Our Policies



This policy relates to learners and each member of staff and others connected with working for HWGTA.

Formal definition:

When collecting personal data from data subjects HWGTA must ensure that its learners, staff and others such as suppliers, customers and applicants are aware of what will be collected and how it will be used. It is the responsibility of all staff that are collecting, using and storing data that they are at all times accurate (within reason) and compliant with any relevant data protections laws.

This policy sets out how HWGTA uses and protects any information that is given to us during your time with the Association.

HWGTA is committed to ensuring that privacy is protected. Should HWGTA ask for certain information by which you can be identified then you can be assured that it will only be used in accordance with this policy.

What we collect:

We may collect the following information:

  • Name, address, post code and date of birth
  • Contact information including telephone numbers, email address and next of kin
  • Demographic information such as preferences and interests
  • Gender, ethnicity, health related and disability related information
  • Other information relevant to customer surveys and/or offers
  • Where photos are taken of Apprenticeship applicants, these are taken with the learners consent and only for identification purposes. Under no circumstances will images be used as part of a selection process.

What we do with the information we gather:

We require this information to be compliant with external requests and to understand needs and provide staff and learners with a better service, and in particular for the following reasons:

  • Monitoring of equality and diversity
  • To ascertain eligibility for programmes and funding
  • Provide external stakeholders such as funding bodies, awarding organisations and inspection bodies with information
  • Internal record keeping
  • We may use the information to seek feedback and improve our services
  • We may periodically send emails about events, send newsletters or other information which we think you may find interesting using the contact details which you have provided
  • From time to time, we may also use your information to contact you for research purposes


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

If in the unlikely event of personal data being lost or stolen, any individuals effected will be informed.

Links to other websites:

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information:

If you have previously agreed to us using your personal information you may change your mind at any time by writing to us or emailing us at info@hgta.org

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

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee may be payable.  Any requests must be formally made in writing to the Chief Executive.

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


This policy will be reviewed every three years by the management team and quality team.

Duane Sanger -Chief Executive (August 2014)


Herefordshire and Worcestershire Group Training Association is committed to eliminating discrimination and encouraging diversity amongst our workforce and learners.  Our aim is that our workforce and learners will be truly representative of all sections of society and each employee and learner feels respected and able to give of their best.

To that end, the purpose of this policy is to provide equality and fairness for all in our employment or participating in our training programmes and not to discriminate on grounds of: age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; sexual orientation.

We oppose all forms of unlawful and unfair discrimination.

All employees and learners, whether part-time, full time or temporary, will be treated fairly and with respect, Selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability.  All employees will be helped and encouraged to develop to their full potential and the talents and resources of the workforce/learners will be fully utilised to maximise the efficiency of the organisation.

Our commitment:

  • To create an environment in which individual differences and the contributions of all staff and learners are recognised.
  • Every employee and learner is entitled to a working environment that promotes dignity and respect to all. No intimidation, bullying or harassment will be tolerated.  For specific examples and details refer to the Association’s separate Bullying and Harassment Policy.
  • Training, development and progression opportunities are available to all staff and learners.
  • Equality in the workplace is good management practice and makes sound business sense.  All of the Association’s practices and procedures will be reviewed at least once annually to ensure fairness. An action plan for improvements will be devised and monitored through the Self Assessment Process
  • Breaches of our Equality and Diversity policy will be regarded as misconduct and could lead to disciplinary proceedings.
  • The Association will ensure, so far as is reasonably practicable, that each training placement and off-the-job training provider used, abides by current legislation with regard to equality of opportunity and, if it discovers any breach that is not immediately rectified, will cease to use that placement or provider.
  • Where appropriate, positive measures will be taken to overcome under-representation in specific occupational areas.
  •  Under the Equality Act 2010, reasonable adjustments are required where disabled staff, learners or visitors personally experience substantial disadvantage in comparison with non-disabled people. These will be negotiated at individual level and where this involves a learner, we will ensure that learning outcomes are met without academic standards being compromised.

This policy is fully supported by the Executive Committee and senior managers and has been agreed with staff and learners


The Association will use its best endeavours to safeguard learners deemed to be ‘children’ through the implementation of this policy.  Children are learners under 19 years of age and school pupils taking part in vocational training with the Association.

The Association will ensure, so far as is reasonably practicable that any placement used is aware of, and complies with the requirements of this Safeguarding policy.

Placement providers for learners under 19 will be reviewed on an individual basis to assess and minimise risk.

Staff and placement providers will receive guidance and where appropriate training on child protection issues.

H/WGTA’s Obligations

As a training provider we have a legal responsibility to safeguard all learners in our care.   In order to do this we will ensure that all employees are registered with the Independent Safeguarding Authority (ISA) and that an enhanced Disclosure and Barring Service (DBS) check is obtained before any appointment is made.   Those already in employment at H/WGTA have had enhanced DBS checks undertaken and will be registered with ISA as soon as this facility becomes available.

Part of our commitment to Safeguarding is ensuring that everyone is aware of the organisation’s policies, procedures and systems.   Every allegation that is made must be taken seriously and the correct action and steps must be taken.

As a Training Provider we have certain obligations that we must carry out to ensure the safest working environment we can for both learners and employees. We must make sure that:

There is a comprehensive and effective safeguarding policy in place

  • There is a designated person who deals with safeguarding
  • There are effective measures to ensure safer recruitment for staff.

Staff at H/WGTA will all go through formal safeguarding training and procedures will be in place to ensure that the dissemination of safeguarding information is effective and efficient.

It is also a moral obligation to report any concerns about learners OR colleagues regardless of their age

Learners and employers will receive an information booklet on safeguarding, whenever a new start occurs.

The Designated Person


The Designated People at Herefordshire and Worcestershire Group Training Association are Stuart Griffiths, Rachel Payne and Grahame Davies.  (Current as of October 2016)

Dave Hider, Workforce Development Manager has overall responsibility for safeguarding. A member of the Associations board also has special responsibility for safeguarding.

A Designated Person is a member of staff who will take responsibility for safeguarding in the company.  They will deal with and be responsible for all safeguarding procedures and will act on any concerns that are raised.   If the designated person decides to further investigate any allegation that is raised, they will appoint a member of staff to conduct the process.

The Designated Person’s responsibilities will include;

  • Taking responsibility for promoting positive safeguarding procedures and practices within the organisation.
  • Receiving information from, and offer advice to staff, learners and employers.
  • Maintaining secure records in relation to safeguarding issues and allegations.
  • Assessing information promptly and taking appropriate action.
  • Being familiar with national and local safeguarding legislation.
  • Knowing who to contact and establish links with their local Safeguarding Children’s Board and the relevant people within children and adult services or police.

If there is a problem regarding the Designated Person, the Chief Executive or any one of the current management team can be approached.

The Employers Obligations

Each employer also has a responsibility to ensure the safeguarding of learners in their employment.   We accept that learners will take part in one to one contact when in company and it would be impractical to expect the employer to DBS check every employee that may come into contact with the learners, but we will require an assurance that the employer is committed to safeguarding and has all the relevant information required to enable them to identify the signs and know how to act.  If an employer has any concerns they can report it to any member of H/WGTA staff (e.g. field/reviewing officer) or directly to a Designated Person.   If H/WGTA has a concern, they will raise the issue with the company representative and agree a course of action.

H/WGTA can refuse to work with and withdraw the services provided to any employer who breaches their commitment to safeguarding.   They will also inform the relevant external agencies of any concerns.

The Learners’ Obligations

Whilst there are not any obligations by law, H/WGTA will expect all learners to be vigilant and aware of the signs of potential abuse and report anything they feel is suspicious.   We will expect all learners to report issues related to themselves and also related to their fellow learners.

Residential Policy

As part of training most Apprentices will attend a five day personal development residential course.  The safeguarding procedures in place for this are:

  • Risk assessment is carried out by the outdoor centres used on their activities and environment and checked annually before the residential weeks commence, by the member of HWGTA staff who has been appointed as a lead on the residential week
  • Sleeping arrangements in the centres for learners are divided by gender and no learners will sleep in isolation
  • HWGTA members sleep separately to learners, but in close enough proximity to monitor safety. HWGTA Staff will be located near to same gender learners for monitoring purposes.
  • Sleeping arrangements when whole group is together in an outdoor environment is divided by gender.  There will always be at least one member of HWGTA staff plus one or more members of activity centre staff present when learners are sleeping in an outdoor environment.
  • Where a learner is deemed as having potential or actual safeguarding issues, a risk assessment will be carried out prior to attending and appropriate support measures put in place
  • HWGTA will ensure that where we have female learners present on residential week we have female members of staff also present
  • HWGTA will ensure that where we have male learners present on residential week we have male members of staff also present
  • Learners will be issued with and expected to sign a code of conduct relating to safeguarding issues and expected conduct.  Alcohol and sexual activity is prohibited for all apprentices when attending residential, regardless of age.
  • HWGTA staff will work with centre staff to ensure a safe environment including regular reviews on weather and environmental conditions

E –communication

Communication between staff and Apprentices using personal social networking platforms such as Facebook and Twitter is strictly prohibited.   Staff may only use official company social networking accounts to communicate one way with Apprentices, ie to send out or publish information rather to engage in any “chat” or conversation.

HWGTA staff may use text messaging and email to contact Apprentices for matters relating to their Apprenticeship only.

Personal relationships with Apprentice Learners

Personal relationships between staff and Apprentice learners are strictly prohibited.

Existing personal relationships, eg a family member, friend of the family, member of a cricket/football/netball team must be declared by the staff member to their line manager in writing prior to the learner joining the programme

Physical Training

Physical training occurs within the first year engineering programme, predominantly through road running with additional time spent in a gymnasium environment. In order to protect the safeguarding of participant learners:

Risk assessment of individual participant abilities

  • Risk assessment of running routes
  • Risk assessment of gymnasium or other environments used for PT
  • Separate changing facilities for staff and learners

Learner Risk Assessment

A central record including support measures will be held of any learners who are deemed to be vulnerable or at risk.


This policy will be reviewed annually to ensure the Association is compliant with legislation and best practice expectations.

D SANGER  Chief Executive (October 2016)