Bullying and Harassment Policy
1. Policy Statement
Datalaw is committed to providing a safe, respectful, inclusive, and dignified environment for all Employees, Apprentices, Learners, Contractors and stakeholders. The Company will not tolerate harassment, bullying, victimisation or any form of discriminatory behaviour.
This Policy applies to conduct based on (but not limited to) the following protected characteristics: Race, colour, ethnic origin, nationality, national origin, religion or belief, sex, sexual orientation, gender reassignment, age, marital or civil partnership status, disability, pregnancy or maternity, neurodiversity (e.g., autism, ADHD), menopause status, as well as any other characteristic protected under the Equality Act 2010 and subsequent amendments or government guidance issued up to 2026.
The Company also prohibits harassment or bullying connected to AI-generated content, online behaviour, digital communications, or misuse of technology, recognising the evolving nature of modern workplaces.
Harassment, bullying or intimidation is misconduct and may constitute unlawful discrimination. Serious breaches may amount to gross misconduct under the Company’s Disciplinary Policy and could result in summary dismissal. In certain cases, harassment may also constitute a criminal offence.
Employees should note that under UK law, individuals may be held personally liable for acts of harassment or discrimination.
The Company does not tolerate bullying or harassment by third parties including Clients, Customers, Contractors, Partners or Suppliers. Appropriate action will be taken where such incidents occur.
Employees and Learners must not victimise or retaliate against any individual who raises a concern, complaint, or participates in an investigation. Such behaviour will be treated as potential gross misconduct.
This policy applies to all work-related environments including: Company premises; remote or hybrid working environments; digital communication platforms (email, messaging, virtual meetings, social media); business travel; and work-related training, events, and social activities.
2. Definitions of Bullying and Harassment
2.1 Bullying
Bullying is offensive, intimidating, malicious or insulting behaviour, or an abuse or misuse of power that undermines, humiliates or injures another person. This includes repeated behaviour or a single severe incident. Examples include (but are not limited to) aggressive or threatening behaviour, persistent criticism or humiliation, abuse of managerial authority, and misuse of digital platforms to intimidate or embarrass.
2.2 Harassment
Harassment occurs when, due to a protected characteristic or related reason, a person engages in unwanted conduct that has the purpose of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment; or has the effect of doing so, even if this was not intentional. The perception of the individual and whether it is reasonable for the behaviour to have that effect are key factors. Harassment related to sex or gender does not require the conduct to be directed at the individual themselves.
2.3 Sexual Harassment
Sexual harassment is any unwanted conduct of a sexual nature that has the purpose or effect described above. Examples include unwanted sexual comments, touching, propositions, or sharing sexual content.
2.4 Forms of Harassment and Bullying
Conduct may be verbal, non-verbal, visual, written, digital or physical. Examples include unwelcome sexual advances or requests for sexual favours; sexual, racist, homophobic, transphobic or otherwise discriminatory comments; the sharing, creation or manipulation of inappropriate images, including through AI tools; jokes, “banter”, memes or images of a sexual, discriminatory or offensive nature; inappropriate questions about personal life, gender identity or health; nicknames or labels relating to a protected characteristic; excluding or isolating someone from work activities or learning opportunities; persistent undermining, belittling or ridiculing; and cyberbullying, such as hostile messages, online humiliation or digital surveillance. A single serious incident may constitute bullying or harassment.
2.5 Victimisation
Victimisation occurs when someone is treated unfavourably because they made or supported a complaint, provided evidence or participated in an investigation, or raised concerns in good faith. Victimisation is strictly prohibited.
3. Employer Responsibilities for Apprentices and Learners
As part of Datalaw’s commitment to safeguarding, employers hosting apprentices and learners must take reasonable steps to prevent harassment or bullying in all training environments, including virtual settings. Employer responsibilities include maintaining accessible, up-to-date anti-bullying and harassment policies; ensuring apprentices understand their rights and how to report concerns; promptly addressing any allegations raised; and cooperating fully in Datalaw-led safeguarding or misconduct investigations. Employers may report concerns to the Apprenticeship Management Team, who will respond in accordance with safeguarding procedures.
4. Reporting and Investigation Procedure
The Company encourages early reporting of concerns and will treat all complaints seriously, confidentially and promptly.
4.1 Informal Resolution (Optional)
Where appropriate and safe, the affected individual may inform the offender that their conduct is unwelcome. The Company recognises that power imbalances or safety concerns may make informal resolution inappropriate.
4.2 Formal Reporting Process
An Employee or Learner should report concerns to their Line Manager; or an alternative Manager; or a Director; or the HR Team; or (if a learner) the Apprenticeship Management Team or Safeguarding Lead. Reports should be made as soon as reasonably possible.
4.3 Investigation
All allegations will be thoroughly investigated. Individuals will be required to provide a written account of events. The alleged harasser will be informed of the complaint and allowed to respond. Confidentiality will be maintained where possible; however, anonymity cannot be guaranteed if it prevents a fair investigation. An impartial investigator may be appointed. The outcome will be communicated in writing to all relevant parties. Where allegations are upheld, appropriate action will be taken, which may include disciplinary action. If the complaint is not upheld, the Company will support all parties in restoring working relationships. No employee or learner will suffer detriment for making a good-faith complaint.
5. Disciplinary Action
Any Employee found to have breached this Policy may face disciplinary action up to and including summary dismissal under the Company’s Disciplinary Procedure. Managers who fail to act on concerns or who ignore known incidents may also face disciplinary action. Misuse of digital tools, including the creation or distribution of AI-manipulated discriminatory or sexual content, will be treated with particular seriousness given emerging legal risks.
6. Training and Awareness
Datalaw will provide periodic training to all Employees and Learners on bullying, harassment, equality and respect; provide specialised training for Line Managers on addressing complaints and maintaining a safe environment; and update training content to reflect legislative or societal changes affecting workplace behaviour (2025-2026).
7. Policy Review
This Policy will be reviewed annually or sooner if legislation, regulatory guidance, or operational needs change. Latest review: 2025-2026.
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Reviewed Date |
04th December 2025 |
Next Review Due Date |
04th December 2026 |
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Reviewed by |
Sarah Parker |
Signature |
Sarah Parker |