Company Policies

1. Equal Opportunities and Anti-Discrimination

1.1 Commitment. We do not discriminate, directly or indirectly, or through harassment or victimisation, against any person on the grounds of age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race (including colour, nationality and ethnic or national origin), religion or belief, sex or sexual orientation. This covers participants, referring organisations, suppliers and anyone we employ or engage.

1.2 Law. We comply with the Equality Act 2010 and the Human Rights Act 1998.

1.3 In practice.

• Sessions are open to every participant referred to us. Nobody is refused or treated less favourably for a protected characteristic.
• We ask about access needs before each session and make reasonable adjustments: large-print or digital handouts, seating, breaks, extra time, and working with the host on step-free access.
• Examples and materials avoid stereotypes, cover a range of backgrounds and jobs, and never assume a participant's age, family situation or history.
• We do not put participants under pressure to buy anything. A training session is never used to sell a product.
• Any recruitment we do in future will be open, based on the needs of the role, and free of discrimination.

1.4 Concerns. Anyone who believes they have been treated unfairly can raise it with the director at admin@etminan-ai-solutions.com. Every concern is acknowledged within 5 working days and investigated fairly. Nobody is victimised for raising one. Where a session was bought by a public body, we also tell that body's contact.

2. Data Protection and Confidential Information

2.1 Scope. This policy covers all personal data we handle, and in particular personal data we receive from the Department for Work and Pensions (DWP) or any other public body about people referred to our training ("referral data"). For referral data the public body is the controller and we are the processor. We process it only on their documented instructions and only to deliver the service they have bought.

2.2 Law and registration. We comply with the UK GDPR and the Data Protection Act 2018, and we hold a current registration with the Information Commissioner (ZC190693).

2.3 Collect the minimum. We ask only for what we need to run the session and confirm attendance: usually a name and attendance record. We do not ask for benefit details, health information or reference numbers unless the buyer's paperwork requires them.

2.4 Where referral data may be kept.

• Only in the United Kingdom. It is not processed outside the UK without the buyer's prior written consent.
• Electronic referral data is held only on one password-protected company computer, which is never taken off site. It is never held on laptops, phones or other portable devices.
• Paper referral data (attendance sheets, referral and SL2 forms) is kept in locked storage whenever it is not in use.
• Never in our own products, never in any AI tool or chatbot, never on removable media (USB sticks, CDs, portable drives) and never on personal cloud storage.
• Paper records are not left in vehicles, and are kept on the person when travelling to and from a session.

2.5 Restricted movement and access. Referral data is accessed only by staff who need it to deliver or invoice the contracted session. It is not shared with anyone else unless the buyer instructs it in writing or the law requires it. We keep an up-to-date list of everyone authorised to access it. When someone stops working on a contract, their access, passwords and keys are removed the same day.

2.6 Clear desk and screen. Referral data is not left visible on desks or screens. Screens lock automatically after 5 minutes and are locked manually whenever unattended. During sessions, attendance sheets stay with the trainer.

2.7 Passwords and systems. Every account uses a unique strong password, with multi-factor authentication where offered. Passwords are never shared or written down where others can see them. The computer receives security updates promptly and runs current antivirus. Only authorised users may use it. Referral data is not copied into backups or any other location.

2.8 Retention and destruction. Referral data is kept only as long as the contract needs it, then returned to the buyer or securely deleted on their instruction. Paper is cross-cut shredded. Contract and payment records (not participant details beyond what the invoice requires) are kept for 6 years from the end of the financial year of the last payment, as DWP terms require.

2.9 Requests and complaints. If we receive a request from a data subject, a request to correct or erase data, a complaint, or any contact from the ICO about referral data, we tell the buyer's contact immediately and help them respond. We do not answer it ourselves.

2.10 Training. Everyone with access to personal data completes data protection training before they start and refreshes it at least every 12 months.

2.11 Everyone else. Website visitors, clients and people who sign up for our own products are covered by our Privacy Policy, as a separate relationship. That is never mixed with referral data.

3. Health and Safety

3.1 Statement of intent. Etminan AI Solutions Ltd will, so far as is reasonably practicable, protect the health, safety and welfare of its staff and of everyone taking part in its training, to the same standard an employer owes its employees. We comply with the Health and Safety at Work etc. Act 1974, the Management of Health and Safety at Work Regulations 1999, the Health and Safety (Training for Employment) Regulations 1990, the Workplace (Health, Safety and Welfare) Regulations 1992, the Regulatory Reform (Fire Safety) Order 2005 and RIDDOR 2013.

3.2 Arrangements. Our risk assessments, first aid and accident reporting procedures, and the health and safety information given to every participant are kept on file and are available to any buyer on request.

4. Fraud Prevention and Anti-Bribery

4.1 Commitment. We protect public money. Claims for payment are made only for training actually delivered, to the participants who actually attended, at the agreed price.

4.2 Controls.

• Every session has a signed or recorded attendance register, which is the only basis for a claim.
• Invoices are raised only after delivery and after the Jobcentre's SL2 form is completed and returned.
• Records supporting every claim (purchase order, register, SL2, invoice) are kept for 6 years from the end of the financial year of the last payment and made available for audit on request.
• Audit: at least every 6 months, the director checks every claim in the period against its register and SL2, and records the check with its date and outcome.
• Reporting concerns: anyone who suspects a false or inaccurate claim, or any fraud or irregularity, reports it to the director, or directly to the buyer if the concern involves the director. Nobody is penalised for raising a concern in good faith. We notify the buyer immediately if we suspect serious irregularity or fraud.
• Segregation of duties: while the company has one person, full segregation is not possible. The register, which participants sign or confirm, and the Jobcentre's own SL2 act as independent checks on every claim. When the company takes on staff, delivery and claiming will be separated.

4.3 Bribery. We never offer or accept any gift, hospitality or payment to influence a contract decision, and we comply with the Bribery Act 2010.

5. Contact

Questions about these policies, or a concern under any of them, go to the director:

• Email: admin@etminan-ai-solutions.com
• Website: Contact Page