- It applies to Information collected by us or provided by you over our Website (including the mobile optimised version of the website accessible from your portable hand-held device) or in any other way (such as over the telephone). It is also intended to assist you in making informed decisions when using our Website our products and services. Please take a minute to read and understand the policy.
- All your personal Information shall be held and used in accordance with the EU General Data Protection Regulation 2016/679 ("GDPR") and national laws implementing GDPR and any legislation that replaces it in whole or in part and any other legislation relating to the protection of personal data. If you want to know what information we collect and hold about you, or to exercise any of your rights as set out in section 9 below, please write to us at the below address or via email at email@example.com:
Larkfleet Group, Larkfleet House, Falcon Way, Southfields Business Park, Bourne, Lincolnshire, United Kingdom, PE10 0FF
- Larkfleet Limited is the controller of your Information for the purposes of the GDPR and is a company registered under number 03520125.
1. What information do we collect on our website?
When you visit our Website (including the mobile optimised version of the website accessible from your portable hand-held device) you may provide us with personal information such as name, postcode, email address and telephone number. You may provide us with Information in a number of ways:
- by supplying us with the Information as listed above, on an individual basis by subscribing to our email database to receive occasional e-newsletters about current and future developments, offers, news etc. from us and other companies in The Larkfleet Group of Companies;
- by filling in the contact form on our website;
- by corresponding with us by email, in which case we may retain the content of your email messages together with your email address and our responses;
- we may collect Information about your computer, including where available your IP address, operating system, browser type and the geographical location of your computer, for system administration purposes. We may also report aggregate information to our advertisers. This is statistical data about browsing actions and patterns and does not identify you as an individual.
2. How we use your information
We will hold, use and disclose your Information for our legitimate business purposes including:
- to keep you up to date about important changes to our business;
- to direct-market products and services, advise you of news and industry updates, events, promotions and competitions and other information. Before we do so, you will be given an option to opt-in to such communications and an option to unsubscribe will also be provided with each communication;
- to apply profiling technology which analyses our customers’ engagement with our direct marketing communications, activity and interests so that we can send you content that is relevant to you;
- to answer your queries;
- to release Information to regulatory or law enforcement agencies, if we are required or permitted to do so.
3. The legal basis for processing your information
Under GDPR, the main grounds that we rely upon in order to process your Information are the following:
- Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your Information. We may also be obliged by law to disclose your Information to a regulatory body or law enforcement agency;
- Necessary for the purposes of legitimate interests - either we, or a third party, will need to process your Information for the purposes of our (or a third party's) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your Information protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and customer experience, informing you about our products and services and ensuring that our operations are conducted in an appropriate and efficient manner;
- Consent – in some circumstances, we may ask for your consent to process your Information in a particular way.
4. How we share your Information
In certain circumstances we will share your Information with other parties. Details of those parties are set out below along with the reasons for sharing it.
- Other parties within our group of companies: Your information may be shared with other companies in The Larkfleet Group of Companies.
- Trusted third parties: In order to provide certain services, we will share your information with third party service providers such as marketing agencies and email logistics providers. We will not share your data with any third party where it is not necessary to do so to provide a service to you.
- Regulatory and law enforcement agencies. As noted above, if we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal information to such bodies or agencies.
5. How long we hold your information
We will only retain your Information for as long as is necessary for the purpose or purposes for which we have collected it. The criteria that we use to determine retention periods will be determined by the nature of the data and the purposes for which it is kept. For example, if we receive your Information through a competition entry, we will retain your data for as long as is necessary to administer the competition. If we receive your Information when you apply for a job, we will retain your data for as long as is necessary to process your application and maintain application statistics. We will not directly market to you for longer than three (3) years, unless you consent to receive direct marketing by opting in again before the expiry of that three (3) year period. In certain circumstances, once we have deleted or anonymised your data, we may need to retain parts of it (for example, your email address), in order to comply with our obligations under GDPR or other legislation, or for fraud detection purposes.
6. Your rights relating to your information
You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
- Right of Access. You have the right at any time to ask us for a copy of the Information about you that we hold, and to confirm the nature of the Information and how it is used. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your Information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
- Right of Correction or Completion. If Information we hold about you is not accurate, or is out of date or incomplete, and requires amendment or correction you have a right to have the data rectified, updated or completed. You can let us know by contacting us at the address or email address set out above.
- Right of Erasure. In certain circumstances, you have the right to request that Information we hold about you is erased e.g. if the Information is no longer necessary for the purposes for which it was collected or processed, or our processing of the Information is based on your consent and there are no other legal grounds on which we may process the Information.
- Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your Information by contacting us at the address or email address set out above. For example, if we are processing your Information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your Information for direct marketing purposes. You may also have the right to restrict our use of your Information, such as in circumstances where you have challenged the accuracy of the Information and during the period where we are verifying its accuracy.
- Right of Data Portability. In certain instances, you have a right to receive any Information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that Information to you or directly to a third-party organisation.
This right exists in respect of Information that:
- you have provided to us previously; and
- is processed by us using automated means.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation's systems. We are also unable to comply with requests that relate to Information of others without their consent.
You can exercise any of the above rights by contacting us at the address or email address set out above. You can exercise your rights free of charge.
Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
To the extent that we are processing your Information based on your consent, you have the right to withdraw your consent at any time. You can do this by unsubscribing via the link provided in any direct marketing communication or contacting us at the address or email address set out above.
Similar to other commercial websites, our Website uses a technology called "cookies" and web server logs to collect information about how our Website is used. A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site's computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies.
Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our Website, and the websites visited just before and just after our Website.
Cookies, in conjunction with our web server's log files, allow us to calculate the aggregate number of people visiting our Website and which parts of the website are most popular. This helps us gather feedback so that we can improve our Website and better serve our customers. Cookies do not allow us to gather any personal Information about you and we do not generally store any personal Information that you provided to us in your cookies.
If you are unhappy about our use of your Information, you can contact us at the address or email address above.
EQUAL OPPORTUNITIES POLICY
1. Equal opportunities statement
Larkfleet Group Limited is committed to promoting equal opportunities in employment. You and any job applicants will receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (Protected Characteristics).
2. About this policy
2.1 This policy sets out our approach to equal opportunities and the avoidance of discrimination at work. It applies to all aspects of employment with us, including recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment.
2.2 This policy covers all employees, officers, consultants, contractors, casual workers and agency workers.
2.3 This policy does not form part of any employee’s contract of employment and we may amend it at any time.
3. Who is responsible for this policy?
3.1 Our board of directors (the board) has overall responsibility for the effective operation of this policy and for ensuring compliance with discrimination law. Day-to-day operational responsibility for this policy, including regular review of this policy, has been delegated to Helen Hick, the HR Director.
3.2 All managers must set an appropriate standard of behaviour, lead by example and ensure that those they manage adhere to the policy and promote our aims and objectives regarding equal opportunities. Managers will be given appropriate training on equal opportunities awareness and equal opportunities recruitment and selection best practice. Helen Hick has overall responsibility for equal opportunities training.
3.3 If you are involved in management or recruitment, or if you have any questions about the content or application of this policy, you should contact the HR department to request training or further information.
3.4 This policy is reviewed annually by the Chairman.
3.5 Staff are invited to comment on this policy and suggest ways in which it might be improved by contacting Helen Hick, the HR Director.
4.1 You must not unlawfully discriminate against or harass other people including current and former employees, job applicants, clients, customers, suppliers and visitors. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work- related contacts or when wearing a work uniform), and on work-related trips or events including social events.
4.2 The following forms of discrimination are prohibited under this policy and are unlawful:
a) Direct discrimination: treating someone less favourably because of a Protected Characteristic. For example, rejecting a job applicant because of their religious views or because they might be gay.
b) Indirect discrimination: a provision, criterion or practice that applies to everyone but adversely affects people with a particular Protected Characteristic more than others and is not justified. For example, requiring a job to be done full-time rather than part-time would adversely affect women because they generally have greater childcare commitments than men. Such a requirement would be discriminatory unless it can be justified.
c) Harassment: this includes sexual harassment and other unwanted conduct related to a Protected Characteristic, which has the purpose or effect of violating someone’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Harassment is dealt with further in our Anti-harassment and Bullying Policy.
d) Victimisation: retaliation against someone who has complained or has supported someone else’s complaint about discrimination or harassment.
e) Disability discrimination: this includes direct and indirect discrimination, any unjustified less favourable treatment because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability.
5. Recruitment and selection
5.1 Recruitment, promotion, and other selection exercises such as redundancy selection will be conducted on the basis of merit, against objective criteria that avoid discrimination. Shortlisting should be done by more than one person and with the involvement of the Human Resources Department, where possible. Our recruitment procedures should be reviewed regularly to ensure that individuals are treated on the basis of their relevant merits and abilities.
5.2 Vacancies should generally be advertised to a diverse section of the labour market. Advertisements should avoid stereotyping or using wording that may discourage particular groups from applying.
5.3 We take steps to ensure that our vacancies are advertised to a diverse labour market. Where appropriate, the Human Resources Department may approve the use of lawful exemptions to recruit someone with a particular Protected Characteristic, for example, where the job can only be done by a woman. The advertisement should specify the exemption that applies.
5.4 Job applicants should not be asked questions which might suggest an intention to discriminate on grounds of a Protected Characteristic. For example, applicants should not be asked whether they are pregnant or planning to have children.
5.5 Job applicants should not be asked about health or disability before a job offer is made. There are limited exceptions which should only be used with the approval of the Human Resources Department. For example:
a) Questions necessary to establish if an applicant can perform an intrinsic part of the job (subject to any reasonable adjustments).
b) Questions to establish if an applicant is fit to attend an assessment or any reasonable adjustments that may be needed at interview or assessment.
c) Positive action to recruit disabled persons.
d) Equal opportunities monitoring (which will not form part of the selection or decision-making process).
Where necessary, job offers can be made conditional on a satisfactory medical check.
5.6 We are required by law to ensure that all employees are entitled to work in the UK. Assumptions about immigration status should not be made based on appearance or apparent nationality. All prospective employees, regardless of nationality, must be able to produce original documents (such as a passport) before employment starts, to satisfy current immigration legislation. The list of acceptable documents is available from UK Visas and Immigration.
5.7 To ensure that this policy is operating effectively, and to identify groups that may be underrepresented or disadvantaged in our organisation, we monitor applicants’ ethnic group, gender, disability, sexual orientation, religion and age as part of the recruitment procedure. Provision of this information is voluntary and it will not adversely affect an individual’s chances of recruitment or any other decision related to their employment. The information is removed from applications before shortlisting and kept in an anonymised format solely for the purposes stated in this policy. Analysing this data helps us take appropriate steps to avoid discrimination and improve equality and diversity.
6. Training and promotion and conditions of service
6.1 Training needs will be identified through regular appraisals. You will be given appropriate access to training to enable you to progress within the organisation and all promotion decisions will be made on the basis of merit.
6.2 Our conditions of service, benefits and facilities are reviewed regularly to ensure that they are available to all of you who should have access to them and that there are no unlawful obstacles to accessing them.
7. Termination of employment
7.1 We will ensure that redundancy criteria and procedures are fair and objective and are not directly or indirectly discriminatory.
7.2 We will also ensure that disciplinary procedures and penalties are applied without discrimination, whether they result in disciplinary warnings, dismissal or other disciplinary action.
8.1 If you are disabled or become disabled, we encourage you to tell us about your condition so that we can support you as appropriate.
8.2 If you experience difficulties at work because of your disability, you may wish to contact the Human Resources department to discuss any reasonable adjustments that would help overcome or minimise the difficulty. The Human Resources Department may wish to consult with you and your medical adviser about possible adjustments. We will consider the matter carefully and try to accommodate your needs within reason. If we consider a particular adjustment would not be reasonable, we will explain our reasons and try to find an alternative solution where possible.
8.3 We will monitor the physical features of our premises to consider whether they might place anyone with a disability at a substantial disadvantage. Where necessary, we will take reasonable steps to improve access.
9. Part-time and fixed-term work
Part-time and fixed-term staff should be treated the same as comparable full-time or permanent staff and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate), unless different treatment is justified.
10. Breaches of this policy
10.1 We take a strict approach to breaches of this policy, which will be dealt with in accordance with our Disciplinary Procedure. Serious cases of deliberate discrimination may amount to gross misconduct resulting in dismissal.
10.2 If you believe that you have suffered discrimination you can raise the matter through our Grievance Procedure or through our Anti-harassment and Bullying Policy as appropriate. Complaints will be treated in confidence and investigated as appropriate.
10.3 There must be no victimisation or retaliation against staff who complain about discrimination. However, making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under our Disciplinary Procedure.
11. Related policies
This policy is supported by the following other policies and procedures:
a) Anti-Harassment and Bullying Policy
b) Grievance Procedure
c) Disciplinary Procedure
d) Flexible Working Procedure
e) Maternity, Paternity, Adoption and Shared Parental Leave Policies
f) Parental Leave Policy
g) Time Off for Dependants Policy
h) Dress Code
i) Homeworking Policy
MODERN SLAVERY TRANSPARENCY STATEMENT 2020
This statement is made in accordance with the Modern Slavery Act 2015. It explains our approach to prevent modern slavery and human trafficking from occurring in our business and our supply chains.
Our business and supply chain
Larkfleet Group Limited is the holding company of a number of companies of which comprises an award-winning housebuilding and development company based in Bourne, Lincolnshire.
Our businesses have a focus on sustainability. We are a sustainable housebuilder, an investor in sustainability with focused R&D projects and a provider of energy-efficiency improvements for new and existing buildings.
We engage a multitude of contractors and subcontractors and take the issue of modern slavery and human trafficking very seriously.
We understand that this is a collaborative effort, which all companies, individuals, sole traders and partnerships should take part in. We will not allow modern slavery to occur in our business or in our supply chains.
What we do
We have procedures in place to prevent slavery and human trafficking and we require our suppliers to take positive steps to ensure slavery and human trafficking is not present in their supply chains. Our suppliers, employees and contractors have been informed of our position and their duty to report any instances which they encounter.
We now ask all of our supply chain to confirm that they take positive steps to eliminate modern slavery and human trafficking.
We recognise that this is an ongoing process and we therefore take a risk based approach to modern slavery and human trafficking by educating our staff and our supply chain with what is expected of them.
Targets for 2020
- To continue to monitor and educate our staff and supply chain;
- To encourage all of our supply chain to confirm that they are taking positive steps to eliminate human trafficking and modern slavery;
- To undertake due diligence to ensure compliance with the Act;
- To continue to develop our approach to tackling the issue of Modern Slavery.
This statement was approved by Karl Hick who is the Chairman of the Larkfleet Group of companies.
HUMAN TRAFFICKING AND MODERN SLAVERY
Larkfleet Group Limited and all its subsidiaries and associated companies (”Larkfleet”) take the view that modern slavery and human trafficking has no place in our society or the world. We therefore will not tolerate any form of modern slavery or human trafficking in our supply chain.
What is modern slavery?
Someone is in slavery if they are:
- forced to work – through coercion, or mental or physical threat;
- owned or controlled by an ’employer’, through mental or physical abuse or the threat of abuse;
- dehumanised, treated as a commodity or bought and sold as ‘property’;
- physically constrained or have restrictions placed on their freedom of movement.
Modern slavery takes on a number of forms including but not limited to:
- Forced labour – any work or services which people are forced to do against their will under the threat of some form of punishment.
- Debt bondage or bonded labour – the world’s most widespread form of slavery, when people borrow money they cannot repay and are required to work to pay off the debt, then losing control over the conditions of both their employment and the debt.
- Human trafficking – involves transporting, recruiting or harbouring people for the purpose of exploitation, using violence, threats or coercion.
The Modern Slavery Act requires all UK companies with turnover in excess of £36m to make an annual statement detailing the steps their business is taking to identify and prevent modern slavery within their business and throughout their supply chain. http://www.legislation.gov.uk/ukpga/2015/30/contents/enacted
We will not tolerate any business/contractor or company which is involved in slavery and human trafficking. Any part of our supply chain which we suspect or have grounds to believe are engaging in human trafficking/modern slavery will be fully investigated.
We recognise that it takes a collaborative effort to eliminate modern slavery and human trafficking once and for all and we therefore require you to report any incidents or suspected incidents of modern slavery to us as soon as possible.