Data Protection Policy 

For the purpose of data protection legislation, the data controller is Curo Interiors of 167-169 Great Portland Street, London, W1W 5PF © Curo Interiors 2022. 

This policy is overseen by our directors Steve Conlin and Darren Pettitt. If you have any queries, complaints or requests please contact [email protected] or +44 (0) 20 7993 1312. 

What information do we collect from you? 

We will collect and process the following data about you: 

Information you give us. This is information about you that you give us directly. You may do this by filling in forms on our website or by corresponding with us by phone, email or otherwise. Information you send to us may be stored and processed by Curo Interiors Ltd. This will include any emails or other electronic messages and any documents, photos or other files stored on or processed through our systems or devices. Please be aware that by entering information onto these systems you are sharing that information with Curo Interiors Ltd. 

Information we collect throughout our relationship. We will collect information throughout your time with us. This may include information about location, employees, projects, working hours and other relevant information. 

The type of information we collect. This may include, but is not limited to the following (and may include Special Categories of Personal Data as defined below): 

• Identification information – name, title. 
• Contact details – address, telephone number, mobile telephone number, email address. 
• Employment related information – job title, company, business contact information, CV and employment application. 

• Browsing behaviour – When you visit our site we may collect information about your online browsing behaviour and any devices you have used to access our site (including your IP address, browser type and mobile device identifiers). 
• Location – We may collect your location data through your IP address. 
• Preferences – We collect what Curo Interiors services you are interested in and the sectors that you wish to be updated on. 
• Dietary requirements – In some cases, such as for attendance at catered events, we may collect and process special dietary requirements for reasons of health or religion. 
• Information about your health – In some cases, we may collect information which is categorised as health data such as in respect of accessibility to buildings or accessibility to documents and other materials 
• Equality and Diversity – You may choose to share information about your ethnicity, sexuality or beliefs with us for inclusion purposes. This information will be treated as highly confidential. 
• Other data which we may notify you of from time to time. 
• Opinion – Curo Interiors may also contact you to ask you to take part in voluntary surveys to hear your opinion of current services or of potential new services on offer. If you choose to take part in these surveys, we will collect the information you provide. We also collect data you provide in emails and phone calls for example, your questions to customer support. 

Why do we collect this information? 

Information you give to us and that we collect. We process your Personal Data for the following reasons: 

• Inform you of our services through email, mail, telephone, or SMS text message; 
• Send you information on promotional content; 
• Remember you when you visit our website and see how you journey through it by using cookies; 
• Remember you when you use our forms to download content or sign up for a newsletter; 
• Supply, improve and support the services we provide; 
• Keep our site and systems safe and secure; 
• Ensuring and protecting the health and safety of our workforce; 
• Understand our customer base and purchasing trends; 
• Defend against or exercise legal claims and investigate complaints; and 
• Understand the effectiveness of our marketing. 

Based on performance of our contract with you, or to take steps at your request to enter into a contract with you, for example: 

• When applying for a vacancy advertised on our website; or 
• In performing our obligations under our contract to which you are a party. 

Pursuant to our legal obligations: 

• The provision of products and services; 
• Data protection; 
• Health and safety; 
• Anti-money laundering; 
• Fraud investigations; 
• Assisting law enforcement; and 

Any other legal obligations placed on us from time to time. We may also process data on the basis of your consent or explicit consent. 

• Where we rely on your consent for processing this will be brought to your attention when the information is collected from you. 

We may inform you of additional purposes for processing your information when that information is collected from you. Information we receive from other sources. See the ‘Who might we share your information with?’ section below for details of how we use information in conjunction with third parties.We may inform you of additional purposes for processing your information when that information is collected from you. 

How can you choose and control what information we send you? 

You can choose whether you wish to opt out of receiving promotional emails, SMS messages and telephone calls from Curo Interiors by contacting [email protected].

How long do we keep hold of your information? 

We only store your information for as long as is required for the purpose it was collected. Should you wish to have more information about how long we retain your data, please contact [email protected] or +44 (0) 20 7993 1312. Information stored generally on IT systems, such as email history, will be deleted regularly in line with our policies. 

Automated decision making 

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances: 

1. Where we have notified you of the decision and given you 21 days to request a reconsideration. 

2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights. 

3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights. 

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights. 

Who might we share your information with? 

Where information is shared with third parties, we will only share the information required for the purpose it is being shared. For the purposes set out in the ‘Why do we collect this information?’ section above, we have the right to share your personal information with: 

• Our clients. 
• Our suppliers and sub-contractors and the suppliers and subcontractors of our clients where required. 

Additionally, we will disclose your personal information to the relevant third party: 

• In the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets. 
• To third parties when it is necessary for the establishment, exercise or defence of legal claims. 
• If we are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets. 
• If we choose to exercise a legal power to do so. 
• If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply contractual terms or other agreements; or to protect the rights, property, or safety of ourselves our customers, our regulator, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention of money laundering and credit risk reduction. 

How your data is stored and kept secure? 

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from [email protected]. 

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. 

We may transfer your data outside the European Economic Area (“EEA”). We will only do so if adequate protection measures are in place in compliance with data protection legislation. We use the following protection measures: 

• Transferring to Commission approved countries; 
• Using Commission approved model contractual clauses; 
• Requiring companies to whom we transfer data to be signed up to appropriate certification; or 
• Transferring when one or more of the conditions set out in Article 49 GDPR are met. 

What are your rights? 

You have the following rights. You can exercise these rights at any time by contacting Curo Construction Ltd. You can make a subject access request verbally or in writing. In order to deal with your request effectively, it would be helpful if you could contact [email protected] in the first instance. Curo Interiors may be contacted in the following ways: By post: Suite 6, Sandhurst House, 297 Yorktown Road, Sandhurst, Berkshire, GU47 0QA. By email: [email protected]

By telephone: +44 (0) 20 7993 1312. 

You have the right: 

• To ask us not to process your Personal Data for marketing purposes; 
• To ask us not to process your Personal Data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing; 
• Where processing of your Personal Data is based on consent, to withdraw that consent at any time. 
• To request from us access to personal information held about you; 
• To ask for the information we hold about you to be rectified if it is inaccurate or incomplete; 
• To ask for data to be erased provided that the Personal Data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate ground for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation; 
• To ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the Personal Data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing); or 
• To ask for data portability if the processing is carried out by automated means and the legal basis for processing is consent or contract. 

Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us using the contact details above. In the event that you are not satisfied with our processing of your Personal Data, you have the right to lodge a complaint with the relevant supervisory authority, which is the Information Commissioner’s Office (ICO) in the UK, at any time. The ICO’s contact details are available here: https://ico.org.uk/concerns/ 

What we ask of you 

Keeping your information accurate and up to date. If your information changes for any reason, for example if you change your name, address, then you should inform us of the change as soon as possible so that we can ensure your information is kept accurate and up to date. Business cards. If you issue business cards to us your data will be processed by those who you share the business cards with. It is reasonably expected that the data will only be processed by those you share it with for business purposes, principally, to contact you in relation to your role and your business. 

Definitions 

Personal Data: Any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier, such identifiers including name, location data or online identifier. Special Categories of Data includes data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. 

Environmental Policy Statement

The company is committed to protecting the environment by complying with all relevant UK legislation, meeting national standards relating to the environment and in accordance with best working practices currently in use by the industry. This is an ongoing commitment which requires working procedures to be frequently reviewed and adapted to reflect the continual changes to ensure the company is at the forefront of the changes with regards to environmental protection and sustainable progression. 

The company uses the word environment to cover natural environment and ecosystems as well as the built environment and the effect the company’s operations can have on people’s lives and heritage. This pledge to environmental protection is further extended to protect the health & safety of employees and the public in general so that the company’s impact on people’s environment is beneficial and not harmful. 

To achieve these objectives the company will: 

• Fully comply with current legislation, our own company operating procedures and/or clients operating procedures to ensure the highest standards are obtained. The company is not satisfied with merely satisfying minimum legal requirements but will be proactive with its clients in setting and achieving higher standards when practicable. 
• Remain committed in reducing its carbon footprint year on year reducing carbon emissions. 
• Minimising the impact of the company’s activities and those appointed by them by adopting best practices that are available at that time. This maxim will be applied to all aspects of the company’s activities including design, site operations, selection and use of plant & transport, energy efficiency, re-use and recycling options, and waste minimisation 
• Ensure that adequate resources are made available to fully implement the objectives of this policy. 
• Retain staff, reducing churn within the fabric of the company’s operation. 

With regards to fixed location operations, the company will carry out an environmental impact assessment of the premises and activities and produce an action plan covering what changes can be made to reduce the effect. 

With regards to site activities, environmental issues will be considered along with quality and health & safety issues at the planning stage and the environment impact assessment will be incorporated into the project health, safety & environmental plan and agreed with the client before work commences. 

The environmental performance of the company is to be monitored by those nominated and will be reviewed annually by the SHE Director. Objectives will be set, and the monitoring and review is to ensure the company is achieving these objectives. This review will also take into account changes in legislation, advances in technological knowledge and changes in industrial practice, and if required, the company’s objectives will be re-set taking into account these changes. 

The company is committed to reducing its carbon footprint within its operation year on year. 

The company is aware of IS0 14001 and will adopt the philosophy detailed in these standards in its operations. 

This environmental policy is approved by the Directors and will be subject to an ongoing annual review by the SHE Director. 

Steve Conlin,

Director

Date: 23 September 2022 

Equality & Diversity Policy

The Company is committed to the principle of equal opportunity in employment. 

The terms equality, inclusion and diversity are at the heart of this policy. Equality means ensuring everyone has the same opportunities to fulfil their potential free from discrimination. Inclusion means ensuring everyone feels comfortable to be themselves at work and feels the worth of their contribution. Diversity means the celebration of individual differences amongst the workforce. We will actively support diversity and inclusion and ensure that all our employees are valued and treated with dignity and respect. We want to encourage everyone in our business to reach their potential. 

We value people as individuals with diverse opinions, cultures, lifestyles and circumstances. All job applicants, employees and workers, including agency workers, are covered by this policy and it applies to all areas of employment including recruitment, selection, training, career development, and promotion. These areas are monitored and policies and practices are amended if necessary to ensure that no unfair or unlawful discrimination, intentional, unintentional, direct or indirect, overt or latent exists. 

Equality of opportunity, valuing diversity and compliance with the law is to the benefit of all individuals in our Company as it seeks to develop the skills and abilities of its people. While specific responsibility for eliminating discrimination and providing equality of opportunity lies with managers and supervisors, individuals at all levels have a responsibility to treat others with dignity and respect. The personal commitment of every employee to this policy and application of its principles are essential to eliminate discrimination and provide equality throughout the Company. 

Management will ensure that recruitment, selection, training, development and promotion procedures result in no job applicant, employee, or worker receiving less favourable treatment because of a protected characteristic within the Equality Act 2010 which are race, including colour, nationality, ethnic or national origin and caste; religion or belief; disability; sex; sexual orientation; pregnancy or maternity; gender reassignment; marriage or civil partnership; and age. In accordance with our overarching equal treatment ethos, we will also ensure that no one is treated less favourably on account of their trade union membership or non-membership, or on the basis of being a part-time worker or fixed-term employee. The Company’s objective is to ensure that individuals are selected, promoted, and otherwise treated solely on the basis of their relevant aptitudes, skills and abilities. 

We will ensure that the policy is circulated to any agencies responsible for our recruitment and a copy of the policy will be made available for all employees and made known to all applicants for employment. 

The policy will be communicated to all private contractors reminding them of their responsibilities towards the equality of opportunity. 

The policy will be implemented in accordance with the appropriate statutory requirements and full account will be taken of all available guidance and in particular any relevant Codes of Practice. 

Management has the primary responsibility for successfully meeting these objectives by: 

not discriminating in the course of engagement against employees, workers or job applicants; 

• not inducing or attempting to induce others to practise unlawful discrimination; 
• bringing to the attention of our workforce that they may be subject to action under the disciplinary procedure, or other appropriate action, for unlawful discrimination of any kind. 

You can contribute by: 

• not discriminating against fellow employees, workers, customers, clients, suppliers or members of the public with whom you come into contact during the course of your duties; 
• not inducing or attempting to induce others to practise unlawful discrimination; 
• reporting any discriminatory action to the Managing Director. 

The successful achievement of these objectives necessitates a contribution from everyone and you have an obligation to report any act of discrimination known to you. 

If you consider that you are a victim of unlawful discrimination you may raise the issue through the grievance procedure. 

For and on behalf of Curo Interiors 

Steve Conlin,

Director

Date: 23 September 2022 

Modern Slavery & Human Trafficking Policy

Curo Interiors recognises that modern slavery and human trafficking is a violation of fundamental human rights and is contrary to the Modern Slavery Act 2015 (the “Act”). 

Curo Interiors takes a zero tolerance approach to non-compliance with this Policy and will not tolerate any slavery or human trafficking in any part of its business or in any part of its supply chain. This Policy applies to all CURO INTERIORS ’s officers, directors and employees, whether permanent or temporary. It also applies to CURO INTERIORS ’s supply chain, which must ensure that both its business and that of its supply chain worldwide comply with this Policy. 

Curo Interiors will take steps to ensure that modern slavery and human trafficking are not taking place in its own business or within any of its supply chain. This will be achieved by ensuring that: 

• Suppliers must comply and act in accordance with this Policy. Its Strategic and Preferred supplier base must be accredited to an Achilles third party scheme. Modern Slavery compliance is covered in this. All other Suppliers must have submitted a Pre-qualification document, which also covers the Act. 
• All recruitment is carried out in a fair and transparent manner and will comply with relevant legislation and standards. 
• The requirements and expectations made of the supply chain in relation to the Act will be clearly communicated and included within contractual terms. 
• Suppliers will be expected to comply with the Immigration, Asylum and Nationality Act 2006. 
• Costain will take a partnership approach with regards to working with its suppliers to combat the threat of modern slavery and human trafficking across its sectors and all the industries in which it operates. 
• Costain will train appropriate staff to understand the risks and issues surrounding modern slavery and human trafficking, how to identify it and appropriate measures to prevent it. 

Every Curo Interiors employee has an individual responsibility to ensure compliance with this Policy, including being alert to the risk of such unlawful practices. Any concerns may be reported to the CURO INTERIORS Risk Management function. 

Curo Interiors considers a breach of this Policy as a serious offence. Any violation of this Policy or the Act by an employee will result in disciplinary action, up to and including dismissal in appropriate circumstances. In addition, Curo Interiors will notify the relevant authorities of an individual or a supplier’s contravention of the Act. 

This Policy will be reviewed annually to ensure that it reflects current legislation and regulations. 

For and on behalf of Curo Interiors. 

Steve Conlin,

Director

Date: 23 September 2022