2025-2026
Policies Appendix
Contents
Appendix A. Homestay Code of Conduct … 3
Appendix B. Student Code of Conduct … 5
Appendix C. Anti-Radicalisation Policy … 7
Appendix D. Low-Level Concerns Policy … 9
Appendix E. Complaints Policy … 11
Appendix F. Anti-Bullying and Cyberbullying Policy … 13
Appendix G. Missing Student Policy … 15
Appendix H. Online Safety and Acceptable Use Policy … 17
Appendix I. Data Protection Policy … 20
Appendix J. Welfare, Health, and Safety Policy … 28
Appendix K. Pandemic Procedure Policy … 31
Appendix L. Whistle Blowing Policy … 34
Appendix A
Homestay Code of Conduct
Effective Date: June 2025
Review Date: June 2026
Hosting a student through the Gabbitas homestay program is a rewarding experience that also carries important responsibilities. To ensure a safe, respectful, and culturally enriching environment, all homestay families are expected to adhere to the following Code of Conduct:
1. Respect and Inclusion
- Treat all students with respect, kindness, and cultural sensitivity.
- Provide a welcoming, non-discriminatory home environment regardless of race, nationality, religion, gender identity, or sexual orientation.
- Encourage the student to participate in family life while respecting their privacy and personal space.
2. Safe and Supportive Environment
- Provide a clean, safe, and adequately furnished private bedroom.
- Ensure the home environment is free from abuse, neglect, and harassment.
- Avoid exposing students to dangerous or illegal activities (e.g., drug use, criminal behaviour).
- Provide Gabbitas with annual gas safety certificates.
3. Communication and Understanding
- Communicate openly and regularly with the student to address any concerns or misunderstandings.
- Be patient and understanding with language and cultural differences.
- Seek support from program coordinators when needed.
4. Supervision and Curfew (for minors)
- Ensure the student’s safety, especially if the student is a minor.
- Enforce appropriate curfews and supervise outings based on program rules.
- Always know the student’s whereabouts when they are away from home.
5. Meals and Daily Living
- Provide meals as outlined in the program agreement.
- Include the student in family meals when possible, and accommodate dietary needs within reason.
- Provide reasonable access to laundry facilities, internet, and household amenities.
6. Cultural Exchange and Learning
- Encourage the student to share their culture and be open to learning about theirs.
- Introduce the student to local customs, holidays, and traditions.
- Avoid forcing religious or political views on the student.
7. Confidentiality and Privacy
- Respect the student’s personal belongings and privacy.
- Do not share the student’s personal information without their consent or unless required by the program or law.
8. Program Compliance
- Comply with all guidelines and policies set by Gabbitas
- Attend/complete required orientation or training sessions, including KCSIE compliant safeguarding training every 3 years.
- Notify program staff immediately of any serious concerns or emergencies involving the student.
Appendix B
Student Code of Conduct
Effective Date: June 2025
Review Date: June 2026
Living with a homestay family offers a unique opportunity to experience another culture in a supportive home environment. To ensure a positive experience for both students and host families, all students are expected to follow this Code of Conduct:
1. Respect and Courtesy
- Treat your host family with respect, kindness, and gratitude.
- Respect household rules, customs, routines, and personal boundaries.
- Use polite language and behaviour at all times.
2. Communication
- Communicate openly and honestly with your host family.
- Inform your host family of your whereabouts and plans, especially if you will be home late or not attending a meal.
- Ask questions if you are unsure about household expectations.
3. Participation in Family Life
- Participate in family meals and activities when invited.
- Be willing to share your culture and learn about your host family’s traditions.
- Offer to help with light household tasks (e.g., clearing dishes, tidying your room).
4. Personal Responsibility
- Keep your room clean and tidy.
- Take care of your personal belongings and respect others’ property.
- Use shared spaces (e.g., bathroom, kitchen) responsibly and leave them clean for others.
5. Safety and Behaviour
- Abide by curfews, safety rules, and local laws at all times.
- Do not engage in risky behaviour, including drug use, underage drinking, or illegal activities.
- Use the internet, social media, and phone respectfully and responsibly – reference Appendix H in policies document.
- Safeguarding concerns can be reported to the DSL Danielle Flood on Danielle.flood@gabbitas.com or 07585824645.
6. Cultural Sensitivity
- Be open-minded and respectful of cultural differences.
- Avoid making offensive or judgmental comments about food, customs, religion, or lifestyle.
- Understand that different families may have different ways of doing things.
7. Conflict Resolution
- Address concerns calmly and respectfully with your host family.
- If you cannot resolve an issue, contact your named consultant at Gabbitas.
- Avoid gossip or public complaints about your host family.
8. Privacy and Confidentiality
- Respect the privacy of your host family and fellow household members.
- Do not go into private rooms without permission.
- Keep personal and family matters private and avoid sharing sensitive information without consent.
9. Program Rules and Compliance
- Follow all guidelines provided by Gabbitas or your school.
- Attend scheduled meetings, orientations, or classes as required.
- Understand that violating program rules can result in disciplinary action or removal from the program.
Appendix C
Anti-Radicalisation Policy
Effective Date: June 2025
Review Date: June 2026
1. Purpose
The purpose of this policy is to:
- Protect individuals from being drawn into terrorism or extremist ideologies.
- Promote community cohesion and shared values.
- Provide a safe environment where radicalisation risks are identified and addressed early.
2. Scope
This policy applies to:
- All staff, students, volunteers, and contractors.
- Activities both on-site and off-site, including digital/online activity.
3. Definition of Radicalisation
Radicalisation is the process by which individuals come to support terrorism or extremist ideologies. Extremism is defined as:
“Vocal or active opposition to fundamental values, including democracy, the rule of law, individual liberty, and mutual respect and tolerance of different faiths and beliefs.”
4. Legal and Policy Framework
This policy operates in line with:
- The Counter-Terrorism and Security Act 2015 (UK)
- The Prevent Duty Guidance
- Equality Act 2010
- Safeguarding and Child Protection Policy
5. Roles and Responsibilities
5.1 Leadership Team / Management
- Ensure the company complies with the Prevent Duty.
- Promote a culture of vigilance and shared responsibility.
5.2 Designated Safeguarding Lead (DSL)
- Act as the primary contact for concerns relating to radicalisation.
- Liaise with external agencies (e.g., police, local authority Prevent teams).
- Ensure staff training and incident reporting procedures are in place.
5.3 Staff and Volunteers
- Provide Prevent awareness information.
- Remain alert to signs of radicalisation and report concerns.
- Model inclusive and respectful behaviour.
5.4 Students and Parents
- Engage with values-based education promoting mutual respect.
- Report any concerns regarding peers or online activity.
- Cooperate with safeguarding procedures.
6. Recognising the Signs of Radicalisation
Possible indicators may include:
- Sudden changes in behaviour or peer groups.
- Expression of extremist views.
- Glorifying violence or intolerance.
- Accessing or sharing extremist material online.
- Withdrawal from family, friends, or school life.
Note: These signs do not necessarily mean a person is being radicalised, but they may warrant further assessment.
7. Reporting Procedures
- Immediate Risk: Call emergency services (999).
- Non-Emergency Concerns: Report to the Designated Safeguarding Lead on 02030267443.
- Documentation: Complete a safeguarding/radicalisation concern form.
- Action: The DSL will assess and, if necessary, refer to the Local Authority Prevent Officer or Channel Panel.
8. Preventive Measures
- Promote critical thinking and digital literacy.
- Encourage open discussion and respectful debate.
- Provide a broad, balanced curriculum that promotes British values (or relevant civic values).
- Monitor internet usage and restrict access to extremist content.
9. Training and Awareness
All staff within the Guardianship Team must complete Prevent training annually.
Students receive age-appropriate guidance through PSHE/citizenship curriculum, workshops, or assemblies within their education establishment.
10. Confidentiality and Data Protection
Concerns will be handled sensitively and in line with the institution’s Data Protection Policy and Safeguarding Policy. Information will be shared on a need-to-know basis.
11. Monitoring and Review
This policy is reviewed annually or following any incident involving extremist behaviour. Updates will incorporate new legislation or guidance.
Appendix D
Low-Level Concerns Policy
Effective Date: June 2025
Review Date: June 2026
This policy sets out the procedure for reporting and managing low-level concerns of the behaviour of adults working with children, young people, or vulnerable adults. It applies to all staff, volunteers, contractors, and visitors.
A low-level concern is any concern—no matter how small or vague—that an adult may have acted in a way that is inconsistent with the organisation’s code of conduct but does not meet the threshold for a formal allegation.
Examples of a low level concern may include:
- Using inappropriate language around children.
- Being overly familiar with a child.
- Failing to maintain proper boundaries.
- Engaging in behaviour that could be misinterpreted or misconstrued.
Note: A low-level concern does not mean the person is guilty of misconduct—it simply means a behaviour needs to be noted and considered to maintain a safe culture.
Creating a culture where all concerns are shared helps:
- Maintain high standards of professional behaviour.
- Identify and respond to patterns of behaviour early.
- Protect children and adults.
- Protect staff by allowing context to be considered.
All staff and volunteers are encouraged to report low-level concerns to the Designated Safeguarding Lead (DSL) Danielle Flood or deputy Cherry Ridar Liu as soon as possible. Reports can be made verbally or in writing. If the concern is about the DSL, it should be reported to the Director of Operations or the Managing Director.
A written record should be kept, including:
- The nature of the concern.
- The context.
- The person reporting it.
- Any action taken.
The DSL will assess the concern and determine whether it remains low-level, needs further investigation, or meets the threshold for referral. Patterns of behaviour may trigger a more formal process if needed. The record will be kept confidential but stored securely in line with the safeguarding record-keeping policy.
Concerns will be handled sensitively and discreetly and no assumptions of wrongdoing will be made based on a low-level concern alone. All staff will be treated with respect and fairness.
Staff will receive training on identifying and reporting low-level concerns and a culture of openness and reflective practice is encouraged.
This policy is part of the wider commitment to safeguarding and professional standards.
Appendix E
Complaints Policy
Effective Date: June 2025
Review Date: June 2026
At Gabbitas, we are committed to providing the highest level of care and service to our clients and their families. We understand that, from time to time, concerns or issues may arise. Our Complaints Policy provides a clear and transparent process for addressing concerns and resolving any issues promptly and fairly.
The purpose of this policy is to ensure that complaints are handled in a professional, consistent, and respectful manner. This policy aims to:
- Provide a clear process for clients and their families to raise concerns.
- Ensure all complaints are taken seriously and investigated appropriately.
- Promote improvements in our services based on feedback.
Complaints can be made by:
- Clients (service beneficiaries)
- Family members or legal representatives of clients
- Any individual or third party who has been impacted by our services
Complaints can be made through the following channels:
- In Person: Speak directly to a member of our team or manager.
- By Phone: Call us at 02030267443
- By Email: Send an email to info@gabbitas.com
- Online: Submit a complaint through our online form at Worldwide Locations – Gabbitas
- Written: Mail your complaint to Gabbitas, 17 Cavendish Square, London, W1G 0PH
Please include details of the issue, such as dates, times, people involved, and the nature of your concern, so we can respond more efficiently. Complaints will be escalated to the DSL, Danielle Flood or the local LADO if necessary.
Upon receipt of a complaint, we will take the following steps:
- Acknowledgment: We will acknowledge receipt of your complaint within 5 business days.
- Investigation: A thorough investigation will be conducted. This may include reviewing relevant records, interviewing involved parties, and gathering additional information.
- Response: After the investigation, we will provide a response detailing our findings and any actions that will be taken to address the complaint. We will aim to resolve complaints within 10 business days, but more complex issues may take longer.
- Resolution: If the complaint is upheld, we will take appropriate corrective action to resolve the issue and prevent future occurrences.
Escalation Process
If you are dissatisfied with the outcome or the way your complaint was handled, you may escalate your complaint to the Managing Director who will review the case and ensure a fair resolution.
Confidentiality
All complaints will be handled with the utmost confidentiality. Personal information related to the complaint will only be shared with those necessary to resolve the issue.
Commitment to Improvement
We are committed to continuously improving the services we provide. All complaints will be reviewed to identify areas where we can enhance our services and ensure better experiences for our clients and their families.
Feedback
We encourage feedback at any time, whether it is positive or constructive, to help us improve. If you are satisfied with the resolution of your complaint, we would also appreciate hearing about your experience.
Appendix F
Anti-Bullying and Cyberbullying Policy
Effective Date: June 2025
Review Date: June 2026
- Policy Statement
We are committed to providing a safe, respectful, and inclusive environment for all individuals. Bullying in any form, including cyberbullying, is strictly prohibited and will not be tolerated. All members of our community have the right to feel secure and supported without fear of being bullied or harassed.
- Purpose
The purpose of this policy is to:
- Define what constitutes bullying and cyberbullying.
- Establish procedures for reporting and responding to incidents.
- Promote awareness, prevention, and accountability.
- Scope
This policy applies to all students, employees, volunteers, and associated members of the organisation, whether on-site, off-site, or online. It covers behaviour that occurs:
- On organisational property or during related activities.
- Using personal or organisational devices, platforms, or social media.
- Definitions
Bullying
Bullying is repeated, intentional behaviour that causes physical, emotional, or psychological harm to another individual. It may include:
- Physical aggression (e.g., hitting, pushing)
- Verbal abuse (e.g., name-calling, threats)
- Social exclusion (e.g., spreading rumours, isolating someone)
- Psychological manipulation (e.g., intimidation, humiliation)
Cyberbullying
Cyberbullying involves the use of digital technologies to harass, threaten, or harm others. This includes:
- Sending threatening or abusive messages via text, email, or messaging apps
- Posting or sharing false, hurtful, or embarrassing content about someone
- Impersonating someone online to damage their reputation
- Repeatedly sending unwanted or harassing digital communication
- Responsibilities
Leadership and Staff
- Promote a culture of respect and safety.
- Act promptly on reports of bullying.
- Maintain confidentiality and fairness in investigations.
- Implement prevention programs and awareness campaigns.
Students
- Treat others with kindness and respect.
- Report bullying incidents to a trusted adult.
- Avoid participating in or encouraging bullying behaviour.
Parents / Guardians / Host Families
- Encourage respectful behaviour at home and online.
- Monitor and guide children’s use of technology.
- Collaborate with the organization to address concerns.
- Reporting Procedures
Any individual who experiences, witnesses, or suspects bullying or cyberbullying is encouraged to report it through the following means:
- In person to a designated staff member (DSL at Gabbitas – Danielle Flood) or leader
- By email or written report to a confidential contact
- Investigation and Response
- All reports will be taken seriously and investigated promptly and fairly.
- Involved parties will be given the opportunity to present their perspectives.
- Appropriate actions will be taken based on the severity of the incident, which may include:
-
- Mediation or restorative practices
- Disciplinary measures (e.g., warnings, suspension, dismissal)
- Support services for those affected
-
- Prevention and Education
We are committed to:
- Offering training on bullying and digital safety
- Creating awareness through posters, workshops, and campaigns
- Encouraging open communication and peer support
- Confidentiality
All reports will be handled with discretion. Information will be shared only with those who need to know to ensure effective resolution and support.
- Policy Review
This policy will be reviewed annually and updated as needed to reflect legal requirements, technological changes, and community feedback.
Appendix G
Missing Student Policy
Effective Date: June 2025
Review Date: June 2026
The purpose of this policy is to establish clear procedures for responding to reports of a missing student participating in the Gabbitas homestay programme. The safety and well-being of students is our highest priority.
1. Definition of a Missing Student
A student is considered missing when:
- Their whereabouts are unknown for a period of time inconsistent with their established patterns of behaviour;
- They have failed to return home or check in at an expected time;
- There is concern for their safety due to unusual circumstances (e.g., not attending school, unresponsive to calls/messages, or last seen in distress).
2. Responsibilities
A. Host Family
If a student is believed to be missing, the host family must:
- Attempt to contact the student via phone, messaging apps, or social media.
- Check with friends, school, and recent contacts.
- Notify your named consultant at Gabbitas immediately (within 1 hour of concern) either on their direct line during working hours (Danielle – 07585824645 or Cherry – 07585836875) or on the Emergency out of hours line – 07575702776.
- If there is immediate concern for the student’s safety, call local emergency services (e.g., 911).
B. Gabbitas Staff
Upon receiving a report:
- Confirm the last known location and time the student was seen.
- Attempt to contact the student directly and verify their well-being.
- Contact the school contact and DSL or other known parties who may have seen the student.
- Inform the local police if the student is not located within 2 hours or earlier if circumstances indicate immediate danger.
- Notify the student’s legal guardian or emergency contact promptly.
3. Immediate Actions
- Within 1 Hour: Attempt all reasonable methods to locate the student (calls, messages, social media, friends).
- Within 2 Hours: If the student remains unlocated and there is no reasonable explanation, the police must be contacted.
- After Police Notification: Work in cooperation with law enforcement and provide all necessary information (student’s photo, description, schedule, known associates).
4. Information to Provide to Authorities
- Full name, age, and physical description of the student.
- Last known location and time.
- Student’s mobile number and social media accounts.
- Known friends or frequent locations.
- Any recent changes in behaviour or unusual incidents.
- Medical or mental health concerns (if relevant and available).
5. Prevention and Preparation
- All students and host families will receive this policy upon orientation.
- Students must provide updated emergency contact information and daily routines.
- Encourage students to check in regularly and inform their host family or program of changes in plans.
- Maintain up-to-date contact lists for students, families, and Gabbitas staff.
6. Follow-Up
- Once the student is found, the Gabbitas Consultant must confirm their safety and document the incident.
- A debrief will be conducted with the student and host family to understand the cause and prevent recurrence.
- In serious or repeated cases, disciplinary action or reassessment of homestay placement may be considered.
Acknowledgment
All parties involved in the homestay program must review and agree to follow this policy to ensure the safety of all students.
Appendix H
Gabbitas Online Safety and Acceptable Use Policy
Effective Date: June 2025
Review Date: June 2026
1. Purpose
The purpose of this policy is to ensure that all students, staff, and other stakeholders understand how to use the internet and digital technologies safely, responsibly, and ethically within Gabbitas. This policy aims to:
- Protect users from online risks including cyberbullying, data breaches, and exposure to inappropriate content.
- Promote the responsible use of digital technologies.
- Provide clear guidelines for acceptable online behaviour and digital communication.
2. Scope
This policy applies to all users of Gabbitas’ internet, networks, email systems, digital platforms, and any personal devices used on-site or for school/work-related purposes. It includes:
- Students
- Staff and educators
- Administrators
- Volunteers and contractors
3. Roles and Responsibilities
3.1 Institution Management
- Ensure infrastructure includes filters, monitoring, and security software.
- Provide training and support on online safety.
- Review and update the policy regularly.
3.2 Staff
- Model safe and responsible online behaviour.
- Report any concerns or incidents to the designated safeguarding lead.
- Supervise students during online activities.
3.3 Students
- Use all digital tools respectfully and appropriately.
- Never share personal information online.
- Report any suspicious or harmful activity immediately.
3.4 Parents/Guardians
- Reinforce online safety practices at home.
- Monitor and support children’s online activity.
- Report any online concerns involving school systems.
4. Acceptable Use Guidelines
✅ Acceptable
- Using devices for learning, research, and communication related to school/work.
- Engaging respectfully with others online.
- Accessing only age-appropriate websites and tools.
❌ Unacceptable
- Accessing or sharing inappropriate or harmful content.
- Cyberbullying or online harassment.
- Using school/work systems for illegal or personal commercial activities.
- Sharing personal or others’ private information without consent.
5. Online Conduct
All users must:
- Follow netiquette (online etiquette).
- Use strong, secure passwords and keep them confidential.
- Log out of accounts when finished.
- Avoid clicking unknown or suspicious links or attachments.
6. Monitoring and Filtering
The institution will:
- Monitor internet activity to detect misuse or harmful behaviour.
- Use filtering systems to block inappropriate content.
- Conduct regular audits of digital use and security.
7. Reporting and Response
Any user who encounters or witnesses:
- Inappropriate content
- Cyberbullying
- Suspected breaches of policy should report it immediately to a teacher, manager, host family or designated safeguarding officer (Gabbitas – Danielle Flood).
Disciplinary actions may include:
- Temporary or permanent loss of digital privileges.
- Parent/guardian notification.
- Suspension or further disciplinary review depending on severity.
8. Data Protection and Privacy
All digital activity is subject to the institution’s Data Protection Policy. Personal data must be collected, stored, and shared in compliance with GDPR.
9. Training and Awareness
Regular training on online safety will be provided to:
- Staff and faculty
- Students (age-appropriate)
- Parents and guardians (where applicable)
- Host families
10. Policy Review
This policy will be reviewed annually or after any significant incident involving online safety. Feedback from staff, students, and parents will be considered in the review.
Appendix I
Data Protection Policy
Effective Date: June 2025
Review Date: June 2026
Your Privacy
Gabbitas is committed to protecting your privacy when you use our services.
The privacy statement below explains how we use information about you and how we protect your privacy.
From 25 May 2018, your personal information will be processed, held and/or controlled in accordance with the General Data Protection Regulations (2016/679).
We have a data protection officer to make sure that we respect your rights and follow the law. You may contact them at any time to:
- request access to information which Gabbitas has about you
- correct any information which Gabbitas has about you
- ask for any information which Gabbitas has about you to be deleted
- discuss any concerns or ask any questions about how we look after your personal information
Please contact info@gabbitas.com or write to:
Gabbitas Ltd.
17 Cavendish Square
London
England
W1G 0PH
Information we collect
Do you know what personal information is?
We may collect personal information about you. This can be anything that identifies and relates to a living person and can include information that when put together with other information can then identify the person. For example, this could be your name, contact details, email address and/or telephone number.
Did you know that some of your personal information might be ‘special’?
Some information is ‘special’ and needs more protection due to its sensitivity. It’s often information you would not want widely known and is very personal to you. This is likely to include anything that can reveal your:
- sexuality and sexual health
- religious or philosophical beliefs
- ethnicity
- physical or mental health
- trade union membership
- political opinion
- genetic/biometric data
- criminal history
Why do we need your personal information?
We may need to use some information about you to:
- deliver services and support to you
- manage those services we provide to you
- train and manage the employment of our workers who deliver those services
- help investigate any worries or complaints you have about your services and to answer your questions and enquiries
- allow you to participate in online training and interactive features of our services if you choose to
- check and improve the quality of our services
- help with research and planning of new services
- send you information which we think might be of interest to you if you have agreed to this
- send to third parties where we have retained them to provide services that we, you or our client have requested
- monitor compliance with our equal opportunities policy
- carry out our obligations arising from any contracts entered into between you and us
- market our related products and services to you, where you have given your consent for us to do so
We reserve the right to transfer your data if Gabbitas is sold, goes into a merger, liquidation or receivership or transfers all, or substantially all, of its assets to a new owner. This will only take place if the third party agrees to adhere to the terms of this privacy statement. We will let you know of any such transfer and you will be able to opt-out if you wish.
How the law allows us to use your personal information
Gabbitas processes personal data, both as a Data Controller and as a Data Processor, as defined by relevant Data Protection Legislation: the General Data Protection Regulations 2016/679, the Data Protection Act 1998, the EU Data Protection Directive 95/46/EC, the Regulation of Investigatory Powers Act 2000, the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699), the Electronic Communications Data Protection Directive 2002/58/EC, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and all applicable laws and regulations relating to processing of personal data and privacy, including where applicable the guidance and codes of practice issued by the Information Commissioner.
There are a number of legal reasons why we need to collect and use your personal information. Generally, we collect and use personal information where:
- you, or your legal representative, have given consent
- you have entered into a contract with us
- it is necessary to perform our statutory duties
- it is required by law
- it is necessary for employment purposes
- you have made your information publicly available
- it is necessary for legal cases
- it is to the benefit of society as a whole
- it is necessary for archiving, research, or statistical purposes
If we have consent to use your personal information, rather than for legal or contractual reasons, you have the right to remove it at any time. If you want to remove your consent, please contact info@gabbitas.com and tell us which service you’re using so we can deal with your request.
We only use what we need
We’ll only collect and use personal information if we need it to deliver a service or meet a requirement.
If we don’t need personal information we’ll either keep you anonymous if we already have it for something else or we won’t ask you for it. For example, in a survey we may not need your contact details we’ll only collect your survey responses.
If we use your personal information for research and analysis, we’ll always keep you anonymous or use a different name unless you’ve agreed that your personal information can be used for that research.
We don’t sell your personal information to anyone else.
What you can do with your information
The law gives you a number of rights to control what personal information is used by us and how it is used by us.
You can ask for access to the information we hold about you
We would normally expect to share what we record about you with you, whenever we assess your needs or provide you with services.
However, you also have the right to ask for all the information we have about you and the services you receive from us. When we receive a request from you in, we must give you access to everything we’ve recorded about you.
However, we can’t let you see any parts of your record which contain:
- confidential information about other people; or
- data a professional advisor thinks will cause serious harm to your or someone else’s physical or mental wellbeing; or
- if we think that giving you the information may stop us from preventing or detecting a crime
This applies to personal information that is in both paper and electronic records.
If you ask us for access to your information then we’ll ask you to provide evidence so that we can verify your identity.
If you have any queries about access to your information please contact info@gabbitas.com.
You can ask to change information you think is inaccurate
You should let us know if you disagree with something written on your file.
We may not always be able to change or remove that information but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
If you ask us to change the information we hold about you then we’ll ask you to provide evidence so that we can verify your identity.
To inform us of any inaccuracies please write to us at:
Gabbitas Ltd.
17 Cavendish Squar
London
England W1G 0PH
You can ask to delete information (the right to be forgotten)
In some circumstances you can ask for your personal information to be deleted, for example:
- where your personal information is no longer needed for the reason it was collected in the first place
- where you have removed your consent for us to use your information (where there is no other legal reason for us to use it)
- where there is no legal reason for the use of your information
- where deleting the information is a legal requirement
Where your personal information has been shared with others, we’ll do what we can to make sure those using your personal information comply with your request for erasure.
Please note that we can’t delete your information where:
- we’re required to have it by law
- it is used for freedom of expression
- it is for scientific or historical research or statistical purposes where it would make information unusable
- it is necessary for legal claims
You can ask to limit what we use your personal data for
You have the right to ask us to restrict what we use your personal information for where:
- you have identified inaccurate information and have told us of it
- we have no legal reason to use that information but you want us to restrict what we use it for rather than erase the information altogether
When information is restricted it can’t be used other than to store securely the data and with your consent; or, to handle legal claims and protect others, or where it’s for important public interests of the UK.
Where restriction of use has been granted, we’ll inform you before we carry on using your personal information.
You have the right to ask us to stop using your personal information for any service we provide. You also have the right to unsubscribe from any materials we may send you. However, if you make a request this may cause delays or prevent us delivering services to you.
Where possible we’ll seek to comply with your request, but we may need to hold or use information because we are required to by law or by contract.
If you wish to contact us with respect to these matters please contact us at info@gabbitas.com.
You can ask to have your information moved to another provider (data portability)
You have the right to ask for your personal information to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.
However, this only applies if we’re using your personal information with consent (not if we’re required to by law).
You can ask to have any ‘computer-made’ decisions explained to you, or choose not to be the subject of a decision which is based on automated processing. You have the right to question decisions made about you by a computer, unless it’s required for any contract you have entered into, required by law, or you’ve consented to it.
You also have the right to object if you are being ‘profiled’. Profiling is where decisions are made about you based on certain things in your personal information, e.g. your health conditions.
If Gabbitas uses your personal information to profile you, to deliver the most appropriate service to you, you will be informed.
If you have concerns regarding automated decision-making, or profiling, please contact info@gabbitas.com where we’ll be able to advise you about how we are using your information.
Who do we share your information with?
We use a range of organisations to either store personal information or help deliver our services to you. Where we have these arrangements, there is always an agreement in in place to make sure that the organisation complies with data protection law.
We’ll often complete a data protection impact assessment (DPIA) before we share personal information to make sure we protect your privacy and comply with the law.
Sometimes we have a legal duty to provide personal information to other organisations. This may be because we need to give that data to the courts.
We may also share your personal information when we feel there’s a good reason that’s more important than protecting your privacy. This doesn’t happen often, but we may share your information:
- to find and stop crime and fraud
- if there are serious risks to the public, our staff or to other professionals
- to protect a child
- to protect adults who are thought to be at risk, for example if they are frail, confused or cannot understand what is happening to them
For all of these reasons the risk must be serious before we can override your right to privacy.
If we’re worried about your physical safety or feel we need to take action to protect you from being harmed in other ways, we’ll discuss this with you and, if possible, get your permission to tell others about your situation before doing so.
We may still share your information if we believe the risk to others is serious enough to do so.
There may also be rare occasions when the risk to others is so great that we need to share information straight away. If this is the case, we’ll make sure that we record what information we share and our reasons for doing so. We’ll let you know what we’ve done and why if we think it is safe to do so.
How do we protect your information?
We’ll do what we can to make sure we hold records about you (on paper and electronically) in a secure way, and we’ll only make them available to those who have a right to see them. Examples of our security include:
- encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password). This is done with a secret code or what’s called a ‘cypher’. The hidden information is said to then be ‘encrypted’
- controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it
- training for our staff allows us to make them aware of how to handle information and how and when to report when something goes wrong
- regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches)
Where in the world is your information?
The majority of personal information is stored on systems in the UK. But there are some occasions where your information may leave the UK either in order to get to another organisation or if it’s stored in a system within the EU.
We have additional protections on your information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with that third party.
We’ll take all practical steps to make sure your personal information is not sent to a country that is not seen as ‘safe’ either by the UK or EU Governments.
We will only keep your information for as long as we need it
We will retain your personal information only for as long as we need it in order to fulfil the purposes for which we have initially collected it, unless otherwise required by law or contractual requirements. Safeguarding records will be retained as per KCSIE guidelines.
Where can I get advice?
If you have any worries or questions about how your personal information is handled please contact us using the details at the top of this page.
For independent advice about data protection, privacy and data sharing issues or if you would like to make a complaint if you think we have done something wrong with the data we hold about you, you can contact the Information Commissioner’s Office (ICO) at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Alternatively, visit www.ico.org.uk or email casework@ico.org.uk.
Changes to our Privacy Statement
From time to time we may make changes to this privacy statement. Any changes will be posted on this website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use personal data in a manner significantly different from that stated in this privacy statement, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice as to whether or not we use your information in the new manner.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Cookies and how you use this website
To make this website easier to use, we sometimes place small text files on your device (for example your iPad or laptop) called cookies. Most big websites do this too.
Cookies improve things by:
- remembering the things you’ve chosen while on our website, so you don’t have to keep re-entering them whenever you visit a new page
- remembering data you’ve given (for example, your address) so you don’t need to keep entering it
- measuring how you use the website so we can make sure it meets your needs
By using our website, you agree that we can place these types of cookies on your device.
We don’t use cookies on this website that collect information about what other websites you visit (often referred to as privacy intrusive cookies).
Our cookies aren’t used to identify you personally. They’re just here to make the site work better for you. You can manage and/or delete these files as you wish.
To learn more about cookies and how to manage them, visit www.AboutCookies.org or watch a video about cookies.
Other people’s cookies
We use videos from YouTube and feeds from other websites such as Facebook and Twitter. These websites place cookies on your device when watching or viewing these pages.
Below are links to their cookie policies:
Turning off cookies
You can stop cookies being downloaded onto your computer or other device by selecting the appropriate settings on your browser. If you do this you may not be able to use the full functionality of this website.
There is more information about how to delete or stop using cookies on www.AboutCookies.org.
Further guidance on the use of personal information can be found at www.ico.org.uk.
Appendix J
Welfare, Health, and Safety Policy
Effective Date: June 2025
Review Date: June 2026
1. Purpose
This policy sets out the commitment of Gabbitas to safeguarding and promoting the welfare, health, and safety of all students under our guardianship and living with homestay families. We aim to provide a safe, nurturing environment that supports students’ academic success, emotional well-being, and personal development.
2. Scope
This policy applies to:
- All staff and volunteers of the guardianship organization
- All registered homestay families
- All students under the care of the organisation
- Partner schools and agencies (where applicable)
3. Guiding Principles
- Student-Centred Care: All decisions and actions prioritize the student’s welfare, safety, and best interests.
- Zero Tolerance for Harm: Any form of abuse, neglect, or exploitation will not be tolerated.
- Proactive Safeguarding: Preventive measures will be taken to minimize risk and respond promptly to concerns.
- Cultural Sensitivity and Inclusion: All students will be respected regardless of their background, nationality, gender, religion, or personal identity.
4. Responsibilities
4.1 The Guardianship Organisation
- Ensure all staff, homestay hosts, and volunteers are properly vetted (including background checks).
- Train staff and homestay hosts on child protection and emergency procedures.
- Provide 24/7 emergency contact support for students and hosts.
- Conduct regular welfare checks with students and host families.
- Maintain up-to-date student records, including health information and emergency contacts.
4.2 Homestay Families
- Provide a safe, clean, and welcoming home environment.
- Offer emotional support, healthy meals, and supervision appropriate to the student’s age.
- Follow all health and safety guidelines outlined by the organisation.
- Report any welfare concerns, illnesses, or injuries promptly.
- Ensure students know how to seek help if they feel unsafe.
4.3 Students
- Respect homestay rules and guidelines.
- Report any health or safety concerns to their host, guardian, or school.
- Behave responsibly and avoid risky or dangerous activities.
- Follow local laws and school regulations.
5. Health and Medical Care
- Ensure students have access to medical care, including registration with a local doctor (GP).
- Hosts must inform the organisation immediately in case of illness, injury, or hospitalisation.
- Medication should only be administered under appropriate supervision and with parental consent (when applicable).
- Any serious health concerns must be recorded and reported to parents/guardians.
6. Mental Health and Emotional Wellbeing
- Promote a supportive atmosphere that fosters open communication.
- Train staff and hosts to recognize signs of stress, anxiety, or depression.
- Provide access to counselling or mental health support when needed via local mental health support providers and working alongside the school.
- Respect students’ privacy while ensuring they are not isolated or withdrawn.
7. Safeguarding and Child Protection
- All safeguarding concerns must be reported immediately to the designated safeguarding lead (DSL).
- All guardianship staff and homestay families must undergo safeguarding training.
- Allegations of abuse or harm will be handled in accordance with national safeguarding laws and referred to appropriate authorities.
8. Health and Safety in the Homestay Environment
- Homestay homes must meet basic safety standards including:
-
- Functioning smoke and carbon monoxide alarms
- Safe electrical and heating systems
- Clear emergency exits and evacuation plans
- Secure and hygienic living conditions
-
- Hosts must ensure students know what to do in an emergency (e.g., fire drill, first aid, calling emergency services).
9. Supervision and Curfews (for Minors)
- Homestay hosts must supervise students according to age and maturity.
- Enforce reasonable curfews as agreed with the guardianship organisation and parents.
- Ensure students are not left unsupervised overnight without prior approval.
10. Transportation and Travel Safety
- Ensure safe transportation to and from school or activities.
- Students must seek permission from their guardian and homestay family before traveling independently or staying away overnight.
11. Monitoring and Compliance
- Regular home visits and termly welfare checks will be conducted.
- Hosts and staff must complete required training and renew background checks as scheduled.
- Non-compliance with this policy may result in removal from the program or disciplinary action.
12. Emergency Procedures
- 24/7 emergency contact must be available to students and hosts.
- All serious incidents (medical emergencies, missing students, accidents) must be reported immediately to the organisation.
- A full incident report must be completed within 24 hours of any emergency.
13. Review
This policy will be reviewed annually or following any significant incident, change in law, or guidance.
Appendix K
Pandemic Procedure Policy
Effective Date: June 2025
Review Date: June 2026
1. Purpose
The purpose of this policy is to establish clear guidelines and procedures to ensure the health, safety, and welfare of students, host families, and staff during a pandemic. The policy supports continuity of care and education, while minimizing the risk of infection and disruption.
2. Scope
This policy applies to:
- All students under guardianship
- All host families (homestay providers)
- Guardianship organisation staff
- Partner schools and transport providers
3. Objectives
- To safeguard the physical and mental health of students.
- To ensure timely communication with parents, schools, and hosts.
- To comply with public health advice and legal requirements.
- To maintain continuity of care and guardianship services.
- To manage isolation, quarantine, and medical needs appropriately.
4. Key Roles and Responsibilities
4.1 Gabbitas
- Monitor updates from health authorities (e.g., WHO, CDC, NHS, local health departments).
- Communicate regularly with families, students, and hosts.
- Develop and maintain contingency plans for lockdowns, travel restrictions, or school closures.
- Provide emergency support and guidance to students and hosts 24/7.
- Maintain a record of student health and isolation status.
4.2 Host Families
- Follow public health guidance regarding hygiene, mask-wearing, testing, and social distancing.
- Monitor students for symptoms of illness and report concerns promptly.
- Support students during isolation or quarantine, including meals, care, and emotional support.
- Ensure cleaning and sanitisation procedures are followed in the home.
- Inform the guardianship organisation immediately of any confirmed or suspected illness in the household.
4.3 Students
- Follow all public health and school-specific pandemic protocols.
- Report symptoms or health concerns promptly to their host family and guardianship consultant.
- Comply with testing, isolation, or quarantine requirements.
- Maintain regular contact with their guardianship consultant.
5. Health Monitoring and Illness Response
If a Student Becomes Unwell or Shows Symptoms:
- Isolate the student immediately from other household members.
- Arrange for a COVID-19 or other relevant test as per government advice.
- Notify Gabbitas and the student’s school.
- If symptoms worsen, seek medical advice or emergency services as appropriate.
- Maintain daily contact with the student and provide emotional support.
6. Quarantine and Isolation Arrangements
- A designated isolation space within the homestay should be available where possible.
- If in-home isolation is not suitable, alternative arrangements (e.g., temporary accommodation) may be made by the Gabbitas.
- Hosts must ensure isolated students have access to meals, internet, study materials, and hygiene products.
- Gabbitas will check in with the student and host daily during any isolation period.
- The cost of any quarantine or isolation stays will be covered by the student and their parents.
7. Travel and Relocation
- All international or domestic travel must follow the latest entry, exit, and quarantine regulations.
- Students should not travel without prior approval from Gabbitas and parents.
- In case of border closures or flight cancellations, contingency accommodation will be provided.
- Travel plans should include:
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- Emergency contacts
- Health documentation (e.g., vaccination records, negative test results)
- Insurance coverage for pandemic-related issues
-
8. Education and School Closures
- If in-person schooling is suspended:
-
- Ensure the student can access online learning platforms.
- Provide a quiet, equipped space for study.
- Maintain communication with the school and support academic progress.
-
- Gabbitas will liaise with schools to ensure continuity of education and welfare support.
9. Mental Health and Wellbeing
- Encourage open discussion about feelings of anxiety, isolation, or homesickness.
- Provide resources for mental health support (e.g., counselling services, online helplines).
- Guardianship consultants will check in regularly with students and hosts to assess wellbeing.
10. Communication
- Provide regular updates to parents/guardians about student wellbeing and relevant health guidelines.
- Emergency contact lines will remain active 24/7.
- All stakeholders will be notified immediately of any confirmed cases or critical changes affecting care.
11. Supplies and Preparedness
Host families and students should be prepared with:
- Masks and hand sanitiser
- Thermometer
- Basic over-the-counter medicines
- Personal hygiene supplies
- Access to food delivery or groceries in case of isolation
12. Policy Review
This policy will be reviewed regularly and updated in line with evolving public health guidance or legal requirements.
Appendix L
Whistle-Blowing Policy
Effective Date: June 2025
Review Date: June 2026
INTRODUCTION
Under certain circumstances, employees are protected from suffering any detriment or termination of employment if they make disclosures about organisations for whom they work.
QUALIFYING DISCLOSURES
Certain disclosures are prescribed by law as “qualifying disclosures”. A “qualifying disclosure” means a disclosure of information that the employee genuinely and reasonably believes is in the public interest and shows that the Company has committed a “relevant failure” by:
a) committing a criminal offence;
b) failing to comply with a legal obligation;
c) a miscarriage of justice;
d) endangering the health and safety of an individual;
e) environmental damage; or
f) concealing any information relating to the above.
These acts can be in the past, present or future, so that, for example, a disclosure qualifies if it relates to environmental damage that has happened, is happening, or is likely to happen. The Company will take any concerns that you may raise relating to the above matters very seriously.
The Employment Rights Act 1996 provides protection for workers who ‘blow the whistle’ where they reasonably believe that some form of illegality, injustice or breach of health and safety has occurred or is likely to occur. The disclosure has to be “in the public interest”. We encourage you to use the procedure to raise any such concerns.
THE PROCEDURE
In the first instance you should report any concerns you may have to a Director via email oninfo@gabbitas.com who will treat the matter with complete confidence. If you are not satisfied with the explanation or reason given to you, you should raise the matter with the appropriate official organisation or regulatory body.
TREATMENT BY OTHERS
Bullying, harassment or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure is unacceptable. Anyone found to have acted in such a manner will be subject to disciplinary action.
