Anti-Slavery & Human Trafficking Statement

January 2023

Introduction from the CEO

Slavery and human trafficking remains a hidden blight on our global society. We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns and management are expected to act upon them.

Organisations’ structure

We are a country’s leading hotel support services company, providing the hospitality industry with top rated services and staff from Room attendants to Executive housekeepers. HotelCare is the trading name of HC Facility Management Ltd. HotelCare has its head office in the UK and all places of work are in the UK. The group has an annual turnover in excess of £50m.

Our business

HotelCare’s business is supplying support services, in the form of providing the hospitality industry with top rated services and staff from Room attendants to Executive housekeepers across numerous sites in the UK.

Our supply chains

Our supply chains includes the sourcing of Employees, Electronical equipment, PPE, Cleaning chemicals and work equipment.

Our policies on slavery and human trafficking

HotelCare is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. HotelCare Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk HotelCare: –

• We limit the geographical scope of our work sites to ensure optimum supervision of the use of our staff across business partnersproperties;
• Where possible we build long standing relationships with Business partners and new customers and make clear our expectations of businessbehaviour;
• With regards to national or international supply chains, our point contact is preferably with a UK company or branch and we expect these entities to have suitable anti- slavery and human trafficking policies and processes. We expect each entity in the supply chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the Supply chain
• Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour
• The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency
• We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.

Supplier / business partners adherence to our values

HotelCare have zero tolerance to slavery and human trafficking. We expect all those in our supply chain, contractors and business partners to comply with our values.

The Divisional Directors, HR Director and Procurement manager are responsible for compliance in their respective departments and for their supplier, business partner relationships.

Training & information

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we aim to provide training to relevant members of staff. All Directors have been briefed on the subject.

The Company requires all staff within the organisation to complete training on modern slavery.

As well as training staff, the organisation has raised awareness of modern slavery issues by distributing flyers to staff/putting up posters at the hotels where the Company delivers services.

Our effectiveness in combating slavery and human trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• Completion of In-House Audits by Divisional Directors, Operations Managers and RecruitmentManagers;
• Use of labour monitoring and payroll systems;and
• Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and alongside our policy constitutes HotelCare’s slavery and human trafficking statement for the current financial year.

Corporate & Social Responsibility Policy

Applicable to Hotelcare

Hotelcare seeks to be a good corporate citizen in everything that it does. We have therefore determined to bring together our existing operating principles into one framework policy under the heading of Corporate Social Responsibility (CSR).

The principles encompassed in this policy cover all areas of the Group’s operations and have been developed and continue to be reviewed

Hotelcare’s Managing Director supports the principles set out in those codes and standards and the aim of this policy is to translate that support into a set of guidelines and standards that set a common approach for Hotelcare and provide practical guidance for our managers and employees on the ground.

Compliance, monitoring and reporting

Compliance with this policy will be continuously monitored and subject to review by the Directors. Each local manager is responsible for ensuring that the principles set out in this policy are communicated to, understood and observed by all employees and for ensuring compliance in their area of responsibility. Employees who reasonably suspect that there has been a breach of this policy must report it to their line manager, senior management. We recognize that employees may be reluctant to report concerns for fear of retaliation and will take disciplinary action against any employee who threatens or engages in retaliation, retribution or harassment of any person who has reported or is considering reporting a concern in good faith. Hotelcare will not criticize management for any loss of business resulting from adherence to the principles set out in this policy. All sections of this policy are underpinned by the Group’s Code of Business Ethics, which is set out in Section 1. The other areas covered by this policy are Health and Safety and Security (Section 2), Employment (Section 3), Customer and Community (Section 4) and Environment (Section 5).

Code of business ethics

This Code of Business Ethics sets out the standards we expect from our employees in their internal and external dealings with colleagues, customers and third parties.

BASIC STANDARDS OF CONDUCT

• We will conduct every aspect of our business with honesty, integrity and openness, respecting human rights and the interests of our employees, customers and third parties.
• We will respect the legitimate interests of third parties with whom we have dealings in the course of our business.
• We will maintain the highest standards of integrity – for example, we will not promise more than we can reasonably deliver or make commitments we cannot or do not intend to keep.

EMPLOYEES

We are committed to:

• Developing a workforce where there is mutual trust and respect, free from bullying and harassment, where every person feels responsible for the performance and reputation of our company.
• Respecting the rights of individuals their customs and traditions and their right to freedom of association and the right to decide whether or not to join a trade union. We will negotiate in good faith with properly elected representatives of our employees.
• Recruiting, employing and promoting employees on the basis of objective criteria and the qualifications and abilities needed for the job to be performed in line with our Equal Opportunities Policy.
• Maintaining good communications with employees through our information and consultation procedures.
• Providing our employees with suitable training and assisting them in realizing their potential
• Ensuring the privacy and confidentiality of our employees’ personal information is respected.
• Suitably rewarding for our employees for their contribution to the success of the business.
• Providing mechanisms whereby employees can raise legitimate concerns confidentially regarding malpractice and ensuring no one will be victimized for a report made in good faith.
• Seeking to protect our employees from third party abuse that might be injurious to their safety, health or well-being.

BUSINESS INTEGRITY

• We aim to develop strong relationships with our clients, suppliers and others with whom we have dealings, based on mutual trust, understanding and respect.
• In those dealings, we expect those with whom we do business to adhere to business principles consistent with our own.
• We will conduct our operations in accordance with the principles of fair competition and applicable regulations.
• Hotelcare’s accounting and other records and supporting documents must accurately describe and reflect the nature of the underlying transactions.
• We will comply with the laws and regulations applicable wherever we do business. We will obtain legal advice where felt necessary to comply with this commitment.
• We will review and track our business risks including social and environmental risks.
• Hotelcare will not facilitate, support, tolerate or condone any form of money laundering.

PERSONAL CONDUCT

• All employees are expected to behave in accordance with the principles set out in this Code of Business Ethics.
• Employees are expected to protect and not misuse company assets such as buildings, vehicles, equipment, cash, etc.
• Employees are expected to use e-mail, internet, IT and telephones in a manner appropriate for business purposes

BRIBERY

• No Hotelcare employee or individual or business working on our behalf must accept or give a bribe, facilitation payment or other improper payment for any reason.
• This applies to transactions with government officials, any private company or person anywhere in the world. It also applies whether the payment is made or received directly or through a third party.

GIFT, ENTERTAINMENT AND IMPROPER PAYMENTS

• Accepting or giving any entertainment or gift that is designed to, or may be seen to influence business decisions, is not acceptable. No employee shall offer, give, seek or receive, either directly or indirectly, inducements or other improper advantages for business or financial gain.
• Any gift or hospitality given or received by an employee of Hotelcare should be reported for inclusion to the Hotel Management and Hotelcare’s Management. In the UK this applies to any gift or hospitality with an estimated or actual value of £50 or more.

CONFLICTS OF INTEREST

• Whilst we respect the privacy of our employees, all Hotelcare employees are expected to avoid personal relations, activities and financial interests, which could conflict with their responsibilities to Hotelcare
• Hotelcare employees must not seek gain for themselves or others through misuse of their positions or company property.
• All actual and potential conflicts (including those arising from the activities or interests of close relatives or partners) should be disclosed to and discussed with an employee’s line manager.
• Employees who have access to price sensitive information are prohibited from being involved in dealings unless given clearance by the Director or the Operations Manager. There should be no unauthorized disclosure of price sensitive information to third parties.

CONFIDENTIALITY

Information received by anyone in the course of his or her employment must not be used for personal gain or for any purpose other than that for which it was given. Where confidential information is obtained in the course of business that confidentiality must be respected.

HEALTH AND SAFETY

• We are committed to creating and maintaining a safe and healthy working environment for our employees, customers and the community.
• Our commitment to ensuring the safety and security of our employees is set out in our Injury Prevention and Security policies.
• We strive to avoid emergency situations but recognize the need to be prepared. We are committed to having effective emergency response procedures in place.

CUSTOMERS

• Hotelcare is committed to providing safe, value for money, high quality, consistent, accessible and reliable services to its customers.
• All employees are expected to behave respectfully and honestly in all their dealings with customers and the general public
• In particular we will safeguard and protect our employees welfare. Employees will be made aware that they hold a position of trust and that they must at all times maintain the highest standards of personal conduct that reflects this trust being placed with them.

SUPPLY CHAIN

• We provide services to a wide range of goods and services required in the operation of our business and we also rely heavily on a number of key suppliers for the delivery of our core services. Good working relationships with our suppliers are therefore central to the success of our business.
• Whilst we are committed to obtaining and retaining competitive goods and services we will at the same time seek to ensure they are from sources that have not jeopardized human rights, safety or the environment.
• We expect our clients to adhere to business principles consistent with our own. We expect them to adopt and implement acceptable safety, environmental, product quality, human rights, social and legal standards
• We will seek to work with our clients to develop long-term meaningful relationships to benefit both parties with the aim of improving the quality, environmental performance and sustainability of goods and services.

HEALTH AND SAFETY POLICY – GENERAL STATEMENT

Injury Prevention is our commitment to health and safety at Hotelcare. It is our core value and part of our way of life and applies to everything we do. Its purpose is to ensure the health and safety of all our employees, safety of our customers and safety of others affected by our businesses.

We believe that:

• All injuries are preventable, and
• Our goal is zero injuries

RESPONSIBILITY

Injury Prevention is the responsibility of every employee and working safely is a condition of employment. Managing Directors and the Operation managers must ensure that all their staff are safe at all times by ensuring:

• Our Injury Prevention processes are properly organized and appropriately resourced;
• Staff are given information, instruction and training on risk assessment and Injury Prevention;
• There is full compliance with Health and Safety laws
• Performance targets are set for continual improvement in Injury Prevention.

Employment

EQUAL OPPORTUNITIES AND DIVERSITY POLICY

Hotelcare’s Director is committed to equality of opportunity both in the provision of services to the public and as an employer. This policy sets out Hotelcare’s commitment to treat equally and with fairness at all times its employees, customers, contractors and those who come into contact with the company.

We are committed to seeking continuous improvement and compliance with legislation based on the following principles.

• Everyone has the right to be treated with dignity and respect.
• We will not discriminate on the grounds of race, gender, disability, nationality, religion, philosophical belief, political belief, age, sexual orientation, family status, trade union activity or any other factor.
• We will adopt fair and inclusive practices throughout our operations and will seek to eliminate all prejudice, discrimination, bullying and harassment.
• All employees have a personal responsibility for the practical application of this policy in their day-to-day activities and must support the policy at all times.
• Non-compliance with this policy will be treated seriously and will not be tolerated.

The Managing Director is required to ensure:

• They create a productive and safe working environment, promoting diversity and inclusion in their workforce;
• They develop new practices, as appropriate, to ensure all employees, contractors and customers are treated fairly; and
• They can demonstrate continuous improvement in practices to promote diversity and equal opportunities for all.

Recruitment 

All recruitment will be carried out with regard to fairness, equality and consistency for all candidates at all times. Recruitment practices will be inclusive and we will endeavour to ensure there are no barriers to employment of suitable candidates.

Staff Training

We will provide our staff with the necessary guidance and training to ensure the effective implementation of this policy and to ensure we are an inclusive employer and service provider.

Complaints

Any employee who feels that he or she has grounds for complaint in relation to bullying, discrimination, harassment or victimization has the right to pursue the complaint through our grievance procedures. Customers who feel they have grounds for complaint may pursue these through our operating company customer complaints procedures. We will ensure our complaints/feedback procedures can be accessed and used by everyone.

HUMAN RIGHTS

Hotelcare will adhere to the following principles in respect of our staff.

• We will treat all employees fairly and honestly, regardless of where they work. All staff will have agreed terms and conditions in accordance with local law or practice and will be given appropriate job skills training.
• We will pay a fair wage reflecting local markets and conditions. We will always meet any national minimum wage.
• Working hours shall not be excessive. They shall comply with industry guidelines and national standards where they exist.
• We will not employ illegal child labour, forced or bonded labour or condone illegal child labour.
• Employees have the rights of freedom of association and collective bargaining. We respect the right of our employees to choose whether or not to join a trade union without influence or interference from management. Furthermore we support the right of our employees to exercise that right through a secret ballot.
• We will negotiate in good faith with the properly elected representatives of our employees.
• We will abide by the non-discrimination laws in every country where we operate.
• We will not use or condone the use of corporal punishment, mental or physical coercion or verbal abuse. We have disciplinary procedures for any member of staff whose conduct falls below the required standard.
• We have formal grievance procedures through which staff can raise personal and work-related issues.

DATA PROTECTION

We will comply with the relevant principles governing data protection in each country in which we operate.

Customer and community

CUSTOMERS

Customer Service: Delivering our promise to our customers is one of our core values. Our commitment is to provide safe, reliable, customer focused, innovative and sustainable transport services.

We will:

• act in accordance with fair business, marketing and advertising practices and take all reasonable steps to ensure the safety of our services
• respect the human rights of our customers
• provide transparent and effective procedures that address customer complaints and contribute to fair and timely resolution of disputes without undue cost or burden
• respect customer privacy and provide protection for personal data in accordance with the relevant law.

Environmental Policy

April 2023

Introduction

As a provider of Facilities Management services to the hospitality industry, HotelCare works with clients across the UK at a wide variety of locations. As a large company with a high level of colleagues, we depend on each other at work so that we can provide great services to all our clients.

All of the HotelCare management team and employees at every level, support and are committed to the concept of environmental management as set out in this policy. This includes protecting natural resources, promoting environmental stewardship, and implementing environmental best practices.

The company is committed to integrating environmental best practice into all its business activities. The company accepts its environmental responsibilities and recognises its obligation to reduce the impact of business activities on the environment. The company will achieve this through a policy of continual improvement in environmental performance.

Who this policy is for

All employees of HotelCare in both Support Service Office and in Sites. It is the responsibility of each employee;

• for his/her adherence to the principles of this policy
• to read and understand the contents of this policy

Any concerns employees may have regarding this policy should seek clarification from the HotelCare Risk Department.

To achieve these objectives, the company will:

• Continually improving our environmental management performance through procedures established in the HotelCare Health and Safety and Environmental committee meetings
• Developing Environmental Management plans with objectives and targets to minimize adverse environmental impacts and measure our progress towards these goals.
• Minimising the impact on natural environment, through the use of non-hazardous chemicals, environmental friendly work practices and trained staff
• Complying with all applicable laws, regulations and other requirements
• Providing all HotelCare staff with the knowledge, skills and tools needed to prevent negative environmental impacts
• Implementing effective pollution prevention and waste minimisation programs to reduce, reuse and recycle materials at all company sites and in cooperation with our clients on their sites where HotelCare staff are employed.
• Ensuring that energy and water are used responsibly.
• Responding to all incidents immediately to minimise any environmental impact.

The contents of this policy and the way in which it is being implemented will be reviewed annually. Next update due April 2024.

Equal Opportunities Policy

Introduction

Who this policy is for

The law

Types of unlawful discrimination

Equal opportunities in employment

Dignity at work

CUSTOMERS, SUPPLIERS AND OTHER PEOPLE NOT EMPLOYED BY THE COMPANY

TRAINING

YOUR RESPONSIBILITIES

GRIEVANCES

MONITORING AND REVIEW

GDPR – Employee Privacy

The company collects and processes personal data relating its employees to manage the employment relationship. The company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What Information does the Company Collect?

The company collects and processes a range of information about you. This includes;

• your name, address and contact details, including email address and telephone number, date of birth and gender;
• the terms and conditions of your employment;
• details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with the company;
• information about your remuneration, including entitlement to benefits such as pensions or insurance cover;
• details of your bank account and national insurance number;
• information about your marital status, next of kin, dependants and emergency contacts;
• information about your nationality and entitlement to work in the UK;
• information about your criminal record;
• details of your schedule (days of work and working hours) and attendance at work;
• details of periods of leave taken by you, including holiday, sickness absence, family leave and sabbaticals, and the reasons for the leave;
• details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence;
• assessments of your performance, including appraisals, performance reviews and ratings, training you have participated in, performance improvement plans and related correspondence;
• information about medical or health conditions, including whether or not you have a disability for which the company needs to make reasonable adjustments;
• details of trade union membership; and
• equal opportunities monitoring information, including information about your ethnic origin, and health.

The company collects this information in a variety of ways. For example, data is collected through application forms, CVs or resumes; obtained from your passport or other identity documents such as your driving licence; from forms completed by you at the start of or during employment (such as benefit nomination forms); from correspondence with you; or through interviews, meetings or other assessments.

In some cases, the company collects personal data about you from third parties, such as references supplied by former employers, information from employment background check providers, information from credit reference agencies and information from criminal records checks permitted by law.

Data is stored in a range of different places, including in your personnel file, in the company’s DPR management systems and in other IT systems (including the company’s email system).

Why does the company process personal data?

The company needs to process data to enter into an employment contract with you and to meet its obligations under your employment contract. For example, it needs to process your data to provide you with an employment contract, to pay you in accordance with your employment contract and to administer benefit, pension and insurance entitlements where applicable.

In some cases, the company needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee’s entitlement to work in the UK, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled.

In other cases, the company has a legitimate interest in processing personal data before, during and after the end of the employment relationship. Processing employee data allows the company to;

• run recruitment and promotion processes;
• maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights;
• operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace;
• operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes;
• operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled;
• obtain occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled;
• operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that the company complies with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled;
• ensure effective general HR and business administration;
• provide references on request for current or former employees;
• respond to and defend against legal claims; and
• maintain and promote equality in the workplace.

Some special categories of personal data, such as information about health or medical conditions, is processed to carry out employment law obligations (such as those in relation to employees with disabilities and for health and safety purposes).

Where the company processes other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring.

Who has access to data?

Your information will be shared internally, including with members of the Payroll, HR and recruitment team, your line manager, managers in the business area in which you work and IT Service Provider if access to the data is necessary for performance of their roles.

The company on occasions shares your data with third parties in order to obtain pre-employment references from other employers, obtain employment background checks from third-party providers and obtain necessary criminal records checks from the Disclosure and Barring Service. The company may also share your data with third parties in the context of a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.

The company also shares your data with third parties that process data on its behalf, in connection with payroll, the provision of benefits and the provision of occupational health services, Heart or Workplace and in some instances Right to Work or contract verification by our clients.

The company will not transfer your data to countries outside the European Economic Area.

How does the company protect data?

The company takes the security of your data seriously. The company has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.

Where the company engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and company measures to ensure the security of data.

For how long does the company keep data?

The company will hold your personal data for the duration of your employment. The periods for which your data is held after the end of employment are set out relevant retention periods i.e Payroll files are kept for 6 years after which they are destroyed.

Your rights

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data
• receive training on the above & GDPR will also be given
• require the company to change incorrect or incomplete data;
• require the company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where the company is relying on its legitimate interests as the legal ground for processing; and
• ask the company to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the company’s legitimate grounds for processing data.

If you would like to exercise any of these rights, you can make a Subject Access Request by completing the company’s subject access request forms via Human Resources at [email protected]

If you believe that the company has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You have some obligations under your employment contract to provide the company with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide the company with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.

Certain information, such as contact details, your right to work in the UK and payment details, have to be provided to enable the company to enter a contract of employment with you. If you do not provide other information, this will hinder the company’s ability to administer the rights and obligations arising as a result of the employment relationship efficiently.

What is your responsibility while working at Hotelcare?

Everyone who works for HotelCare has responsibility for ensuring data is collected, stored and handled appropriately,andthatishandledandprocessedinlinewiththispolicyanddataprotectionprinciples.

These people have key areas of responsibility:

The Data Controller determines the purposes and means of processing personal data for Hotelcare and that it meets its legal obligations. The Data Processor i.e. Head Housekeeper or Operations Manager is responsible for processing the data on behalf of the Data Controller. You must take all reasonable steps to safeguard your data, other employee and company data.

• You must follow all company policies and procedures in regards to GDPR and data related matters at all times
• You must not share data with unauthorised persons
• You must not share your password with unauthorised persons including fellow colleagues
• You must no use another person’s passwords
• You must not access data if you are not authorised to do so
• You must control and restrict data sharing with any person who require or have authorisation to see and use such data
• You must ensure the safeguard removal and/or deletion of such data as soon as possible (hard copy data to be destroyed in line with company policy)
• You must report any breach of data (hard copy or electronic) within 12 hours to the you Data Controller
• You must report any loss of equipment (laptop, company phones or actual data) within 12 hours to your Data Controller

Other rights

Individuals have a number of other rights in relation to their personal data. They can require the organisation to:
• rectify inaccurate data;
• stop processing or erase data that is no longer necessary for the purposes of processing;
• stop processing or erase data if the individual’s interests override the organisation’s legitimate grounds for processing data (where the organisation relies on its legitimate interests as a reason for processing data);
• stop processing or erase data if processing is unlawful; and
• stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override the organisation’s legitimate grounds for processing data.

To ask the organisation to take any of these steps, the individual should send a written request to [email protected]

Data security

The organisation takes the security of personal data seriously. The organisation has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse, or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties. The business will identify and restrict who has access to the stored data. Other managers requiring access will have to state their reasons for viewing the requested documents; access will only be given if necessity if proven.
Where the organisation engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

Impact Assessments

Some of the processing that the organisation carries out may result in risks to privacy. Where processing would result in a high risk to individual’s rights and freedoms, the organisation will carry out a data
protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

Data breaches

If the organisation discovers that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, it will be reported to the Information Commissioner within 72 hours of discovery. The organisation will record all data breaches regardless of their effect.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

HC Facility Management Ltd (trading as HotelCare LTD) Privacy Policy

About this Policy.

The purpose of this policy is to make you aware of how we will handle your personal data as a client of HotelCare Ltd.  This policy is for clients and customers who we provide our services to.

During the course of our activities we, HotelCare Ltd, will process personal data about our clients and we recognise the need to treat it in an appropriate and lawful manner, in accordance with the UK General Data Protection Regulation (UK GDPR).

Personal data refers to recorded information that we hold about you from which you can be directly or indirectly identified.

The type of personal information we collect.

We collect and process the following personal information:

• Individual’s identification and contact information including; full name, phone number, personal address, Gender, Nationality and email address or equivalent.
• Individual’s emergency contact details, name, email and telephone number.
• Company’s identification and contact information including; name of the company, business address, email address, contact number, responsible person/s and job positions.
• Financial information including; credit and debit card information including card number, expiry date and CVV code, card holder name, financial transactions or equivalent, invoices and details about what products and/or services you have purchased.
• Location and Site Information including; residence at time of providing our services, location access details; e.g. key or code details.
• Written agreement/s between the client and us.
• Correspondence between the client and us
• Information related to legal requirements including; customer due diligence, anti-money laundering requirements, accounting.

How we collect the personal information and why we have it.

Most of the personal information we process is provided to us directly by yourself for one of the following reasons:

• To provide our services and fulfil our contractual agreement with you.
• To verify your identify and business details if applicable.
• To ensure an open line of communication for our services and if any queries arise for legitimate purposes.
• To ensure payment is met for the service.
• To comply with any applicable laws and meet legal obligations.

We also receive personal information indirectly from Zettle for the purpose of providing apartment services.  We collect your name, location, and email address for this purpose. 

Zettle’s privacy policy can be found here:  https://www.zettle.com/gb/legal/privacy-policy.

We use the information that you have given us directly or indirectly in order to carry out the contracted service that you have requested. 

You are under a contractual obligation to provide the personal data that we require to provide our service.  If you do not provide us with personal data then we will be unable to provide your contracted service. If you withdraw your consent to process your personal data then out agreement will subsequently be terminated.

We will not share any personal information with any third parties without your consent unless we are satisfied that they are legally entitled to the data. 

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

Our contractual obligation.

We have a legitimate interest.

Our legal obligation
How we store your personal information.

We always process personal data in accordance with applicable laws and regulations, and we have implemented appropriate technical and organizational security measures to prevent that your personal data is used for non-legitimate purposes or disclosed to unauthorized third parties and otherwise protected from misuse, loss, alteration or destruction.

The technical and organizational measures that we have implemented are designed to ensure a level of security appropriate to the risks that are associated with our data processing activities, in particular accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your personal data including access control to premises, facilities, systems and data, disclosure control, input control, job control, availability control and segregation control.

How long do we store your personal data?

We will not process personal data for a longer period than is necessary for fulfilling the purpose of such processing, as set out in this Privacy Policy. We only retain your personal data to ensure compliance with our legal and regulatory requirements. Your personal data will be anonymised or deleted once it is no longer relevant for the purposes for which it was collected.

This means that we as an example will only keep your data for as long as necessary for the performance of a contract and as required by applicable laws. If we keep your data for other purposes than those of the performance of a contract, such as anti-money laundering purposes, bookkeeping and regulatory capital adequacy requirements, we keep the data only if necessary and/or mandated by laws and regulations for the respective purpose.

We keep your name, Telephone number, email address and address for the below for examples of the retention periods that we apply:

• Preventing, detecting and investigating money laundering, terrorist financing and fraud: minimum five (5) years after termination of the business connection.
• Bookkeeping regulations: seven (7) financial years.

We will then dispose your information by deleting this from our records and systems as all data is collected from you the customer and secured electronically on our website and servers.Your data protection rights.

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances unless they come into conflict with other policies set into this Privacy Policy.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at [email protected] if you wish to make a request.

How may we change this Privacy Policy?

We are constantly working on improving and developing our services, products and websites, so we may change this Privacy Policy from time to time. We will not diminish your rights under this Privacy Policy or under applicable data protection laws in the jurisdictions in which we operate. If the changes are significant, we will provide a more prominent notice, when we are required to do so by applicable law. Please review this Privacy Policy from time to time to stay updated on any changes.

How to complain or contact us.

Our contact details:

Name: Joseph Costello

Address: HotelCare, 5th Floor, 14-16 Dowgate Hill, London, EC4R 2SU.

Website: www.hotelcare.co.uk  

E-mail: [email protected]  

If you wish to make a subject access request or if you have any concerns or complaints about our use of your personal information, you can contact us at [email protected] or in writing to HotelCare, 5th Floor, 14-16 Dowgate Hill, London, EC4R 2SU.

You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data.

The ICO’s contact details:

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Gender Pay Gap Report 2023

HC FACILITY MANAGEMENT LIMITED (trading as HotelCare)

HotelCare is the market leading outsourced Housekeeping Company for top hotel collections and independently owned hotels across the United Kingdom.
Our  commitment is to provide a professional service carried out by thoroughly trained staff. This dedication has led to long-standing relationships with top hotel chains and brands as well as independently owned franchises and stand-alone properties across the UK.

Due to the nature of our industry, we have a higher percentage of woman in our work force, as 83% of our staff identify as Female.

We have a high percentage of women in the top quartile, highest-paid jobs at 85%.
We also have a high percentage of women in the lower middle quartile, lower-paid jobs at 80%.

Therefore, this reflects on the overall mean and median, as we have now more women in senior management roles.

As of the snapshot date below, we had a position of 112 Senior Managerial roles, 103 occupied by women while 9 by men which comes to 92% of Managerial roles filled by women.

This report and figures below are the snapshot of our employees as of the 5th April 2023.

Women’s mean hourly rate is 1.08% higher than men’s.
Our Median gender pay gap of Women to Men is -1.66%.
We can confirm that no staff received bonus pay either Women or Men during the snapshot period.

What is HotelCare doing to address its gender pay gap?
 

The median rate was 0% but is now -1.67%, showing a change in higher rate for female staff but also reflecting the nature of our business as only 17% of our staff identify as male.

HotelCare is never complacent and we are still committed to doing everything that we can to reduce the gap even further. However, HotelCare also recognizes its scope to act, is limited in some areas – it has, for example, no direct control over the subjects that individuals choose to study or the career choices they make.

Supporting Those Wishing To Progress: We are currently making use of our Apprenticeship levy to help run various Apprenticeship schemes, which is available to all members of HotelCare, helping them progress with their careers from entry to senior level. As quite a few of our Senior Management Team started out in entry roles within HotelCare.

Flexible Working Policy: HotelCare has a Flexible Working Policy that is available to all levels of it staff from room attendant to Senior management, regardless of part time or full-time employment. This has been achieved we believe as it has enabled employees to arrange their work around their other commitments.

Declaration

We are still committed to reducing our gender pay gap and providing greater opportunities for women to progress into senior positions. HotelCare has increased its percentage of Women in senior roles, from 2022s figure of 90% to now 92%.
I confirm the information in this statement is accurate to the best of my knowledge at the time of production.

Joseph Costello,

Head of Payroll, Benefits & Data Analysis Services

Health & Safety

Hotelcare Health and Safety Policy Statement

• To take reasonable care of our own safety
• To take reasonable care of the safety of others who may be affected by what we do or fail to do
• To co-operate so that we can all comply with our legal duties
• To ensure we do not interfere with or misuse anything provided in the interests of health and safety.