Please find below all of our policies.

Name	Version no.	Date
Health & Safety Policy Statement of Intent	16	05.01.26
Anti Bribery and Corruption Policy	14	05.01.26
Bullying & Harassment Policy	3	05.01.26
Corporate Social Responsibility	14	05.01.26
Customer Feedback Policy	15	05.01.26
Data privacy policy	17	05.01.26
Environmental Policy	14	05.01.26
Equality & Diversity Policy	14	05.01.26
Grievance, Complaint & Appeals Procedure	15	05.01.26
Initial Assessment Policy	13	05.01.26
Malpractice & Maladministration Policy	13	05.01.26
Modern Slavery and Human Trafficking Statement	2	05.01.26
Modern Slavery and Human Trafficking Due Diligence Procedure	2	05.01.26
Quality Policy Statement	14	05.01.26
Reasonable Adjustment & Special Consideration Policy & Procedure	13	05.01.26

The Health & Safety Policy is available from HSF Training Ltd’s office. The current version is version 16, dated the 5^th January 2026

 

HSF Training Ltd

      Health & Safety General Policy Statement of Intent

Our policy is to provide and maintain safe and healthy working conditions for all our employees, providing them with suitable and sufficient conditions, equipment, training, information, supervision and safe systems of work as they need to perform all our work activities.

We also accept our responsibilities for the health and safety of our students and other persons not employed by ourselves who may be affected by our work activities.

We will ensure that adequate employer’s and public liability insurances will be in place at all times and that a minimum indemnity limit of £10,000,000 will be in place for employer’s liability and £5,000,000 for public liability.

Where required all risks will be assessed and all employees who may be affected will be made aware of the level of risk involved and control measures required. All actions shown to be necessary to eliminate or reduce risk will be implemented.

Any work activities that may endanger the health of any employee will be monitored and, where necessary, arrangements made for their health surveillance.

The responsibilities and duties of management and particular arrangements for health and safety will be clearly defined within this policy.

We plan to minimise the risk created by our work activities and organise ourselves in a way which will secure involvement and participation at all levels, measuring performance against our pre-determined standards. Our commitment to this policy will assist us to develop a positive health and safety culture. Additionally, we keep up to date with legislation and industry standards.

Our policy will be reviewed each year and, if required, amended to meet any changes to our business or nature of work.

Name:           Mr Keith Hutchinson CMIOSH

Signature:

Date:              5^th January 2026

Position:        Director, HSF Training Ltd

 

                    Anti-Bribery and Corruption Policy

HSF Training Ltd expect all representatives of the company to behave in a manner which upholds high standards of behaviour and ethics at all times.

HSF Training Ltd therefore prohibits:

• The acceptance of bribe by any of our employees or anyone else associated with our business for any reason.
• The proffering of a bribe by any of our employees or anyone else associated with our business for any reason.
• Acting in a manner which could be interpreted as corruption, i.e. the abuse of power for gain.

Our business operations sometimes involve our employees working overseas. No matter the local practices present, company representatives are expected to ensure they adhere to the ethics of the company.

This policy is not meant to prohibit the following practices providing they are customary, proportionate and properly recorded:

• normal and appropriate hospitality
• the giving of a ceremonial gift on a festival or at another special time
• the use of any recognised fast-track process which is available to all on payment of a fee.

The prevention, detection and reporting of bribery or corruption is the responsibility of all persons within or associated with HSF Training Ltd. Any such reports should be made to the directors at the earliest possible opportunity.

A zero tolerance approach will be shown to any individual within the company or acting in the company’s behalf which could be constituted to be a breach of this policy.

J. Hutchinson & K. Hutchinson

Directors, HSF Training Ltd
5^th January 2026 (Version 14)

 

Bullying and Harassment Policy

HSF Training Ltd is committed to providing a working environment that is free of harassment and bullying, and where everyone is treated, and treats others, with dignity and respect. We will not permit or condone any form of bullying or harassment.

This policy covers bullying or harassment of or by anyone engaged to work at HSF Training Ltd, and also by third parties such as customers or suppliers. The policy encompasses bullying or harassment that occurs in the workplace, and also out of the workplace, such as at on business trips or at work-related social events.

This policy does not form part of a contract of employment, and we may amend it at any time.

What is harassment?

Harassment is any unwanted physical, verbal or non-verbal conduct 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. A single incident of this nature can amount to harassment if sufficiently serious.

Unlawful harassment may involve sexual harassment, or it may be related to any other of the Protected Characteristics detailed in our Equal Opportunities policy (age, disability, gender, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation). Our stance is that harassment is unacceptable, whether or not it is targeted at any of these categories.

Examples of harassment may include (but are not limited to) the following:

• Display or circulation of sexually suggestive material or material with racial overtones.
• Use of slang names for racial groups, age groups, or for disabled persons.
• Professional or social exclusion.
• Unwanted physical conduct, such as touching, pinching, pushing and grabbing.
• Unwelcome sexual advances or suggestive behaviour.
• Offensive emails, text messages or social media content.

It is important to note that harassment occurs even if the harasser perceives his/her behaviour as being harmless and without malice, or ‘just a bit of fun’. What matters is how the behaviour makes the recipient feel, and not what the perpetrator’s intentions were. Also, a person may be harassed even if they were not the intended ‘target’ of the behaviour. For example, a man may be harassed by sexist jokes about women if the jokes create an environment that is offensive to him.

What is bullying?

Bullying is a sustained form of psychological abuse. It is defined as offensive, intimidating, malicious or insulting behaviour, involving the abuse or misuse of power, which has the purpose or effect of belittling, humiliating or threatening the recipient.

Workplace bullying usually takes one of three forms: physical, verbal or indirect. It can range from extreme forms such as violence and intimidation to less obvious actions, such as professional or social exclusion.

Examples of bullying may include (but are not limited to) the following:

• Shouting or swearing at people in public or private.
• Spreading malicious rumours.
• Inappropriate derogatory remarks about someone’s performance.
• Physical or psychological threats.
• Constantly undervaluing effort.
• Rages, often over trivial matters.
• Ignoring or deliberately excluding people.
• Overbearing and intimidating levels of supervision.
• Deliberately sabotaging or impeding work performance

Please note that managers are duty-bound to give their team members feedback and to generally manage their performance. Legitimate, reasonable and constructive criticism of a team member’s performance or behaviour, or reasonable instructions given to an employee in the course of their employment, will not amount to bullying on their own.

What to do if you are being harassed or bullied

Informal approach

You may be able to sort out matters informally. The person may not know that their behaviour is unwelcome or upsetting, so an informal discussion may help them to understand the effects of their behaviour and agree to change it.

If you feel able to, tell the person what behaviour you find offensive and unwelcome, and say that you would like it to stop immediately. You should keep a note of the date and what was said and done. This will be useful if the unacceptable behaviour continues and you wish to make a formal complaint.

If this is too difficult for you, then please talk to your manager, or a trusted colleague, for advice and assistance. They may, for example, speak to the person concerned on your behalf, or accompany you when you speak to them.

If the informal approach is not appropriate, or has not been successful, you should raise a formal grievance.

Formal procedure

When a team member feels that they need to deal with an issue of harassment or bullying formally, they should do so according to HSF Training Ltd’s Grievance, Complaint & Appeals procedure.

We will investigate complaints in a timely, confidential and sensitive manner. Where possible, the investigation will be conducted where possible by someone with appropriate seniority and experience, and no prior involvement in the complaint. Details of the investigation, and the names of the people involved, will only be disclosed on a ‘need to know’ basis. We will consider whether any steps are necessary to manage the ongoing working relationship between you and the person accused during the investigation.

Once the investigation is complete, we will inform both parties (separately) of our decision. Whether or not your complaint is upheld, we will consider how best to manage any ongoing working relationship between you and the person concerned.

Consequences of a breach of this policy

If after due investigation we consider that a team member has been harassed or bullied by an employee the matter will be dealt with under the disciplinary procedure as a case of possible misconduct or gross misconduct. The person concerned may be suspended on full pay during the disciplinary investigation until any eventual disciplinary proceedings have been concluded. If the complaint of bullying or harassment is upheld, a disciplinary penalty may be imposed up to and including dismissal, depending on the seriousness of the offence and all relevant circumstances.

Some bullying or harassment will constitute unlawful discrimination if it relates to any of the Protected Characteristics as detailed above and in our Equality & Diversity policy. Such behaviour could constitute a criminal offence, punishable by a fine and/or imprisonment.

Where it is found that an employee has been harassed by a third party, such as a customer, supplier or independent contractor, HSF Training Ltd will take such steps as are reasonably practicable to prevent any recurrence.

If someone makes a complaint which is not upheld, and HSF Training Ltd has good grounds for believing that the complaint was not made in good faith, we will take disciplinary action against the person making the false complaint.

Protection and support for those involved/whistleblowers

Team members who make complaints in good faith, or who participate in any investigation must not suffer any form of retaliation or victimisation as a result. Any employee engaged in retaliation will be subject to disciplinary action.

Record keeping

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

How we can all help to stop bullying and harassment

We all have a shared responsibility to help create and maintain a working environment free of bullying and harassment. You can do this by:

• Considering how your own behaviour may affect others and changing it.
• Being receptive, rather than defensive, if asked to change your behaviour.
• Treating your colleagues with dignity and respect.
• Taking a stand if you think inappropriate jokes or comments are being made.
• Making it clear to others when you find their behaviour unacceptable.
• Intervening, if possible, to stop harassment or bullying, and giving support to victims.
• Reporting harassment or bullying to your manager or another appropriate officer of HSF Training Ltd
• Being open, honest and objective in any investigation of complaints.

Managers have a particular responsibility to:

• Set a good example by their own behaviour.
• Ensure that there is a supportive working environment in their team.
• Communicate to team members what standards of behaviour are expected from them.
• Intervene to stop bullying or harassment.
• Report promptly to a Director any complaint of bullying or harassment.

J. Hutchinson & K. Hutchinson

Directors, HSF Training Ltd
5^th January 2026 (Version 3)

 

Corporate Social Responsibility Policy

At HSF Training Ltd, we recognise that our business activities do impact on our community and environment. We believe that every business and individual must accept responsibility for their own activities. We therefore aim to do whatever we can to contribute in a positive way to our community and minimise any negative impact on our environment.

We do this by the following means.

Environment

• Reusing items as far as is possible within the office – e.g. scrap paper, packaging materials
• Minimising handouts by, for example, ensuring all paperwork is printed double sided, wherever possible
• Switching off electrical items when not in use
• Invest in newer, more energy efficient technology, where this is available and economically viable
• Only printing emails and other documents where absolutely necessary
• Segregating our office waste and recycling in line with currently available facilities
• Car sharing for journeys where this is a possible option
• Communicating by email with our clients and others, such as for the issuing of invoices or training updates.

Community

• Promoting health, safety and hygiene awareness throughout all of our courses and the benefits of these

to the wider community

• Supporting a local riding for the disabled charity
• Supporting local charities by offering reduced training rates, where possible.

CSR values are promoted to employees and form an integral part of our day to day business practices.

J. Hutchinson & K. Hutchinson

Directors, HSF Training Ltd
5^th January 2026 (Version 14)                                                                 

                                                       

Customer Feedback Policy

The purpose of this policy is to detail how we deal with feedback from our customers. This policy explains:

• How customers can report their feedback
• How we deal with this feedback
• What timescales are involved in communicating feedback responses
• How we learn from the feedback received.

What is Customer Feedback?

We label all feedback received from users of the services provided as customer feedback. Feedback is categorised as being a compliment, comment or complaint.

How can our customers give us feedback?

• By telephone: 0191 502 2515
• By post: Directors, HSF Training Ltd, The Hub, New Century House, Crowther Road, Washington, Tyne & Wear, NE38 0AQ
• By e-mail: admin@hsftraining.co.uk
• Via completion of post event evaluation forms available at the training venue.

What happens when we receive feedback?

All feedback is categorized as a compliment, complaint or comment.

All feedback requiring action is delegated to relevant personnel within 48 hours of receipt.

What happens when we receive a compliment, complaint or comment?

Where applicable, for compliments and comments the customer will receive an acknowledgement letter or email specifying to whom the feedback has been directed and thanking them for their comments. The customer may receive further communication from the relevant personnel depending upon the matter.

Our staff are encouraged to resolve complaints on the spot to the satisfaction of the complainant. Our grievance/complaint & appeals procedure should be implemented where this is not possible, or where the complainant requests this be followed up by further action.

J. Hutchinson & K. Hutchinson

Directors

HSF Training Ltd
5^th January 2026 (Version 15)

 

Data Privacy Policy

HSF Training Limited uses the following methodology to demonstrate its commitment to ensuring data security, personal and customer privacy and its alignment to the requirements of the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 in respect of handling and processing personal data.

Our contact details are:

HSF Training Ltd can be contacted by:

Phone: 0191 5022515

Email: admin@hsftraining.co.uk

Post: The Hub, New Century House, Crowther Road, Washington, Tyne & Wear, NE38 0AQ

Data collection:  HSF Training Ltd (HSF) is registered with the UK Information Commissioner’s Office as a Data Controller. Its registration number is Z8876123. We have conducted a risk assessment and determined our lawful basis for processing personal information as Legitimate Interests.

We will collect data provided to us from our individual and contract clients and suppliers. Personal data may be included in the data you provide about learners and client/supplier employees and contacts. It is important that contractual arrangements are made with those individuals and they are made aware that by adding individuals’ personal data to HSF Training Ltd’s systems or by sending personal data via email or by other methods to HSF Training Ltd, they give consent to us processing the data and they confirm that they have obtained the appropriate consent from the relevant individuals for the personal data to be processed using HSF Training Ltd’s Learner system.

HSF Training Ltd will retain and use this data to perform the contract between us whilst you remain a customer and may use it further where it is within our legitimate interests, for example where an Awarding Organisation suspects malpractice.

We do not sell personal information about any of our customers, to any party, for any reason.

Personal data (learner)

• May be collected following information requests from HSF Training Ltd to respond to correspondence, provide information on other products/services in accordance with communication preferences, improve customer service, to meet contractual commitments, to notify clients about any changes to the site or our services, such as improvements or changes that may affect either;
• Information may be provided to us with personal data about learners when learner details are added to courses. The personal data is usually limited to the details required for us to undertake the basic functions of an accredited training centre and the certification process.
• These details will usually include a learner’s name, date of birth, gender and qualification awarded. In line with our regulatory/awarding body requirements and requirements to deliver future services such as certificate re-prints and the confirmation of awards, this basic learner-level data will be held by HSF Training Ltd indefinitely.
• Learners may also contact us to request certificate replacements. In these circumstances, a record of a learner’s address is taken so that the replacement certificate can be sent. This is held on file for a maximum of 6 months before it is destroyed or deleted
• Information processed as part of a learner’s qualification, such as physical exam papers, will be held for a maximum of five years in the form of scanned copies.
• Personal data captured as part of a quality visit (such as video evidence of training) will be used for the purpose and outcomes of the visit, and then destroyed or deleted.

Business/contract data contacts

Businesses may provide us with information about contacts who will administer the activities associated with HSF Training Ltd on behalf of the business. These details may include:

• names
• employee numbers
• email addresses
• telephone numbers
• billing information
• information about other personnel and contacts for the business. For example:
  • organisational charts,
  • health and safety and other policies which may include personal data, e.g. the names of those with specific health and safety responsibilities.

It is important that our clients seek permission from the relevant personnel if any personal data is supplied to us. This information will only be retained for as long as we provide a service to a business client. If business contacts leave the organisation, it is the organisation’s responsibility to inform us, so that personal details and accounts can be disabled and removed.

Data storage, computers and electronic communications (excluding website)

• All e-mail enabled computers run up-to-date proprietary branded, antivirus software.
• Virus scans are conducted daily, prior to any electronic communications taking place.
• No emails with an attachment are sent unless specifically requested, or required as part of a work agreement, such as a progress report, attendance lists or learner scores/certificates.
• Details of our policies regarding data collection and storage are available from our website and are also available by contacting us in writing by either email admin@hsftraining.co.uk or in writing to HSF Training Ltd. The Hub, New Century House, Crowther Road, Washington, Tyne & Wear, NE38 0AQ
• All personal data that is stored in electronic format is stored in secure, password protected files, either in our bespoke learner management system or in password protected files stored in our dedicated and secure Dropbox for Business system.
• Passwords for protected data are changed regularly and sensitive data is only able to be accessed via these passwords by nominated HSF Training Ltd personnel who have received in-depth training regarding data information use and sharing.

Website data collection and security

• When the website is accessed by users, data traffic is encrypted using up to date secure socket layer (SSL) technology so that it can only be accessed by the end user.
• All sensitive information on the website, such as passwords used for ‘backend’ data input and for managing e-learning programmes, are encrypted by a proprietary encryption system.
• All personal data can only be accessed by the relevant end users by way of unique user names and passwords that must be entered when a user logs in to the systems.
• Our website and online e-learning systems use cookies to distinguish you from other users of our website. For detailed information on the cookies we use please refer to the terms and conditions on the website.
• We may automatically collect the following information when you visit our website:

• IP (Internet Protocol) address,
• login information,
• browser type,
• time zone settings,
• browsers and operating systems used;
• information about your visit, such as the pages visited or documents downloaded.

• HSF Training Ltd’s online systems have security measures in place to help protect against the loss or misuse of any data under our control.
• Payment card information is never stored on HSF Training Ltd’s systems and is only used to authorise the specific transaction through HSF Training Ltd’s card payment authority (PayPal) and then removed. The secure credit/debit card processing service used is provided by https://www.paypal.com/uk/. Details may be transferred to Paypal for the sole purpose of processing any transactions instigated by the customer.
• Alternatively, payments may be made directly by the customer using POS device or online payment link, either option ensures that the customer does not have to provide any details directly to HSF Training Ltd. For full details of the device and system being used and details of their data processing policies, please email admin@hsftraining.co.uk
• Under no circumstances will credit/debit card information be passed on, sold or loaned to any third party.
• Credit/debit card information is kept for the duration of the transaction in question only.
• If a customer is in any doubt, we are happy to accept payment by cheque or bank transfer.
• It is the customer’s responsibility to ensure that they have established a secure connection before supplying any credit/debit card information.

Where we store data

• All data in HSF Training Ltd’s systems is stored either on a secure set of servers hosted by our hosting provider (based in the USA) or in a secure, dedicated cloud based system (Dropbox for Business).
• Data in the hosting providers system is frequently backed up and stored in the provider’s backup / disaster recovery facility. This is in a secure server hosting facility with the necessary environmental, physical and technical controls in place to ensure unapproved access is prevented.
• HSF Training Ltd’s email data is stored with Microsoft located in EU data-centres and follows Microsoft standard security and backup processes.

 

Paperwork

The nature of our business necessitates the use of some paper-based systems, such as booking forms, course registers, feedback forms and completed assessment records. Certain accounts records are also paper based. To ensure the security of the data contained within these, the following measures are in place:

• Data captured in paper format is kept to a minimum and is only what is necessary, as outlined above, e.g. student names are required on all courses, but dates of birth are only requested for some accredited courses.
• Only authorised employees have access to certain information captured – e.g. purchase order numbers on booking forms. Other employees are supplied only with the information needed to run a course and, where appropriate, fulfil regulatory/awarding body requirement. For example, a client may book a first aid revalidation course and supply a list of proposed attendees and current certificate expiry dates. These would be supplied to the trainer who must state these on the register to verify delegates are within the allowed renewal period.
• All trainers store completed paperwork securely prior to returning it to HSF Training Ltd for processing, e.g. in a locked storage area.
• Prior to processing, hard copies of course paperwork are held in a secure office to which only authorised HSF Training Ltd personnel have access.
• Data required is entered onto and paperwork scans are stored using our secure electronic systems (as outlined above). The retention of paperwork scans is a requirement of some awarding organisations and is necessary to verify queries post course, such as an employer checking that someone physically attended a course can be evidenced by showing a completed assessment form. This data is stored for a maximum of 10 years then permanently deleted.
• Once fully processed – usually once certificate receipt has been confirmed by the client – all physical paperwork is destroyed using a cross cut shredder, except where an awarding organisation requires retention of paper copies for a specified time (e.g. NEBOSH require paperwork be held for 3 years after results are released). Where this is necessary, paperwork is stored securely in our office, with only authorised personnel having access. Retained paperwork is reviewed regularly and shredded, using a crosscut shredder, once the required storage time has elapsed.
• Accounting procedures and information provided by customers are stored securely for a period in line with current tax and VAT requirements. Following this, all paperwork is destroyed using a crosscut shredder.

We may use personal data collected for functions such as:

• Communicating activities between our clients, HSF Training Ltd and in some cases, relevant awarding bodies. For example:
• To inform the client of course or exam results and to send certificates
• Reporting statistical data, for example completed course feedback from learners, number of people trained, examination success rates
• Identifying relevant people with whom we should communicate to organise training course dates, times and venues
• Communicating regulatory changes and updates, and, if permitted, marketing/updating HSF Training Ltd products and/or services
• Purchasing and delivery of training and products
• The client’s contact details will be retained for as long as we provide a service to them, e.g. responding to future certificate date queries
• If contacts leave a client’s business, it is the client’s responsibility to inform HSF Training Ltd so that personal details and accounts can be disabled and removed.
• Marketing
• HSF Training Ltd maintains a marketing database that contains the basic details of individuals and businesses who have consented to HSF Training Ltd sending information about new products or services to them, usually via email. We may also contact (businesses) existing customers who have bought or discussed buying similar training or consultancy services from us in the past.

We may also, following a suitable assessment and balancing test (for example through ensuring suitable legitimate market targeting) directly market products to businesses where there is minimal privacy impact and where people in the business would not be surprised or likely to object to the marketing we are conducting. Any e-marketing conducted will comply with legal and ethical standards. Any business contacted will be able to unsubscribe from future marketing at any point as identified below.

• HSF Training Ltd use a secure data compliant proprietary marketing and mailshot facility ‘Mailchimp’ for marketing purposes and to distribute blogs and newsletters to businesses who have opted to receive these services:
  • All MailChimp forms, regardless of opt-in method, collect the email address, IP address, and timestamp associated with everyone who submits the form.
  • All HSF Training Ltd marketing emails that are sent provide the receiver with the ability to unsubscribe from receiving future emails.
  • Alternatively, subscribers can opt-out by sending a request specifying their request to admin@hsftraining.co.uk

Data Sharing

No personal data regarding any clients, client employees, students, HSF Training Ltd employees is sold to any party for any reason.

Other than as set out in in this policy, we will never distribute or share personal data that is held on our system with any third parties other than HSF Training Ltd’s employees, consultants and associates.

Customer personal data

We may share personal data with regulatory bodies in respect of:

• Awarding Organisations (where accredited qualifications are delivered), there are some legal requirements regarding certain personal information being required to ensure the authenticity of learners taking accredited examinations, such as dates of birth.
• One of the awarding organisations we use provides a certificate verification service that allows members of the public to check that a certificate presented to them is valid and has been produced by this awarding organisation. The website address for this service is https://checkcert.highfieldqualifications.com. The personal data provided to individuals using this service is a learner’s forename and surname, the qualification they attained, and the date of award.

HSF Training Ltd employees

Employees provide HSF Training Ltd with information about their experience and qualifications that confirm their ability to teach the qualifications and suitably complete other associated work activities, including awarding body associations. Additionally, employment law and payroll requirements necessitate the holding of certain information. As such, HSF Training Ltd hold a substantial set of personal details about employees. These may include:

• names,
• email addresses
• telephone numbers and other contact information;
• teaching and training qualification certificates;
• proof of professional qualifications;
• employment history and training experience
• references

This data may be required for either/both legal and regulatory purposes to ensure that we meet the necessary conditions of an approved awarding organisation training centre. We have sought permission from each staff member before holding this information and sharing any of their personal data with Client and Awarding Organisations. This data remains on HSF Training Ltd’s systems for as long as the individuals continue to work for HSF and for as long as is necessary to verify their competency to train for us, e.g. a client may request evidence of our trainer’s competency to teach a certain subject some time after the course took place.

If any of the above require their personal data to be removed from HSF Training Ltd’s systems because they are no longer fulfilling the role, they are required to inform HSF Training Ltd so that relevant data can be removed from our systems.

Providing information and responding to requests

• HSF Training Ltd support people’s requests to have personal data corrected or completed, transferred to another organisation, prohibited for certain uses, or removed completely in a timely manner (within 7 working days of requests being received).
• Where requested by an individual or business, HSF Training Ltd commit to informing the relevant parties how their personal data is being stored and what it is used it for. If asked, and following suitable checks regarding the authenticity of the person or business requesting the information, we will share the personal data we hold on an individual or business or offer them way to access it.

Data breach incident management

• In line with our regulatory requirements as an accredited training centre, HSF Training Ltd has a set of processes for issue and incident management, including data breaches.
• These processes include the required notifications to be sent to awarding organisations and to customers.

Employees

• All employees are responsible for ensuring that any personal data they are required to process as part of their job role is handled in accordance with the principles of legislation
• The contravention of any of these principles by any member of staff will be viewed as serious misconduct, and as such the member of staff will be subject to disciplinary action
• If any employee becomes aware of the misuse of personal data by anyone, within HSF Training Ltd or otherwise, this must be reported without delay to one of the directors.

J Hutchinson & K Hutchinson

Directors, HSF Training Ltd

5^th January 2026 (Version 17)

                                                                        

Environmental Policy

HSF Training Ltd recognises that businesses must take reasonable steps to minimise their impact on the environment by reducing pollution and waste. Effective management of environmental concerns provides synergy with good business management as it also ensures efficient use of resources.

We therefore ensure we follow the hierarchy of waste control:

– Eliminate the production of waste

e.g. using paperless systems where possible, such as emailing rather than posting client invoices and using e certificates.

– Reduce the amount of raw materials used and the amount of waste produced

e.g. ensuring all paper handouts produced in-house are printed double sided and looking at where less/condensed handouts are possible.

– Re-use items

e.g. instructing tutors to return all unused training materials at the end of a training session.

wherever feasible, utilising ‘green products’, e.g. recycled paper.

– Recycle items

e.g. where recycling facilities are available, segregating items prior to disposal.

– Responsibly dispose of remaining waste

e.g. using licenced waste disposal contractors.

We will also:

• Encourage good practices and promote their benefits to all our Associate Trainers/Employees and course delegates.
• Promote good practice in relation to environmental considerations in training to ensure that the sector continues to make significant contributions to sustainable development.

J Hutchinson & K Hutchinson

Directors, HSF Training Ltd

5^th January 2026 (Version 14)

 

Equality & Diversity Policy

HSF Training Ltd fully supports the principle of equal opportunities in employment and opposes all forms of unlawful or unfair discrimination. HSF Training Ltd is committed to maintaining and managing a diverse work force.

The purpose of this policy, therefore, is to ensure that HSF Training Ltd complies with the Equality Act 2010 and to ensure that people falling within the definition of the Act are treated equally and fairly. The “protected characteristics” in the Equality Act 2010 are: age, disability, gender, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation.

This Equality & Diversity Policy covers all employees and job applicants.

HSF Training Ltd will:

• Endeavour to give training and guidance to all relevant personnel to ensure that the risk of possible discriminatory attitudes affecting decisions are minimised and that there is an understanding of the relevant provisions of the Equality Act 2010.
• Operate a Grievance Procedure to enable grievances, including those relating to unfair discrimination on grounds of age, disability, gender, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief or sexual orientation to be formally heard.
• Investigate all reasonable and necessary changes and make any justified changes to the workplace and to employment arrangements so that disabled people are not at any substantial disadvantage compared to non-disabled people. This covers all areas of employment, including recruitment, promotion and training.
• Modify selection techniques in recruitment and selection, where appropriate, and make any other reasonable changes to ensure that all candidates can be considered equally.
• Ensure that all receive equal treatment in training and development, and, where appropriate, will supply additional training.
• Adopt a flexible approach, where possible and justified, giving consideration to reallocation of duties, time off for rehabilitation, assessment or treatment or other appropriate measures to ensure equal opportunity.
• Make every effort to ensure that contract workers are not discriminated against on any grounds and will ensure that any contract workers and other agencies that may be used are aware of this policy.
• Actively encourages promotion of this policy in its internal and external recruitment by ensuring that advertisements, job descriptions and person specifications do not discriminate. We welcome applications from all.
• Ensure that all new employees are aware of this policy as part of their induction and will regularly review and monitor this policy to ensure its implementation and effectiveness.

In addition, the company will endeavour to promote equal opportunities within its own workplace and within the learning and working environment for adult learners.

HSF Training Ltd believes that individuals should be enabled to achieve their full potential in a learning environment and to this end will promote:

• Mutual respect.
• Equality of access.
• The removal of barriers to learning because of prejudice or discrimination.
• Open and frank discussions where individuals can share a diversity of views, perspectives, values and issues, but opposition to, and eradication of, unfair barriers and discrimination.
• Transparency of company policies and procedures.

J Hutchinson & K Hutchinson

Directors, HSF Training Ltd

5^th January 2026 (Version 14)

 

 Grievance, Complaint and Appeals Procedure

Grievances/Complaints

It is important that any contractor, employee or trainee (delegate or candidate) who feels dissatisfied with any matter relating to his/her/their work/training should have immediate means by which such grievance can be aired and resolved. HSF Training Ltd is committed to addressing such issues at the earliest possible opportunity to prevent minor misunderstandings developing into major issues.

The following steps should be taken:

Contractors/Employees

1. Raise the matter initially with a director verbally, explaining the full nature and extent of the grievance. The director shall document this meeting. All parties must sign and document this record.

You may, if you so wish, ask a colleague to accompany you to help clarify the details of the grievance

2. If an immediate resolution is not possible, the first reasonable and mutually convenient opportunity within five working days, shall be set aside to discuss the grievance further to resolve the issue. Again, this meeting will be documented and signed by all parties.
3. If a resolution of the grievance is not achievable through this route, the matter will be referred to ACAS and their guidance will be sought.

Trainees/Delegates/Candidates

1. Raise the matter initially with the trainer that you are in direct contact with verbally, explaining the full nature and extent of the grievance. The trainer shall document this meeting. All parties must sign and document this record.

You may, if you so wish, ask a colleague/other trainee to accompany you to help clarify the details of the grievance.

2. If an immediate resolution is not possible, the first reasonable and mutually convenient opportunity within five working days shall be set aside to discuss the grievance further to resolve the issue. Again, this meeting will be documented and signed by all parties.
3. If a resolution of the grievance is not achievable through this route, the matter will be referred to your employer (if you are employed) and an alternative senior representative of HSF Training Ltd.

Appeals

Should a learner wish to appeal a decision made by a member of HSF Training Ltd’s team, they should follow the procedure outlined below. The appeal could be regarding an assessment decision, the outcome of a request for reasonable adjustment or special consideration or a learner feeling they have been disadvantaged in some way. Learners have 5 working days from the date of the issuing of decisions to appeal.

1. In the first instance, a learner who wishes to appeal should speak to their course tutor who will document the request. Where possible, the tutor will explain the reason(s) for the decision. The course tutor will also bring the matter to the attention of a director of HSF Training Ltd.
2. Should a learner feel they cannot speak to their tutor or is unhappy with the explanation provided, they should contact HSF Training Ltd’s client management team on 0191 5022515 who will take details of the appeal and ensure it is assigned to a director of HSF Training Ltd’s.
3. The director will review the evidence regarding the original decision and either uphold or amend this, informing both the learner and the tutor of the outcome and the reasons for this. The review will be documented.
4. Where the appeal regarding a decision needs to be made to the awarding body, then HSF Training Ltd will act in the learner’s behalf, e.g. to obtain and complete required appeal forms.

If the qualification is accredited, the complaint/appeal can be escalated to the relevant Awarding Organisation, in line with their grievance/complaint/appeals procedures. Each awarding organisation’s procedure are available on request from head office by calling 0191 5022515 or emailing admin@hsftraining.co.uk Please note that there is usually a timescale set by awarding organisations for appeals regarding assessment related decisions.

The contact details for the awarding organisations are as follows:

Awarding body	Contact telephone number	Website
NEBOSH	(0)116 263 4700	www.nebosh.org.uk
HABC	0845 2260350	www.highfieldabc.com
IOSH	(0)116 257 3100	www.iosh.co.uk

Alternatively, regulatory advice can be obtained from the body which approves qualifications:

• For NEBOSH qualifications this is Qualifications Scotland Accreditation http://accreditation.sqa.org.uk.
• For all other accredited qualifications, information can be obtained from The Office of Qualifications and Examinations Regulation (Ofqual) https://www.gov.uk/government/organisations/ofqual

J. Hutchinson & K. Hutchinson

Directors, HSF Training Ltd

5^th January 2026 (Version 15)

 

Initial Assessment Policy

HSF Training Ltd aim to provide a comprehensive Initial Assessment Process for all delegates taking part in a training course. Where applicable, we collect and use the information from your pre-course questionnaires to help us design training programmes that match your needs.

Our Initial Assessment process is designed to help us to:

• Provide the training at the right level for the delegate
• Increase the motivation of delegates by providing learning opportunities based around individual needs
• Improve the quality of training, by identifying realistic and achievable learning goals, based upon ability, potential and interests.

If applicable, either prior to the course or on the day of your training we will aim to spend a little time reviewing your pre-course questionnaire, this will enable you to:

• Feel that your views are listened to and important
• Understand how your past experience will relate into your chosen course
• Understand any limitations that may be imposed due to following an awarding body syllabus (where applicable)
• Understand how this course will enable you to further your career
• Understand how this course will benefit you in your workplace
• Have an opportunity to prove your ability and boost your confidence
• Be motivated and achieve your goals
• Know what support is available and what support you may need.

J. Hutchinson & K. Hutchinson

Directors, HSF Training Ltd

5^th January 2026 (Version 13)

 

Modern Slavery and Human Trafficking Statement

Introduction

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 august 2025.

HSF Training Ltd (‘the company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain and its products. We have zero tolerance towards slavery and require our supply chain to comply with our values.

Organisational Structure

HSF Training Ltd has business operations in the United Kingdom and operates in the training & consultancy sector.

The nature of our supply chain is as follows:

We work with a number of UK based suppliers who provide us with goods and services which enable us to offer training and consultancy, including website hosting, stationery and course materials. We deliver our own courses and a number provided by awarding organisations.

For more information on the company, please visit our website hsftraining.co.uk

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

• Only working with reputable UK based businesses, who themselves have, where applicable, produced a Modern Slavery and Human Trafficking Statement
• Assessing our existing supply chain and any new suppliers to identify and assess the likelihood that goods and services purchased are made by slave labour.

Risk and Compliance

The company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

• Evaluating the slavery and human trafficking risks of each new supplier.
• We do not consider that we operate in a high-risk environment because the majority of our supply chain is UK based and in low-risk industries such as internet and utilities provision and retailers of course materials.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our procedures by any of our suppliers, we will seek to terminate our relationship with that supplier as soon as is practicable.

This statement was approved by the directors of the company.

J. Hutchinson & K. Hutchinson

Directors, HSF Training Ltd
5^th January 2026 (Version 2)

 

Modern Slavery and Human Trafficking Due Diligence Procedure

We recognise our responsibility to exercise due diligence to prevent modern slavery. We therefore have the following measures in place:

• We do not use temporary labour
• We purchase good s and services only from reputable, UK based suppliers
• We only work with recognised awarding organisations – Highfield, IOSH and NEBOSH
• We only deliver training and consultancy for UK based, reputable, traceable companies – e.g. local authorities who themselves have, where applicable, modern slavery statements and procedures in place.
• Any new suppliers or clients are assessed for risk of modern slavery prior to working with them. For example, when a new client contacts us regarding delivering training for them, we endeavour to ascertain details regarding their credibility. Where they are assessed as high risk, further assessment will be needed prior to contracting any work or purchasing services from them.

If we become aware of any organisation in our supply chain who fail to comply with the requirements of the Modern Slavery Act 2015, we will  cease our relationship with that organisation as soon as is practicable.

J. Hutchinson & K. Hutchinson

Directors, HSF Training Ltd
5^th January 2026 (Version 2)

 

Malpractice & Maladministration Policy

Introduction

This policy is aimed at any of our learners and employees who are involved in suspected or actual cases of malpractice or maladministration. It is also for use by our employees to ensure they handle all malpractice and maladministration investigations in a consistent manner.

We will review this policy periodically as part of our internal audit arrangements and revise it as and when necessary in response to client/learner feedback, changes in our practices, actions from qualification regulators, updates to awarding organisation requirements, changes in legislation or trends identified from previous cases.

Malpractice – Definition

Malpractice is any activity or practice which deliberately contravenes regulations and compromises the integrity of our training delivery and qualifications in any way. Malpractice could involve anyone throughout the training process. For the purpose of this policy the term also covers misconduct and forms of unnecessary discrimination or bias towards learners.

Listed below are examples of malpractice. Please note that this list is not exhaustive and only intended as guidance on our definition of malpractice.

• Contravention of our centre/qualification approval conditions from our awarding bodies, including delivery, assessment, examination and verification arrangements
• Deliberate failure to follow our administration procedures
• Fraudulent claims for certificates
• Forgery of evidence
• Collusion or permitting collusion in the assessment process
• Plagiarism of any nature by learners
• Inappropriate assistance given to learners by others
• Submission of false information to gain a qualification or unit.

Maladministration – Definition

Maladministration is any activity or practice which results in non-compliance with administrative regulations and requirements and includes the application of persistent mistakes or poor administration, e.g. poor learner records.

Process for making an allegation of malpractice and/or maladministration

Anyone who identifies or is made aware of suspected or actual cases of malpractice or maladministration must immediately notify HSF Training Ltd, put their concerns in writing and either posting or emailing these along with supporting evidence.

All allegations must include (as far as is possible):

• Name, address, company and number of the person making the allegation
• Learner’s name
• Details of any personnel involved in the case
• Title of course/qualification affected
• Date(s) of the suspected or actual incident(s) occurred
• Full nature of the suspected or actual incident(s)
• Written statements from those involved in the case
• Date of the report and the informant’s name, position and signature.

Responsibility for the investigation

All suspected or alleged cases will be examined promptly by HSF Training Ltd to establish if there are reasonable grounds for the suspicion or allegation. If it is possible that malpractice/ maladministration has occurred or may occur, we will try to establish the facts and take all reasonable steps to prevent any adverse effect. If an adverse effect has already occurred we shall mitigate it as far as possible and correct it.

A Director of HSF Training Ltd will be responsible for ensuring the investigation is carried out in a prompt and effective manner.

HSF Training Ltd will acknowledge receipt of a report within 5 working days, allocate a suitable member of staff to lead the investigation and review any supporting evidence to establish whether malpractice or maladministration has occurred.

At all times we will ensure that personnel assigned to the investigation have the appropriate level of occupational competence and quality assurance qualification and have had no previous involvement and have no personal interest in the matter.

Investigation timelines, expectations and notifications

In all cases we shall notify the relevant persons. We expect all parties, whether directly or indirectly involved in the investigation, to fully cooperate with HSF Training Ltd.

We aim to action and resolve all stages of the investigation as promptly as possible. We will keep all relevant parties informed of the stages of the investigation.

Investigation report

After an investigation, we shall produce a draft report in order for all parties concerned to check the factual accuracy and any subsequent amendments will be agreed between them and ourselves. We shall make the final report available to all parties concerned and to any other external agencies as required.

If it was an independent/third party that notified us of the suspected or actual case or malpractice/maladministration we shall inform them of the outcome. In doing so we may withhold some details if to disclose such information would breach a duty of confidentiality or any other legal duty.

If it is an internal investigation against a member of our staff the report will be agreed by the relevant internal managers.

Investigation outcomes

If the investigation confirms that malpractice/maladministration has taken place we will take any action appropriate, for example we may:

• Impose actions on the learner with specified deadlines in order to address the instance of malpractice/maladministration and to prevent it from reoccurring
• Amend aspects of our training delivery, assessment and/or monitoring arrangements and associated guidance to prevent the issue(s) from reoccurring.

Should anyone wish to appeal against any action to be taken following an investigation, pleases refer to our Grievance/Complaints Policy.

NEBOSH qualifications

All cases of suspected malpractice/maladministration relating to NEBOSH qualifications must be reported to NEBOSH. All suspicions must be reported within two working days to the Head of Course Provider who will be responsible for reporting the matter to NEBOSH at the earliest opportunity using their report of suspected malpractice form. For further information, please refer to NEBOSH’s Policy and procedures for suspected malpractice in examinations and assessments.

Highfield qualifications

All cases of suspected malpractice/maladministration relating to Highfield qualifications must be reported to Highfield. The responsibility for reporting any suspected incident will be with a senior member of HSF Training Ltd’s management team within 3 working days of being made aware of the suspected incident. Highfield may need to hold or suspend leaner certification decisions until an outcome in the subsequent investigation is reached.

Contact us

If you have any queries about the contents of the policy or wish to give feedback please do not hesitate to contact us using admin@hsftraining.co.uk

J. Hutchinson & K. Hutchinson

Directors, HSF Training Ltd

5^th January 2026 (Version 13)

 

Quality Policy Statement

HSF Training Ltd is dedicated to the quality policy that will ensure that its products and services fully meet the requirements of its customers at all times. The goal of HSF Training Ltd is to achieve a high level of customer satisfaction at all times. Commitment to the implementation of supporting managerial and business operational systems is essential to realising that goal.

The quality policy is based on 3 fundamental principles:

1. Ensuring that we fully identify and conform to the needs of our customers.
2. Looking at our service provision processes, identifying the potential for errors and taking the necessary action
   to eliminate them.
3. Everyone understanding how to do their job and doing it right first time.

To ensure that the policy is successfully implemented, employees will be responsible for identifying customer requirements and ensuring that the correct procedures are followed to meet those requirements.

Objectives needed to ensure that the requirements of this policy are met and that continual improvement is maintained in line with the spirit of the policy, will be set, determined and monitored at Management Review.

The quality policy principles and objectives will be communicated and available to staff at all times. Training will be an integral part of the strategy to achieve the objectives.

We will constantly review and improve on our services to ensure tasks are completed in the most cost effective and timely manner for the benefit of all our customers.

We shall ensure that all our personnel understand and fully implement our  policies and objectives and are able to perform their duties effectively through an ongoing training and development programme.

J. Hutchinson & K. Hutchinson

Directors, HSF Training Ltd

5^th January 2026 (Version 14)

 

Reasonable Adjustment & Special Consideration Policy & Procedure

Definitions & Principles

Reasonable Adjustment – Definition

A Reasonable Adjustment is any action which addresses and helps to reduce the effect of the disability or difficulty which would substantially disadvantage a learner during an examination or assessment situation.

Examples of categories of need include physical environment, visual and hearing impairment, learning difficulties, medical conditions, English as a second/additional language, language translators and translated examination papers.

Special Consideration – Definition

Special Consideration may be granted in instances where, following a scheduled assessment, a candidate may have been disadvantaged by adverse circumstances arising at or near the time of assessment or who misses part of the assessment owing to circumstances beyond their control.

Examples of instances when Special Consideration may be given include:

• alternative assessment arrangements that were agreed in advance but which, through no fault of the learner, proved to be unworkable;
• where the learner’s performance in other parts of the qualification is considerably better than part of the assessment where it is being asked that Special Consideration should be applied;
• part of an assessment is missed by a learner due to unforeseen circumstances beyond their control, e.g. bereavement, illness;
• unforeseen circumstances during an examination, e.g. excessive noise in the examination room, a fire alarm, gas leak or power cut.

Principles of Reasonable Adjustment and Special Consideration

• Any adjustments must comply with disability and equal opportunity legislation and comply with regulatory requirements
• No adjustment should provide any student with an unfair advantage
• All adjustments will comply with the requirements of the awarding body for which the assessment is being conducted
• When identifying the adjustment(s) necessary, take into consideration the learner’s normal way of working and how previous assessment has been made during teaching, as well as the assessment requirements of the qualification
• Any adjustment should be based on the individual learner’s need to access the assessment.

Procedures for Reasonable Adjustment and Special Consideration

HSF Training Ltd will

• Ensure all booking forms and joining information sent to clients request information regarding any special learner requirements prior to training taking place
• Decide in conjunction with the client and the learner what adjustment may be required
• Ensure the tutor is informed and provide any assistance necessary to make agreed adjustments available (e.g. printing large print text notes for a visually impaired student)
• Ensure the adjustment identified complies with the awarding body’s reasonable adjustment policy and permission, where applicable, has been granted
• Ensure all reasonable adjustment/special consideration information is confidential
• Provide tutors with all support and information necessary in order for them to be able to comply with these policy & procedures.

It is recognised that it will not always be possible to identify students with special requirements, for example due to not being informed by a client prior to the training taking place, or clients making amendments to the attendees of a course. Therefore, the procedures below should be applied by tutors.

Tutors should:

• Have delegates complete an Individual Learning Plan at the start of each course, where applicable
• Where completion of the ILP identifies a learner with a special requirement, contact HSF Training Ltd as soon as possible to discuss possible adjustments which can be accommodated
• Identify learners having or likely to have difficulties accessing assessment throughout the training and contact HSF Training Ltd as soon as possible to discuss possible adjustments which can be accommodated
• Advise learners to make any adjustment needs known at the earliest opportunity.

All adjustments and communication with learners and clients regarding reasonable adjustments and special considerations will be treated by HSF Training Ltd and tutors with the strictest confidence and with sensitivity.

Further information regarding adjustments allowed by HABC is contained in the appendix of this document; NEBOSH & IOSH adjustments policies are available from HSF Training Ltd’s office.

J. Hutchinson & K. Hutchinson

Directors, HSF Training Ltd

5^th January 2026 (Version 13)

Highfield Qualifications Reasonable Adjustment Summary (from Reasonable Adjustment policy January 2024)

In all circumstances trainers MUST contact the office prior to allowing any Reasonable Adjustment.

Special Consideration (from Highfield Qualification’s Special Consideration policy August 2021)

A special consideration is a post-assessment adjustment that can be made should a learner experience an event that is likely to, or has, affected the learner’s assessment.

3. Special Consideration Eligibility

3.1 A special consideration is a consideration to be given to a learner who has temporarily experienced an illness or injury, or some other event outside of their control, which has, or is reasonably likely to have, materially affected the learner’s ability to:

3.1.1 take an assessment.

3.1.2 demonstrate their level of attainment in an assessment.

 

3.2 Circumstances, at the time of, or during, assessment where a learner may be eligible for a special consideration include:

3.2.1 an accident, injury, or temporary illness.

3.2.2 a serious domestic issue.

For example, bereavement of an immediate family member within 3 months of the assessment.

3.2.3 failure by the centre (or assessor in the case of EPA) to provide the correct assessment materials.

3.2.4 technical issues with the assessment or associate assessment materials.

3.2.5 a serious disruption of the assessment. For example, a fire alarm.

3.2.6 failure by the centre (or assessor in the case of EPA) to implement access arrangements that have been approved in advance of the assessment.

3.2.7 a significant issue arising from a learning difficulty, disability or long-term illness that is exacerbated at the time of assessment that would not normally require a reasonable adjustment.

 

3.3 The list in 3.2 above is not intended to be exhaustive.

 

3.4 Circumstances where a learner will not be eligible for a special consideration include:

3.4.1 minor domestic issues and arrangements. For example, moving house or a wedding.

3.4.2 consequences of committing unlawful activities, taking recreational drugs and alcohol.

3.4.3 a minor disturbance of assessment. For example, a phone ringing.

3.4.4 ill preparation of the learner for assessment by the centre or the learner themselves.

3.4.5 failure by the learner to complete all required elements of teaching and assessments.

 

3.5 The list in 3.4 is not intended to be exhaustive.