Our Policies

This Policy sets out the following:

What personal data we collect and process about you in connection with your relationship with us as a customer and through your use of our website, mobile applications and online services;
Where we obtain the data from;
What we do with that data;
How we store the data;
Who we transfer/disclose that data to;
How we deal with your data protection rights;
How we comply with the data protection rules;
How all personal data is collected and processed in accordance with UK and EU data protection laws.

What do we use your personal data for?

Your data may be used for the following purposes:

Providing products and services you request: we use the information you give us to perform the services you have asked for in relation to your stay at our hotel.
Contacting you in the event of a change or cancellation: we send you communications about the services you have asked for and any changes to such services. These communications are not made for marketing purposes and cannot be opted-out of;
Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and / or prevent any fraudulent activities;
Administrative or legal purposes: we use your data for statistical and marketing analysis, systems testing, customer surveys, maintenance and development, or in order to deal with a dispute or claim. By providing any personal data you explicitly agree that we may use it to perform profiling activities in accordance with this Privacy Policy;
Immigration/customs control safety: we may be obliged to provide your information to border control agencies;
Security, health, administrative, crime prevention/detection: we may pass your information to government authorities or enforcement bodies for compliance with legal requirements;
Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us;
Provide tailored services: we use your data to provide information we believe is of interest to you, prior to, during, and after your stay with us and to personalise the services we offer to you, such as special offers;
Marketing: from time to time we will contact you with information regarding in house promotions via e-communications. You will have the choice to opt in or opt out of receiving such communications by indicating your choice at the booking stage. You will also be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material;
We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for;
Only children aged 16 or over can provide their own consent;
We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means;
When we no longer need your personal data, we will securely delete or destroy it.

What personal data we collect:

Personal data means any information relating to you which allows us to identify you, such as your name, contact details, booking reference number, payment details and information about your access to our website.

We may collect personal data from you when you book our Hotel (either directly or indirectly through our trusted third party partners), use our website and other websites accessible through our website, participate in a survey or competition, or when you contact us.

Specifically, we may collect the following categories of information:

Name, home address, e-mail address, telephone number, passport or other recognized personal ID card numbers and details, credit/debit card or other payment details;
Advance Personal Information, which includes your name, nationality, date of birth, gender, passport or ID number, expiry date and country of issue;
Hotel customers with dietary requirements;
Information about your use of our website;
The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media;
Location, including real-time geographic location of your computer or device through GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell locations, if you use location-based features and turn on the Location Services settings on your device and computer. Personal details about your physical or mental health, alleged commission or conviction of criminal offences are considered “sensitive” personal data under applicable data protection laws. We will process any such data only if you have given your explicit consent, or it is necessary (for instance if you request special assistance), or you have deliberately made it public.

Sharing your personal data

Your personal data may be shared with third parties for the purpose described in this Privacy Policy:

Government authorities, law enforcement bodies, online agents through which you book your reservation with;
Credit and debit card companies which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment;
Legal and other professional advisers, law courts and law enforcement bodies in all countries;
Social media: You may be able to access third party social media services through our website before coming to our website. When you are registered with your social service account, we will obtain the personal information you choose to share with us through these social media services pursuant to their privacy settings in order to improve and personalize your use of our website. We may also use social media plugins on our website. As a result your information will be shared with your social media provider and possibly presented on your social media profile to be shared with others in your network. Please refer to the privacy policy of these third-party social media providers to find out more about these practices.

Your Data Protection Rights

Under certain circumstances, by law you have the right to:

Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it;
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you;
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format;
Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Security of your personal data and how it is stored

We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. The data you provide to us is protected standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet.

We may disclose your information to trusted third parties for the purposes set out in this Privacy Policy. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line EU law on data protection rules.

Our Privacy Policy may change from time to time and any changes to the statement will be communicated to you by way of an e-mail or a notice on our website.

You may request details of personal information which we hold about you under the GDPR legislation which came into force in May 2018. If you would like a copy of the information held on you please write to The DPO, GDPR Enquiries, pa@bgeducation.co.uk.

Health & Safety Policy

CONTENTS
PART 1 STATEMENT
PART 2 RISK ASSESSMENT
PART 3 ORGANISATION AND RESPONSIBILITIES
PART 4 ACCIDENT
PART 5 FIRST-AID
PART 6 TRAINING
PART 7 FIRE
PART 8 EQUIPMENT
PART 9 HAZARDOUS SUBSTANCES
PART 10 MANUAL HANDLING
PART 11 PERSONAL PROTECTIVE EQUIPMENT 7 CLOTHING (PPE)
PART 12 ELECTRICAL
PART 13 PREMISES

HEALTH AND SAFETY POILCY STATEMENT

This statement forms part of our health and safety policy required under Health and Safety at Work etc. Act 1974(section 2(3)). The Health Safety Policy also includes; the organization with responsibilities for Health and Safety; risk assessments; and the arrangements (protective and preventive measures) for Health and Safety.

It is our policy to comply with all Health and Safety legislation, acts, regulations, codes of practice and other guidance. We will endeavour premises, equipment and systems of work that are, as far as is reasonably practicable, safe and without risk to health.

To ensure the policies are understood and implemented we will provide suitable and sufficient information, instruction and training for employees. Employees must comply with any training and information which is given and follow the arrangement and safe systems of work including the use of any necessary personal protective equipment/clothing.

We accept our responsibility for Health, Safety and Welfare of others (public, contractors and visitors)

This policy will be brought to the attention of all employees.

The safety policy will be kept up to date by periodical review (at least annually) and will take account of any new equipment, processes or change to work which affect Health and Safety.

Named: Mr G Sutton
Signed:
Date: 06/07/2020

PART 2: RISK ASSESSMENTS

2.1 Risk assessment record sheets are located in reception. Specific risk assessment sheet can be found for;

Display screen equipment
Manual handling
Machinery and equipment
Hazardous substances

2.2 Control measures are in place as a result risk assessments. The control measures have been implemented and are included in the arrangements part of this policy or in the records of risk assessment.
2.3 Risk assessments will be reviewed annually or earlier if significant changes take place.
2.4 It is the responsibility of the Proprietor to ensure that risk assessment have been completed and that reviews are carried out by the due date.
2.5 The significant risk have been identified, written down and will be made known to all relevant persons. Training, information, instruction and supervision will be provided as required. Control measures will be put into practice as recommended from the risk Assessment process.

PART 3: ORGANISATION AND RESPONSIBILITIES

3.1 The Proprietor will lead on Health and Safety matters and have day to day responsibility when present at the Company premises. The Manager will take responsibility in the absence of the Proprietor
3.2 The Proprietor will ensure that this policy is carried out and will inspect the premises and activities every 3 months.
3.3 The manager have been designated to be responsible for Health and Safety and supervision of employees. The manager will report any failures of policy, hazards, dangerous events etc. to the Proprietor.
3.4 All employees have a duty to act responsibly and not to put themselves or others at risk by their acts or omissions. Employees must report any unsafe condition to the manager and employees must co-operate with the Company on Health and Safety matters. Employees must keep the workplace clean and tidy.
3.5 Health and Safety will be discussed at work meetings when appropriate and information will be posted on the staff notice board.
3.6 The manager are responsible for the first-aid and also responsible for the accident book and for reporting any accidents to HSE on form F2508 “RIDDOR”.
3.7 The Manager are responsible for emergencies including fire and will act as fire warden, organize and record drills.

PART 4: ACCIDENT

4.1 All employees who have an accident at work or are ill as a result of work must report it to the Manager and fill in the accident book which is kept in reception.
4.2 The Manager will inform HSE of any reportable accidents, fill in and send off form F2508 to HSE “RIDDOR”
4.3 THE Manger will investigate all accidents and ill-health to determine the cause and will be responsible to put matters right.
4.4 Any visitor or contractor who has an accident must also report the matter and he employee responsible for the visitor or contractor must ensure the accident book is filled in correctly.
4.5 Employees are encouraged to report any serious incident (whether or not there is an injury/accident) to the Manager.
4.6 Any dangerous occurrence will be reported immediately to HSE and F2508 sent by the manager
4.7 The Hotel aims to fulfil the requirement of the Reporting of injuries, Diseases and Dangerous Occurrences Regulations 1995.

PART 5: FIRST-AID

5.1 First aid boxes are kept in reception, in the kitchen and the swimming pool.
5.2 For a qualified first-aider contact the manager.
5.3 Notices are placed around the premises in respect to First-aid.
5.4 A record of first-aid will be kept on the appropriate form in the Health and Safety File.
5.5 Employees must not take it upon themselves to render first-aid and must seek the first-aider or appointed persons. Emergency telephone numbers are displayed on the first-aid notice.
5.6 The Hotel aims to fulfil the requirement of the Health and Safety (First aid) Regulations 1981.

PART 6: TRAINING

6.1 All employees will be informed of this policy, risk assessments and the control measures. All new employees will be shown around the premises and have Health and Safety arrangements explained to them by The Manger.
6.2 Employees will be shown how to do things safely prior to use, this particularly applies to the use of any equipment.
6.3 The Hotel will endeavour to ensure that employees are capable in terms of Health and Safety for every task that is asked of them.
6.4 Specific training and instruction will be provided as appropriate to the employees work as identified in the risk assessment. All employees will be trained in

Fire arrangements
Hazardous substances
Safe use of equipment
Employee responsibly
Use of personal protective equipment
Health and Safety arrangements
Risk Assessments and control measures
Accident and First Aid arrangements
Electrical safety
Manual handling
Use and safety of the swimming pool

PART: 7 FIRE

7.1 The arrangements for fire are as follows:

Fire extinguishers are provided around the hotel
Emergency lights are provided around the hotel
Fire escape route are provided throughout the hotel with fire exit and routes marked.
Fire alarm system fitted in the hotel.
Assembly point is in the front carpark

7.2 If an employee discovers a fire the alarm should be activate. Trained staff are only permitted to use fire extinguishers; other employees should not tackle a fire but proceed safely to the assembly point via the escape routes.
7.3 The manager will be responsible to see the premises are clear and call the emergency services if appropriate.
7.4 An annual fire drill will be carried out, organized by the manager and a fire record will be kept.
7.5 Fire extinguishers and emergency lights will be checked every year and Fire Alarm 3 times a year by contractor. A record will be kept in the fire file
7.6 Employees must not interfere with any fire safety arrangements, keep fire routes and exits clear and abide by the notice explaining the fire arrangements.
7.7 Smoking is forbidden in all areas of the hotel building.
7.8 The Hotel aims to fulfil the requirements of the REGULATORY REFORM (FIRE SAFETY) ORDER 2005

PART 8: EQUIPMENT

8.1 All equipment provided by the company will be the correct safety standards
8.2 Any fault or defect in a piece of equipment or controls must be reported immediately to the manager. The machine must not be used until it has been repaired and safe to use again. Employees should check machine before operating them.
8.3 Employees will not be allowed to use equipment until they have been trained to do so.
8.4 The Hotel aims to fulfil the requirements of the provision and Use of Work Equipment Regulations 1998

PART 9: HAZARDOUS SUBSTANCES

9.1 An assessment of all hazardous substances has been made and these are included in the risk assessment part of this policy.
9.2 Employees must follow the precautions and rules as a risk assessment so that they do not expose themselves or others to any risk.
9.3 Hazardous substances must be disposed of carefully as recommended in the risk assessment.
9.4 Any PPE must be worn by employees as recommended.
9.5 All hazardous substances must be stored in their original containers and those containers store correctly.
9.6 The Hotel aims to fulfil the requirements of the Control of Substances Hazardous to Health Regulations 1999 (COSHH)

PART 10: MANUAL HANDLING

10.1 Employees must not move any loads which they think may cause them an injury. Risk assessment of the main task has been carried out and training will be given to employees in safe methods.
10.2 Employees should use lifting and carrying aids including trolleys to move loads.
10.3 Employees will be shown how to lift and carry loads in the correct manner as part of the Hotel training policy.
10.4 The Hotel aims to fulfil the requirements of Manual Handling Operations Regulations.

PART 11: PERSONAL PROTECTIVE EQUIPMENT 7 CLOTHING (PPE)

11.1 The Hotel will provide free of charge all necessary PPE for employees who must use it.
11.2 The Hotel will treat the misuse or non-use of PPE as a breach of contract and employees will be subject to disciplinary procedures.
11.3 The Hotel aims to fulfil the requirements of the Personal Protective Equipment at Work Regulation 1992.

PART 12: ELECTRICAL

12.1 The main electrical system in the building will be tested every 5 years by a competent electrician.
12.2 All Electrical equipment will be maintained an annual inspection and testing.
12.3 Any defects or damage to electrical equipment must be reported immediately by employees to the manager and must not be used until it has been repaired and safe to use again
12.4 The Hotel aim to fulfil the requirements of the Electrical at Work Regulations 1989.

PART 13: PREMISES

13.1 THE Premises will be maintained in a safe and healthy condition at all times. Employees must take responsibility for general housekeeping, cleaning and tidiness.
13.2 The Hotel aim to meet the requirement if the Workplace (Health and Safety Welfare) Regulations 1992.

Complaints Policy

This complaints policy is issued to ensure proper procedures for handling complaints concerning deficient goods and services sold and offered in the The Bank Hotel & Bistro.

1. The Right to Complain

Clients are entitled to complain about any deficits in provided services and defects in purchased goods and they are entitled to removal of such defects, replacement, supplement or provision of a new replacement service or to a reasonable discount on the agreed price of services or goods that have been paid.

Subject of the Complaint
Deficient quality of food and beverages for immediate consumption shall be claimed by clients immediately at the moment of discovering the deficit, directly with the attending staff.

If deficits in food and beverages for immediate consumption relate to quantity and weight, they must be claimed prior to consumption.
Deficits in other goods or services can be claimed especially in the restaurant or the hotel, where the goods or services have been purchased, immediately or without undue delay, based on the proof of purchase. A complaint may not be recognized unless a proof of purchase is submitted.
Deficits in accommodation can be claimed with the operating manager on duty and without any undue delay. The right to claim deficits in accommodation shall lapse if not exercised before the departure of the client.
To lodge a claim, clients shall submit all relevant documents concerning the provision of the service or acquisition of the goods claimed.

2. Complaint Handling Procedures

Catering services

If proper quality, weight, measure or temperature of food or beverages is not provided, clients are entitled to request proper and immediate removal of the claim free of charge.
If the defect in food and beverages cannot be removed, clients are entitled to a full replacement food or drink, or to a refund of the price paid or to a discount.

Accommodation services

Clients are entitled to request proper and timely removal of defects free of charge, namely:

Replacement of damaged equipment or provision of additional petty equipment of the room.
If defects of a technical nature in the room assigned to the client cannot be removed (faulty heating system, poor water pressure, no hot water, faulty electricity supply, etc.) and if the hotel cannot offer another, alternative accommodation to the client, and if the room is provided to the client in spite of these faults, the client is entitled to a discount from the basic price of the accommodation based on a mutual agreement, or entitled to terminate the contract before the stay and a refund of the price paid for accommodation.
Complaints are handled by the operating manager or employees authorised by the operating manager, who are obliged to review the complaint and decide on how it will be handled. If a complaint cannot be settled by agreement, the operating manager or an employee authorised by the operating manager shall make a complaint record with the client. In such record, the client shall provide exact specification of the provided service or purchased goods, the time of provision of the service or purchase of the goods and a description of their deficiency. Hotel manager or an employee authorised by the hotel manager shall carefully review the complaint and decide on how it will be settled immediately; in complex cases within 15 days in maximum.
For vouchers entitling to a stay that can be claimed within the calendar year, the advancement paid is valid for one year from the date of crediting the supplier’s account (the “payment date”). The customer is obliged to make use of the stay within one year from the date of advance payment. If the customer fails to make use of the stay within one year from the date of advance payment, the order is cancelled and the supplier will charge a cancellation fee to the customer as a one-off compensation in the amount of advancement that has been paid. Bookings, orders or parts thereof can be cancelled by written notification sent to the provider to pa@bgeducation.co.uk. Cancellation applies also in cases where the customer failed to notify cancellation of the booking, order or parts thereof and the service ordered was not used. Cancellation fees do not apply to clients who fail to check-in due to disease /medical certificate/ or for serious family reasons.

Every consumer has the right to contact alternative dispute resolution entity in order to protect their consumer rights. Consumers cooperate with the ADR entity during the alternative dispute resolution for the sake of swift resolution of the dispute. In cross-border disputes, consumers are entitled to contact the European Consumer Centre, which will provide an address for service, email address or telephone number of the ADR entity which is competent to deal with the dispute.

Company’s identification data:

The BGE Hotels
Guestling
Hastings
East Sussex

pa@bgeducation.co.uk

Pet Policy

The Hall Hotel is pet-friendly in certain rooms. We welcome up to two (2) pets to stay with you in your room. A Pet Maintenance Fee of £20 per pet (or equivalent) will be added to your daily room rate. We offer a variety of complimentary pet amenities available upon request. In addition to a pet bed, pet blanket, food & water dish which will be provided for the use of your pet during your stay, we also have leashes for you to borrow at no additional charge. In order to ensure a happy experience for all of our hotel guests, pet owners agree to acknowledge the following:

PET QUALIFICATIONS
We welcome quiet, non-aggressive pets that are housetrained, and well behaved so as not to disturb other guests. All pet guests must be completely free of fleas and ticks, be clean, well groomed and up to date on shots and vaccinations.

PET RULES IN THE ROOM
All pets must sleep in their crates, carriers, or a pet bed. Pets are not allowed on beds or furniture. Under no circumstances may a guest pet be bathed in the guest room bathrooms. Please check with the hotel manager for the name of a nearby pet grooming service should your pet require bathing.

PET RULES OUTSIDE THE ROOM
Dogs must always be on a leash when outside the room and on the premises of the hotel. You can walk your dog in our garden, but please be careful around the pond as the ground is uneven near and the water is quite deep.

PROPERTY GROUNDS / PET CLEANUP
The grounds and gardens are for the enjoyment of all our guests, and we therefore request that, pets be walked off property for the purpose of relieving themselves. Guests accompanied by pets are responsible for the cleaning up after their pets; a trash can for waste disposal is located behind the garage building. Please use a plastic bag and never use the hotel’s towels or linen.

PET DAMAGE
Owners are responsible for all damage caused to the room and premises by their pet. Each room of pet guests is inspected after checkout, with damages assessed and charged accordingly. Excessive damage may include charges for professional cleaning, rug replacement, and lost revenue charges while the room is out of service due to cleaning and repairs.

Equal Opportunities Policy

Part I: Policy Details

1. What does this policy cover?

We do not tolerate discrimination or harassment in any part of The Bank Hotel & Bistro’s operations. We are fully committed to promoting equal opportunities in employment.

So, this policy covers any and all aspects of our company operations, how we treat those who work for and with us and how we recruit or engage others to join that community.

This means that our policy covers, but is not limited to, the following:

Your pay and your employment conditions
Our recruitment processes
How we may appraise, reward, incentivise, promote, train, and commit to the continuing professional development of our workers
Our procedures for addressing grievances and disciplinary matters
How we end employment contracts and exit employees, including related matters, such as how we give references
How visitors, clients and suppliers and other key business contacts and stakeholders are treated

It also means that we will ensure, as far as possible:

full access to everyone applying for job vacancies and job opportunities with our business, and
that all relevant decisions are made on the basis of objective criteria.

You should familiarise yourself with this policy and all The Bank Hotel & Bistro’s other policies including, in particular our Grievance Policy and our Harassment and Bullying Policy.

2. Who does it apply to?

All employees, apprentices, consultants, officers, contractors, interns, volunteers, job applicants, agency and casual workers.

3. It is not part of your employment contract

This policy is not part of your employment contract. We, The Bank Hotel & Bistro, may amend this policy at any time.

4. What is discrimination?

Under UK employment law, there are a number of characteristics relevant to an individual who is covered by the policy that must not unfairly be considered (if accounted for at all) in decisions relating to any aspect of their working life.

These characteristics are called ‘protected characteristics’ and they are listed immediately below:

Age
Disability
Gender reassignment
Marital or civil partnership status
Pregnancy or maternity
Race (which includes colour and ethnic/national origin)
Religion or belief
Sex
Sexual orientation

If employment-related decisions are made about an individual on the basis (whether wholly or partially), of any of these protected characteristics, it is almost inevitable that unlawful discrimination will have taken place.

The sorts of actions that would fall into this category of unlawful and prohibited initiatives, include (but aren’t limited to) those set out below. These actions need not be intended or directly committed by someone (indirect responsibility may be sufficient for someone to have unlawfully discriminated) and an omission or failure to do something may be just as culpable as a positive action.

We will not tolerate their practice by anyone within our business:

Direct discrimination…

when someone with a protected characteristic is treated less favourably than somebody else has or would have been in identical circumstances. An example of this would be where an applicant for a job is rejected on grounds of their racial background. Further examples would be where a pregnant employee, or one with young children, is not promoted

Indirect discrimination…

when a group of people with one of the protected characteristics is disadvantaged by a provision, criterion or practice that is applied to all staff (unless the treatment may be justified for a good business reason). Examples of this would be:

Insisting, without good reason, that all staff must work full time, (which indirectly discriminates anyone with child-care responsibilities, women in particular)
Requiring all staff to work onsite and refusing to consider a request to work remotely or under alternative conditions, like flexible hours to avoid commute times, which could disadvantage someone with a disability or a phobia (e.g. someone who suffers claustrophobia or panic attacks on commuting routes)
Refusing to provide a room for reflection and prayer, which would discriminate against individuals practising certain faiths
Dismissing or not employing a woman because she is pregnant or of child-bearing age

Harassment…

covers hostile, humiliating, degrading, intimidating or similarly offensive treatment or conditions to which an individual with one or more protected characteristics is subjected. Any such actions deprive an individual of their dignity and violate them. We draw no distinction between actions that may be labelled as ‘joking’ and not intended to cause offence, and those that may have been more direct and premeditated in their delivery. So, for example, in line with legal definitions, reflecting general standards of decency, we will regard any of the following as falling within the definition of harassment:

making lewd comments and/or displaying pornographic material
calling someone unkind, derogatory or otherwise unwelcome names or nicknames
making insensitive jokes, whether about someone directly, or the content of which would be evidently offensive to anyone with a protected characteristic
excluding colleagues and/or making them feel that they have no option but to exclude themselves

You should refer to our Bullying and Harassment Policy for a full run-down of the matters that we consider to be covered by this definition.

Victimisation

This has a particular meaning under UK employment law and it is narrower than an ordinary dictionary definition, covering the situation only where:

a worker has complained of discrimination (or harassment),
or has supported a fellow worker in making a complaint about these concerns,

and has then suffered reprisals from others, including those responsible for that worker’s employment prospects and working conditions.

Other discriminatory actions that are also prohibited

The UK’s employment law also identifies other actions that can be unlawful under the equal opportunities legislation. Examples of these include:

Failing to make reasonable adjustments to minimise certain disadvantages suffered by a disabled employee (or job applicant)
Instructing another person (or applying pressure on them) to discriminate
Knowingly assisting somebody else when they carry out a discriminatory act
Discriminating against somebody believed to have a protected characteristic, whether or not they actually do, or because they associate with a third party who does.

Part II: Our procedures and approach to this policy

1. Duties and responsibilities

Overall responsibility for the effective implementation and operation of the policy lies with The Bank Hotel & Bistro’s management. All managers are expected to lead by example, and attain and maintain appropriate standards of behaviour within the teams they manage.

However, everyone who works in and with The Bank Hotel & Bistro is responsible for ensuring that this policy works to prevent the activities that it prohibits from taking place within our business.

Because we are a values-led business, this goes beyond the legal obligations that each one of us has, (and regardless of our job titles or how long any of us has worked for or with The Bank Hotel & Bistro).

However, you need to be aware that the breach of these legal obligations alone will mean that any individual can be found personally liable for unlawful discrimination where they have breached this policy and they will face disciplinary action by us and potentially other legal actions. This is because if you breach this policy, you may also make the Company liable for your actions, and both of us may have to pay compensation to anyone who claims against us.

We therefore expect you to take personal responsibility for adhering to this policy’s aims and commitments and for promptly and appropriately drawing any breaches of them to our attention.

We always welcome feedback on how we can best promote and ensure equal opportunities throughout The Bank Hotel & Bistro. Please let your manager know if you have any ideas or would like to be involved in any of our existing initiatives.

2. Recruitment, promotions and identifying candidates for other opportunities

In any selection process that we use within our business, whether we’re selecting interviewees for job opportunities, offering jobs, identifying individuals for promotion or considering other opportunities or necessities (like redundancy situations), we will apply a rigorous, objective selection process using non-discriminatory criteria, as far as possible.

We emphasise here, however, that both direct and indirect age discrimination may be justified and lawful, if the less favourable treatment, criterion or practice amounts to a proportionate means of achieving a legitimate aim.

A legitimate aim must relate to a genuine business need on our part that is not related to age discrimination itself. For example, a legitimate aim potentially justifying age discrimination might include:

Economic factors such as business needs and efficiency;
The health, welfare and safety of the individual concerned (including the protection of young people or older workers);
The particular training requirements of the job.

All job adverts and opportunity announcements must be:

Discussed with and signed off by the director, one of whose responsibilities is to ensure that any advert is compliant with this policy
Located and/or circulated so as to reach as wide and diverse a pool of interested candidates as possible, and
Worded so as to encourage, as far as possible and reasonable, applications from individuals of all characteristics to apply – or, at the very least, so as not to discourage any individuals with protected characteristics from applying.

There may be circumstances where some indication of required skills (that do discriminate) is justified and where self- deselection is inevitable, for example, where the job vacancy is for a window cleaner who works at height, wearing abseiling harnesses. The job advert might specify that interested candidates must be willing and capable of abseiling to be considered for the job.

If you are involved in interviewing and or any other part of our recruitment process, you must never ask a job applicant about their health, attendance record, or whether they have a disability before making a job offer to them (except in very limited circumstances).

You can ask someone if they have any particular needs or requirements with which you can assist if they are coming to meet you for an interview. In certain limited cases, it may also be permitted to make a job offer conditional on a successful medical examination.

During interviews or other interactions with candidates for a role, you must not ask anything that might infer a bias against any candidate with one or more protected characteristics. So, for example, asking a candidate if they are married, intend to have children (or any more children), or whether their religion permits them to work at weekends, are strictly no-go zones.

If you are ever in doubt about what can or must not say, or if you believe that a particular job vacancy needs a medical examination as part of the recruitment or onboarding process, you must check the position with the director.

3. Monitoring the policy and our personnel

During any recruitment and onboarding process, we may ask questions that include some protected characteristics to help us monitor our diversity and how we are succeeding in our commitment to promote equal opportunities. Including health or disability questions in equal opportunities monitoring exercises is acceptable, but the data gathered must not be used for any employment-related decisions, such as whether to offer a role or opportunity to a particular candidate.

We may also record and analyse information about equal opportunities more generally within the workplace. We do this so that we can make sure this policy operates successfully. The data helps us to refine it, review the composition of our workforce, and to promote workplace equality.

When you join the Company, you give us consent to gather and process this data about you.

4. Handling breaches and enforcement

We take all allegations of breach and any breaches that we discover very seriously. All allegations and/or suspicions of breach will therefore be thoroughly investigated.

If you wish to complain or raise an allegation of breach (or potential breach) under the policy, you should contact the director as soon as possible. If you want to take formal action, you will need to follow our grievance procedure and read our policy on harassment and bullying.

Anyone raising a concern about matters covered by this policy, who does so in good faith, will have our full support and co-operation in getting to the bottom of what has happened and any appropriate action that needs to follow on from that examination. This will be the case regardless of our conclusions and including where we determine that the allegation was mistakenly made. There will never be any reprisals against those who genuinely have, or consider that they have, valid grounds to bring concerns about discrimination to our attention.

However, complaints made in bad faith, for whatever reason (including where this is an attempt to avoid or to deflect disciplinary action), will be treated as misconduct and may lead to a dismissal for gross misconduct.

We will also take prompt disciplinary action against you if we discover that you have harassed or discriminated against anyone else in breach of this policy. If we conclude that your behaviour amounts to gross misconduct, we will be within our rights to dismiss you without notice and with no payment in lieu of that notice.