & WEB ACTIVITY 

We keep a record of the emails and marketing information we send you. Through the use of the Mailchimp e-marketing platform and Salesforce CRM we may track whether you receive, open or forward our communications so that we can make sure we are sending you the most relevant information. 

We receive and store certain details whenever you use our website. We use “cookies” to help us make our site – and the way you might use it – better. Cookies mean that a website will remember you and enable online transactions. It also helps us understand how you use our website, where we can make improvements and how best to tell our audiences about events they might be interested in. Find more information on our Cookie Policy here. 

We use social media to broadcast messages and updates about events and news. On occasion we may reply to comments or questions you make to us on social media platforms. Depending on your settings or the privacy policies on social media and messaging services like Twitter, Instagram, Facebook or LinkedIn, you might give third parties (like Hospital Rooms) permission to access information from those accounts or services. 

 

FROM THIRD PARTIES 

Your information may be shared with us by other organisations and websites, but only when you have indicated that you give your consent to hear from us. You should check their Privacy Notice when you provide your information to understand fully how they will process your data. 

DATA PROFILING AND DATA FROM PUBLICLY AVAILABLE SOURCES 

To ensure that our fundraising activities are appropriate, we may carry out profiling techniques based on the information that we hold about you. If our research identifies that you may be willing and able to support us, we may gather more information about you such as professional history, affiliation with other charities and companies, trusteeships, and club and livery membership, from publicly available sources 

These sources could include, but are not limited to: 

• Companies House 
• Charity Commission 
• LinkedIn 
• Company websites 
• Recent press coverage 

This type of profiling allows us to target our resources effectively, to understand the background of the people who attend our events and those who support us. It helps us to make appropriate requests to customers and supporters who may be able and willing to give more than they already do. And importantly, it enables us to raise more funds, sooner, and more cost-effectively, than we otherwise would. If you would prefer us NOT to use your data in this way, you can ask us not to. 

SHARING YOUR INFORMATION 

We will not share any personal details with third parties without your consent, or unless required in order to fulfil our contract with you, or allowed by law. 

In general, any third party providers used by us to fulfil our contract with you will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. These providers include, but are not limited to, our fundraising platforms JustGiving and TotalGiving, our corporate purpose platform Benevity, our CRM platform Donorfy, our email provider Mailchimp, and our payment gateways Stripe Gateway, PayPal and GoCardless. We have agreements in place with each to ensure that your data is secure at all times, and cannot be accessed or used for any other purpose. 

The only other circumstances where we may share your information with selected third parties include: 

• Advertisers and advertising networks that require data to select and serve adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience. 
• Social media sites for the purposes of data analytics and targeted advertising. 
• Analytics and search engine providers that assist us in the improvement and optimisation of our site. 

LAWFUL BASES FOR PROCESSING 

Under the UK GDPR, the lawful bases we rely on for processing this information are. 

• We have your consent – you are able to remove your consent at any time by contacting data@hospital-rooms.com 
• We have a contractual obligation e.g. fulfilling and dispatching orders. 
• We have a legal obligation e.g. DBS checks, keeping records for HMRC. 
• We have a legitimate interest e.g. undertaking research, analysing donor/customer information. 
• We have a vital interest. 
• We need it to perform a public task. 

HOW WE STORE YOUR PERSONAL INFORMATION 

Your personal data will be held and processed on Hospital Rooms systems or systems managed by suppliers on behalf of Hospital Rooms. 

We maintain secure systems to hold contact details and a record of your interactions with us such as merchandise purchases, queries, complaints and attendance at events. Where possible we aim to keep a single record for each donor/customer. 

We will always seek to hold your data securely. Access to donor/customer information is strictly controlled and can only be accessed by people who need it in order to do their job. Certain data, for example sensitive information, is additionally controlled and is only made visible to members of staff who have a reason to work with it. 

Any payment transactions will be encrypted. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. 

We may need to disclose your details if required to by the police, regulatory bodies or legal advisors. 

We will only ever share your data in other circumstances if we have your explicit and informed consent as detailed above. 

 All information received by us is retrieved using secure technology. In order to provide a safe and secure environment for your personal information we use up to date technology with a view to protecting that information against loss, misuse or unauthorised alteration.  

Data is held by us for as long as is legally or practically necessary for our business. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. You can find out more about our retention policy by contacting data@hospital-rooms.com 

We will retain personal data of event attendees, donors and those who purchase merchandise from us, for two years without activity before anonymising it. 

Once that necessity is past we have a regular programme of data anonymisation. This ensures that your data is not held indefinitely on our systems. 

YOUR DATA PROTECTION RIGHTS 

Under data protection law, you have rights including: 

 

Your right of access 

You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which mean you may not always receive all the information we process. 

 

Your right to rectification 

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. 

 

Your right to erasure 

You have the right to ask us to erase your personal information in certain circumstances. 

 

Your right to restriction of processing 

You have the right to ask us to restrict the processing of your information in certain circumstances. 

 

Your right to object to processing 

You have the right to object to processing if we are able to process your information because the process forms part of our public tasks, or is in our legitimate interests. 

 

Your right to data portability 

This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. 

 

YOUR RIGHT TO BE INFORMED 

You have the right to be informed about the collection and use of your personal data. 

Your right to automated decision making including profiling 

The UK GDPR has provisions on: 

• automated individual decision-making (making a decision solely by automated means without any human involvement); and 
• profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process. 

You are not required to pay any charge for exercising your rights. We have one month to respond to you. Please contact us at data@hospital-rooms.com if you wish to make a request. 

GIVING YOU CONTROL 

We try to make it as easy as possible for you to tell us how you’d like to hear from us. You can withdraw your consent at any time by emailing info@hospital-rooms.com or calling 07863247051

If you have opted out of marketing communications, we may still get in touch with you. For example, we may email you to give you important information about the events you have booked or to tell you about any changes. 

How to complain 

If you have any concerns about our use of your personal information, you can make a complaint to us by contacting Kerry Bishop. You can contact them at kerry@hospital-rooms.com or via our postal address. 

You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address: 

Information Commissioner’s Office 

Wycliffe House Water Lane Wilmslow Cheshire 

SK9 5AF 

Helpline Number: 0303 123 1113 ICO Website: https://www.ico.org.uk 

INTRODUCTION 

We may have to collect and use information about people with whom we work. This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means. 

We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business. We will ensure that we treat personal information lawfully and correctly. 

To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR). 

This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our human resources function as described below. It also covers our response to any data breach and other rights under the GDPR. 

This policy applies to the personal data of job applicants, existing and former employees,  apprentices, volunteers, placement students, workers and self-employed contractors. These are referred to in this policy as relevant individuals. 

DEFINITIONS 

“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data. 

“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes). 

“Criminal offence data” is data which relates to an individual’s criminal convictions and offences. 

“Data processing” is any operation or set of operations which is performed on personal  data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 

DATA PROTECTION PRINCIPLES 

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that: 

1. processing will be fair, lawful and transparent 
2. data be collected for specific, explicit, and legitimate purposes 
3. data collected will be adequate, relevant and limited to what is necessary for the purposes of processing 
4. data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay 
5. data is not kept for longer than is necessary for its given purpose 
6. data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures 
7. we will comply with the relevant GDPR procedures for international transferring of personal data

TYPES OF DATA HELD 

We keep several categories of personal data on our employees in order to carry out effective and efficient processes. We keep this data in a personnel file relating to each employee and we also hold the data within our computer systems, for example, our holiday booking system. 

Specifically, we hold the following types of data: 

1. personal details such as name, address, phone numbers 
2. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter, references from former employers, details on your education and employment history etc 
3. details relating to pay administration such as National Insurance numbers, bank account details and tax codes 
4. medical or health information 
5. information relating to your employment with us, including: 
6. job title and job descriptions 
7. your salary 
8. your wider terms and conditions of employment 
9. details of formal and informal proceedings involving you such as letters of concern, disciplinary and grievance proceedings, your annual leave records, appraisal and performance information 
10. internal and external training modules undertaken 

All of the above information is required for our processing activities. More information on  those processing activities are included in our privacy notice for employees, which is available from your manager. 

EMPLOYEE RIGHTS 

You have the following rights in relation to the personal data we hold on you: 

1. the right to be informed about the data we hold on you and what we do with it; 
2. the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”; 
3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’; 
4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’; 
5. the right to restrict the processing of the data; 
6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’; 
7. the right to object to the inclusion of any information; 
8. the right to regulate any automated decision-making and profiling of personal data. 

More information can be found on each of these rights in our separate policy on employee rights under GDPR. 

RESPONSIBILITIES 

In order to protect the personal data of relevant individuals, those within our business who  must process data as part of their role have been made aware of our policies on data protection. 

We have also appointed employees with responsibility for reviewing and auditing our data protection systems. 

LAWFUL BASES OF PROCESSING 

We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity. 

Where no other lawful basis applies, we may seek to rely on the employee’s consent in order to process data. 

However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. Employees will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time. 

ACCESS TO DATA 

As stated above, employees have a right to access the personal data that we hold on them. To  exercise this right, employees should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit. 

No charge will be made for complying with a request unless the request is manifestly unfounded,  excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied. 

Further information on making a subject access request is contained in our Subject Access Request policy. 

DATA DISCLOSURES 

The Company may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include: 

1. any employee benefits operated by third parties; 
2. disabled individuals – whether any reasonable adjustments are required to assist them at work; 
3. individuals’ health data – to comply with health and safety or occupational health obligations towards the employee; 
4. for Statutory Sick Pay purposes; 
5. HR management and administration – to consider how an individual’s health affects his or her ability to do their job; 
6. the smooth operation of any employee insurance policies or pension plans; 
7. to assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders or to assess or collect any tax or duty. 

These kinds of disclosures will only be made when strictly necessary for the purpose. 

DATA SECURITY 

All our employees are aware that hard copy personal information should be kept in a locked filing cabinet, drawer, or safe. 

 Employees are aware of their roles and responsibilities when their role involves the processing of  data. All employees are instructed to store files or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops etc when unattended. No files or written information of a confidential nature are to be left where they can be read by unauthorised people. 

Where data is computerised, it should be coded, encrypted or password protected both  on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must itself be kept in a locked filing cabinet, drawer, or safe. 

Employees must always use the passwords provided to access the computer system and not abuse them by passing them on to people who should not have them. 

Personal data relating to employees should not be kept or transported on laptops, USB  sticks, or similar devices, unless prior authorisation has been received. Where personal data is recorded on any such device it should be protected by: 

1. ensuring that data is recorded on such devices only where absolutely necessary. 
2. using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted. 
3. ensuring that laptops or USB drives are not left where they can be stolen. 

Failure to follow the Company’s rules on data security may be dealt with via the Company’s  disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure. 

THIRD PARTY PROCESSING 

Where we engage third parties to process data on our behalf, we will ensure, via a data processing  agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data. 

INTERNATIONAL DATA TRANSFERS 

The Company does not transfer personal data to any recipients outside of the EEA. 

REQUIREMENT TO NOTIFY BREACHES 

All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach. 

More information on breach notification is available in our Breach Notification policy. 

TRAINING 

New employees must read and understand the policies on data protection as part of their induction.  

All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach. 

The nominated data controller/auditors/protection officers for the Company are trained appropriately in their roles under the GDPR. 

All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures. 

RECORDS 

The Company keeps records of its processing activities including the purpose for  the processing and retention periods in its HR Data Record. These records will be kept up to date so that they reflect current processing activities. 

DATA PROTECTION COMPLIANCE 

Our appointed compliance officer in respect of our data protection activities is: 

Kerry Bishop (Interim CEO) kerry@hospital-rooms.com

INTRODUCTION 

Our vision is for the Organisation to be a successful, caring and welcoming place for staff, artists and patients/service users. We want to create a supportive and inclusive environment where our staff & artists can reach their full potential and care is provided in partnership with patients/service users, without prejudice and discrimination. We are committed to a culture where respect and understanding is fostered and the diversity of people’s backgrounds and circumstances will be positively valued. 

This Policy will help us to achieve this vision. 

 

LEGAL RESPONSIBILITIES 

The rights of our staff and patients/service users with regards to discrimination are protected by anti-discrimination legislation. By adopting this Policy, we accept our responsibility to ensure that discrimination does not take place and that everyone is treated fairly and equally. 

 AIMS 

The aim of this Policy is to achieve equality of experience by removing any potential discrimination towards our staff and in the way that our patients/service users are cared for and treated by the Organisation, including preventing discrimination towards: 

• people with health conditions or impairments 
• people of different sexual orientations 
• transgender people 
• people of different races 
• people on the grounds of their sex 
• people of faith and of no faith 
• people in relation to their age 
• people in relation to their social class 
• people who are married or in a civil partnership 
• women who are pregnant, have recently given birth or are breastfeeding 

POLICY STATEMENT 

The terms equality, inclusion and diversity are at the heart of this policy. ‘Equality’ means ensuring everyone has the same opportunities to fulfil their potential free from discrimination. ‘Inclusion’ means ensuring everyone feels comfortable to be themselves at work and feels the worth of their contribution. ‘Diversity’ means the celebration of individual differences amongst the workforce. We will actively support diversity and inclusion and ensure that all our employees are valued and treated with dignity and respect. We want to encourage everyone in our organisation to reach their potential. 

We recognise that discrimination is unacceptable and although equality of opportunity has been a long standing feature of our employment practices and procedure, we acknowledge the importance of adopting a formal policy. Breaches of the policy will lead to disciplinary proceedings and, if appropriate, disciplinary action up to and including dismissal. 

The aim of the policy is to ensure no job applicant, employee, worker or stakeholder is discriminated against either directly or indirectly on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation. 

We will ensure that the policy is circulated to any agencies responsible for our recruitment and a copy of the policy will be made available for all employees and made known to all applicants for employment.  

The policy will be communicated to all private contractors reminding them of their responsibilities towards the equality of opportunity. 

The policy will be implemented in accordance with the appropriate statutory requirements and full account will be taken of all available guidance and in particular any relevant Codes of Practice. 

We will maintain a neutral working environment in which no employee or worker feels under threat or intimidated. 

 

PUTTING THIS POLICY INTO PRACTICE 

We aim to develop and support equality and diversity measures by: 

• Providing patients/service users with information in a variety of languages, if required 
• Providing services that are accessible to staff and patients/services users with health conditions or impairments 
• Involving staff and patient/service user groups and individuals in the design of our service 
• Responding positively to the diverse needs and experiences of our staff and patients/service users and the community even when those needs are challenging to deal with. 

RECRUITMENT & SELECTION 

The recruitment and selection process is crucially important to any equality, inclusion and diversity policy. We will endeavour through appropriate training to ensure that employees making selection and recruitment decisions will not discriminate, whether consciously or unconsciously, in making these decisions. 

All decisions in relation to promotion and advancement will be made within the overall framework and principles of this policy.  

Job descriptions, where used, will be revised to ensure that they are in line with this policy. Job requirements will be reflected accurately in any personnel specifications. 

We will adopt a consistent, non-discriminatory approach to the advertising of vacancies. 

We will not confine our recruitment to areas or media sources which provide only, or mainly, applicants of a particular group. 

All applicants who apply for jobs with us will receive fair treatment and will be considered on their ability to do the job. 

All employees involved in the recruitment process will periodically review their selection criteria to ensure that they are related to the job requirements and do not unlawfully discriminate. 

Short listing and interviewing will be carried out by more than one person where possible. 

Interview questions will be related to the requirements of the job and will not be of a discriminatory nature. 

 We will not disqualify any applicant because they are unable to complete an application form unassisted unless personal completion of the form is a valid test of the standard of English required for the safe and effective performance of the job. 

Selection decisions will not be influenced by any perceived prejudices of other staff. 

TRAINING & PROMOTION 

Senior staff will receive training in the application of this policy to ensure that they are aware of its contents and provisions. 

All promotion will be in line with this policy. 

COMMENTS AND CONCERNS 

If you believe you have been treated in any way contrary to this Policy or you have any comments on how we can ensure that it works better, please contact the Interim CEO, Kerry Bishop (kerry@hospital-rooms.com) We will investigate your concerns and take appropriate action. 

INTRODUCTION 

A complaint is a formal expression of discontent where something about the service is unsatisfactory or unacceptable. 

Hospital Rooms is committed to ensuring that its work is of the highest quality. The complaints policy and procedures allow Hospital Rooms to record and review its work, to enable continuous learning and improvement for its future. 

PURPOSE 

The purpose of this policy is to ensure that people have the opportunity to make complaints about the service and work of Hospital Rooms should they need to, that all complaints are taken seriously, investigated diligently and objectively; and that the outcome is clearly communicated to the complainant. 

POLICY 

Our policy is: 

• To provide a complaints procedure which is fair, easy and as transparent as possible. 
• To publicise the existence of our complaints procedure so that people know how to contact us to make a complaint. 
• To ensure complainants are treated with respect and courtesy and receive appropriate support throughout the handling of the complaint. 
• To make sure all complaints are investigated efficiently, appropriately and within the agreed time frame. 
• Wherever possible to make sure that complaints are resolved and that relationships are repaired. 
• To learn from complaints and use the procedure to improve Hospital Rooms’ work and drive forward a culture of continuous improvement. 

PROCEDURE 

MAKING A COMPLAINT ABOUT HOSPITAL ROOMS COMPLAINTS (Other than regarding CEO)

STAGE ONE (INFORMAL) 

• To make an initial complaint (Stage 1), please speak to or email the individual(s) concerned (if you feel comfortable doing this) or their line manager and Hospital Rooms will respond to your complaint and let you know of any remedial action that is to be taken. 
• If you do not know who to contact or you do not want to contact the individual(s) involved or their line manager, please email Tim (CEO) at tim@hospital-rooms.com” 
• Hospital Rooms will acknowledge your complaint (usually by email if provided) within 3 working days. 
• In order for us to resolve your issue to the best of our ability, please include as much detail as possible regarding your complaint, including any relevant communications or documentation. 
• We will endeavour to respond to Stage 1 complaints within 7 working days. 

STAGE TWO (FORMALLY REGISTERING A COMPLAINT) 

• If you are not satisfied with the response you receive at Stage 1, or you would prefer your complaint to be formally investigated, you can request your complaint to be escalated to Stage 2, either through your contact at Stage 1, or directly to the CEO. 
• Please submit the details of your complaint verbally by telephone or in person, or by emailing the Interim CEO, Kerry Bishop (kerry@hospital-rooms.com) or in writing FAO: CEO, Hospital Rooms, Unit 404, 7 Corsican Square, London, E3 3YD 
• Hospital Rooms will acknowledge your complaint (usually by email if provided) within 3 working days. 
• Hospital Rooms will write to you within 10 working days from the date of the complaint or will write to you within this period with an alternative reasonable time frame stating the reasons for this extended period. 
• If you are not satisfied with the response to your complaint, you will be given the opportunity to speak to the CEO or Director and given the option to appeal (Stage 3). 

STAGE THREE (APPEAL) 

• To appeal, please outline the reasons for your dissatisfaction in writing or electronically to the Chair of Trustees. 
• The Chair will make the final decision of the complaints process. They will review the investigation(s) conducted, make any further enquiries and/ or investigation considered necessary and then deliver their final decision with reasons. 
• The Chair will write to you within 20 working days from the date of the appeal or will write to you within this period with an alternative reasonable time frame stating the reasons for this extended period. 

COMPLAINTS REGARDING A CEO or DIRECTOR 

If a complaint is about the CEO or Director then it should be addressed to Amie Corry who is responsible as Chair of the Board of Trustees of the organisation. 

MAKING A COMPLAINT ABOUT A SERVICE OR HOSPITAL 

Complaints received about a hospital, their staff or their volunteers will be directed to the relevant NHS Trust or organisation who should instigate their own complaints policy and procedures. Depending on the nature of the complaint against a partner hospital, Hospital Rooms may also decide to investigate. 

To make a complaint please speak to or email your Hospital Rooms primary contact or the CEO (see above for details). 

Hospital Rooms will acknowledge your complaint within 3 working days and pass to the relevant NHS Trust or organisation. 

CONFIDENTIALITY 

All complaint information will be handled sensitively in line with our Privacy Policy, telling only those who need to know and following any relevant data protection requirements. 

FUNDRAISING REGULATOR 

If you are dissatisfied with Hospital Rooms’ response to your fundraising complaint you can contact the Fundraising Regulator to access their independent complaints procedure. 

 

CHARITY COMMISSION 

If you are dissatisfied with the outcome of the Hospital Rooms’ complaints process, you can contact the Charity Commission to raise a concern. 

https://forms.charitycommission.gov.uk/raising-concerns/ 

INTRODUCTION 

Hospital Rooms aims to be an environmentally active and conscious organisation. We aim to consider our organisations and teams impact on the environment and minimise this wherever possible. We will do this by a culture of care and open discussion as well as active choices and actions to minimise our negative impact on the environment. 

The Organisation’s policy is to comply or exceed the requirements of environmental legislation and regulation.

The Organisation’s policy is to comply or exceed the requirements of environmental legislation and regulation. 

 

GREEN TEAM 

Hospital Rooms has set up a ‘Green Team’, this team is led by our Projects Manager, 2 of our Project Curators. Our trustee Elizabeth Neilson chairs bi-annual meetings for this . 

POLICY 

The specifics of our environmental policy are as follows: 

We aim to: 

• Comply with all relevant regulatory requirements. 
• Monitor and reduce our environmental impact. 
• Increase employee awareness and monitor our environmental performance. 

ENERGY & WATER 

• We will seek to conserve resources, use suppliers that are environmentally conscious and renewable. 
• Implement a switch off policy for all electronic equipment. 

PAPER 

• We will recycle and purchase recycled. 
• We will encourage a minimal printing culture. 

ART MATERIALS 

• We will aim to source recyclable materials where possible 
• We will use the least polluting materials available. 
• We will use carbon neutral paint for site installs 

TRANSPORT 

• We will plan and use the least polluting method possible. 
• Including prioritising staff travelling my public transport and shared vehicles, art transport to be kept to a minimum and road and sea used before any other. 

PACKAGING 

• We will aim to use recycled / compostable materials wherever possible. 

MAINTENANCE / CLEANING 

• Use non-polluting, green products. 
• Reuse/recycle equipment from computers to cleaning cloths. 
• Buy most environmentally sound option at every renewal. 

MONITORING & IMPROVEMENT 

• The Green Team will continue to monitor and improve every 6 months. 
• We will review this policy at the annual group meeting and adapt where necessary to ensure we are holding ourselves to the highest possible standards.