Our policies

Privacy policy

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

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

Your privacy

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

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

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

Website usage

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

Facebook adverts (sponsored posts)

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

When you create an account (individual)

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

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

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

When you become a Care Professional on Curam

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

When you contact us by ‘phone

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

When you contact us via email

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

When you take part in online research or surveys

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

Links to other websites

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

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

The information we need.

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

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

Collecting your personal information

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

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

Children

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

Where is your information stored?

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

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

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

Sharing your information

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

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

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

Retaining your information

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

What are your rights?

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

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

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

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

How to contact us

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

About Us

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

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

Care Professional Privacy Notice

Introduction

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

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

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

Personal information that we process

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

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

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

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

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

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

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

How we collect personal information

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

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

How we use your personal information

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

Where you have freely provided information (consent).
Where we need the information to perform the contract between us or any other contract between us.
Where we need the information to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

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

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

Purpose for which we process your personal information

We will process your personal information for the following purposes:

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

How we use special category information

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

Transfers to third parties

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

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

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

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

Transfers outside of the UK/EEA

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

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

Information security

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

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

Information retention

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

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

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

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

What are your rights?

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

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

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

If you require a copy of our policy. Please email info@curamcare.com.

Client Privacy Notice

Introduction

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

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

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

Personal information that we process

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

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

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

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

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

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

How we collect personal information

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

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

How we use your personal information

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

Where you have freely provided the information (consent).
Where we need the information to perform the contract between us or any other contract between us.
Where we need the information to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

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

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

Purposes for which we process your personal information

We will process your personal information for the following purposes:

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

How we use special category information

Transfers to third parties

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

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

Transfers outside of the UK/EEA

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

Information security

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

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

Information retention

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

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

What are your rights?

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

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

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

If you require a copy of our policy. Please email info@curamcare.com.

Safeguarding Guidance

This guidance is based on national guidance and The Care Act 2014.

Introduction:

Curam believes in protecting an adult’s right to live in safety, free from abuse and neglect. This policy sets out the roles and responsibilities of Curam in working together in promoting the adult’s welfare and safeguarding them from abuse and neglect. Curam employees and approved Care Professionals are made aware of this guidance.

Guidance and related procedures are applicable employees and Curam Care Professionals. Failure to comply will be addressed without delay and may ultimately result in dismissal/exclusion from the organisation.

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

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

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

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

Safeguarding as Part of the Deal:

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

Key Principles of Adult Safeguarding:

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

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

Recognising the signs of abuse:

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

Types of Abuse:

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

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

Radicalisation to Terrorism:

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

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

Reporting Concerns:

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

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

Safe Recruitment & Selection:

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

Curam has policies and procedures that cover the recruitment of all Curam employees and approved Care Professionals. See Curam Care Professional recruitment internal guidelines document.

Is there a Person in a Position of Trust Involved?

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

Training and Awareness:

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

All Curam employees undertake mandatory annual, Safeguarding Adults and Children training that enables them to:

Understand what safeguarding is and their role in Safeguarding Adults and Children.
Recognise signs/symptoms of abuse and when to raise a concern.
Understand how to report a safeguarding concern.
Understand dignity and respect when working with individuals.
Have knowledge of this Safeguarding Adults Policy.

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

Mental Capacity:

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

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

Confidentiality and Information Sharing:

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

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

Recording and Record Keeping:

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

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

Whistleblowing:

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

Important Contacts:

Senior Lead for Safeguarding

Name: Gemma Stokes

Email address: gemma@curamcare.com

Telephone number: 01387 730766

Deputy Lead for Safeguarding

Name: Jessica Huntley

Email address: jessica@curamcare.com

Telephone number: 01387 730766

Local Authority

Use the following link to contact the required Local Authority and contact the appropriate Safeguarding team/ Social services department to report a safeguarding concern.

Find your local council - GOV.UK (www.gov.uk)

Police

Emergency – 999

Non-emergency – 101

Telephone: 0808 2000 247

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

Modern Slavery Statement

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

Key elements that we consider:

Our policy

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

Risk management

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

Awareness

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

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

2021 Introduction

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

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

Our Policies

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

We have a Modern Slavery Policy which is reviewed on an annual basis.

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

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

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

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

Our Supply Chain

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

Recruitment
Technology development
Marketing Analytics
IT Support Services
Financial services

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

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

Progress and Future Actions

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

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

This document constitutes our Modern Slavery Statement for the financial year ending 31st March 2025 and has been created in accordance with the Modern Slavery Act 2015.

Diversity and Inclusion Policy

Equality and Diversity Policy

1. Purpose

1.1 To outline the commitment of Curam to the concept of equal opportunities in all aspects of its operations.

2. Statement

2.1 Curam is committed to providing employment opportunities and services to Service Users on an equal and fair basis and commits to follow the codes of practice published by the Equality and Human Rights Commission to uphold legal obligations against discrimination, harassment, or victimisation based on the following the nine protected characteristics outlined within the Equality Act 2010:

Age
Disability
Gender reassignment
Marriage and civil partnership
Pregnancy and maternity
Race
Religion and belief
Sex
Sexual orientation

2.2 Curam will seek to establish and maintain fair treatment for everyone who works for Curam, those to whom Curam provides services and those who supply goods and services to Curam. Curam expects everyone associated with the business to behave entirely within the law and gives zero tolerance to inappropriate behaviour. Everyone must be treated fairly, with dignity and with respect.

2.3 The commitment from every employee in Curam to the aims and ideals of this policy is fundamental to our success, and any employee who feels that these ideals are not being adequately followed are required to make their feelings known without delay so that corrective measures, where necessary, can be implemented. Employees who discriminate unfairly may be subject to disciplinary action and sanction, which may include dismissal.

3. Procedure and Guidance

3.1 Curam’s reputation is a key ingredient in relation to whether it is successful or not. Being recognised as both an employer and provider of services on an equal and non-discriminatory basis will help develop and enhance our reputation within the community we serve.

3.2 Equally, the identification, promotion and monitoring of good practice is likely to benefit Curam and result in significant benefits, such as greater employee satisfaction, which in turn helps attract new staff and retain existing staff, leading to reduced recruitment costs and increased productivity.

4. Forms of Discrimination

4.1 Discrimination takes many forms, and it is important to understand how the law sees many different forms of discrimination which might occur in the workplace, affecting both Service Users and employees of Curam.

4.2 The principal forms are:

(a) Direct discrimination

Direct discrimination occurs when someone is treated less favourably than another person because of a protected characteristic they have or are thought to have or because they associate with someone who has a protected characteristic.

(b) Discrimination by association

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

The clause in the 2010 Equality Act provides that it is discrimination to treat a disabled person in a particular way which, because of his or her disability, amounts to treating him or her badly and the treatment cannot be shown to be justified. For this type of discrimination to occur, the employer or other person must know, or could reasonably be expected to know, that the disabled person has a disability. Also, the person who treats the disabled person in that way may still be liable for discrimination under this provision, whether or not the duty to make reasonable adjustments has been complied with.

The protection by association could have implications in relation to requests for time off or flexible working, parking permits for student parents with disabled children, etc.

(d) Perception discrimination

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

(e) Indirect discrimination

Indirect discrimination is when a condition, rule, policy or even a practice applies to everyone, but has a disproportionate impact on people with a protected characteristic. Indirect discrimination can be justified if we can demonstrate that we acted reasonably for a sound business reason: i.e. that it is ‘a proportionate means of achieving a legitimate aim’.

A legitimate aim might be any lawful decision, but if there is a discriminatory effect, the sole aim of reducing costs is likely to be unlawful. Being proportionate really means being fair and reasonable, including showing that we have looked at ‘less discriminatory’ alternatives to any decision we make.

(f) Harassment

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

Employees can complain of behaviour that they find offensive even if it is not directed at them, and the complainant need not possess the relevant characteristic themselves. Employees are also protected from harassment because of perception and association.

(g) Third party harassment

The Equality Act 2010 makes us potentially liable for harassment of our employees by people (third parties) who are not employees (for example, contractors or external trainers). Strict requirements for third party harassment means that one-off incidents may still occur without the employee having recourse to complain: we will be liable however when harassment has occurred on at least two previous occasions, and we are aware that it has taken place and have not taken reasonable steps to prevent it from happening again.

(h) Victimisation

Victimisation occurs when an employee is treated badly because they have made or supported a complaint or raised a grievance under the Equality Act 2010; or because they are suspected of doing so. An employee is not protected from victimisation if they have maliciously made or supported an untrue complaint.

5. Curam’s practical steps to ensure fairness for all

5.1 Information and Instruction

(a) Curam will ensure, through the circulation of this policy document, that all employees are made aware of the importance of equal treatment for all, regardless of any particular characteristics they may possess. Curam’s Service Users will also be made aware of Curam’s policy, and that whilst Service Users may rightfully expect to receive equal treatment from Curam’s employees, then they are expected in turn to treat our employees with the dignity and respect they deserve and in a non-discriminatory fashion. Where further instruction and training is deemed necessary, then Curam will make suitable arrangements.

5.2 Recruitment and management of staff

(a) Curam’s reputation should be enhanced where it can demonstrate a clear strategy aimed at encouraging a diverse workforce, and one which reflects the local labour market, and the diversity of Service Users. To achieve this goal, Curam will demonstrate a clear understanding of how to avoid discrimination in employment through the creation and use of recruitment tools which:

are equally relevant to the widest range of job applicants
do not collect data which is not essential to any early recruitment decisions (e.g., call for interview), such as sex, ethnic origin etc.

(b) Job adverts will avoid the use of language which might suggest inappropriate and unlawful intent to discriminate. Such actions will help ensure that selection for employment will be on the basis of aptitude and ability. So as to eliminate possibilities of discrimination or prejudice before interview, employment application forms do not include questions concerning age, race or ethnic origin, creed, colour, religion, sex, political affiliation, parenthood or sexual orientation. Thereafter, employee selection criteria will proceed purely according to the merits and abilities of the applicant to perform the tasks and duties listed in the relevant job description. Refer to the ‘Care Professional Approval/Recruitment internal guidelines Policy’.

(c) Staff will be promoted on their individual ability to do the job and performance. All staff will have equal and fair access to learning and development as identified through their performance appraisal.

(d) All employees should clearly feel that decisions about recruitment, training, development, promotion, or indeed any aspect of their employment are based purely on merit, and not as a result of unfair discrimination, although should there be significant imbalances in the workforce, then some form of positive action may be investigated. If an employee feels that they have been treated unfairly in any aspect of the employment relationship, then they are encouraged to raise the matter with their immediate supervisor or line manager.

5.3 People with a disability

(a) Curam attaches particular importance to the needs of disabled people and will:

make reasonable adjustments to maintain the services of an employee who becomes disabled, for example, training, provision of special equipment, reduced working hours etc.
include disabled people in training/development programmes.
give full and proper consideration to disabled people who apply for jobs, having regard to making reasonable adjustments for their particular aptitudes and abilities to allow them to be considered equally and fairly alongside all other candidates.

6. Monitoring and Review

(a) Curam understands that it is important to be able to confirm that its policy is being followed appropriately, and will monitor this through appropriate means, such as the collection of key data, discussions with employees and Service Users, monitoring and review of complaints, or expressions of dissatisfaction, modelling attitude surveys to determine Service User and employee responses to equality and diversity issues in quality audits etc. Where improvements need to be made, then an action plan will be developed and implemented.

(b) In order to ensure a fair working environment for all employees, discrimination or harassment (physical or verbal conduct that violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment) will not be tolerated within Curam. Curam provides facilities for any employee who believes that he or she has been treated unfairly within the scope of this policy to address the matter through a documented and established grievance procedure. Refer to the Comments, Compliments and Complaints Policy. Each complaint will be thoroughly investigated and where it is identified that an individual has treated a colleague unfairly, they will be subject to Curam’s disciplinary procedure.

(c) This policy statement will be kept under systematic and regular review by the most Senior Manager (or other nominated individual) to ensure that it remains consistent with legal imperatives and good practice.

Updated 11th Feb 2025

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