Policies

1. Policy Statement

Eyes 4 Positivity CIC (“the Organisation”) is committed to safeguarding and promoting the welfare of vulnerable adults who engage with our services, activities, and programmes.

The Organisation recognises its statutory and moral duty of care to protect vulnerable adults from abuse, neglect, and exploitation and to act promptly where safeguarding concerns arise.

Eyes 4 Positivity

• Adopts a zero-tolerance approach to abuse and neglect
• Promotes a culture of vigilance, accountability, and transparency
• Ensures safeguarding responsibilities are clearly defined and understood

Safeguarding is the responsibility of all directors, staff, volunteers, contractors, and associates.

2. Scope of the Policy

This policy applies to:

• All activities, services, and projects delivered by Eyes 4 Positivity CIC
• All vulnerable adults who access or are impacted by our work
• All individuals working for or on behalf of the Organisation

This policy should be read alongside:

• Safeguarding Procedures
• Code of Conduct
• Whistleblowing Policy
• Safer Recruitment Policy
• Data Protection Policy
• 
  

3. Legal and Regulatory Framework

This policy complies with and is informed by the following legislation and guidance (England):

• Care Act 2014 and Care and Support Statutory Guidance
• Mental Capacity Act 2005
• Safeguarding Vulnerable Groups Act 2006
• Human Rights Act 1998
• Equality Act 2010
• Data Protection Act 2018 and UK GDPR
• Working Together to Safeguard Adults (where applicable)
• 
  

4. Definition of a Vulnerable Adult

For the purposes of this policy, a vulnerable adult is any person aged 18 or over who:

• Has needs for care and support (whether or not these are met), and
• Is experiencing, or is at risk of, abuse or neglect, and
• Is unable to protect themselves from abuse or neglect due to those needs

The Organisation recognises that vulnerability may be temporary, fluctuating, or long-term.

5. Categories of Abuse and Neglect

Safeguarding concerns may include, but are not limited to:

• Physical abuse
• Domestic abuse
• Sexual abuse
• Psychological or emotional abuse
• Financial or material abuse
• Modern slavery
• Discriminatory abuse
• Organisational abuse
• Neglect and acts of omission
• Self-neglect

6. Safeguarding Principles

Eyes 4 Positivity adheres to the six statutory safeguarding principles:

1. Empowerment
2. Prevention
3. Proportionality
4. Protection
5. Partnership
6. Accountability

7. Governance and Accountability

Directors / Senior Management

• Hold ultimate accountability for safeguarding within the Organisation
• Ensure effective safeguarding systems, policies, and procedures are in place
• Ensure safeguarding risks are identified and managed
• Review safeguarding performance and incidents

Designated Safeguarding Lead (DSL)

The Organisation will appoint a Designated Safeguarding Lead who will:

• Act as the primary safeguarding authority within the Organisation
• Receive and assess safeguarding concerns
• Make referrals to Local Authority Safeguarding Adults Teams
• Liaise with statutory agencies
• Maintain secure and confidential safeguarding records
• Report safeguarding matters to Directors as appropriate

Staff, Volunteers, and Contractors

All personnel must:

• Comply with this policy and associated procedures
• Undertake safeguarding training commensurate with their role
• Maintain clear professional boundaries
• Report safeguarding concerns immediately

8. Safer Recruitment and Workforce Management

Eyes 4 Positivity CIC operates safer recruitment practices including:

• Role-appropriate DBS checks for regulated activity
• Verification of identity, qualifications, and references
• Clear role descriptions and codes of conduct
• Safeguarding responsibilities included in induction

9. Responding to Safeguarding Concerns

Where a safeguarding concern involving a vulnerable adult is identified:

1. Immediate action
   • Emergency services will be contacted if there is immediate risk

1. Reporting
   • All concerns must be reported to the Designated Safeguarding Lead without delay

1. Recording
   • Concerns will be recorded factually, accurately, and securely

1. Decision-making and referral
   • The DSL will determine whether a referral to the Local Authority is required

The Organisation will act in a timely, proportionate, and lawful manner at all times.

10. Mental Capacity and Consent

The Organisation presumes capacity unless proven otherwise and will apply the Mental Capacity Act 2005.

Where capacity is in question:

• A best-interests approach will be taken
• Advocacy and support will be considered

Safeguarding action may proceed without consent where:

• There is a serious risk of harm
• A criminal offence may have occurred
• Others may be at risk

11. Information Sharing and Confidentiality

• Information will be shared on a lawful, proportionate, and need-to-know basis
• Records will be stored securely in line with data protection legislation
• Confidentiality will be breached where necessary to protect a vulnerable adult or others

12. Allegations Against Staff, Volunteers, or Contractors

Any allegation or concern involving a person working for or on behalf of the Organisation will be:

• Treated as a safeguarding matter
• Managed promptly and impartially
• Referred to statutory bodies where required
• Addressed through internal procedures

13. Whistleblowing

The Organisation encourages the reporting of concerns about unsafe or unethical practice.

Whistleblowers will be protected from victimisation or retaliation.

14. Monitoring, Review, and Continuous Improvement

Eyes 4 Positivity CIC will:

• Monitor safeguarding practice and compliance
• Review this policy annually
• Update the policy in response to legislative or organisational change
• Review safeguarding arrangements following serious incidents

15. Key Contacts (to be completed)

• Designated Safeguarding Lead:
• Deputy Safeguarding Lead:
• Local Authority Safeguarding Adults Team:
• Emergency Services: 999

Last updated: 8th February 2026

Eyes 4 Positivity (“we”, “us”, “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data when you interact with us online, by phone, messaging services, or in person.

1. Who We Are

Organisation name: Eyes 4 Positivity

Legal status: UK Non-Profit Organisation

Registered address:16 Chaldon Road, London, SW6 7NJ

Contact email: info@eyes4positivity.co.uk

Website: www.eyes4positivity.co.uk

For the purposes of the UK General Data Protection Regulation (UK GDPR), Eyes 4 Positivity is the data controller.

2. How We Collect Personal Data

We collect personal data through:

• Our website (forms, class or outing purchases, enquiries)
• Telephone calls
• WhatsApp messages
• Text messages and emails
• In-person conversations, meetings, and events
• Class or outing bookings, made online or in person

3. What Personal Data We Collect

Depending on how you interact with us, we may collect:

a) Contact & Identity Information

• Name
• Email address
• Telephone number
• Postal address (if required)

b) Booking & Purchase Information

• Classes or outings booked
• Dates and attendance details
• Payment amounts and transaction references

(We do not store full debit/credit card details.)

c) Communication Information

• Messages sent via WhatsApp, phone, email, website forms
• Notes from in-person conversations, meetings, or events (where relevant)

d) Event & Participation Information

• Attendance records
• Accessibility or support requirements (only if provided voluntarily)

e) Technical Information (Website Users)

• IP address
• Browser type
• Cookies and basic analytics data

4. How We Use Your Personal Data

We use your data to:

• Respond to enquiries and communications
• Manage bookings for classes and outings
• Process payments and keep financial records
• Organise meetings and events
• Communicate important information related to services you have purchased
• Improve our services and website
• Meet legal, safeguarding, and regulatory obligations

5. Lawful Basis for Processing

We process personal data under the following lawful bases:

• Consent – where you have given clear permission (e.g. follow-up contact)
• Contract – to provide classes, outings, or services you purchase
• Legal obligation – accounting, safeguarding, or regulatory requirements
• Legitimate interests – operating and promoting our non-profit activities, provided your rights are not overridden

6. Payments and Financial Data

Payments made through our website or in person are processed securely via trusted third-party payment providers.

We retain:

• Transaction references
• Amounts paid
• Dates of payment

We do not store full card or bank details.

Booking & Cancellation Data

When you book a class or outing with Eyes 4 Positivity—either through our website or in person—we collect and process personal data necessary to manage your booking.

What Data We Collect for Bookings

This may include:

• Your name and contact details
• Details of the class or outing booked
• Dates, times, and attendance records
• Payment and transaction references
• Any information you provide relating to accessibility or support needs

How We Use Booking Data

We use this information to:

• Confirm and manage your booking
• Communicate important updates or changes
• Manage attendance and safeguarding requirements
• Process cancellations, refunds, or rescheduling
• Maintain accurate financial and participation records

Cancellations, Refunds, and Changes

If you cancel a booking or if an event is cancelled or rescheduled by us:

• We will retain relevant booking and transaction data to manage refunds, credits, or rebooking
• Financial records will be retained as required for accounting and legal purposes
• Communication relating to cancellations may be retained for audit or dispute resolution

Retention of Booking Data

Booking and cancellation data is retained only for as long as necessary to:

• Deliver the service
• Meet legal, safeguarding, and financial obligations
• Resolve queries or disputes

After this period, data is securely deleted or anonymised.

Lawful Basis

Booking and cancellation data is processed under:

• Contract – to provide the class or outing you have booked
• Legal obligation – for financial and regulatory compliance
• Legitimate interests – to manage our services fairly and effectively
  

7. How We Store and Protect Your Data

We take appropriate security measures, including:

• Password-protected systems
• Limited access to personal data
• Secure handling of paper records (where used)
• Use of trusted digital platforms

We keep personal data only as long as necessary for the purposes it was collected or as required by law.

8. Sharing Your Data

We do not sell your personal data.

We may share data with:

• Payment processors
• IT, booking, or communication service providers
• Legal or regulatory authorities if required

All third parties are required to keep your data secure and confidential.

9. Your Rights Under UK GDPR

You have the right to:

• Access your personal data
• Request corrections
• Request deletion of your data
• Restrict or object to processing
• Withdraw consent at any time
• Request data portability

To exercise your rights, contact us at [insert email].

10. Cookies

Our website uses cookies to improve functionality and analyse usage.

You can manage cookies through your browser settings.

11. Children and Young People

Where activities involve children or young people, personal data is handled with additional care and, where required, parental or guardian consent.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our website.

13. Complaints

If you have concerns about how we handle your data, you may contact us directly or complain to the UK Information Commissioner’s Office (ICO):

Website: https://www.ico.org.uk

Helpline: 0303 123 1113