Our Policies

Privacy Policy

Canolfan Gerdd William Mathias (CGWM) is committed to protecting your privacy and ensuring that the personal information you provide to us is kept secure, in compliance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

As you use our services or when you visit our websites, we will direct you to read our Privacy Policy. If you disagree with the practices described in our Privacy Policy you must not use our services and websites.

We will take every possible care to ensure that the personal data you provide to us is processed and stored (where appropriate) as securely as possible, whether in digital or hard copy format.

We use services from external companies to store, process and analyse data (e.g. email marketing service, web server, cloud storage, card payment processing company). We take care to ensure that the external companies we use have high standards of data protection and comply with GDPR.

What kind of information do we collect?

To enable us to provide you with a service and respond to your queries we will collect personal data from you. This personal data may include information such as your name, email, telephone number, date of birth, nationality, address, any medical information you choose to share with us, and data relating to any payments made to us.

Lawful Basis for Processing Data
We mostly process data on a contract basis as you use our services. We also process data on the basis of legitimate interest.

Equality Monitoring

As part of all recruitment processes, CGWM collects and processes information or personal data, relating to job applicants. We will only use the data to promote equality and aim to improve equality of opportunity in employment. All equality monitoring data will be anonymised and removed from application forms before shortlisting and interviewing.

Photography and Filming

We ask for permission from a parent / guardian before we photograph or film a child taking part or attending our activities and explain how we will use the photo or film.

Cookies and Statistics on the Use of our Websites:

Most of the cookies we use are necessary for our websites to function properly.

We also use the Google Analytics service to provide us with statistics about how our websites are used by visitors. This is achieved by using cookies. Please note that we ask for your permission to set cookies when you visit our websites for the first time, and without your permission, Google Analytics cookies will not be set.

Our Email List:

We use the MailChimp service to administer our email list and send emails to our subscribers for CGWM news and events. Emails of this type are not sent to you unless you have opted in to receive them. You can unsubscribe at any time by clicking the link to do so which appears at the bottom of every email sent via MailChimp or by contacting us.

Key rights according to GDPR:

GDPR gives you the right to request access to the personal information we hold on you. You can submit a Text Request to View Data by using the contact details below. We will comply with these requests within one month (unless circumstances prevent us from doing so e.g. there is a legal reason for not doing so).

Updating and Deleting Your Personal Data:

You should ask us to correct or update any personal information we hold about you e.g. if you change your name or address or phone number.

You can ask us to remove any information we hold about you at any time. We will do this in accordance with the applicable laws of England and Wales and EU laws and regulations, GDPR.

Please note that we have legal obligations to retain certain types of customer information for certain periods e.g. for accounting purposes.

We will only keep information for the length of time required for the services you have asked for, or we have agreed to provide, or to meet legal requirements.

Find out more about your rights under the GDPR law and your right to make a complaint:

You can find out more about your rights according to GDPR by visiting the Information Commissioner’s Office (ICO) (UK) website.

Contact details

Meinir Llwyd Roberts (Director, William Mathias Music Center)

CGWM, Galeri, Victoria Dock, Caernarfon, LL55 1SQ


Date of last review and update by CGWM board : 02/07/2021

Safeguarding Of Children & Adults At Risk Policy

Canolfan Gerdd William Mathias (CGWM) is committed to a practice which protects all young people under 18 years of age and Adults at Risk from harm. All staff, tutors and volunteers in CGWM accept and recognise their responsibility to develop awareness of the issues which might cause children and Adults at Risk harm. They must be fully aware of, and operate within the terms of, this policy.

CGWM will endeavour to safeguard children and Adults at Risk by:

  • Adopting child and Adults at Risk protection guidelines through procedures and a code of conduct for staff and volunteers.
  • Sharing information about child protection and good practice with children, parents and carers, staff and volunteers.
  • Sharing information about concerns with agencies who need to know, and involving parents and children appropriately.
  • Following carefully the procedures for recruitment and selection of staff and volunteers taking into account any changes in DBS requirements.
  • Providing effective management for staff and volunteers through supervision, support and training.
  • Appoint a member of staff and a member of the Board of Trustees to be responsible for dealing with Child Protection issues.

CGWM is committed to reviewing its child protection policy and good practice at regular intervals and at least annually.

Recruitment Procedures
All CGWM employees including free-lance tutors or volunteers who offer regular tuition or supervision at CGWM and all members of board of Trustee-Directors are required to have the required level of DBS check which has been obtained through CGWM or has been checked using the online updating service if appropriate.

CGWM will be able to run a free online check on a DBS certificate presented by a person who has subscribed to the update providing that:

  • the candidate has given permission
  • the post they are applying for qualifies for the same level of check as the original certificate

If the original certificate is of a lower level than required, CGWM must request a new application. DBS certificates should be checked through the online service or renewed every three years.

All new recruits to have an interview / meeting with the Director or member(s) of the board as appropriate.

References must be obtained from a person who has experience of their work and contact with children.

Designated staff and board child protection officers will keep up to date with the any further developments to the requirements of the DBS service ensuring that staff, tutors and volunteers comply with the requirements of this scheme.

In the event of a visiting artist giving a ‘one-off’ workshop, masterclass or performance involving children or Adults at Risk  the artist must not be alone with the children or Adults at Risk  in any circumstance and a member of staff / volunteer with a satisfactory DBS disclosure  must be present at all times to act as chaperone.

Risk Assessment
CGWM staff are required to undertake risk assessments on all activities to ensure the safety of the participants and ensuring that activities are accessible to all children and Adults at Risk  who wish to take part. If arranging a group activity the member of staff responsible for the activity must make sure that there is a sufficient number of staff to children or young people.

Currently the HSE recommend:

Children age 5 – 8                    a ratio of  1: 6
Children age over 8                a ratio of  1:15


When a group activity is taking place keeping within the above ratios, a second responsible adult should be present in the building for example in CGWM office.

With respect to workshops for Adults at Risk  including Hidden Talents, CGWM will depend on guidance from the local social services department who nominate the clients for the activities and determine the appropriate adequate staffing levels.

No child or young person under the age of 18 is permitted to leave the venue where the activity is taking place at any time except when accompanied by their parent or expressly authorised representative of CGWM.

Consent has to be given by parents or carers before any child or Adults at Risk can be photographed or filmed by CGWM participating in any activity and consent form should state how the images will be used and for what purpose.

Health and Safety
Staff should always make sure that the activity complies with CGWM’s Health and Safety Guidelines.

Information relating to children and Adults at Risk
To ensure best possible care of children and Adults at Risk  whilst in the care of CGWM, parents or carers are asked to provide CGWM with the following information:

  • Name, Address, Date of Birth,
  • Information about any medical and physical ailments and allergies,
  • Name of parent or carer together with emergency contact numbers

Guidance for individuals working with children and VA in CGWM activities
CGWM has developed a code of conduct document which advises tutors and those who work with children and VA in CGWM on appropriate behaviour when working with children and VA. All staff and regular tutors should receive a copy of the code of conduct together with this policy and should sign a declaration stating that they have understood and will adhere to them or request a meeting with one of CGWMs’ designated persons to have further guidance and explanations.

Board members and all employees are expected to be fully aware of this policy and attend appropriate courses from time to time.

CGWM will provide opportunities for free-lance musicians linked to the Canolfan to attend training on Child Protection issues as well as continue to ensure that its designated responsible staff attend regular training to keep up to date with new legislation

Designated Child and Adults at Risk Protection persons:
Staff: Meinir Llwyd Roberts (Director)
Board: John Pritchard

Reporting of abuse or suspected abuse
If a person working with CGWM is concerned that a child or an adult at risk is a victim of abuse, they should discuss the matter with the designated member of staff named above who will discuss further with the designated member of the Board, write a report and decide if the matter should be shared with the statutory child / adult at risk protection agency.  An internal report form should be completed for each and every incident of issue or concern, ideally as soon as possible and within 24 hours of the incident.


CGWM will provide internal report forms for individuals to record any incidents or concerns (copies available in CGWM office). Copies of the referral forms of the North Wales Regional Safeguarding Board are also available in CGWM office and will be completed by designated persons should it be decided that the matter should be referred. 

If a child makes an allegation of abuse to a tutor, a member of staff, or volunteer working with CGWM, that person should contact the designated member of staff as soon as possible and record in writing using the child’s own words. The record should be signed and dated and the information passed on to the relevant child protection agency who will decide if further action is required.

If a member of staff or volunteer is concerned about the behaviour of a colleague in relation to working with children or Adults at Risk they should discuss their concerns in confidence with the designated staff member named above who will discuss the matter further with the designated board member and decide on subsequent action.

When a staff member, tutor or volunteer is in regulated activity, there is a duty to refer to DBS any person who harms or poses a threat of harm to a person in their care when they are removed from regulated activity (resigned, dismissed, retired) in relation to the situation of harm. This referral would mean the individual would be considered for barring.

CGWM will report to the Charity Commission as soon as possible any safeguarding incidents, complaints or allegations according to the Charity Commissions guidelines.

NSPCC posters displaying the helpline contact number are displayed in CGWM teaching areas.

This document has been written with reference to the Arts Council of Wales’ Child Protection Policy and the NSPCC First Check publication.
Guidance received from WCVA Safeguarding officer during review of document in 2016.

Date of last review and update by CGWM board :  24/10/2019

According to the Social Services and Well-being Act (2014) the definition of the term ‘Adult at Risk’ is:

A person who is 18 years of age or over, and who: is experiencing or is at risk of abuse or neglect, has needs for care and support (whether or not the local authority is meeting any of those needs)

Equality and Diversity Policy


Canolfan Gerdd William Mathias (CGWM) recognises the benefits of implementing an Equality and Diversity Policy. The aim of this policy is to ensure that employees, potential employees, volunteers, self-employed contractors, clients, service users and visitors are treated in a fair and equal manner regardless of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, colour, religion or belief, sex, or sexual orientation (Protected Characteristics). They will not be discriminated against, harassed or persecuted.
We recognise the conventions outlined in the Human Rights Act 1998 and are committed to providing a working environment that values ​​the diversity of all  – our staff and those we encounter at work. We fully support people’s right to be treated with dignity and respect and value people as individuals with diverse views, cultures, lifestyles and circumstances.

We are committed to ensuring equality of opportunity in the employment and training of our staff and the delivery of our services by following practices that are free from unfair and unlawful discrimination.

In addition, CGWM:

  • is committed to reflecting the diversity of Wales and to making its services accessible to all. This applies to its services, its service users and staff.
  • aims to create and sustain an inclusive work environment which provides equality of opportunity for everyone.
  • is committed to ensuring that all self-employed workers or contractors, whether part-time, full-time or temporary, are treated fairly and with respect at all times. Qualification and ability will be the basis for selection for a job, promotion, training or any other benefit.

The policy applies to all aspects of employment with CGWM, including recruitment, pay and conditions, training, appraisals, promotions, conduct at work, disciplinary and grievance procedures, and termination of employment.
This policy is not part of an employment agreement and may be amended at any time.

What is equality and diversity?

Equality is about complying with our legal obligations to provide equal access to opportunities and services for everyone. It is also about removing any barriers or discriminatory practices that may affect particular groups.

Diversity is a concept based on the principle that everyone is different in some way, and that taking an inclusive approach brings benefits and advantages. It is about recognising, respecting and valuing the differences that everyone has.

Responsibilities for Equality and Diversity in CGWM

The CGWM Board / Management Committee has responsibility for ensuring that this policy is implemented.
Everyone, including Board Members, employees, self-employed contractors and volunteers, has a duty to act within the guidelines of this policy. Staff should not unlawfully harass or discriminate against others, including current and former staff, job applicants, service users, suppliers and visitors. This applies to the workplace, outside the workplace (when dealing with service users, suppliers or work-related contacts), and on work-related trips or events, including social events .
No employee should persuade another employee, individually or collectively, to practice unlawful discrimination.

We encourage staff / tutors or participants who are concerned about a diversity and equality issue to raise the matter orally or in writing with the Director or Chair of the HR Committee.

Providing a Service

CGWM makes every effort to ensure that its activities are fully accessible to everyone. Its centres, at Galeri and Theatr Twm o’r Nant are ideally placed to deliver access to everyone.

CGWM ensures that other venues used for its activities are accessible.

Equal Opportunities Policy Statement
The following forms of discrimination are unlawful and are prohibited under this policy:
• direct discrimination: treating someone less favorably because of a Protected Characteristic (see list above)
• indirect discrimination: a provision, criterion or practice that is not justified. They apply to everyone but have a greater adverse effect on people with a particular Protected Characteristic. This may apply to a variety of circumstances, including employment or service delivery issues
• harassment: this includes sexual harassment and other undesirable behaviors involving a Protected Character. Their purpose and effect is to interfere with someone’s dignity or create an intimidating, unfriendly, degrading, humiliating or offensive environment for them. Harassment is dealt with further in our Respect at Work Policy
• victimisation: retaliation against someone who has complained or upheld someone else’s complaint of discrimination or harassment
• disability discrimination: this includes direct and indirect discrimination, any unjustified less favorable treatment because of the impact of disability, and failure to make reasonable adjustments to minimise disadvantages caused by disability.

Children’s Rights
CGWM recognizes that investing in children’s human rights brings real benefits to organisations and enables more children and young people to become better involved in public services. Children’s policy and legislation in Wales is based on the United Nations Convention on the Rights of the Child (UNCRC). The Rights of Children and Young Persons (Wales) Measure 2011, the Social Services and Well-being (Wales) Act 2014 and the Well-being of Future Generations (Wales) Act 2015 place duties on public authorities that contribute to the realization of children’s rights.
Although not a public body, CGWM is committed, to the best of its ability, to operating in accordance with the main principles of the Children’s Rights Approach, a principled and practical framework for working with children.

In particular, CGWM, to the best of its ability, will:
• treat all children fairly, provide them with opportunities and resources according to their needs in an equal way with others, and ensure that they are able to develop to their full potential
• ensure that all children have an equal opportunity to make the most of their lives and talents
• work towards the realisation of human rights for children by ensuring that they:
Ø respect their rights. We will not judge a child’s human rights as less important because he or she is under a certain age, or because we presume what is best for the child.
Ø protect rights. We will try to ensure that others do not violate a child’s human rights, by taking action where there is evidence that children do not receive their rights, e.g. where children are subjected to abuse, exploitation or discrimination
Ø fulfill rights. We will take steps to ensure that children have every opportunity to enjoy, or enhance, their human rights by making children aware of their rights, and that children’s rights are appropriately prioritised in terms of resources.
More details about Children’s Rights can be found by following this link – https://www.childcomwales.org.uk/wp-content/uploads/2017/04/The- Right-Way.pdf

Recruitment and Selection
CGWM will conduct recruitment, promotion and other selection practices such as fair selection of redundancies, on merit against objective criteria that avoid discrimination. Shortlists are made by more than one person.
Vacancies are generally advertised using channels that reach various sections of the labor market. CGWM will avoid stereotyping when advertising, or use words that may not support particular groups when applying.
CGWM will not ask job applicants questions that may indicate an intention to discriminate on the basis of a Protected Characteristic. (Health or disability questions can be included in equal opportunities monitoring forms but these are not used for selection or decision making. Equality questionnaires are drawn from applications before shortlisting and interviewing).

Equal Pay
CGWM will ensure that all employees, male or female, are entitled to the same pay and other contractual benefits for the same or similar work.

The Welsh Language

The Welsh language is not a “protected characteristic” under the Act but CGWM is committed to ensuring equality of the language as outlined in our Welsh language policy.

Raising concerns

All staff/tutors are required to comply with the principles of this policy and to act in accordance with its objectives so as to remove any barriers to equality. Where staff/tutors or service users raise an allegation of discrimination the complaint will be considered by the HR sub-committee which will report as appropriate to the full board of Directors.

Breach of Policy
Any breaches of this policy will be dealt with in accordance with our Disciplinary Procedure. Serious cases of willful discrimination can amount to gross misconduct, which will lead to dismissal.
Any member of staff who considers themselves to have been discriminated against can raise the matter through the Grievance Procedure or Respect at Work Policy. Complaints will be treated confidentially and investigated as appropriate.


CGWM will monitor equality information regarding recruitment.  The purpose of monitoring data enables CGWM to meet its legal obligations. CGWM is extremely aware of the need to provide a comprehensive service for all and to this end; CGWM monitors the resources and facilities available at every venue it uses.

Date of last review and update by CGWM board : 6/2/2020

In addition to this policy CGWM has an Action Plan which is reviewed annually and sets specific targets for the year (Last review June 2020)

Welsh Language Policy

(Prepared under the Welsh Language Act 1993 and reviewed following the 2011 Act)

This policy sets out how Canolfan Gerdd Williams Mathias adopts the principle of treating the Welsh and English Language on a basis of equality. Wales is a bilingual country and as an organisation, we recognise the benefits of providing good quality Welsh language services. According to the 2011 Census. 65% of Gwynedd’s population are Welsh speakers. It’s important that these Welsh speakers, in addition to children and adults who are learning Welsh are offered provision through the medium of Welsh at CGWM.

Canolfan Gerdd William Mathias recognises the principle of equality between the Welsh and English Languages. Regard for both languages has been integral to the administration of CGWM since its inception.

CGWM operates as a bilingual organisation and is committed to communicating with the public in Wales bilingually. The publication of this policy incorporates many of the current working practices of CGWM.

Within CGWM, the Director and the Board of Directors are responsible for the operation of the policy and for communicating it to all staff and tutors.

Summary of Measurers:
• All Board members involved with relevant policy formulation, staff and tutors will be made aware of CGWM’s Welsh Language policies and its responsibilities under the Welsh Language Act 1993 and 2012.
• CGWM will strive to ensure that its dealings with the public are of an equally high standard in Welsh and English.
• CGWM will ensure that staff providing public services are trained to supply a quality service in Welsh and English that is of an equal standard.
• Pupils are generally able to be taught in the language of their choice as the vast majority of tutors at CGWM are either bilingual or if not fluent Welsh speakers, are learning Welsh and are able to understand the language.
• CGWM’s website is bilingual.
• All letters received by CGWM will receive signed replies in the language of the originating correspondence.
• When CGWM initiates correspondence, the preferred language of the addressee will be used if known, and if not, the communication will be issued bilingually.
• Telephone callers to the main CGWM number will be addressed in the language of the caller’s choice.
• At all CGWM public meetings and concerts held in Wales, people attending will be able to contribute in Welsh or English.
• Staff who welcome the public at CGWM front desk will be expected to greet visitors bilingually and be able either to deal with them in the language of their choice or to direct them to a member of staff who is able to do so.
• CGWM adopts a bilingual public image and identity.
• CGWM is committed to providing print in both Welsh and English.
• Minutes of Board Meetings are produced bilingually.
• Marketing, advertising and promotional materials for events and activities, including leaflets will be produced in both English and Welsh.
• CGWM is fully committed to supporting staff and tutors who want to learn Welsh or improve their ability to use Welsh.
CGWM formally adopted this policy on December 4th, 2009.


Date of last review and update by CGWM board : 24/10/2017

In addition to this policy CGWM also has a Welsh Language Plan which is reviewed annually and sets specific targets for the year (last review July 2020)

Concerns and Complaints Policy


This policy applies to service users, participants, parents and guardians, tutors and anyone involved with Canolfan Gerdd William Mathias (CGWM) other than a member of staff. CGWM has a specific grievance policy and procedure for its staff.


CGWM aims to provide a service of the highest quality to all and welcomes the views of any person on the service provided, so that it can be improved if needed. CGWM will endeavour to deal effectively and promptly with any concerns or complaints you may have about our provision.


If your concern or complaint relates to the protection of a child or vulnerable adult, CGWM will act by following the process set out in CGWM’s Safeguarding of Children and Adults at Risk policy.


If your concern or complaint relates to an equality and diversity matter CGWM will act by following the process set out in CGWM’s Equality and Diversity Policy.


If your concern or complaint relates to harassment or bullying the procedure set out in the Respect at Work Policy and CGWM Activities will be followed.


Informal Resolution

CGWM will endeavor to resolve any concern or complaint informally wherever possible in a spirit of co-operation.

You are therefore encouraged to raise your concern or complaint in the first instance with the member of CGWM staff on duty at the CGWM Office or activity venue.

If the complaint relates to a tutor or activity leader or a member of CGWM’s administrative staff the full-time CGWM Administrator (Gwydion Davies) or CGWM Director (Meinir Llwyd Roberts) should be contacted as appropriate, by telephoning the Office 01286 685230 or emailing gwydion@cgwm.org.uk/ meinir@cgwm.org.uk


Formal process

If your concern or complaint cannot be resolved informally, or you wish to put your complaint in writing, in the first instance, please contact the Director of CGWM (Meinir Llwyd Roberts) 01286 685230 meinir@cgwm.org.uk stating clearly your wish to make a complaint under the Concerns and Complaints Policy. The formal submission should explain the basis and nature of the complaint and the desired outcome.


If your complaint relates to the Director of CGWM then it should be referred to the Chair of the Finance and Resources Sub-Committee of the CGWM Board of Directors / Trustees, John Pritchard.

CGWM will acknowledge receipt of written complaints within 5 working days and investigate the matter internally.


The person investigating the complaint (‘the investigator’) will consider the relevant evidence including any documents, notes of conversations or emails. She/he may ask to meet with you to discuss the matter in question and may interview any person to whom the complaint relates and any relevant witnesses.


The investigator may recommend specific action to be taken in response to the concern or complaint including referring the matter to members of CGWM’s Board of Directors / Trustees.

If, after considering all relevant evidence, the investigator recommends disciplinary action against a member of staff the procedure in the Staff Disciplinary Policy and Procedure must be followed.

The complainant will be issued with the written outcome of the investigation within 28 working days.



If you do not feel that your concern or complaint has been satisfactorily resolved an appeal may be made to the Chair of CGWM’s Board of Directors-Trustees, Wyn Thomas



The appeal should be submitted in writing to the Chair within five working days of the written notification of the outcome of the complaint stating clearly the grounds of appeal.


The Chair will investigate the grounds of appeal and all relevant evidence and inform you of the outcome within 21 working days of receipt of the appeal. The outcome will be final and there will no further right of appeal.


Concerns and Complaints : Date of last review and update by CGWM board 17/8/2020

Terms of Use of our Websites

These terms of use govern your use of websites operated by Canolfan Gerdd William Mathias (including Canfod y Gân, Wales Harp Festival, Wales Piano Festival). If you disagree with any part of these terms of use, you must not use our website.

Unless otherwise stated, we own the intellectual job rights and material on our websites. You must not republish or sell material from our websites.

Personal information may be submitted to us through our websites – to learn more please view our Privacy Policy.

Our websites may include hyperlinks to other websites owned and operated by third parties. These links are not recommendations and we have no control over the contents of third-party websites.

Respect at Work and CGWM Activities Policy


This policy applies to members of staff, Board members, tutors, service users (including parents, pupils and carers), volunteers and everyone involved with CGWM.


CGWM recognises that everyone has the right to be treated with dignity and respect. Bullying and harassment are harmful. They cause distress and can lead to accidents, illness and poor performance. CGWM will not tolerate or accept any form of discrimination, bullying or harassment. It will take complaints of such behaviour very seriously, take immediate action, and in the case of a member of staff this can lead to disciplinary action.



Bullying can be defined as “offensive, intimidating, malicious or insulting behaviour, an abuse of power through means that undermine, humiliate, denigrate or injure the recipient”. (ACAS)

Examples of bullying may include:

  • spreading malicious rumours, or insulting someone by word or behaviour (especially on grounds of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (Protected Characteristics);
  • sending a communication in any form, critical about someone, to other people where they did not need to receive the information;
  • ridiculing or demeaning someone – picking on them or setting them up to fail;
  • excluding or victimising anyone;
  • treating anyone unfairly;
  • overbearing supervision or other misuse of power or position;
  • unwanted sexual propositions or advances – touching, standing too close, displaying offensive material.
  • making unfounded threats or comments about job security;
  • deliberately undermining a member of staff through overloading and constant criticism;
  • preventing individuals progressing by intentionally blocking opportunities for promotion or training.



Harassment can be defined as “unwanted conduct which has the purpose of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual”. “(ACAS)

Harassment includes unwelcome and unrequested behaviour, particularly in the following areas:

  • age
  • disability
  • gender reassignment
  • marriage and civil partnership
  • pregnancy and maternity
  • race
  • religion and belief
  • sex or sexual orientation.

Although CGWM appreciates that reporting a case of bullying and harassment can be embarrassing, once a case has been reported, they have a duty to act on the matter. Reports of bullying and harassment will be investigated in all cases.


The Process

Informal Approach

Any person who believes that he/she is being bullied or harassed should make it clear to the person who is acting unacceptably that the behaviour is unacceptable and should stop. A note should be kept of any informal communication that occurs.

It is appreciated that a child or young person under the age of 18 or a vulnerable adult may not have the confidence to raise the matter directly with the person acting unacceptably. If a parent, guardian or carer or any other person with responsibilities for the child or young person or vulnerable adult (‘their representative’) is aware that such a child or person is unhappy with the behaviour towards him / her he or she should raise the issue with the Director and the Director will seek to resolve the situation informally.

If the representative considers the unacceptable behaviour to be ‘abusive’ (a safeguarding matter) then the Child Protection and Vulnerable Adults Policy should be implemented.


Formal Approach

If informal methods fail, or serious bullying or harassment occurs, the aggrieved person or their representative is advised to make a formal complaint. The complaint should be in writing and, where possible, state:

  • Name of the alleged perpetrator
  • The nature of the alleged behaviour
  • The dates and times when the behaviour occurred
  • The names of witnesses to any cases of alleged bullying or harassment, if available
  • Any action already taken to prevent the alleged behaviour.


The complaint should be sent to the Director. If the complaint relates to the Director the complaint should be referred to the Chair of the Human Resources Sub-Committee or if it involves a Board member it should be sent to the Chair of the Board.


Upon receipt of a complaint immediate action should be taken to separate the person responsible for the alleged conduct. For a member of staff this may mean a temporary transfer to another area of ​​the business, or suspension from paid work until the complaint is resolved.


The Director or Chair of the Human Resources Sub-Committee or Chair of the Board as appropriate will investigate the allegation by conducting a thorough investigation as soon as possible, ensuring confidentiality at all times. Everyone involved in the investigation is expected to respect the need for confidentiality. Failure to do so will constitute misconduct in accordance with the Company’s Disciplinary Policy.


Following the investigation, the Director or Chair of the Human Resources Committee or Chair of the Board will consider what further action to take and inform the relevant parties of her / his decision. In the case of a member of staff this may involve action in accordance with the formal disciplinary procedure, which may include dismissal.

Right of Appeal

A member of staff subject to any form of disciplinary action will have the right of appeal against the decision in accordance with the appeal procedure in the Disciplinary Policy and Procedure.

Any other person will have the right to appeal any judgment against them by following the Appeals Procedure under the Complaints Procedure.

Date of last review and update by CGWM board : 17/8/2020