Policies and Procedures Manual

Comprehensive Policy Framework

• Company Registration Number: 6085832
• Registered Office: Savoy House, Old Oak Common Lane, Savoy Circus, London, W3 7DA
• Version: 3.0
• Last Updated: April 2026
• Next Review Date: April 2027

Table of Contents

1. Modern Slavery and Human Trafficking Statement
2. Safeguarding Policy
3. Equality, Diversity and Inclusion Policy
4. Privacy Policy
5. Cookie Policy
6. Data Protection and GDPR Compliance Policy
7. Terms and Conditions
8. Disclaimer

1. Modern Slavery and Human Trafficking Statement

1.1 Introduction and Commitment

Landell Fraser Limited is committed to preventing modern slavery and human trafficking in all its forms within our business operations and supply chains. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps we have taken and continue to take to ensure that slavery and human trafficking are not occurring in our business or supply chains.

We have a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our organisation or in any of our supply chains.

1.2 Our Business and Organisational Structure

Landell Fraser Limited (Company Number 6085832) is a business consultancy providing human resource management, organisational development, employment law, and learning and development solutions. Our registered office is located at Savoy House, Old Oak Common Lane, Savoy Circus, London, W3 7DA.

Our services include:

• Consultancy services in HR and organisational development
• Coaching services for professional development
• Learning and training services both online and face-to-face
• Employment law solutions

1.3 Our Supply Chains

Our supply chains include the procurement of:

• Technology and software services for online learning platforms
• Professional services from associate consultants and trainers
• Venue hires for face-to-face training delivery
• Office supplies and equipment
• Marketing and promotional materials

1.4 Our Policies on Slavery and Human Trafficking

We have implemented the following policies to ensure modern slavery and human trafficking do not occur in our business:

1.4.1 Recruitment and Employment Practices

• We conduct right-to-work checks for all employees in accordance with the Immigration, Asylum and Nationality Act 2006
• All employees are provided with written terms and conditions of employment
• We pay all employees at least the National Minimum Wage/National Living Wage in accordance with the National Minimum Wage Act 1998
• We do not withhold identity documents or require employees to pay for their jobs

1.4.2 Supplier Due Diligence

• We assess the risk of modern slavery in our supply chains before engaging new suppliers
• We require suppliers to confirm their compliance with modern slavery legislation
• We include anti-slavery and human trafficking provisions in our contracts with suppliers
• We reserve the right to terminate contracts with suppliers who breach modern slavery obligations

1.5 Due Diligence Processes

As part of our commitment to identifying and mitigating risk, we have in place systems to:

• Identify and assess potential risk areas in our supply chains
• Monitor potential risk areas in our supply chains through regular reviews
• Reduce the risk of slavery and human trafficking occurring by ensuring our suppliers adhere to our values and ethical standards
• Provide appropriate training to relevant staff members on modern slavery issues

1.6 Training and Awareness

We provide training to relevant members of staff to ensure they understand:

• The signs of modern slavery and human trafficking
• How to report suspected cases of modern slavery
• Our commitment to ethical business practices
• The importance of supply chain transparency

1.7 Reporting Concerns

We encourage all employees, customers, suppliers, and other business partners to report any concerns related to our business or supply chains. We have established the following reporting mechanisms:

• Email: enquiries@https://landellfraser.com
• In writing to: The Directors, Landell Fraser Limited, Savoy House, Old Oak Common Lane, Savoy Circus, London, W3 7DA

All reports will be investigated thoroughly, and whistleblowers will be protected in accordance with the Public Interest Disclosure Act 1998.

1.8 Effectiveness and Key Performance Indicators

We measure the effectiveness of our approach through:

• Annual review of supplier compliance with modern slavery obligations
• Recording and investigating any modern slavery concerns raised
• Completion of modern slavery training by relevant staff members
• Regular audits of recruitment and employment practices

1.9 Governance and Approval

This statement has been approved by the Board of Directors of Landell Fraser Limited. It will be reviewed annually and updated as necessary to reflect changes in our business and legislative requirements.

Signed on behalf of Landell Fraser Limited
Date: April 2026

1.10 Legislative References

• Modern Slavery Act 2015
• Immigration, Asylum and Nationality Act 2006
• National Minimum Wage Act 1998
• Public Interest Disclosure Act 1998

2. Safeguarding Policy

2.1 Policy Statement and Commitment

Landell Fraser Limited is committed to safeguarding and promoting the welfare of children, young people, and vulnerable adults who come into contact with our organisation through our training, coaching, and consultancy services. We recognise that safeguarding is everyone’s responsibility.

This policy applies to all staff, consultants, contractors, volunteers, and anyone working on behalf of Landell Fraser Limited. We will not tolerate abuse or exploitation of any kind and are committed to creating and maintaining a safe environment for all participants in our services.

2.2 Scope and Definitions

2.2.1 Who is Covered

This policy covers:

• Children and young people under 18 years of age
• Adults at risk: adults who have care and support needs, are experiencing or at risk of abuse or neglect, and as a result are unable to protect themselves from that abuse or neglect

2.2.2 Types of Abuse

We recognise the following categories of abuse:

• Physical abuse: causing physical harm including hitting, shaking, poisoning, or causing illness
• Emotional abuse: persistent emotional maltreatment causing severe adverse effects on emotional development
• Sexual abuse: forcing or enticing a person to take part in sexual activities
• Neglect: persistent failure to meet basic physical and/or psychological needs
• Financial abuse: unauthorised use of someone’s money or property
• Discriminatory abuse: abuse based on protected characteristics under the Equality Act 2010
• Organisational abuse: abuse that occurs in institutional settings
• Self-neglect: neglecting to care for one’s personal hygiene, health, or surroundings
• Domestic abuse: any incident of controlling, coercive, or threatening behaviour between those aged 16 or over who are or have been intimate partners or family members

2.3 Safer Recruitment

We are committed to safe recruitment practices to ensure unsuitable people are prevented from working with vulnerable groups. Our procedures include:

• Obtaining Disclosure and Barring Service (DBS) checks at the appropriate level for all staff and consultants who have contact with children or vulnerable adults
• Verifying identity, right to work, and qualifications of all staff
• Obtaining at least two professional references for all employees
• Conducting structured interviews that explore attitudes towards safeguarding
• Ensuring all staff receive safeguarding training appropriate to their role
• Maintaining a Single Central Record of all pre-employment checks

2.4 Designated Safeguarding Leads

We have appointed Designated Safeguarding Leads (DSLs) who are responsible for:

• Acting as the first point of contact for safeguarding concerns
• Coordinating safeguarding activities within the organisation
• Liaising with local safeguarding partnerships, police, and social services
• Maintaining records of safeguarding concerns and actions taken
• Ensuring safeguarding training is delivered to all staff
• Reviewing and updating safeguarding policies annually

Contact details for the Designated Safeguarding Lead:

• Email: enquiries@https://landellfraser.com
• Address: Landell Fraser Limited, Savoy House, Old Oak Common Lane, Savoy Circus, London, W3 7DA

2.5 Recognising Signs of Abuse

All staff must be vigilant and aware of potential indicators of abuse. These may include but are not limited to:

• Unexplained injuries or a pattern of injuries
• Behaviour changes such as withdrawal, aggression, or inappropriate sexual behaviour
• Fear of particular individuals or situations
• Disclosure of abuse (direct or indirect)
• Poor personal hygiene or presentation
• Unexplained gifts, money, or possessions
• Signs of self-harm or suicidal thoughts

2.6 Reporting Procedures

2.6.1 If You Have a Concern

If you have a safeguarding concern, you must:

• Report it immediately to the Designated Safeguarding Lead
• Record what you have seen or heard in writing, using the person’s own words where possible
• Do not investigate or ask leading questions
• Maintain confidentiality on a ‘need to know’ basis

2.6.2 If Someone Discloses Abuse to You

• Listen carefully and take what is said seriously
• Do not promise confidentiality; explain you will need to tell appropriate people
• Do not press for details or ask leading questions
• Reassure the person they were right to tell you
• Report to the Designated Safeguarding Lead immediately
• Record the conversation in writing as soon as possible

2.6.3 Emergency Situations

If a child or vulnerable adult is in immediate danger:

• Call 999 (emergency services) immediately
• Inform the Designated Safeguarding Lead as soon as possible
• Follow any immediate safety instructions from emergency services

2.7 Information Sharing and Confidentiality

We recognise that effective safeguarding requires information sharing. We will share information:

• On a ‘need to know’ basis to protect children and vulnerable adults
• With relevant authorities including police, social services, and local safeguarding partnerships
• In accordance with the Data Protection Act 2018 and UK GDPR
• With appropriate consent where possible, but safeguarding concerns override confidentiality

2.8 Training and Awareness

All staff and associates will receive:

• Safeguarding induction training within their first month
• Refresher training annually as a minimum
• Access to this safeguarding policy and procedures
• Updates on safeguarding matters as required

Designated Safeguarding Leads will receive specialist training every two years and attend regular update sessions.

2.9 Safe Practice Guidelines

All staff must adhere to the following safe practice guidelines:

• Maintain professional boundaries at all times
• Avoid being alone with a child or vulnerable adult wherever possible
• Ensure all online interactions are professional and appropriate
• Never share personal contact details with participants
• Do not transport participants in personal vehicles without authorisation
• Challenge inappropriate behaviour from colleagues or participants
• Respect diversity and avoid discriminatory behaviour

2.10 Record Keeping

We will maintain accurate and secure records of:

• All safeguarding concerns raised
• Actions taken in response to concerns
• Referrals to external agencies
• Safeguarding training completed by staff
• DBS checks and other pre-employment checks

All records will be stored securely in accordance with the Data Protection Act 2018 and retained in line with our data retention policy.

2.11 Allegations Against Staff

We take all allegations of abuse by staff members seriously. If an allegation is made against a member of staff:

• The matter will be reported to the Designated Safeguarding Lead immediately
• We will notify the Local Authority Designated Officer (LADO) within one working day
• The individual will be suspended pending investigation if appropriate
• We will cooperate fully with any external investigation
• We will make a referral to the DBS if dismissal or removal occurs

2.12 Working with Parents and Carers

We value working in partnership with parents and carers. We will:

• Ensure parents/carers are aware of our safeguarding policy
• Communicate openly about safeguarding where appropriate
• Seek consent for information sharing where possible, but prioritise child safety
• Provide support and signposting to relevant services

2.13 Online Safety

Given our provision of online training, we have specific measures in place to protect participants online:

• Use of secure, password-protected platforms for online delivery
• Clear acceptable use policies for online participants
• Monitoring of online sessions by appropriately trained staff
• Reporting mechanisms for online concerns
• Privacy settings that protect participant information

2.14 Review and Monitoring

This policy will be reviewed annually or following:

• Changes in legislation or statutory guidance
• Significant safeguarding incidents
• Changes in organisational structure or services
• Recommendations from safeguarding audits or inspections

2.15 Legislative References and Guidance

• Children Act 1989
• Children Act 2004
• Safeguarding Vulnerable Groups Act 2006
• Protection of Freedoms Act 2012
• Care Act 2014
• Counter-Terrorism and Security Act 2015 (Prevent Duty)
• Data Protection Act 2018
• Working Together to Safeguard Children (2023, updated 2024)
• Care and Support Statutory Guidance (Care Act 2014)

2.16 Useful Contacts

• National Child Abuse Helpline (NSPCC): 0808 800 5000
• Childline: 0800 1111
• Action on Elder Abuse Helpline: 0808 808 8141
• Samaritans: 116 123
• Police (emergency): 999
• Police (non-emergency): 101

3. Equality, Diversity and Inclusion Policy

3.1 Policy Statement

Landell Fraser Limited is committed to promoting equality of opportunity, celebrating diversity, and fostering an inclusive environment for all employees, associates, clients, and stakeholders. We recognise that a diverse and inclusive workplace drives innovation, creativity, and business success.

We will not tolerate any form of discrimination, harassment, or victimisation. This policy applies to all aspects of our operations including recruitment, training, promotion, service delivery, and business relationships.

3.2 Our Commitment

We are committed to:

• Creating a culture where diversity is valued and everyone feels included and respected
• Treating all individuals fairly and with dignity, irrespective of their protected characteristics
• Ensuring our workforce reflects the diversity of the communities we serve
• Providing equality of opportunity in all aspects of employment and service delivery
• Creating an environment free from discrimination, harassment, and victimisation
• Making reasonable adjustments to remove barriers faced by individuals with disabilities
• Regularly reviewing and monitoring our practices to ensure equality and inclusion

3.3 Legal Framework

This policy is underpinned by the Equality Act 2010, which protects individuals from discrimination based on the following protected characteristics:

• Age
• Disability
• Gender reassignment
• Marriage and civil partnership
• Pregnancy and maternity
• Race (including colour, nationality, ethnic or national origin)
• Religion or belief (including lack of belief)
• Sex (gender)
• Sexual orientation

We also extend protection beyond the protected characteristics to include other aspects of diversity such as socio-economic background, caring responsibilities, and neurodiversity.

3.4 Forms of Discrimination

We prohibit all forms of unlawful discrimination, including:

3.4.1 Direct Discrimination

Treating someone less favourably because of a protected characteristic.

3.4.2 Indirect Discrimination

Applying a provision, criterion, or practice that disadvantages people with a particular protected characteristic unless it can be objectively justified.

3.4.3 Harassment

Unwanted conduct related to a protected characteristic that violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating, or offensive environment.

3.4.4 Victimisation

Treating someone unfavourably because they have made or supported a complaint of discrimination or raised a grievance under the Equality Act 2010.

3.4.5 Associative and Perceptive Discrimination

Discrimination against someone based on their association with a person who has a protected characteristic, or because they are perceived to have a protected characteristic (whether or not they actually do).

3.5 Recruitment and Selection

We are committed to fair and transparent recruitment processes:

• All job advertisements will be inclusive and accessible
• Job descriptions and person specifications will focus on essential requirements only
• Selection will be based solely on merit, skills, qualifications, and experience
• Interview panels will receive equality and diversity training
• Reasonable adjustments will be made for disabled applicants throughout the recruitment process
• We will monitor recruitment data to identify and address any potential barriers to equality

3.6 Training and Development

We ensure equal access to training and development opportunities:

• All employees will receive equality and diversity training during induction
• Training needs will be identified through fair and objective appraisal processes
• Training opportunities will be advertised internally and accessible to all
• We will make reasonable adjustments to ensure all employees can access training
• Senior leadership will receive enhanced EDI training to champion inclusion

3.7 Promotion and Career Development

Promotion and career progression will be based on:

• Objective criteria related to performance, skills, and experience
• Fair and transparent processes accessible to all employees
• Regular performance reviews conducted without bias
• Support for employees with caring responsibilities or those returning from parental leave

3.8 Reasonable Adjustments

Under the Equality Act 2010, we have a duty to make reasonable adjustments for disabled employees and service users. This includes:

• Modifying premises to improve accessibility
• Providing auxiliary aids or services (e.g., assistive technology, interpreters)
• Adjusting working arrangements (e.g., flexible hours, home working)
• Modifying equipment or providing specialist equipment
• Allowing absence for rehabilitation, assessment, or treatment
• Providing training or mentoring support
• Modifying procedures for testing or assessment

Employees or service users requiring reasonable adjustments should contact enquiries@https://landellfraser.com to discuss their needs.

3.9 Flexible Working

We recognise that flexible working arrangements can promote equality and inclusion. We will consider all requests for flexible working in accordance with the Employment Rights Act 1996 (as amended by the Flexible Working Regulations 2014), including:

• Part-time working
• Job sharing
• Flexible start and finish times
• Working from home
• Compressed hours

3.10 Service Delivery

We are committed to providing inclusive and accessible services:

• All training and consultancy services will be designed to be accessible and inclusive
• We will make reasonable adjustments to accommodate diverse needs
• Materials and content will be free from bias and stereotyping
• We will use inclusive language and imagery in all communications
• Venues will be accessible or alternatives will be provided
• Online platforms will meet accessibility standards (WCAG 2.1 Level AA minimum)

3.11 Pay Equity

We are committed to equal pay for equal work, as required by the Equality Act 2010:

• Pay structures are transparent and based on job evaluation
• Starting salaries are determined by role requirements, not negotiation
• Pay reviews are conducted objectively based on performance and market rates
• We conduct regular equal pay audits to identify and address any disparities

3.12 Preventing and Addressing Discrimination

All employees have a responsibility to:

• Treat others with dignity and respect
• Challenge discriminatory behaviour or language
• Report incidents of discrimination, harassment, or victimisation
• Cooperate with investigations into equality concerns
• Attend mandatory equality and diversity training

3.13 Reporting Concerns and Complaints

If you experience or witness discrimination, harassment, or victimisation:

• Informal approach: Speak directly to the individual if you feel comfortable doing so
• Formal complaint: Contact your line manager or the Directors via enquiries@https://landellfraser.com
• All complaints will be investigated promptly, fairly, and confidentially
• Whistleblowing: Protected disclosures can be made under the Public Interest Disclosure Act 1998

We will not tolerate retaliation against anyone who raises a genuine concern about discrimination.

3.14 Positive Action

Where appropriate and lawful under sections 158 and 159 of the Equality Act 2010, we may take positive action to:

• Enable or encourage people from under-represented groups to overcome disadvantages
• Meet the particular needs of people with protected characteristics
• Use tie-break provisions in recruitment where candidates are equally qualified

3.15 Monitoring and Review

We will monitor the effectiveness of this policy through:

• Collection and analysis of equality monitoring data (with consent)
• Regular equality impact assessments of policies and practices
• Employee surveys and feedback mechanisms
• Analysis of recruitment, retention, and progression data
• Review of complaints and grievances related to discrimination
• Annual policy review and update

3.16 Responsibilities

3.16.1 Board of Directors

• Set the strategic direction for equality, diversity, and inclusion
• Ensure adequate resources are allocated to EDI initiatives
• Monitor progress against EDI objectives

3.16.2 Managers

• Lead by example in promoting equality and inclusion
• Ensure team members receive appropriate EDI training
• Address discriminatory behaviour promptly
• Support requests for reasonable adjustments and flexible working

3.16.3 All Employees

• Comply with this policy and treat colleagues and clients with respect
• Challenge discrimination and report concerns
• Participate in EDI training and initiatives

3.17 Legislative and Regulatory References

• Equality Act 2010
• Employment Rights Act 1996
• Flexible Working Regulations 2014
• Public Interest Disclosure Act 1998
• Human Rights Act 1998
• Equality and Human Rights Commission Code of Practice on Employment
• Web Content Accessibility Guidelines (WCAG) 2.1

4. Privacy Policy

4.1 Introduction

Landell Fraser Limited (“we”, “us”, “our”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information in accordance with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).

For the purposes of data protection legislation, Landell Fraser Limited (Company Number 6085832, registered office at Savoy House, Old Oak Common Lane, Savoy Circus, London, W3 7DA) is the data controller.

4.2 Personal Information We Collect

We may collect and process the following categories of personal information:

4.2.1 Information You Provide Directly

• Identity data: name, title, date of birth, gender
• Contact data: postal address, email address, telephone numbers
• Financial data: payment card details, billing address
• Transaction data: details of services purchased and payments made
• Profile data: username, password, preferences, feedback
• Professional data: job title, employer, professional qualifications
• Marketing data: preferences for receiving marketing communications

4.2.2 Information We Collect Automatically

• Technical data: IP address, browser type and version, operating system, time zone setting
• Usage data: information about how you use our website, products, and services
• Location data: general geographic location derived from IP address

4.2.3 Special Category Data

We do not routinely collect special category data (sensitive personal data such as health information, racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, or data concerning sexual orientation). If we need to process special category data for a specific purpose (e.g., to make reasonable adjustments for a disability), we will:

• Obtain your explicit consent, or
• Process it under another lawful basis as permitted by UK GDPR
• Ensure additional safeguards are in place

4.3 How We Collect Personal Information

We collect personal information through:

• Direct interactions: when you contact us, register for services, make a booking, or subscribe to newsletters
• Automated technologies: cookies and similar tracking technologies when you visit our website
• Third parties: payment processors, analytics providers, social media platforms
• Publicly available sources: professional networking sites, company websites

4.4 How We Use Your Personal Information

We will only use your personal information when the law allows us to. We use your personal information for the following purposes:

4.4.1 Contract Performance

To perform our contract with you, including:

• Processing your bookings and delivering training services
• Managing payments and financial transactions
• Providing customer support
• Administering your account and profile

4.4.2 Legal Obligations

To comply with our legal and regulatory obligations, including:

• Tax and accounting requirements
• Record-keeping obligations
• Health and safety requirements
• Employment law obligations

4.4.3 Legitimate Interests

Where it is necessary for our legitimate business interests (or those of a third party), provided your rights do not override these interests:

• Improving our services and developing new offerings
• Managing our business operations and internal administration
• Protecting our business and your information from fraud and security threats
• Analysing website usage to improve user experience
• Conducting research and analysis to understand client needs

4.4.4 Consent

Where you have given us consent:

• Sending you marketing communications about our services
• Using cookies and similar technologies (see our Cookie Policy)
• Processing special category data where required

You have the right to withdraw consent at any time by contacting us.

4.5 How We Share Your Personal Information

4.5.1 Service Providers

Third-party service providers who perform services on our behalf:

• IT and system administration services
• Payment processing services
• Email marketing platforms
• Online learning platforms
• Professional advisers (lawyers, accountants, insurers)

4.5.2 Legal and Regulatory Authorities

We may disclose your information to:

• Law enforcement agencies, courts, or regulatory authorities
• HM Revenue & Customs, regulators, and other authorities
• Third parties to whom we may choose to sell, transfer, or merge parts of our business

4.5.3 Data Processors

All third-party service providers are required to:

• Process your personal data only on our instructions
• Implement appropriate security measures
• Comply with UK GDPR and Data Protection Act 2018

4.6 International Transfers

We primarily store and process your data within the United Kingdom. If we transfer your personal information outside the UK, we will ensure:

• The transfer is to a country deemed adequate by the UK government, or
• We use UK International Data Transfer Agreement (IDTA) or approved Standard Contractual Clauses, or
• We have obtained your explicit consent for the transfer

4.7 Data Security

We have implemented appropriate technical and organisational measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Regular security assessments and penetration testing
• Access controls and authentication measures
• Staff training on data protection and security
• Incident response and breach notification procedures
• Regular backups and disaster recovery plans

4.8 Data Retention

We will retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including:

• Customer data: for the duration of our relationship plus 6 years for tax purposes
• Financial records: 6 years after the end of the financial year
• Employment records: up to 6 years after employment ends
• Marketing data: until you unsubscribe or withdraw consent
• CCTV footage: typically 30 days unless required for investigation

4.9 Your Data Protection Rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights:

4.9.1 Right of Access

You have the right to request a copy of the personal information we hold about you.

4.9.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information.

4.9.3 Right to Erasure

You have the right to request deletion of your personal information in certain circumstances.

4.9.4 Right to Restrict Processing

You have the right to request that we limit the processing of your personal information in certain circumstances.

4.9.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used format and transmit it to another controller.

4.9.6 Right to Object

You have the right to object to processing based on legitimate interests or for direct marketing purposes.

4.9.7 Right to Withdraw Consent

Where we rely on consent, you have the right to withdraw it at any time.

4.9.8 Right to Complain

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113.

4.10 Exercising Your Rights

To exercise any of your data protection rights, please contact us at:

• Email: enquiries@https://landellfraser.com
• Post: Data Protection Officer, Landell Fraser Limited, Savoy House, Old Oak Common Lane, Savoy Circus, London, W3 7DA

We will respond to your request within one month. In complex cases, we may extend this by two months and will notify you of any such extension.

4.11 Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our website at www.https://landellfraser.com. We will notify you of significant changes by email where appropriate.

4.12 Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us at contact@https://landellfraser.com.

4.13 Legislative References

• UK General Data Protection Regulation (UK GDPR)
• Data Protection Act 2018
• Privacy and Electronic Communications Regulations 2003 (PECR)
• Human Rights Act 1998

5. Cookie Policy

Last updated: April 2026

5.1 Introduction

This Cookie Policy explains what cookies are, how we use them on www.https://landellfraser.com, and how you can control them. This policy should be read in conjunction with our Privacy Policy.

5.2 What Are Cookies?

Cookies are small text files that are placed on your device when you visit a website. They are widely used to make websites work more efficiently and provide information to website owners. Cookies can be:

• Session cookies: temporary cookies that expire when you close your browser
• Persistent cookies: cookies that remain on your device for a set period or until you delete them
• First-party cookies: set by the website you are visiting
• Third-party cookies: set by a domain other than the website you are visiting

5.3 Why We Use Cookies

5.3.1 Strictly Necessary Cookies

These cookies are essential for our website to function properly. They enable core functionality such as security and authentication, network management, remembering your cookie preferences, and shopping basket functionality for our online courses.

Legal basis: These cookies are necessary for the performance of our contract with you or to comply with legal obligations. They do not require consent under PECR.

5.3.2 Performance and Analytics Cookies

These cookies help us understand how visitors interact with our website by collecting anonymous information, including number of visitors, pages visited, navigation behaviour, and error messages. We use Google Analytics for this purpose. These cookies do not collect personally identifiable information.

Legal basis: Consent (you can opt out via our cookie banner or browser settings).

5.3.3 Functional Cookies

These cookies enable enhanced functionality and personalisation, including remembering your preferences, recognising when you return to our website, and providing customised content.

Legal basis: Consent (you can opt out via our cookie banner).

5.3.4 Targeting and Advertising Cookies

We currently do not use targeting or advertising cookies. If we introduce these in future, we will update this policy and seek your consent.

5.4 Cookies We Use

5.5 Managing Cookies

5.5.1 Cookie Banner

When you first visit our website, you will see a cookie banner allowing you to accept or reject non-essential cookies. You can change your preferences at any time by clicking the ‘Cookie Settings’ link in our website footer.

5.5.2 Browser Settings

Most web browsers allow you to control cookies through their settings. You can typically view, delete, or block cookies. Please note that blocking all cookies may prevent you from using certain features of our website. For guidance, visit www.aboutcookies.org or www.allaboutcookies.org.

5.5.3 Opting Out of Analytics

To opt out of Google Analytics tracking across all websites, you can install the Google Analytics Opt-out Browser Add-on.

5.6 Third-Party Cookies

Our website may include content from third-party services such as social media platforms (e.g., LinkedIn, Instagram), video hosting services (e.g., YouTube, Vimeo), and payment processors (e.g., PayPal, Stripe). These third parties may set their own cookies. We do not control these cookies, and you should check the relevant third party’s website for information about their cookies and how to manage them.

5.7 Web Beacons and Similar Technologies

In addition to cookies, we may use web beacons (also known as pixel tags or clear GIFs) in our emails and on our website. These help us track email open rates and link clicks, understand which content is most engaging, and improve our marketing communications.

5.8 Changes to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in technology, legislation, or our business practices. The latest version will always be available on our website.

5.9 Contact Us

If you have questions about our use of cookies, please contact us at contact@https://landellfraser.com

5.10 Legislative References

• Privacy and Electronic Communications Regulations 2003 (PECR)
• UK General Data Protection Regulation (UK GDPR)
• Data Protection Act 2018
• ICO Guidance on the use of cookies and similar technologies

6. Data Protection and GDPR Compliance Policy

6.1 Introduction and Purpose

This policy sets out our approach to data protection and our compliance with the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018. It should be read alongside our Privacy Policy and applies to all employees, contractors, associates, and third-party data processors working on behalf of Landell Fraser Limited.

6.2 Data Protection Principles

We are committed to complying with the seven key data protection principles under Article 5 of UK GDPR:

6.2.1 Lawfulness, Fairness and Transparency

• We process personal data lawfully, fairly, and transparently
• We clearly explain how we use personal data in our Privacy Policy
• We have identified a lawful basis for all processing activities

6.2.2 Purpose Limitation

• We collect data for specified, explicit, and legitimate purposes only
• We do not use data in ways that are incompatible with the original purpose
• We maintain records of processing activities (ROPA) documenting all purposes

6.2.3 Data Minimisation

• We only collect personal data that is adequate, relevant, and necessary
• We regularly review data collection forms to remove unnecessary fields
• We do not collect data ‘just in case’ it might be useful in future

6.2.4 Accuracy

• We take reasonable steps to ensure personal data is accurate and up to date
• We provide mechanisms for individuals to update their information
• We erase or rectify inaccurate data without delay

6.2.5 Storage Limitation

• We retain personal data only for as long as necessary for the purposes collected
• We have established retention periods for different data categories
• We conduct regular reviews to delete data that is no longer needed

6.2.6 Integrity and Confidentiality (Security)

• We implement appropriate technical and organisational security measures
• We protect data against unauthorised or unlawful processing
• We protect against accidental loss, destruction, or damage

6.2.7 Accountability

• We are responsible for and can demonstrate compliance with all principles
• We maintain comprehensive documentation of our data processing
• We conduct regular audits and reviews of our data protection practices

6.3 Lawful Bases for Processing

We only process personal data when we have a lawful basis under Article 6 of UK GDPR:

• Consent: The individual has given clear consent for a specific purpose
• Contract: Processing is necessary for a contract, or to take steps to enter one
• Legal obligation: Processing is necessary to comply with the law
• Vital interests: Processing is necessary to protect someone’s life
• Public task: Processing is necessary to perform a task in the public interest
• Legitimate interests: Processing is necessary for our legitimate interests, unless overridden by individual rights

6.4 Special Category Data

Special category data (Article 9 UK GDPR) includes data about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, and sex life or sexual orientation.

We only process special category data when we have both a lawful basis under Article 6 and a condition under Article 9, such as explicit consent, employment and social protection law, vital interests (where consent cannot be obtained), or substantial public interest.

6.5 Individual Rights

6.5.1 Subject Access Requests (SARs)

• We respond to SARs within one month (extendable by two months in complex cases)
• We verify the identity of requestors before providing information
• We provide information free of charge unless requests are manifestly unfounded or excessive
• We provide information in a concise, transparent, intelligible, and easily accessible form

6.5.2 Right to Rectification

• We correct inaccurate data within one month
• We notify recipients of any corrections where appropriate

6.5.3 Right to Erasure (‘Right to be Forgotten’)

We erase personal data when:

• It is no longer necessary for the purpose it was collected
• Consent is withdrawn and there is no other legal basis
• The individual objects and there are no overriding legitimate grounds
• The data has been unlawfully processed
• Erasure is required to comply with a legal obligation

6.6 Data Security Measures

6.6.1 Technical Measures

• Encryption of data at rest and in transit using industry-standard protocols (TLS 1.2+, AES-256)
• Multi-factor authentication for access to systems containing personal data
• Regular security updates and patch management
• Firewall protection and intrusion detection systems
• Regular data backups with secure off-site storage
• Pseudonymisation and anonymisation where appropriate

6.6.2 Organisational Measures

• Access controls based on role and need-to-know principle
• Mandatory data protection training for all staff
• Clear desk and clear screen policies
• Secure disposal procedures for physical and electronic media
• Visitor management and physical security measures
• Business continuity and disaster recovery plans

6.7 Data Breach Management

6.7.1 Detection and Containment

• Staff are trained to recognise and report potential breaches immediately
• We take immediate steps to contain the breach and limit damage
• We preserve evidence for investigation

6.7.2 Assessment

• We assess the breach to determine severity and risk to individuals
• We consider factors including volume, sensitivity, and potential consequences
• We document our assessment and decision-making process

6.7.3 Notification

• We notify the Information Commissioner’s Office (ICO) within 72 hours if the breach is likely to result in a risk to individuals’ rights and freedoms
• We notify affected individuals without undue delay if the breach is likely to result in a high risk to their rights and freedoms
• We provide clear information about the nature of the breach and steps taken

6.7.4 Documentation and Review

• We maintain a register of all data breaches, whether reported to ICO or not
• We investigate root causes and implement corrective actions
• We review and update our security measures based on lessons learned

6.8 Data Protection Impact Assessments (DPIAs)

We conduct DPIAs when processing is likely to result in high risk to individuals, including when using new technologies, processing special category data on a large scale, systematically monitoring publicly accessible areas, making automated decisions with significant legal effects, or processing vulnerable individuals’ data.

6.9 Third-Party Data Processors

When engaging third-party processors, we:

• Conduct due diligence to ensure they can provide sufficient guarantees
• Establish written contracts meeting Article 28 UK GDPR requirements
• Ensure processors only act on our documented instructions
• Require appropriate security measures and confidentiality
• Monitor compliance through regular audits and reviews

6.10 Staff Responsibilities

All staff must:

• Complete mandatory data protection training
• Process personal data only as authorised and instructed
• Maintain confidentiality of personal data
• Report actual or suspected data breaches immediately
• Not remove or copy personal data without authorisation
• Comply with all data protection policies and procedures

6.11 Accountability and Governance

• The Board of Directors is ultimately responsible for data protection compliance
• We maintain a Record of Processing Activities (ROPA) as required by Article 30 UK GDPR
• We conduct annual data protection audits
• We review and update policies at least annually
• We maintain documentation to demonstrate compliance with UK GDPR

6.12 Legislative References

• UK General Data Protection Regulation (UK GDPR)
• Data Protection Act 2018
• Privacy and Electronic Communications Regulations 2003 (PECR)
• Human Rights Act 1998 (Article 8 – Right to Privacy)
• ICO Codes of Practice and Guidance

7. Terms and Conditions

Last updated: April 2026

7.1 Introduction

These Terms and Conditions govern the use of our services and website. Accessing our website or booking a service constitutes acceptance of these terms. Please read them in full before proceeding.

7.2 Definitions

• “We”, “us”, “our” refers to Landell Fraser Limited
• “You”, “your” refers to the customer or user of our services
• “Services” includes all training, coaching, consultancy, and professional services we provide
• “Website” refers to www.https://landellfraser.com and all associated web pages

7.3 Booking and Registration

7.3.1 How to Book

Bookings can be made via:

• Our website at www.https://landellfraser.com
• Third-party platforms (e.g., Eventbrite, LinkedIn) — subject to their additional terms
• Email to events@https://landellfraser.com
• By telephone as advertised on specific courses

7.3.2 Booking Confirmation

• You will receive booking confirmation by email as soon as we receive your payment
• A contract is formed when we send you booking confirmation
• Please check your confirmation details carefully and notify us of any errors within 48 hours

7.4 Payment Terms

• Full payment must be made at the time of booking for public courses and online events
• For corporate bookings, payment is due within 30 days of invoice date unless otherwise agreed
• We accept payment via PayPal, credit/debit card, and bank transfer
• We do not store your card details; all payment processing is handled securely by our payment providers
• All prices are quoted in GBP and exclude VAT unless stated otherwise
• We reserve the right to charge interest on late payments at 8% above Bank of England base rate

7.5 Cancellation and Refund Policy

7.5.1 Cancellations by You – Online Events

All cancellations must be notified in writing to events@https://landellfraser.com. The following charges apply:

• More than 14 days before the event: 15% administration charge; 85% refunded
• 8–14 days before the event: 50% charge; 50% refunded
• Within 7 days of the event: Full fee charged; no refund

7.5.2 Cancellations by You – Face-to-Face Public Courses

• More than 28 days before the course: 15% administration charge; 85% refunded
• 15–28 days before the course: 50% charge; 50% refunded
• Within 14 days of the course: Full fee charged; no refund

7.5.3 Substitute Delegates and Transfers

• You may nominate a substitute delegate to attend in your place at no additional charge
• Subject to availability, you may transfer your booking to an alternative course date
• Please contact events@https://landellfraser.com as soon as possible to arrange substitutions or transfers

7.5.4 Cancellations by Us

• We may cancel or postpone events due to insufficient bookings, trainer illness, or other unforeseen circumstances
• We will give you as much notice as possible of any cancellation
• If we cancel an event, you will receive a full refund or the option to transfer to an alternative date
• We are not liable for any travel, accommodation, or other expenses you have incurred
• We are not responsible for consequential losses resulting from cancellation

7.6 Joining Instructions and Access

• For online events, joining instructions will be sent at least 3 days before the course start date
• For face-to-face courses, joining instructions will be sent at least 7 days before the course start date
• Please contact events@https://landellfraser.com if you do not receive joining instructions within these timeframes
• You are responsible for ensuring you have the necessary technology and internet connection for online courses

7.7 Programme Changes

• We reserve the right to change trainers, speakers, or course content without prior notice
• We may change course venues, formats (online/face-to-face), or timings where necessary
• We will notify you of any material changes as soon as reasonably practicable
• If changes fundamentally alter the nature of the course, you may cancel for a full refund

7.8 Your Responsibilities

• You must attend courses punctually and participate constructively
• You must comply with all venue rules and health and safety requirements
• You must treat trainers, staff, and other participants with respect
• You must not record, photograph, or share course materials without our permission
• We reserve the right to remove participants who behave inappropriately, without refund

7.9 Intellectual Property Rights

• We own or license all intellectual property rights in our website and course materials
• You may not copy, reproduce, republish, upload, post, transmit, or distribute our materials without written permission
• Course materials are provided for your personal learning only
• All trademarks, service marks, and logos are the property of their respective owners

7.10 Limitation of Liability

These terms do not exclude or limit our liability for death or personal injury caused by our negligence, fraud or fraudulent misrepresentation, or any other liability that cannot be excluded by law.

Subject to the above, we are not liable for loss of profits, revenue, contracts or business opportunities, loss of anticipated savings or goodwill, loss of data or information, indirect or consequential losses, or any losses arising from your use or inability to use our website or services.

Our total liability for all claims arising from any single course or service shall not exceed the fees paid for that course or service.

7.11 Data Protection and Privacy

We handle all personal data in accordance with the Data Protection Act 2018 and UK GDPR. Please see our Privacy Policy and Data Protection Policy for full details. By booking our services, you consent to us processing your data as described in our Privacy Policy.

7.12 Force Majeure

We are not liable for failure to perform our obligations due to circumstances beyond our reasonable control, including but not limited to acts of God, extreme weather, natural disasters, war, terrorism, civil unrest, government action, pandemic, epidemic, public health emergency, strikes, or failure of utilities, telecommunications, or internet services.

7.13 Entire Agreement

These Terms and Conditions, together with our Privacy Policy and any specific course or service agreement, constitute the entire agreement between us. Any variations must be agreed in writing. If any provision is found to be invalid or unenforceable, the remaining provisions shall continue in full force.

7.14 Governing Law and Jurisdiction

These Terms and Conditions are governed by English law. Any disputes shall be subject to the exclusive jurisdiction of the courts of England and Wales.

7.15 Contact Information

Landell Fraser Limited
Registered Company Number: 6085832
Registered Office: Savoy House, Old Oak Common Lane, Savoy Circus, London, W3 7DA
Email: enquiries@https://landellfraser.com
Events Email: events@https://landellfraser.com
Website: www.https://landellfraser.com

8. Disclaimer

Last updated: April 2026

8.1 General Disclaimer

The information provided by Landell Fraser Limited on www.https://landellfraser.com is for general informational purposes only. While provided in good faith, no representation or warranty is made regarding its accuracy, adequacy, validity, reliability, availability, or completeness. Users should seek appropriate professional advice before relying on any content.

8.2 Professional Advice Disclaimer

• The website cannot and does not contain professional advice (legal, financial, HR, or otherwise)
• All information is provided for general informational and educational purposes only
• The information should not be used as a substitute for professional advice specific to your circumstances
• Before taking any actions based on information from our website or services, consult with appropriate professionals
• Your use of or reliance on any information contained on the website is solely at your own risk

8.3 No Warranties

Under no circumstances shall we have any liability for any loss or damage of any kind incurred as a result of the use of the website, reliance on any information provided on the website, inability to access the website, or errors, omissions, or interruptions on the website.

8.4 External Links Disclaimer

• The website may contain links to external websites operated by third parties
• These links are provided for your convenience only
• We have no control over the content of third-party websites
• We do not investigate, monitor, or check external websites for accuracy or completeness
• We do not warrant, endorse, guarantee, or assume responsibility for any third-party content
• We will not be liable for any transactions between you and third-party providers
• Always check privacy policies before submitting personal data to third-party websites

8.5 Testimonials Disclaimer

• Testimonials on our website reflect the real experiences and opinions of service users
• Individual experiences are personal and may not be representative of all users
• We do not claim that all users will have the same experiences
• Individual results may vary depending on personal circumstances
• Testimonials are reviewed before posting but appear verbatim except for corrections of grammar or typing errors; some may be shortened for brevity
• We do not pay or otherwise compensate users for testimonials

8.6 Limitation of Liability

It is a condition of your use of this website that you accept we are excluded from liability for loss of any kind arising from your use of the website to the fullest extent permitted by law, including loss of profits or revenue, loss of business or contracts, loss of anticipated savings, loss of or damage to data, loss of goodwill or reputation, and indirect or consequential losses.

Nothing in this disclaimer excludes or limits our liability for death or personal injury caused by negligence, fraud or fraudulent misrepresentation, or any other liability that cannot be excluded by law.

8.7 Intellectual Property Rights

• Unless otherwise stated, all intellectual property rights in materials on this website are our exclusive property
• The materials are protected by copyright, trademark, and other intellectual property laws
• You must not copy, reproduce, reorder, or redeploy content without our express written consent
• By using our website, you agree not to infringe our intellectual property rights in any form

8.8 Data Protection

Any information you provide via our website will be used only for the purposes for which it was given. We process all data in accordance with the Data Protection Act 2018 and UK GDPR. For full details, please see our Privacy Policy and Data Protection Policy.

8.9 Changes to This Disclaimer

We may update this disclaimer from time to time. The latest version will always be available on our website. Continued use of the website after changes constitutes acceptance of the updated disclaimer.

8.10 Company Information

Landell Fraser Limited
Registered in England
Company Number: 6085832
Registered Office: Savoy House, Old Oak Common Lane, Savoy Circus, London, W3 7DA

End of Policies and Procedures Manual — Version 3.0, April 2026