POLICIES
EQUAL OPPORTUNITIESEQUALITY, DIVERSITY + ACCESSIBILITYDATA PROTECTIONSAFEGUARDINGHEALTH + SAFETYBUSINESS CONTINUITY
EQUAL OPPORTUNITIES POLICY
Thomas Carter Projects (TCP) is committed to extending its work to all parts of society, through active equal opportunities policy and implementation.
No person should receive less favourable treatment on the basis of, nor suffer disadvantage by reason of:
— Class or socio-economic status;
— ethnic origin, nationality (or statelessness) or race;
— gender (including gender reassignment);
— marital or civil partnership status;
— sexual orientation;
— disability (including mental or physical ability);
— political belief;
— pregnancy;
— religion or belief (including the absence of belief).
All TCP contractors should seek to practise that equality, especially in promoting access to all parts of society. TCP opposes all forms of racism.
Anti-Racism Statement
TCP is an anti-racist organisation and strives to contribute to the growing collective awareness against all forms of racism. This means we are committed to the mission of discussing, tackling, and responding to racism when we see or experience it. We explore, among other things, how prejudices, inequalities, and racism are ingrained in technology. We also want to use our position as a media production company to inform the public about racism in order to encourage positive change. We do this through all our projects and programmes, and in collaboration with our current and future partners.
Freelancers and other volunteers
To carry out its work, TCP seeks to appoint effective and appropriate freelancers, and sometimes to involve other volunteers in supporting roles, all of whom are required to accept fully the responsibilities of their commitment.
The overriding considerations in making all appointments shall be the safety and security of all concerned in production work, and their continued development in accordance with the Purpose and Values of TCP.
Accordingly, all those whom TCP accepts as volunteers must be ‘fit and proper’ persons to undertake the duties of the particular position to which they have been appointed.
Within these constraints, and those imposed by the need to ensure equal opportunities for all ….
No person volunteering their services should receive less favourable treatment on the basis of, nor suffer disadvantage by reason of:
— age;
— class or socio-economic status;
— ethnic origin, nationality (or statelessness) or race;
— gender (including gender reassignment);
— marital or civil partnership status;
— sexual orientation;
— disability (including mental or physical ability);
— political belief;
— pregnancy;
— religion or belief (including the absence of belief).
EQUALITY, DIVERSITY + ACCESSIBILITY POLICY
Our Policy
Thomas Carter Project’s (TCP) Equality, Diversity + Accessibility policy provides a framework for equality and fairness and ensures accessibility for all in our employment. It expresses our commitment not to discriminate on the grounds of age, disability, sexual orientation, gender, gender reassignment, marital status (including civil partnerships), race, ethnic origin, colour, nationality, national origin, religion or belief. We oppose all forms of unlawful and unfair discrimination.
The policy applies to all freelancers , whether part-time, full-time or temporary. All freelancers must be treated fairly and with respect.
Equality
The policy’s purpose is to not unlawfully discriminate in accordance with the Equality Act 2010.
We oppose all forms of unlawful discrimination in terms of pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for parents/carers, requests for flexible working, and selection for employment, promotion, training or other developmental opportunities.
TCP commits to creating a working environment free from bullying, harassment, victimisation, unlawful discrimination, and promotes dignity and respect for all. Sexist, racist, homophobic, transphobic or otherwise offensive and inflammatory behaviour are not accepted. These constitute harassment, and have no place within TCP. Individual differences and the contributions of all employees are recognised and valued.
We will protect all who work with us from sexual harassment. Sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 — which is not limited to circumstances where harassment relates to a protected characteristic — and the 2023 Protection from Sex-based Harassment in Public bill, is a criminal offence.
We commit to make opportunities for training, development and progress available to all freelancers where applicable, who will be helped and encouraged to develop their full potential, so their talents and resources can be fully utilised to maximise the success and/or efficient running of the company.
Decisions concerning freelancers are based on merit (apart from in any necessary and limited exemptions and exceptions allowed under the Equality Act).
We aim to review employment practices and procedures when necessary to ensure fairness, updating them and the policy to take account of changes in the law.
Diversity
Inclusion and respect: we follow the BBC’s Diversity Radio Commissioning Guidelines in all our programme making.
TCP recognises that diversity and inclusion help to support creativity and innovation: they are essential ingredients in a successful audio production company. We are committed to encouraging diversity and inclusion and to ensuring there is no discrimination within our company. We want our workforce to be truly representative of all sections of society and our company to be one in which every freelancer feels respected and able to give of their best.
TCP actively seeks to increase the number of people we work with who are from groups and communities under-represented in the entertainment industry as a whole, aiming to reflect all sections of society within our creative output (for instance, in terms of age, disability, gender, sex, sexual orientation, relationship status, race (including colour, nationality, and ethnic or national origin), religion or belief within our creative output.
We also seek to increase the number of people we work with in other job roles within the company where minorities are underrepresented.
We will regularly monitor the make-up of the company, including Creative Advisory Board and freelancers, regarding information such as age, gender, ethnic background, sexual orientation, religion or belief, and disability in encouraging equality and diversity and in meeting the aims and commitments set out in the equality policy.
Accessibility
We aim for all content made by TCP to be recorded in venues that are accessible to wheelchair users. We work closely with Graeae, a disability led arts organisation, and arrange for BSL interpreters and personal assistants as required.
We encourage and work with the platforms and commissioning bodies we work with to ensure full accessibility of the work, particularly in relation to Hard of Hearing/Deaf and neurodivergent people.
Selection for employment
Selection will be on the basis of aptitude and ability. Access to opportunities for promotion, training or any other benefit will also be on the basis of aptitude and ability. All freelancers will be encouraged to develop their full potential, talents and resources so that the workforce will be fully utilised to maximise the creativity and success of the company.
TCP will:
— Review formal and informal employment/hiring practices and procedures to ensure they are fair and help us to identify the best talent.
— Identify and take opportunities to increase the diversity of casting/crew decisions and seek to increase the diversity of our talent networks, both on and off air.
— Ensure access support is in place to enable disabled people to work in or with our company, both on and off air.
— Create an environment in which individual difference and the contributions of all production teams are recognised and valued.
— Ensure every freelancer is able to work in an environment that promotes dignity and respect for all. We will not tolerate any form of intimidation, bullying or harassment.
Freelancer responsibility
Responsibilities include freelancers conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination.
All freelancers should understand they, as well as TCP, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow workers, customers, suppliers and the public.
Freelancers must take seriously any complaints of bullying, harassment, victimisation and unlawful discrimination by fellow freelancers, visitors, the public and any others in the course of the company’s work activities. Such acts will be dealt with as misconduct under the company’s grievance and/or disciplinary procedures, and any appropriate action will be taken. Extremely serious complaints could amount to gross misconduct and lead to dismissal without notice.
Reviewing the Equality, Diversity + Accessibility Policy
Director Polly Thomas is responsible for monitoring the success of the policy and will review progress every two years.
Breaches of the policy may be regarded as misconduct and could lead to disciplinary proceedings. Details of the company’s grievance and disciplinary policies and procedures can be requested from Polly Thomas. This includes with whom to raise a grievance.
Use of the company’s grievance and/or disciplinary procedures does not affect a freelancer’s right to make a claim to an employment tribunal within three months of the alleged discrimination.
DATA PROTECTION POLICY
Thomas Carter Projects (TCP) is a media and performance production company. TCP takes the privacy of its audience and users very seriously. This Data Protection Policy outlines how personal information is collected, used and treated by TCP, in accordance with the Data Protection Act, 2018.
All freelancers employed by TCP are required to read and adhere to this policy in their dealings with TCP audience and users, for the duration their contract with TCP. All data collected and stored by TCP remains within the company, and is not to be copied or removed.
Because we can use personal information in a number of different ways, we have split this policy into sections that cover each category.
However, for all personal information we hold, we undertake to:
— Tell users about how their data is used, either at the time we collect it (if collected directly) or as soon as is practical afterwards (if we collect it from a third party).
— Keep it securely and make it available only to those within the organisation who need to see it. Where we share data with other organisations, we will tell users first wherever possible (sometimes there may be legal reasons not to).
— Where data is processed by other organisations on our behalf, make sure that the processing is clearly defined, secure and governed by a contract.
— Respect users’ rights over personal data.
— Inform users about major changes to this policy.
This policy is effective from 1st August 2018, and last updated 7th January 2023. It is reviewed annually.
TCP’s Data Protection Officer is Polly Thomas, company co-director.
Contact the Data Protection Officer at pfat1965@gmail.com or by post:
Thomas Carter Projects, c/o 47 Nutclough, Hebden Bridge, West Yorkshire, HX7 8HA, United Kingdom
Users’ rights over their information
TCP users have the right to:
— Have a copy of the personal information TCP holds about them.
— Correct inaccurate information or have incomplete information completed.
— Have their data erased (‘right to be forgotten’ or ‘right to erasure’) in certain circumstances.
— Restrict the processing of their personal information in certain circumstances.
— Data portability: have their information supplied in a commonly used format and transmitted to another organisation.
— Object to the processing of their personal information.
— Object to automated decision making or profiling.
Further information on these rights can be obtained from the Information Commissioner’s website at: ico.org.uk
If users are unhappy about the response they receive from TCP, they can contact the Information Commissioner’s office by writing to the Information Commissioner at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or via ico.org.uk
User information is stored on a company password-protected laptop.
TCP retains user data for specific projects with specified end dates and, generally speaking, data is kept until that end date. At the end of each project, we contact users to ask they whether they would like their data deleted.
How we use data for direct marketing
If users/audience sign up a TCP event, we will ask for their email address. We use this personal information to inform them about forthcoming TCP events, news and offers which may be of interest. We only do this with their direct consent, and they can withdraw it at any time.
Objecting to direct marketing
If users do not wish to receive any further marketing information from us, they can contact us directly at pfat1965@gmail.com, giving their name, email address and if possible a copy of the last communication received (this will help us identify them).
We will need to retain a small amount of information (usually name and email address) to add to our ‘stop list’. When we send marketing mailings, we run the recipients against this list to ensure those who have objected are not contacted.
How we use data for fundraising purposes
When fundraising, TCP may collect personal information in two ways:
— Directly from users when they buy a ticket to a TCP event, make a donation or make an enquiry.
— From publicly available sources, such as annual reports or newspaper articles, to help us identify potential donors.
The information we collect
We collect: name(s) and addresses, email addresses, telephone number(s) and other relevant contact details and preferences.
Donors to TCP
For donors, we also collect:
— Information about our relationship with them, correspondence, meeting notes, attendance at events, etc.
— Occupation and professional activity, network(s) and interests where relevant to our needs.
— If relevant and publicly available: philanthropic interests and giving history.
— If relevant and publicly available: financial data and potential giving capacity.
How we use this information
We use this information to:
— Process donations (to fulfil the contract we have with the donor, ensuring their donation is recorded, auditable and used for the right project).
— Contact donors with further information about our fundraising actives, or about the progress of a project they are supporting if they have given us permission to do so (see earlier).
— Carry out targeted prospect research into potential donors who have an affinity with TCP and/or our subject matter.
Prospect research involves collating information on specified individuals, including their interests, suitability and likelihood to donate to TCP. We only carry this out using publicly available sources or information that they have provided. This activity assists us in understanding the background of the people who support us and helps us to make appropriate requests to supporters who may have the interest and means to give. We may also use this information to contact them if them have a business address.
We carry out the last two activities because we believe it is in our legitimate interests to do so. All TCP’s funding is self-generated and our project funding agreements often specifically require us to generate income through fundraising. A significant way of doing this is through prospect research. We balance this out by ensuring that the information we collect and use is strictly limited to what is already widely known about that individual (see ‘Donors to TCP’ section above).
Although it is often not practical to inform users when we start to carry out this research, each is provided with a copy of this Privacy Policy on first contact, and can ask us to delete any information we hold about them and to not contact them again.
How long do we keep their information for fundraising?
Donation information is kept for six years for audit and accounting purposes. In the case of major donations (defined as a gift of over £500), we keep the details for longer, as part of TCP’s historical record.
We keep information on potential donors for a maximum of two years if no further contact is intended in regard to future relevant projects. Where their information is no longer required, we will ensure it is disposed of securely.
Donors can ask for a copy of their information held on our fundraising database, and/or for it to be amended or deleted, by contacting TCP’s Data Protection Officer (see earlier).
How we use personal information for enquiries
We may also collect information about users when they write to us with an enquiry. This information is only used to answer the enquiry.
We believe that using their information this way fulfils our function as an independent media production company — that is, to provide access to information about our operations and activities.
How we use personal information for market research
If users have given their consent, we may contact them to participate in general market research activity regarding TCP — via telephone, email or face–to–face.
We may also use personal information for market research purposes: to track activity on our website, to publish trends or to improve usefulness and content. Where we use user-data in this way, we will ensure that it is made anonymous, so that individuals can’t be identified.
We do this because we believe it is in our legitimate interests to do so.
Cookies
Cookies are usually set when users visit a particular page on the TCP website, or if they take a particular action, such as filling in an online form.
The information we collect via cookies usually consists of things like IP addresses, sites visited and actions taken. We don’t use the data to identify users by name, nor do we record things like email addresses or bank details.
The TCP website also contains third party cookies set by other organisations.
How to unsubscribe
To unsubscribe from any or all of TCP’s services — at any time — clink on the relevant link on our website or in email received from us.
Contact details
If you have any questions or concerns about the way in which we handle personal information, please email pfat1965@gmail.com
Policy updates
This policy was reviewed by TCP on the 7th January 2024.
Policy and Procedures for …
SAFEGUARDING CHILDREN, YOUNG PEOPLE AND VULNERABLE ADULTS
Thomas Carter Projects (TCP) creates live and broadcast performance across all media. It strives to develop innovative and inclusive arts works for a wide range of audiences.
TCP creates media and performance projects and events; sometimes these involve working with young people. In all its work with young people, TCP is committed to providing an environment where the welfare of young people is actively promoted.
Policy remit
Throughout this policy statement, the terms ‘young person’ and ‘young people’ are used to denote children, young people and vulnerable adults.
The term ‘staff’ is used throughout the policy to refer to any individual who is working on behalf of TCP whether in a paid or unpaid role and therefore includes freelancers, artists, volunteers, placements. This also refers to those who have a governance role, such as the Board.
TCP believes that the welfare of young people is paramount and that all young people, whatever their colour, race, nationality, ethnic origin, religion, socio-economic background, gender, sexual orientation, age or ability, have the right to protection from abuse.
It is the duty of ALL teams working for TCP to prevent the physical, sexual or emotional abuse of any young people with whom they come into contact through the course of their work. TCP will take seriously any allegation or suspicion of abuse and respond to it swiftly and appropriately, and ensure that all freelancers and young people working with us know the available channels for reporting. Anyone found to be in breach of the provisions of this policy and its appendices will be subject to disciplinary procedures (outlined in TCP’s Grievance and Disciplinary Policy, which is available on request).
TCP has a legal responsibility to ensure that all freelancers are fully aware of TCP’s Safeguarding Procedures.
All freelancers who work directly with young people will undertake an Enhanced DBS check (Enhanced Disclosure & Barring Service Check) at signature of contract.
Where DBS checks cannot be obtained, i.e., for International artists, we will hold their equivalent of a DBS checks conducted in their country on record. We will also ensure that they are fully aware of our Safeguarding Policy, and, when working with young people, that they are accompanied by a DBS-checked member of TCP staff.
TCP recognises that freelancers working with young people must also be provided with safeguards and made aware of best practice so they can be protected from wrongful allegations. Our guidelines to be followed when working with young people are available on request.
TCP will take seriously any allegation made against a member of production. We will contact the Social Services team at the appropriate Council to discuss the allegation and determine the best way forward.
The Directors are responsible for monitoring the operation of the policy.
Policy objectives
AWARENESS AND PREVENTION
TCP recognises that there are four main types of abuse suffered by young people. These are physical abuse, sexual abuse, emotional abuse and neglect.
All TCP’s workers will be made aware of this policy and the procedures and guidelines for working with young people.
Through awareness and good practice, TCP’s teams can minimise the risk of abuse to young people and also protect themselves against false allegations of abuse.
TCP is committed to careful planning of appropriate activities for young people in order to minimise situations where abuse could occur.
RECRUITMENT
TCP workers will be carefully selected, inducted, trained and monitored to ensure that the wellbeing of young people with whom they may come into contact is promoted.
TCP will take all appropriate steps to ensure that unsuitable people are prevented from working with young people. TCP has a legal responsibility to ensure that all freelancers working directly with young people have enhanced DBS check with lists at signature of contract.
DBS checks will be paid for and processed by TCP.
All artistic companies which will be working directly with young people will provide TCP with their safeguarding policy and write a letter to TCP indicating that all their staff members have current Enhanced DBS checks with lists (or their equivalent for international artists).
Any exception to these two requirements will be subject to approval on a case-by-case basis by the Directors.
Interview and Induction
All workers are required to apply formally and to undergo an interview carried out within TCP’s approved procedures, which includes two professional references. All freelancers receive formal and informal induction.
Training
In addition to initial employment induction, the safeguarding process includes training after recruitment to help refresh their practice and stay informed of relevant policy developments.
Risk assessment
When TCP is organising an activity specifically, if not solely, for young people, the lead TCP production member will be responsible for preparing a risk assessment to highlight any potential areas of risk and devise strategies to manage such risks.
This risk assessment will be made available, on request, to an organisation bringing a group of young people to a TCP activity. We will also support them in conducting their own risk assessment if requested.
TCP will work to appropriate Child Licensing legislation when hiring young people as performers with appropriate chaperones, and adhere to Working with Children performance guidelines.
Reporting
TCP promotes a culture within which TCP workers feel able to point out inappropriate attitudes, behaviours and situations demonstrated by their colleagues to their line manager or other senior member of the team.
Any TCP worker who suspects that abuse or inappropriate behaviour may have taken place, or who has had a disclosure made to them by a young person, will report it to their production manager or a designated person from a partner organisation in the first instance. Further details of the procedure to be followed ia available on request.
All suspicions and allegations of abuse will be taken seriously and responded to swiftly, appropriately and in accordance with our procedures, which are available on request.
Policy review basis
This policy will be reviewed regularly by the Directors.
HEALTH + SAFETY POLICY
Statement of intent
Our health and safety policy is intended to:
— prevent production accidents or health issues
— manage health and safety risks
— provide clear guidance, information and support to ensure all production teams and freelancers are competent to do their work
— consult with production teams on matters affecting their health and safety
— prevent production accidents or health issues
— manage health and safety risks
— provide clear guidance, information and support to ensure all production teams and freelancers are competent to do their work
— consult with production teams on matters affecting their health and safety
— ensure safe handling of production equipment
— maintain safe and healthy working conditions
— ensure evacuation procedures are understood and acted upon where necessary
— ensure that we work in venues that have robust health and safety policies, and cascade relevant information to our production teams
— update and revise this policy regularly
Responsibilities for health and safety
Overall and final responsibility for health and safety: Polly Thomas
Day-to-day responsibility for ensuring this policy is put into practice: designated production lead — including designated executive producer.
To ensure health and safety standards are maintained/improved, the following people have responsibility in the following areas:
— Polly Thomas … disseminating policies to freelancers, consulting production teams and maintaining information about any accidents
— designated executive producer … sign-off on production risk assessments
All freelancers should:
— co-operate with supervisors and managers on health and safety matters;
— take reasonable care of their own health and safety; and
— report all health and safety concerns to an appropriate person (as detailed above).
Arrangements for health and safety
We will complete industry standard risk assessments for every new production. Copies of risk assessments will be on site, and amended if conditions change.
Where appropriate, we will provide training and support to production teams to fulfil their health and safety obligations.
BUSINESS CONTINUITY PLAN
Thomas Carter Projects (TCP) has a business continuity plan in place regarding all aspects of the business.
All contracts and programme paperwork are stored on a secure protected cloud server, accessible from any location. We use a range of alternative professional studio and edit facilities as well as freelance personnel available to us, if required, for business continuity purposes.
The storage and protection of sensitive documents in relation to programme content, children or vulnerable adults, is reviewed annually. All staff working directly with children are Enhanced DBS checked (Enhanced Disclosure & Barring Service).
All programme material is backed-up during the recording and editing process, by qualified freelance technical staff. All final TX wavs will be retained for 10 years. Insurance is in place for loss of tapes (recordings), and also Employment Liability and Public Liability. We have three insurances — Public Liability, Employers’ Liability and Loss of Tapes.
Thomas Carter Projects is registered with ICO for data protection.
The two directors have full details of banking information and codes to access password-protected storage of information and programme material.
Thomas Carter Projects Limited
reg. in England and Wales I reg. no. 05167347
47 Nutclough, Hebden Bridge, West Yorkshire HX7 8HA
VAT no. 430 5783 03
reg. in England and Wales I reg. no. 05167347
47 Nutclough, Hebden Bridge, West Yorkshire HX7 8HA
VAT no. 430 5783 03
thomas@thomascarterprojects.com
carter@thomascarterprojects.com