Policies

CILEx Law School takes these policies seriously. If you have any questions or concerns, please get in touch.

Note: these policies are reviewed and updated regularly and as a result some are currently under review. Please contact our team for further information.

This policy is to help members of the public and our members to understand how we use cookies on our website.

About cookies

Cookies are small files which are stored on the user’s hard drive for the purpose of identifying the user agent (web browser) and ensuring web pages are correctly served to older versions of web browsers. Some cookies are essential in order for a website to run, while other cookies allow CILEx Law School to provide you with a better service. For administration of its website CILEx Law School may use session cookies; a session cookie is a temporary file stored in a web browser that is deleted when either it expires or the browser is closed. No personal information is stored permanently within a cookie from this web site.

Our cookies policy

The main purpose of our use of cookies is to optimise your user experience. CILEx Law School use cookies for navigational and functional purposes. When you access CILEx Law School’s website or log in to the secure CILEx Law School Student Area area we use encrypted session cookies in order to validate your access to different parts of the websites. If cookies are disabled this disrupts the general functionality of the CILEx Law School websites. We also use a cookie for marketing purposes on the page relating to the LLB in Legal Practice which we offer with City University London.

The cookies we use

The following tables show the cookies we use across our websites.

  • Cookies on www.cilexlawschool.ac.uk and associated third party cookies:
Where
Online shop PHPSESSID Session cookie that stores encrypted state information. Allows service to trace and determine if a user is actively engaged (ie is “in session”). Expires at end of session
Online shop Worldpay Third-party cookie in payment process. See http://www.worldpay.com/shopper/index.php?page=safety&sub=privacy
LLB in Legal Practice page Quantserve.com mc Collects data on the user’s visit to the webpage. The registered data is used for targeted ads for up to 13 months.
Where
Student Area online services MoodleSessionprod Session cookie that stores encrypted state information for online application software. Allows the service to trace and determine if a user is actively engaged with the site (ie is “in session”). Expires at end of session.
Student Area online services vuid player __utmz __utmt_player __utmc __utmb __utma These are Vimeo video player associated cookies. You can find more information on Vimeo cookies here.
Student Area online services JSESSIONID This cookie is associated with Blindside and expires when the browsing session ends.
Student Area online services dtCookie This is an Adobe cookie which expires when the browsing session ends.
LexisLibrary Third-party cookie relating to your use of LexisLibrary. See http://www.lexisnexis.co.uk/privacy/#HandleCookies)

Analytics

The CILEx Law School websites use Google Analytics, an analytics service provided by Google, Inc. Google Analytics uses cookies to help us to understand how users use our sites. This ensures that we can optimise and improve your experience of our websites. Read more about how Google uses cookies.

Disabling/enabling cookies

You have the ability to accept or decline the use of cookies by changing your browser settings. You can also manually remove cookies from your system. However, we would like you to have the best experience of our websites and it is likely that disabling cookies will limit the functionality of the CILEx Law School website and CILEx Law School Student Area. If you are concerned about the use of cookies in relation to “spyware” you can use anti-spyware software to delete cookies that may be considered invasive, rather than disabling cookies altogether.

Third-party sites

Please be aware that some of the websites to which we provide links may collect personally identifiable information about you. We do not control these sites and are not responsible for the content or practices of third-party websites. This cookies policy does not cover such sites.

Consent

By accepting cookies within your browser settings and using the CILEx Law School website, you consent to the processing of data about you by CILEx Law School, its third-party suppliers in the manner and for the purposes set out above.

Further information

A comprehensive set of guidelines, and information on how to clear cookies from your website can be accessed from the Information Commissioner’s Office.

Our accessibility policy is in line with the CILEx Group Single Equality and Diversity Scheme and Action Plan.

Our commitment 

CILEx Law School (CLS) is committed to the provision of accessible learning and wishes to support all students in their studies. To this end, we will make reasonable adjustments in accordance with section 29 of the Equality Act 2010 and the associated Code of Practice on Services, Public Functions and Associations.

All CLS students can apply for Learner Support in relation to a disability, health condition or learning difficulty. Applicants will be contacted by our Learning Support Advisor (LSA), who will discuss the student’s needs and create a mutually agreed Learner Support Plan.

If you are a prospective student and wish to discuss the reasonable adjustments that CLS may be able to make to assist you in your studies, please contact our LSA at clslearnersupport@cilexlawschool.ac.uk.

Please note that adjustments made by CLS are applicable to your learning only. Reasonable adjustments required for exams must be accessed via application to CILEx.

Website

This website has been produced in accordance with current accessibility guidelines. Should you encounter any difficulty accessing content within this site, please send your suggestions to IT@cilexlawschool.ac.uk.

CLS Hub (VLE)

The Web Content Accessibility Guidelines (WCAG) defines requirements for designers and developers to improve accessibility for people with disabilities.

The CLS Hub is built using Totara Learn 11. Because of the customisable nature of Totara, it can be difficult to exactly map the conformity of the site with the WCAG. Totara Learn is working towards compliance with WCAG 2.1, the current WCAG guidelines. Not all of the WCAG guidelines are applicable to Totara.

Other adjustments

Adjustments are dependent on your personal needs and will vary from student to student. A personalised Learner Support plan will be devised between the Learning Support Advisor (LSA) and the student which will detail the changes to be made for that individual. Adjustments may include, but are not limited to:

  • Providing materials in PDF or Word format for use with screen reading software
  • Additional submissions for skills assignments
  • Easy access rooms for face-to-face sessions
  • Regular contact with the LSA for planning and target setting
  • Permission to audio record face-to-face sessions
  • Providing materials for induction days, skills workshops and revision sessions in advance.

Eligibility

Learner Support is provided for students who have conditions which fall within one or more of the following categories:

  • Disability
  • Physical illness – long or short-term
  • Mental Health condition
  • Learning difficulty
  • Physical injury

Evidence must be provided with every application submission.

How to apply

Once you complete your purchase, you will receive a confirmation email containing application instructions and/or a link to the Learner Support application form. You will also find a link to the application form on the My Courses page in the CLS CRM Portal and on the Learner Support page in the CLS Hub.

The Chartered Institute of Legal Executives (CILEx) is the governing body for Chartered Legal Executives, paralegals and other legal professionals. CILEx as a professional association provides professional development, support and guidance to its members. It delivers legal education and training through CILEx Law School (CLS), qualifications through its Awarding Body function and independent regulation through CILEx Regulation.

CILEx takes your privacy and your rights to your personal data extremely seriously and we are committed to protecting the privacy of all personal data obtained about individuals. Data is held in compliance with data protection legislation and will be collected and used only for the purposes for which it was originally submitted or in accordance with your preferences.

For more information about how we collect and use your data, please take a look at our Privacy Statement, which can be found on our website. The information below relates specifically to CLS in its function as a training and apprenticeship provider.

Data collection and use –  students, apprentices and purchasers of publications

The primary reason we collect information is to allow us to process your application and deliver our services for the duration of your course or apprenticeship, or to fulfil the order for any publication you have purchased. In addition, only if you’ve agreed to it, we might also contact you about relevant products and support services.

Where sensitive data is required, we will detail why the data is collected and how it will be used.

In some circumstances it is necessary for us to share data with third parties in order to deliver our services. These requirements vary depending on the nature of the services being delivered. Examples are given in the ‘Sharing your data’ section below.

CLS also processes data for the purposes of monitoring and improving our performance and for business analysis.

Sharing your data with partner organisations, awarding bodies and government departments

CLS is wholly owned by the Chartered Institute of Legal Executives (CILEx). CILEx holds data on common software platforms to be used only for the purposes agreed by you.

The other organisations in this category that we share data with will vary according to the nature of your transaction with us. Depending on the nature of the services being delivered, the third parties with whom we share your data with may include, but may not be limited to:

  • your employer where they have paid for your course fees on a distance learning course or have secured an apprenticeship with them
  • your prospective employer if you are an applicant for an apprenticeship
  • our partner organisation for your course or apprenticeship where the course or apprenticeship is jointly delivered by us and either De Montfort University, City University, Northumbria University or Manchester Metropolitan University for the purposes of teaching, course delivery and maintaining your student record
  • City & Guilds where your course is awarded by them
  • the Learner Record Service, a government department, with whom we are required to share your data if you are enrolling on a course or apprenticeship listed on Ofqual’s Register of Recognised Qualifications. The LRS privacy notice can be found here: https://www.gov.uk/government/publications/lrs-privacy-notices/lrs-privacy-notice
  • the Education and Skills Funding Agency (ESFA), a government department, for reporting purposes for apprenticeship funding. If you are enrolling on an apprenticeship we are required to share the ESFA’s privacy notice with you, which can be found here: https://www.gov.uk/government/publications/esfa-privacy-notice/education-and-skills-funding-agency-privacy-notice-may-2018.
  • the Office for Standards in Education, Children’s Services and Skills (OFSTED) if we are inspected by them in respect of our delivery of an apprenticeship programme on which you are enrolled. For the OFSTED privacy notice, please visit: https://www.gov.uk/government/publications/ofsted-privacy-notices/further-education-and-skills-ofsted-privacy-notice,
  • the Federation for Industry Sector Skills and Standards (FISSS) to request your apprenticeship completion certificate through their online portal Apprenticeship Certificates England (ACE). For the ACE privacy notice, please visit: https://acecerts.co.uk/web/privacy-policy,
  • the Office for Students (OfS) where you are on a Chartered Legal Executive Apprenticeship. You can find the OfS privacy notice here: https://www.officeforstudents.org.uk/ofs-privacy/

Sharing your data with our suppliers

CLS works with a number of software and other suppliers in order to deliver our services to you. Organisations we share your data with may include, but may not be limited to:

  • our print contractor to send out your course materials or a publication you have purchased,
  • the e-commerce software provider for our online shop,
  • our virtual learning environment providers so you can access and use the functionality of the Student Area,
  • our e-portfolio provider so you can access and use the functionality of OneFile,
  • our video conferencing software for the delivery of webinars,
  • our learner management and reporting software to assist us in keeping apprenticeship records for internal analysis and external reporting,
  • our freelance tutors who mark your study exercises or assignments,
  • our freelance tutors who deliver your face-to-face sessions/webinars or provide additional study support,
  • our GCSE and functional skills assessment provider to determine your English, Maths and/or ICT level (for apprenticeships),
  • the email software and survey tool providers we use to issue mass communications, including surveys.

As required under the GDPR, we are putting agreements in place to ensure that these organisations have all signed data processing agreements to ensure that they comply with our requirements for the use of your data.

Data collection and use – business-to-business communications

Where business-to-business relationships exist, details of non-student staff at client organisations who are sponsoring students or employing apprentices are held on the basis of legitimate interest, as defined by the GDPR, rather than on the basis of consent.

From time to time, on a limited basis, CLS may contact organisations for the purposes of providing information on CLS’s products and services. Should the organisation or individual representative contacted indicate that they do not wish to receive further communications, their contact details will be deleted save for the purposes of maintaining a suppression list.

Complaints procedure

Ensuring compliance with data principles is the responsibility of the Privacy Officer. If you have a complaint about the processing of your Personal Data, you should put forward the matter in writing to the Privacy Officer (see contact details below). An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case and you will be informed of the progress and the outcome of the complaint within a reasonable period.

Should you feel that your complaint has not been handled satisfactorily or have additional concerns about our organisational practices, you can also contact the Information Commissioner’s Office. Please visit their website for more information.

Contact details

For additional information, to exercise your rights under GDPR (such as making a subject access request, requesting a data rectification, etc.) and other data protection-related legislation or to raise a complaint, please contact:

The Privacy Officer, The Chartered Institute of Legal Executives, Kempston Manor, Manor Drive, Kempston, Bedford MK42 7AB.
Email: privacyofficer@cilex.org.uk

Context

CILEx Law School aims to provide all of its students with the support and guidance they need to achieve success. The Student Code of Conduct sets out the standard of conduct we expect of you as a student of CILEx Law School and that we believe is consistent with helping you to undertake your studies in a supportive and non-threatening environment.

What students can expect from CILEx Law School:

CILEx Law School is committed to providing the highest standards in both educational provision and administrative services.

We will:

  • Give you clear, accurate and timely advice, information and guidance to help you choose a programme of study that is right for you
  • Provide you with the opportunity to attend an induction session to help you make the most of your course
  • Provide you with up-to-date courses and course materials that have been prepared specifically for the purpose described
  • Help you with scheduling your studies by providing guidance and support
  • Provide you with appropriately qualified teaching staff
  • Deal with your enquiries promptly and courteously
  • Investigate a complaint with any aspect of our service promptly and courteously
  • Value people equally, respecting our democratic values of freedom of speech, appreciation of different beliefs, the rule of law and individual liberty

What CILEx Law School expects from our students

We expect students to:

  • Take responsibility for your own learning by making use of course resources, seeking help when you need it, and acting upon the feedback and support you receive
  • Treat with respect and courtesy everyone with whom you come into contact within the context of your CILEx Law School course
  • Adhere to the Health and Safety policies and to any specific requirements that apply to any premises attended for a CILEx Law School event
  • Value people equally, respecting our democratic values of freedom of speech, appreciation of different beliefs, and the rule of law and individual liberty.

What CILEx Law School will not accept from our students

CILEx Law School considers the forms of unacceptable conduct that are set out below to constitute misconduct that is likely to lead to disciplinary action. However, the list should not be regarded as exhaustive.

We will not tolerate behaviour that:

  • Disrupts or improperly interferes with the teaching, learning, administrative, or other activities of CILEx Law School, whether on CILEx Law School premises or elsewhere
  • Obstructs or improperly interferes with the functions, duties or activities of any student, member of staff or freelance tutor of CILEx Law School
  • Amounts to discrimination, harassment, or victimisation of others on the grounds of their age, disability, gender, gender reassignment, pregnancy, maternity, race, religion, belief, or sexual orientation
  • Amounts to bullying or harassment of any kind towards a student, a member of staff or freelance tutor by any means including cyber-bullying, cyber-harassment, or harassment through social media
  • Is violent, indecent, intimidating or threatening, or that involves offensive behaviour
  • Is likely to cause injury or jeopardise safety during any CILEx Law School activity
  • Breaks the regulations of any premises being used for any tutorial, revision session or examination centre, including health and safety matters
  • Reveals confidential information without permission, including personal information about other students, clients or staff and information covered by CILEx Law School’s registration under the Data Protection Act 1998
  • Amounts to student malpractice in line with the CLS Malpractice Policy or that breaches CILEx regulations relating to examinations, professional skills assessments and competence qualifications
  • Abuses copyright: this specifically includes, but is not limited to, any breach or infringement of copyright or licence, whether owned or controlled by CLS or by a third party, by copying, distributing or offering for sale course or assessment material
  • Involves the recording of lectures, other academic sessions or conversations without prior authorisation through a Learner Support Plan or the express agreement of the tutor holding the session.

CILEx Law School is under a duty to have due regard to the need to prevent people from being drawn into terrorism.  We also have an integral part to play in fostering a set of shared ‘British values’ and promoting community cohesion for our apprentices. CILEx Law School has a Prevent policy, which seeks to ensure that CILEx Law School (CLS) meets this requirement.

Our apprentices all have access to the Prevent Policy.  If any of our clients would like to see a copy of our Prevent Policy, please email us at apprenticeenquiry@cilexlawschool.ac.uk

CILEx Law School is committed to ensuring the safety and welfare of all apprentices. This commitment reflects our shared ethos of working in the best interests of our learners and helping them to thrive.

The aims of our Safeguarding Policy, procedures and associated guidance are to:

  • protect the right of every apprentice to learn within a safe environment
  • promote staff awareness of the need to safeguard our apprentices and to recognise that safeguarding is everyone’s responsibility
  • identify the responsibilities of staff in relation to safeguarding
  • ensure effective and proportionate safeguarding practices and procedures are in place
  • ensure staff act professionally, sensitively and in ways that promote and support the welfare of our apprentices
  • mitigate the risk of abuse by ensuring procedures and standards are in place

Our apprentices all have access to the Safeguarding Policy.  If any of our clients would like to see a copy of our Safeguarding Policy, please email us at apprenticeenquiry@cilexlawschool.ac.uk

  1. Introduction and context

At CILEx Law School (CLS) we believe that all learners should have the opportunity to make the most of their talents, irrespective of any defining personal characteristic. This policy sets out how we intend to ensure learners can study in an environment that supports a diverse student body, as reflected in the nine protected characteristics.

Details of the protected characteristics can be found at https://www.equalityhumanrights.com/en/equality-act/protected-characteristics. In brief they are:

  • Age
  • Disability
  • Gender reassignment
  • Marriage and civil partnership
  • Pregnancy and maternity
  • Race
  • Religion and belief
  • Sex
  • Sexual orientation
  1. Roles and responsibilities

2.1 CLS board of directors – The CLS board of directors are responsible for setting policies at CLS and monitoring their implementation at the highest level. They will set priorities and check fulfilment of policy statements. They will ensure that CLS’s priorities and activities are compatible with, support and promote the CILEx Group’s Equality and Diversity action plan.

2.2 The Group Executive – The Group Executive is responsible for ensuring that there is a consistent approach to the application of policies across the CILEx Group, and that we conduct an equality impact assessment across the Group. The Group Executive are also answerable to the Group Board in respect of delivering the CILEx Group Equality and Diversity action plan. The Group Executive will report on, and publish equality data in accordance with the plan.

  • Colleagues – It is the responsibility of colleagues to ensure their

behaviour does not cause others to feel uncomfortable because of discriminatory words or actions. CLS will provide periodic training to assist colleagues, who must ensure that they participate in the same. Taking personal responsibility includes challenging others’ discriminatory behaviour. If necessary, colleagues are encouraged to use the whistle-blowing policy to bring discriminatory incidents to the attention of senior management.

2.4 Managers. The role of managers is crucial in the successful implementation of this policy. Specifically, they must ensure

  • that reports understand their responsibility not to discriminate in respect to other colleagues, learners, employers and any other stakeholder (such as external tutors etc).
  • they do their utmost to protect those who report into them from discriminatory words and actions.
  • when offering development opportunities, that these are made on the basis of merit and that no discriminatory factors influence the decision making process.
  • that the process of preventing discrimination is actively pursued and is not merely reactive.

2.5 Contractors – All external contractors, whether delivering face-to-face teaching, marking or services that do not involve direct contact with learners are obligated to adhere to this policy. Acknowledgement and adherence to this policy (in the absence of the supplier having its own policy which we believe is equally effective) will be included in our terms of business.

2.6 Learners – All learners will be made aware of their rights and responsibilities in respect of equality and diversity under this policy (see below). This policy will be accessible through the CLS Student Area. Complaints will be taken seriously. If a complaint is against a fellow learner and is found to be justified then subsequent action could include removal from the course/s and a report to CILEx Regulation.

2.7 Visitors – Visitors will be expected to comply with all aspects of this policy while on site.

  1. Legislation

CLS will adhere to the prevailing statutory provision in force, and observe best practice as represented by codes of practice and other forms of guidance. CLS’s aim is to:

  • promote equality of opportunity irrespective of an individual’s innate characteristics to eliminate discrimination;
  • take steps to avoid incidents of harassment and victimisation;
  • encourage cultural diversity and tolerance by respecting different identifiable groups equally.
  1. Learners

4.1 Marketing and admissions

CLS is Matrix accredited which requires us to support applicants with balanced, unbiased advice. This includes being mindful of the requirements and needs of a diverse student body. Therefore our approach will be to:

  • Ensure that no applicants are treated less favourably because of disability, gender reassignment, age, pregnancy and maternity, marriage and civil partnership, race, religion and belief, sex (gender) and sexual orientation;
  • Ensure our recruitment and publicity materials encourage applications from diverse sources because they are
      • objective and representative of all groups in the community
      • available and accessible to all potential learners in a variety of formats
  • use objective criteria to evaluate applications for courses, using entry criteria, as specified in course information;
  • ensure access to learner support is signposted at the application stage and that learners can request support at an appropriate stage of the process;
  • ensure that where applicants are interviewed, only objective criteria are used to determine the candidate’s success;
  • if assessment forms part of the application process, then this will be applied objectively. Reasonable support and adjustments will be made available to support the application process;
  • ensure that learners have access to this policy by bringing it to their attention as part of induction and making it available on our on-line Student Area.

4.2 Ensuring access to learning

CLS will ensure:

  • Its continued commitment to access by continually reviewing courses to tackle barriers;
  • That courses are written in a way that is representative and culturally sensitive and avoids stereotypes. Our starting point is one of inclusion;
  • Our learning support facilities are as comprehensive as resources reasonably allow. We will monitor access to learning and review participation rates as a measure;
  • Equality and diversity is an integral part of our teaching strategy, which is inclusive and embraces the diverse community of learners that we serve.

4.3 Helping learners

So that all learners can get the best from CLS courses, CLS will provide support and help for our learners by:

  • Identifying an English and Maths champion at CLS;
  • High quality subject expert tutoring;
  • Careers counselling;
  • Reference to free specialist welfare/personal counselling through Lawcare;
  • Helping to support those with physical needs including adjustments to the presentation of learning materials and access to a learning support specialist;
  • Accessible classroom accommodation;
  • Ensuring the above are publicised and are incorporated into the induction process and set out in the on-line Student Area;
  • Take reasonable steps to continually improve access and facilities for learners to improve participation rates
  1. Colleagues

5.1 CLS will:

  • When recruiting, create a job specification which sets out the competencies necessary for the role. This includes those skills, behavioural attributes and experience required for the job;
  • In so far as budgets and logistics permit, roles will be advertised so that they are accessible to a broad a range of candidates;
  • Candidates for roles will be evaluated against objective criteria in the job specification.

5.2 Developing staff

CLS will

  • Incorporate Equality and Diversity as part of new staff induction, and in accordance with wider CILEx Group policies;
  • Conduct performance reviews twice per year to ensure that all staff have access to training and development opportunities pertinent to their roles.

5.3 College House

CLS will make reasonable adjustments to accommodate colleagues with protected characteristics.

  1. Creating a tolerant workplace

6.1 Any form of harassment, victimisation or discrimination will not be tolerated.

6.2 Colleagues believing they have been subjected to harassment, victimisation or discrimination should use the Group procedures that guide the reporting and handling of such incidents. There is also a comprehensive grievance procedure for complainants who believe their concerns have not been addressed.

6.3 Learners should refer any incident to the Academic Director, whose contact details are on the Student Area.

6.4 Deliberate misuse of procedures can undermine the system of tackling harassment, victimisation or discrimination and will be treated as a serious infraction of the behavioural standards that are expected of learners and colleagues alike.

6.5 Where colleagues or learners are found to have committed an act of harassment, victimisation or discrimination then they will be subject to the relevant disciplinary policies, which can in the case of learners include exclusion from CLS and reporting to CILEx Regulation.

  1. Monitoring

CLS will monitor enrolment, retention, achievement and success data for different groups of learner, and identify actions to improve performance if an identifiable learner group is under-performing relative to another group. These actions are fed into quality improvement plans and are monitored regularly.

  1. Associated policies and procedures

This policy should be read in conjunction with the following:

  • CILEx Group Equality & Diversity Action Plan.
  • Teaching, Learning and Assessment Policy
  • Learner support policy and procedure
  • Student code of conduct
  • Learner Disciplinary procedure
  • Staff Grievance Procedure
  • Staff Disciplinary Procedure
  • Safeguarding Policy and Procedures
  1. Introduction and context

CILEx Law School (CLS) is committed to delivering high quality service at all times, however we do recognise that there may be occasions when things do not go as planned. CLS values all feedback and aims to learn from any comments to help us to improve continually. CLS considers, records and acts upon all comments received and provides feedback as appropriate. CLS will handle all expressions of dissatisfaction with our service under this policy.

It is an essential principle that all CLS learners should have the opportunity to raise matters of concern without risk of being disadvantaged, discriminated against or victimised as a result of making a complaint. All complaints, whether formal or informal, will be recognised and dealt with sympathetically and constructively. Requests for confidentiality will be respected, wherever possible.

  1. Objectives

This policy and procedure is intended to:

  • Be simple to understand and use
  • Ensure a full and fair investigation
  • Provide timely and effective responses to complainants
  • Respect confidentiality where appropriate
  • Provide information to managers so that services can be improved.
  1. Applicability

This Policy covers complaints in respect of the following CLS services:

  • Information, advice and guidance
  • Teaching and learning, including course resources
  • Our online learning environment (the Student Area) and associated resources
  • Course administration and other course-related problems
  1. Issues not covered by this policy
  • Academic assessment, e.g. grades and marks. These are covered by the Appeals procedure
  • Bullying, harassment or discrimination. These are covered by the Anti-bullying policy.
  1. Procedure

Stage 1: Informal

If you are dissatisfied with any CLS services, it is usually appropriate to raise the matter informally with a member of staff first. Explain what you are unhappy about and ask for their help in putting it right. Most problems can be resolved quickly and informally in this way. However, there may be some instances where the complaint needs to be referred to the appropriate line manager. The member of staff will tell you if this is the case.

Stage 2: Formal

If you wish to make a formal complaint, you should contact the CLS Customer Service Manager. You can do this telephone, email or letter. If you have verbally reported your complaint, you may be asked to confirm this in writing so that we can be absolutely clear about the relevant details. Where a complaint is addressed to CLS but is actually relevant to CILEx, the professional association, then we will refer the matter to them. We will tell you who at CILEx is dealing with the matter and ask them to contact you.

You will be sent an acknowledgement within three working days of receiving your complaint, although we do aim to respond on the date of receipt where possible.

Complaints will be allocated to the appropriate line manager who will investigate and respond within 10 working days, although this may take longer during holiday periods. We aim to provide a fair conclusion to all complaints within 20 working days, although again this may take longer during holiday periods.

The Managing Director is made aware of all complaints. Responses to complaints will be reviewed by the Academic Director (learner complaints) or Director of Business and Apprenticeships (employer complaints), as appropriate, and logged accordingly. The complaints log will be reviewed on a regular basis at CLS quality assurance meetings to ensure that any necessary improvements are addressed.

  1. Further comments or appeal

Any comments about the way in which the complaint was dealt with, or any appeal against the findings and/or actions, should be made in writing to the CLS Managing Director, setting out the grounds for appeal, within five working days of receipt of the outcome.

In the unlikely event that the complaint has not been resolved to your satisfaction at this stage, it is possible to complain to the Education and Skills Funding Agency (ESFA). The ESFA will not re-investigate the original complaint, but will review whether CLS has properly investigated your original complaint in line with our procedures. The ESFA not only investigate until the CLS complaints procedure has been fully exhausted.

  1. Contact details for Customer Service Manager (Ruby Denton)
  1. Approval and review

This policy was approved by the CLS Senior Management Team and will be reviewed on an annual basis.

  1. Introduction and context

CILEx Law School (CLS) is committed to safeguarding and promoting the welfare of our learners.  This commitment requires staff to foster a caring, friendly and safe environment that is free from discrimination and bullying. Bullying of any kind is unacceptable and all learners should be able to report incidents confident in the knowledge that they will be dealt with promptly and effectively.

This policy covers allegations relating to learners and CLS staff. Although the nature of CLS’s delivery means that such allegations are likely to be a rare occurrence, staff should nonetheless be alert to the possibility and adopt an “it could happen here” attitude. Allegations of bullying relating to an apprentice’s workplace should be handled through the Safeguarding Policy and Procedure.

This policy should be read alongside the Code of Conduct for Learners, Safeguarding and Prevent policies, and Social Media guidance.

  1. Policy aims

This policy aims to:

  • Help foster an environment that supports staff and learners to recognise and challenge bullying, and encourage positive intervention to prevent re-occurrence;
  • Establish clear lines of responsibility;
  • Ensure that all staff and learners are aware of the procedures to follow should they wish to report bullying;
  • Ensure that all incidents of bullying are handled professionally, proportionately, and in a timely manner, with the best possible outcome for those involved.
  1. Definition of bullying

The following definition is the starting point when applying this policy:

“Bullying is behaviour by an individual or group, usually repeated over time, that intentionally hurts another individual or group, physically or emotionally” (Department for Education)

CLS recognises that bullying does not only depend on the intention of the offender, but also on the impact of their behaviour on others. It is therefore important to consider the perceptions and feelings of the person affected rather than simply the intention of the offender.

  1. Forms of bullying

Examples of bullying behaviour include:

  • Verbal – name-calling, sarcasm, spreading rumours, teasing.
  • Physical – pushing, kicking, hitting, punching or any use of violence.
  • Sexual – unwanted physical contact or sexually abusive comments.
  • Emotional – being unfriendly, excluding, and tormenting.
  • Racist – deliberate exclusion, racial taunts, graffiti, gestures.
  • Homophobic – because of or focusing on the issue of sexuality.
  • Religious/cultural – targeting a learner’s faith, beliefs or practices.
  • Intellectual – ridiculing a learner and/or their attempts to engage in educational or related activities.
  • Cyber – this can include all areas of internet activity, such as email, social networking, text messaging and calls. This can also include misuse of associated technology such as photos and videos. This type of bullying can also form the platform for other forms of bullying.
  1. Responsibilities

All staff and contractors are expected to share CLS’s commitment to safeguarding and promoting the welfare of our learners. It is therefore everyone’s responsibility to ensure that learners feel safe and that all incidents of bullying and harassment are dealt with appropriately.

The Senior Management Team is responsible for monitoring the effectiveness of this policy and associated procedures on an annual basis.

The Academic Director is responsible for reporting to the Senior Management Team on the effectiveness of this policy and associated procedures.

The Apprenticeship Manager is responsible for overseeing the implementation of this policy.

The Designated Safeguarding Officer is responsible for maintaining a register of reported bullying incidents and outcomes.

The Safeguarding Committee (comprising the Academic Director, Apprenticeship Manager, Deputy Apprenticeship Manager (Quality) and Designated Safeguarding Officer) is responsible for reviewing this policy and associated procedures, monitoring the number of bullying incidents in a given period, identifying trends and developing anti-bullying strategies, where appropriate.

  1. Prevention of bullying

CLS recognises the role it plays in countering bullying through educating its learners to stay safe and respect others. This is achieved through a variety of means, including:

  • raising awareness of our anti-bullying policy through the induction process and progress reviews;
  • ensuring that learners and staff are aware of what constitutes bullying and the consequences for those involved;
  • raising awareness of cyber bullying and appropriate social media usage;
  • promoting British Values;
  • ensuring through induction and the apprentice handbook that learners are aware of whom to approach with a concern and their rights to confidentiality in this context;
  • ensuring that staff understand whom learners should approach with a concern;
  • giving advice on what constitutes bullying and the support that CLS offers.
  1. Reporting a bullying concern

Learners may report bullying to any member of CLS staff, although it is likely that their Legal Assessor and Trainer will be the first point of contact.

All allegations of bullying should be taken seriously and handled promptly by the member of staff concerned.

The member of staff who receives the report must inform the learner that a record will be made of the report and this information may be passed to the Designated Safeguarding Officer.

Where there is believed to be a risk of significant harm the case must be referred to the Designated Safeguarding Officer and dealt with through the safeguarding procedures.

If the allegation of bullying is against another member of CLS staff it must be reported to the CLS Managing Director. Depending on the nature of the allegation, it will either be handled under the staff Disciplinary Procedure or referred to an appropriate external agency.

  1. Recording an allegation of bullying

When a learner reports bullying, the staff member should record the following information:

  • date(s), times(s) and place(s) of incident(s)
  • what actually happened and how it made the complainant feel
  • the name(s) of any witnesses
  • any action already taken e.g. reported to a member of staff
  • original copies of any correspondence or written material connected with the issue
  • where cyber bullying has taken place, printouts should be obtained wherever possible (e.g. of emails), or the member of staff making the record should sign it to say they have seen any text messages/call records on the learner’s mobile phone
  • what the learner’s wishes are in terms of next steps, although it must be made clear that it may not be possible to comply with those wishes.
  1. Procedure following a report

Issues of bullying are often complex and there is no single approach that is effective or appropriate in all circumstances.  In some cases the individual may just want to talk about the bullying but may not wish to take matters further. If the individual wants to take matters further, there may be an informal or formal investigation (involving the Disciplinary procedure), depending on the needs of the complainant and the nature of the complaint.

9.1 No further action required

If the learner does not wish to take matters further, support should be offered and followed up at appropriate intervals by the member of staff concerned. It may be appropriate to provide the complainant with contact details for CLS internal support (e.g. learner support) or an external agency (e.g. LawCare or Childline).

It must be recognised that there will be instances where an individual talks on an informal basis, but because of the nature of the incident and the risk of harm to self or others, the Designated Safeguarding Officer must be informed. This will always be discussed with the complainant to gain their consent and/or understanding that the matter must be taken further.

9.2 Informal investigation and resolution

Often an informal approach at an early stage can offer the best solution before matters escalate. The member of staff to whom the matter is reported should discuss how to approach the informal investigation with the Apprenticeship Manager.

9.3 Formal investigation and resolution

Where there is a serious or repeated allegation of bullying the investigation will be handled under the Disciplinary procedure.

9.4 Guiding principles

The following principles underpin our approach to both formal and informal investigations:

  • All allegations of bullying will be taken seriously and handled in a proportionate and timely manner.
  • In serious cases of bullying, the incidents will be recorded by the Apprenticeship Team and a member of staff will monitor the situation until a resolution is reached.
  • In serious cases of bullying involving a learner under 18, the individual’s parents may be informed and asked to join a meeting to discuss the issue.
  • The bullying behaviour or threats of bullying will be fully investigated and measures will be implemented to protect the victim and ensure that the bullying stops quickly.
  • The underlying aim is that the issues leading to the bullying are understood by all parties, that apologies are offered and accepted and that further bullying behaviour is avoided. Both the person responsible for the bullying and the complainant will be supported by CLS to meet this end.
  • If possible, the parties will be reconciled so that they are able to move forward with confidence.
  • After the incidents have been investigated and dealt with, each case will be monitored to ensure repeated bullying does not take place.
  • An attempt will be made to help the individual responsible for bullying to change their behaviour.
  • Where a young person repeats bullying behaviour and refuses to modify their conduct this may ultimately result in their permanent exclusion from CLS.
  1. Confidentiality

All reports should be kept in a locked cabinet with access to be provided only to the learner and designated members of staff. Records will be kept until the January which falls two years after the completion of, or earlier termination of, the apprenticeship for which CLS was the training provider.

A learner’s wishes regarding confidentiality will usually be respected provided this does not lead to a conflict with the CLS Safeguarding policy and procedure. If in doubt, the member of staff who receives the report should hold an initial discussion with the Designated Safeguarding Officer on a no names basis.

  1. Monitoring and review

All incidents of bullying that are subject to a formal or informal investigation, and the outcomes of that investigation will be recorded on a register maintained by the Deputy Apprenticeship Manager (Compliance). Where the matter has been referred to the Designated Safeguarding Officer it will be recorded as for safeguarding issues. The Safeguarding Committee will review the register and consider whether this policy and procedure are effective, and any implement any necessary changes.

  1. Associated documentation
  • Code of Conduct
  • Disciplinary Policy
  • Safeguarding Policy
  • Prevent Policy
  • Health and Safety Policy
  • Equality and Diversity Policy
  • Apprentice’s Commitment Statement or Apprenticeship Agreement

Social Media Guidance

The directors and senior management team at CILEx Law School (CILEx Law School) recognise that our business has an impact on the environment. We are committed to continuous improvement in the company’s environmental performance. Environmental regulations, laws and codes of practice are regarded as setting the minimum standards of environmental performance. Our policy in environmental matters is:

  • To consider the environmental impacts of our products, and to continually reduce the environmental impact through our sourcing of raw materials.
  • To conserve resources through efficient use, and by progressively improving heating and lighting systems, investing in energy efficient copiers, IT and electrical equipment, and by ensuring that all building work undertaken has the concept of environmental responsibility as a central issue within the working brief
  • To adopt a sustainable waste management policy by recycling materials wherever possible
  • To minimise waste, especially hazardous waste, and to dispose of all waste through safe and responsible methods
  • To work with our suppliers to ensure they recognise and reduce the environmental impact of their products and transportation
  • To implement our policies through guidelines and training

Our progress to date

We have moved from PVC to biodegradable polypropylene for our course binders. The paper that we use in our course manuals is from renewable forests and bleached with non-chloride bleach. We recycle all office paper and print cartridges after use. Obsolete computers and other hardware are passed on to charities for use in developing countries. We use a distributor for sending out our course materials with a published environmental statement.

Introduction

This policy forms part of the Chartered Institute of Legal Executives’ (CILEx) internal control and corporate governance arrangements. CILEx means here the Chartered Institute of Legal Executives and its subsidiary companies.

This policy details CILEx’s response to the Modern Slavery Act 2015, documents the roles and responsibilities and outlines the main reporting procedures.

The Group Council of CILEx is committed to ensuring that effective anti-bribery, anti-corruption and anti-slavery and human trafficking procedures operate throughout CILEx. CILEx is committed to carrying on business fairly, openly and honestly with a zero tolerance approach to bribery and corruption.

This policy does not form part of any employee’s contract of employment. CILEx therefore reserves the right to amend this policy and procedure as necessary to meet any changing requirements.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and 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 in our own business or in any of our supply chains.

Purpose and scope of Policy

The aim of this policy is to encourage a culture of openness.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

2. Responsibility for the policy 2.1 The Group Council has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

2.2 The Corporate Compliance Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

2.3 Line managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

3. Compliance with the policy

3.1 You must ensure that you read, understand and comply with this policy and statement.

3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3.3 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.

3.4 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the Corporate Compliance Manager.

3.5 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Corporate Compliance Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

4. Communication and awareness of this policy

4.1 Awareness training of this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular refresher training will be provided as necessary.

4.2 Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

5. Breaches of this policy

5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

5.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Modern Slavery Act 2015 Transparency Statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that the CILEx Group is taking to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Although CILEX is not bound by the Act, we are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The CILEx Group has a zero tolerance approach to any form of modern slavery.

Our Business

The Chartered Institute of Legal Executives (CILEx) is the professional association and governing body for Chartered Legal Executive lawyers, other legal practitioners and paralegals. The CILEx group includes the CILEx Law School and CILEx Regulation, together with two Charitable Trusts- CILEx Benevolent Fund and The CILEx Pro Bono Trust. CILEx represents around 20,000 members. CILEx continually engages in the process of policy and law reform. At the heart of this engagement is public interest, as well as that of the profession.

As it contributes to policy and law reform, CILEx endeavours to ensure relevant regard is given to equality and human rights, and the need to ensure justice is accessible for those who seek it.

Our High Risk Areas

Having assessed our activities we have no areas of operation which would be considered to be of high risk of modern slavery. Operational areas that may be of risk are detailed as follows. This list will be reviewed and updated from time to time:

  • Use of staff by subcontractors or suppliers to CILEx, where the suppliers’ processes may not be compliant.
  • Employment of sub consultants, suppliers and sub-contractors by CILEx, where their work practices may be non-compliant.

Our Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

  • Equal Opportunities Policy: We are fully committed to ensuring that equal opportunities policies are implemented and maintained. All terms and conditions of service apply on a fair and consistent basis to every member of staff.
  • Recruitment Policy. We operate a robust recruitment policy, including conducting checks on work eligibility for all employees to safeguard against human trafficking or individuals being forced to work against their will.
  • Whistleblowing Policy: We aim to encourage openness and will support anyone who raises genuine concerns in good faith under the Whistleblowing policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion.

Our Subcontractors & Suppliers

We are committed as an organisation to tackling modern slavery and human trafficking and want to work with suppliers who share our values.

To this end, the CILEx group will review its supplier policies and create and maintain a preferred subcontractor/supplier list.

Our Modern Slavery policy will form part of our contract with our subcontractors and suppliers and they will be required to confirm that no part of their business operations contradicts this policy.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our organisation and our supply chains, we intend to roll out awareness training to our Group Executive team and provide regular updates to our staff through our intranet.

Our Performance Indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.