1 INTRODUCTION
1.1 This Privacy Policy forms part of the Terms and covers the Active Neuro website which may be accessed via; https://active-neuro.co.uk/ (the “Website”) and the services provided through it. It describes how We collect, protect and use information We receive from Website visitors. The data controller for the Website is Active Neuro (“We”, “Us”, “Our” or “Active Neuro”) whose head office is at 3rd Floor, Mercury House, 117 Waterloo Road, London, SE1 8UL.
1.2 We will ensure that all personal and sensitive information provided by you is stored and processed in accordance with the Data Protection Act 2018 and the data protection and privacy principles set down in the General Data Protection Regulations 2018.
2 INFORMATION WE MAY COLLECT FROM YOU
2.1 You are able to access and browse our website without disclosing your personal data.
2.2 We may collect and process the following data from you:
(a) Information that you provide by filling in forms on our website; https://active-neuro.co.uk/ (our site). This includes information provided at the time of enquiring about our services, providing feedback, completing our contact form or through a job application.
(b) If you contact us, we may keep a record of that correspondence.
3 USE OF PERSONAL INFORMATION
3.1 We use the personal information We collect via the Website for the purposes of: (a) Providing, developing, improving and personalising our services and the Website. (b) Providing you with information about our services.
(c) Dealing with your enquiries and requests.
(d) Generating anonymous reports about use of the Website and its features. (e) Using your contact information for recruitment purposes.
4 SECURITY AND CONFIDENTIALITY
4.1 All of our employees who have access to and are associated with the processing of this data, are obliged to respect the confidentiality of such data in line with the Data Protection Act 2018 and the General Data Protection Regulations 2018.
4.2 Active Neuro safeguards the security of the personal information you provide to us with physical, electronic and managerial procedures. We use industry-standard Secure Sockets Layer (SSL) encryption on all pages where We collect personal information.
4.3 Any personal information you provide will be held securely and your personal information will not be sold or traded to third parties. In some circumstances We may need to disclose your personal information (i) to a third party to provide a service you have requested, (ii) to fulfil a request for information, (iii) to comply with a legal requirement or request from a competent court, regulator or other authority, or (iv) if We believe that there has been a violation of the Terms, of Our rights or the rights of any third party. Any information about you that We pass to a third-party service provider will be held securely by that party and used only to provide the services or information you have requested.
5 COOKIES
5.1 Cookies are small pieces of data sent to your computer when you visit the Website and which enable us to collect information about you. They are stored in the cookie directory of your hard-drive, and do not necessarily expire at the end of your session although session cookies are automatically deleted when you close your browser. The information We collect in this way may include data about how you use the Website, information about your computer (including your IP address and browser type), demographic data and, if you visited the Website by clicking on a link from a different website, the URL of that website. We may also collect information about your online activity, such as the pages you have viewed. Our use of cookies also allows registered users of the Website to be presented with a personalised version of the Website.
5.2 Although your browser may be set up to allow the creation of cookies, you can specify that you wish to be prompted before a website puts a cookie on your hard drive, so that you can decide whether to allow it. Alternatively, you can set your computer not to accept any cookies. Please refer to your browser instructions or help screen for information about how to do this. If you disable cookies, you may not have access to certain features that make your experience of the Website more efficient and some of our services may not function properly. Visitors who disable cookies can still make use of the website.
6 SOCIAL NETWORKING
6.1 Our Website may offer you the opportunity to share or follow information about the Website (or the products and/or services available through it) using third party social networking functionality (such as through “share this”, “like” or “follow” buttons).
6.2 We offer this functionality in order to generate interest in our website among the members of your social networks, and to permit you to share and follow opinions, news and recommendations about the Website with your friends. However, you should be aware that sharing personal or non-personal information with a social network may result in that information being collected by the social network provider or result in that information being made publicly available, including through Internet search engines.
6.3 Please note that We do not exercise any endorse or control the policies or practices of any third-party social network whose functionality you may access through Our Website. You should always read the privacy policy of any social network through which you share information carefully in order to understand their specific privacy and information usage practices.
7 ACCESS TO YOUR INFORMATION AND CONTACTING ACTIVE NEURO
7.1 You have the right to request a copy of the personal information Active Neuro holds about you and to have any inaccuracies corrected. Please address requests (with a return email address where possible) to either:
Data Protection Officer
3rd floor
Mercury House
117 Waterloo Road
London
SE1 8UL
7.2 Or address requests by email to: dpo@activecaregroup.co.uk
7.3 If you have a query or complaint about this Privacy Policy or about the Website, you can contact Us at dpo@activecaregroup.co.uk
8 LINKS TO EXTERNAL SITES FROM THE WEBSITE
8.1 The Website contains links to other websites, mainly government departments, but also to those of other third parties. These websites are not covered by this Privacy Policy and Active Neuro is not responsible for the privacy practices within any of these other websites. You should be aware of this when you leave the Website and we encourage you to read the privacy statements of other websites.
9 CHANGES TO THIS PRIVACY POLICY
9.1 If this Privacy Policy changes in any way, We will place an updated version on this webpage. If you do not agree with the changes We make please do not continue to use the Website. Regularly reviewing this webpage ensures you are always aware of what information We collect, how We use it and under what circumstances, if any, We will share it with other parties.
10 EQUALITY IMPACT STATEMENT
10.1 This policy has been equality impact assessed and we believe that it is in line with the Equality Act 2010 as it is fair, it does not prioritise or disadvantage any employee or applicant and it helps to promote equality in our services.
11 REFERENCES
11.1 Legislation
Data Protection Act 2018
General Data Protection Regulations 2018
1 INTRODUCTION
1.1 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 to exploit them for personal or commercial gain.
1.2 Active Neuro has a zero-tolerance approach to modern slavery and human trafficking, 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.
2 DEFINITIONS
2.1 Modern Slavery is a serious and often hidden crime in which people are exploited for criminal gain. The impact can be devastating for the victims.
2.2 The common factors are that a victim is, or is intended to be, used, or exploited for someone else’s (usually financial) gain without respect for their human rights under four broad categories of labour exploitation, domestic servitude, sexual exploitation, and criminal exploitation.
2.3 For adult victims there will be some element of coercion involved such as threats, use of force, deception, or abuse of power.
2.4 Victims may appear to give consent but in reality they have little ability to choose to leave the situation.
2.5 Child victims and vulnerable adults are not able to give informed consent and therefore exploitation even without any element of coercion could constitute modern slavery.
3 RESPONSIBILITIES
3.1 Active Neuro’s Executive Board have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under their control comply with it.
3.2 Active Neuro’s zero tolerance approach to modern slavery will be communicated to all suppliers, contractors, and business partners at the outset of any business relationship and reinforced as appropriate thereafter.
3.3 We do not enter business with any organisation which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.
4 REPORTING MODERN SLAVERY
4.1 Where a colleague suspects a case of modern slavery, this should be reported to their line manager or follow C&L09 Freedom to Speak Up Policy. Additionally, it should be reported by one of the following methods:
- Phoning 999 if there is an immediate risk of harm.
- Reporting to the police by calling 101 if there is no immediate risk of harm.
4.2 We aim to encourage openness and will support anyone who raises a genuine concern in good faith, even if they turn out to be mistaken.
5 BREACHES OF THE POLICY
5.1 Colleagues should be aware that if they are found to be operating under the definition of the Modern Slavery Act, they will be subject to disciplinary action which could result in their dismissal.
5.2 Active Neuro may terminate our relationship with other individuals or organisations working on its behalf if we believe a breach has occurred.
6 COMMUNICATION & AWARENESS
6.1 In accordance with Section 54 of the Modern Slavery Act 2015, Active Neuro will develop and post on the company’s website an annual Modern Slavery Statement setting out the steps taken to ensure modern slavery is not taking place in our business and/or our supply chains.
7 EQUALITY IMPACT STATEMENT
7.1 This policy has been equality impact assessed, and we believe that it is in line with the Equality Act 2010 as it is fair, it does not prioritise or disadvantage any employee or applicant, and it helps to promote equality in our services.
8 LEGISLATION
8.1 Modern Slavery Act 2015
9 ASSOCIATED DOCUMENTS
9.1 Modern Slavery Statement Modern Slavery Statement for Financial Year 2025/2026
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Active Neuro has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chains.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Active Neuro has a zero-tolerance approach to any form of modern slavery. 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 chains.
Our Policies
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- Modern Slavery Policy – This policy sets out the organisation’s stance on modern slavery and explains how colleagues can identify any instances of this and where they can go for help.
- Safer Recruitment Policy – We operate robust recruitment procedures, including conducting eligibility to work in the UK checks (prior to employment commencing and during employment when a re-check is required), for all colleagues to safeguard against human trafficking or individuals being forced to work against their will.
- Disciplinary Policy – We are committed to creating a culture and work environment, which is free from bullying, harassment, and victimisation, where everyone is treated with the utmost dignity and respect. Active Neuro will not tolerate bullying, harassment or victimisation of any kind. Any behaviour that undermines this aim is totally unacceptable and will be dealt with via our Disciplinary Policy.
- Equality, Diversity, and Inclusion Policy – We are committed to ensuring equality of opportunity for all colleagues irrespective of age, disability, sex, gender reassignment, sexual orientation, race, religion or belief, marital status and civil partnerships and aims to ensure all that all managers, colleagues and contractors are made fully aware of the behaviour that is and is not acceptable within the business.
- Freedom to speak Up Policy – We operate a robust policy and confidential hotline to ensure all colleagues know that they can raise concerns confidentially about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
- Anti-Bribery and Anti-Corruption Policy – This policy exists to set out the responsibilities of Active Neuro and those who work for us in regard to observing and upholding our zero-tolerance position on bribery and corruption. It also exists to act as a source of information and guidance for those working for our business it helps them recognise and deal with bribery and corruption issues and understand their responsibilities.
- Conduct Policy – This policy is intended to guide colleagues on the required standards of conduct within Active Neuro. It outlines the professional conduct expected of all colleagues.
Our Suppliers
Active Neuro operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes requesting to see their policy in relation to modern slavery as part of the tender process. Our Modern Slavery Policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.
In addition to the above, as part of our contract with suppliers, during new tenders we require that they confirm to us that:
- They have taken steps to eradicate modern slavery within their business. 2. They hold their own suppliers to account over modern slavery.
- (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate).
- (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations.
Reviews
We hold regular management meetings and reviews. We regularly check the internet for any bad news in relation to our suppliers, both during the tender process and for current suppliers.
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 colleagues, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.