- This Communications, Email, and Internet Policy applies to all employees, contractors, and agents of Role Models Life Skills Limited who use the communications equipment, computers, devices, and systems provided by the Company (“Users”).
- Users are encouraged to use email and the internet at work as a fast and reliable method of communication with significant advantages for business.
- In light of the fact that communications made by Users and their other activities online reflect upon the Company and are capable of creating a number of commercial, professional, and legal problems, this Policy is intended to clarify what the Company expects from Users and their responsibilities when using the Company’s communications, email, and internet facilities (collectively, “the Company’s Internet and Communication Facilities”).
- The Company’s Internet and Communication Facilities include:
- Whilst the Company’s Internet and Communications Facilities are made available to Users for the purposes of the business, a certain amount of limited personal use is permitted insofar as such personal use is consistent with this Policy and the duties of the User.
- In addition to this Policy, when using the Company’s Internet and Communications Facilities, Users must also comply with other Company Policies including the Company’s Data Protection Policy, Equal Opportunities and Diversity Policy and IT security policy.
2. General Principles
There are certain general principles that should be borne in mind when using any type of communication, be it external or internal, including hard copy letters, memos, and notices. The Company expects all Users to:
- Use the Company’s Internet and Communication Facilities, and non-electronic facilities including but not limited to Company letterheads and stationery, responsibly and professionally and at all times in accordance with their duties;
- Be mindful of what constitutes confidential or restricted information and ensure that such information is never disseminated in the course of communications without express authority;
- Be mindful of what constitutes personal data and ensure that personal data relating to customers is never disseminated in the course of communications unless it is used in accordance with the Company’s Data Protection Policy and with express authority;
- Ensure that they do not breach any copyright or other intellectual property right when making communications;
- Ensure that they do not bind themselves or the Company to any agreement without express authority to do so; and
- Be mindful of the fact that any communication may be required to be relied upon in court, to the advantage or the detriment of the individual or the Company, and to conduct their use of communication systems and equipment accordingly.
- The viewing, transmission, downloading, uploading, or accessing in any way of any of the following material using the Company’s Internet and Communications Facilities will amount to gross misconduct with the possibility of summary dismissal:
- Material which is pornographic, sexist, racist, homophobic, or any other discriminatory or otherwise offensive material;
- Illegal or criminal material, including material which breaches copyright or any other intellectual property right;
- Any material which has the object or effect of causing harassment to the recipient;
- Material which the User knows, or reasonably ought to know, is confidential or restricted information and which they are not authorised to deal with;
- Any website or online service which the Company has blocked access to.
3. Internet Use
- The Company provides access to the internet for the sole purpose of business and to assist Users in the performance of their duties. However, the Company recognises that Users may need to use the internet for personal purposes and such use is permitted provided it is reasonable and does not interfere with the User’s performance of their duties. Users may be asked to justify the amount of time they have spent on the internet or the sites they have visited.
- Users must not use the internet to gain or attempt to gain unauthorised access to computer material or private databases, including restricted areas of the Company’s network. Nor must they intentionally or recklessly introduce any form of malware, spyware, virus, or other malicious software or code to the communications equipment or systems of the Company.
- Users must not access or attempt to access any information which they know or reasonably ought to know is confidential or restricted.
- Users must not access or use personal data online in any manner that is inconsistent with the Company’s Data Protection Policy.
- Users must not download or install any software without the express permission of the IT manager.
- In accordance with paragraph 2.7, Users must not attempt to download, view, or otherwise retrieve illegal, pornographic, sexist, racist, offensive, or any other material which is in any way in bad taste or immoral. Users should note that even material that is legal under UK law may nonetheless be in sufficiently bad taste to fall within this definition. As a general rule, if any person might be offended by any content, or if that material may be a source of embarrassment to the Company or otherwise tarnish the Company’s image, viewing that material will constitute a breach of this Policy. Any such attempt will constitute a disciplinary offence and in addition to internet access being reviewed, reduced, or withdrawn, may be subject to disciplinary action or summary dismissal.
- Certain websites are blocked and cannot be accessed using the Company’s Internet and Communication Facilities. If a User has a genuine and specific business need to access a blocked site, they must contact the IT Manager.
4. Social Media Use
- Users may use social media for personal purposes occasionally during work hours, for example during breaks, provided that such usage complies with the provisions of the Company’s safeguarding policy and provided that it does not interfere with their work responsibilities or productivity.
5. Company Email Use
- Users may use Company email for personal purposes, provided that such use is kept to a minimum and does not interfere with the performance of the User’s duties. In any case Users are not permitted to use their Company email address to subscribe to any newsletters or to receive any marketing, as this will result in extra unnecessary burden being placed upon the Company’s communications systems. All personal emails should be labelled “personal” in the subject line.
- If Users do use Company email for personal reasons, they will be deemed to agree to the possibility that any emails sent or received may be subject to monitoring in accordance with Part 10 of this Policy.
- Users must not send abusive, obscene, discriminatory, racist, harassing, derogatory, pornographic, or otherwise inappropriate material in emails. If any User feels that they have been or are being harassed or bullied, or if they are offended by material received in an email from another User, they should inform another member of the team with whom they are comfortable talking to.
- Users should at all times remember that email messages may have to be disclosed as evidence for any court proceedings or investigations by regulatory bodies and may therefore be prejudicial to both their and the Company’s interests. Users should remember that data which appears to have been deleted is often recoverable. If secure deletion is required, for example, where an email contains confidential information or personal data, Users should follow the steps set out in the Company’s Data Protection Policy.
6. Personal Email Use
- Users are permitted to access and use their personal email accounts only to the extent that such use is reasonable and does not interfere with the User’s performance of their duties.
7. Company Telephone System Use
- The Company’s telephone lines and mobile phones issued by the Company are for the exclusive use by Users working on the Company’s business. Essential personal telephone calls regarding Users’ domestic arrangements are acceptable, but excessive use of the Company’s telephone system and/or mobile phones for personal calls is prohibited. Any personal telephone calls should be timed to cause minimal disruption to Users’ work.
- Users should be aware that telephone calls made and received on the Company’s telephone lines] may be routinely monitored to ensure customer satisfaction or to check the telephone system is not being abused.
- If the Company discovers that the telephone system or a mobile phone issued by the Company has been used excessively for personal calls, this will be treated as a disciplinary matter and will be handled in accordance with the Company’s disciplinary procedures.
8. Personal Mobile Phone Use
- Essential personal telephone calls regarding Users’ domestic arrangements are acceptable, but excessive use of Users’ own mobile phones for personal communications (including, but not limited to, calls, messaging, emailing, and web browsing) is prohibited. In order to avoid disruption to others, mobile phones should be set to silent during normal working hours.
- Any personal telephone calls on Users’ own mobile phones should be timed to cause minimal disruption to Users’ work and to colleagues working nearby.
- The integrity of the Company’s business relies on the security of the Company’s Internet and Communications Facilities. Users bear the responsibility of preserving the security of Company’s Internet and Communications Facilities through careful and cautious use. In addition to the general provisions contained in this Policy, Users must also comply with the Company’s Data Protection Policy and IT Security Policy.
- Access to certain websites and online services via the Company’s Internet and Communications Facilities may be blocked. Often the decision to block a website or service is based on potential security risks that the site or service poses. Users must not attempt to circumvent any blocks placed on any website or service by the Company.
- Users must not download or install any software or program without the express permission of the IT Manager and are reminded of paragraphs 3.2 and 3.5 of this Policy.
- Users must not delete, destroy, or otherwise modify any part of the Company’s Internet and Communications Facilities (including, but not limited to, hardware and software) without the express permission of the IT Manager.
- Users must not share any password that they use for accessing the Company’s Internet and Communications Facilities with any person, other than when it is necessary for maintenance or repairs by IT support staff. Where it has been necessary to share a password, the User should change the password immediately when it is no longer required by IT support staff. Users are reminded that it is good practice to change passwords regularly.
- Users must ensure that confidential information, personal data, and other sensitive information is kept secure. The security of personal data in particular is governed by the Company’s Data Protection Policy, which Users must comply with at all times when handling personal data. Workstations and screens should be locked when the User is away from the machine and hard copy files and documents should be secured when not in use.
- If a User has been issued with a laptop, tablet, smartphone, or other mobile device, that device should be kept secure at all times, particularly when travelling. Mobile devices must be password-protected and, where more secure methods are available, such as fingerprint recognition, such methods must be used. Confidential information, personal data, and other sensitive information stored and/or accessed on a mobile device should be kept to the minimum necessary for the User to perform their duties. Users should also be aware that when using mobile devices outside of the workplace, information displayed on them may be read by unauthorised third parties, for example, in public places and on public transport.
- Users using Company-issued mobile devices (as outlined above in paragraph 9.7) must not connect such devices to public wi-fi networks, for example, in cafes, restaurants, and on public transport without the express approval of a particular network from IT Manager.
- When opening email from external sources Users must exercise caution in light of the risk malware, spyware, viruses, and other malicious software or code pose to system security. Users should always ensure that they know what an attachment is before opening it. If a User suspects that their computer has been affected by a virus they must contact the IT Manager.
- No equipment or device that has not been issued by the Company may be connected to or used in conjunction with the Company’s Internet and Communications Facilities without the prior express permission of the IT Manager. Such permission may be conditional on the testing and/or inspection of the equipment or device in question.
- To the extent permitted or required by law, the Company may monitor Users’ use of the Company’s Internet and Communications Facilities for its legitimate business purposes which include (but are not necessarily limited to) the following reasons:
- To ensure Company policies and guidelines are followed, and standards of service are maintained;
- To comply with any legal obligation;
- To investigate and prevent the unauthorised use of the Company’s Internet and Communications Facilities and maintain security;
- If the Company suspects that a User has been viewing or sending offensive or illegal material (or material that is otherwise in violation of this Policy);
- If the Company suspects that a User has been spending an excessive amount of time using the Company’s Internet and Communications Facilities for personal purposes.
- Users should be aware that all internet and email traffic data sent and received using the Company’s Internet and Communications Facilities is logged, including websites visited, times of visits, and duration of visits. Any personal use of the internet will necessarily therefore be logged also. Users who wish to avoid the possibility of the Company becoming aware of any political or religious beliefs or affiliations should avoid visiting websites at work which might reveal such affiliations. By using the Company’s Internet and Communications Facilities for personal use, Users are taken to consent to personal communications being logged and monitored by the Company. The Company shall ensure that any monitoring of Users’ use of the Company’s Internet and Communications Facilities complies with all relevant legislation including, but not limited to, the UK GDPR and the Human Rights Act 1998. For further information, please refer to the Company’s Data Protection Policy.
- When monitoring emails, the Company will normally restrict itself to looking at the address and heading of the emails. However, if it is considered necessary, the Company may open and read emails. Users should be aware that sensitive and confidential communications should not be sent by email because it cannot be guaranteed to be private. Users are reminded that any permitted personal emails should be marked as “personal” in the subject line.
The Company may use internet searches to carry out due diligence as part of its recruitment process. In these circumstances, the Company will act in accordance with its equal opportunities and data protection obligations.
12. Misuse and Compliance
- Any User found to be misusing the Company’s Internet and Communications Facilities will be treated in line with the Company’s Disciplinary Policy and Procedure. Misuse of the internet can, in some cases, amount to a criminal offence.
- Where any evidence of misuse of the Company’s Internet and Communications Facilities is found, the Company may undertake an investigation into the misuse in accordance with the Company’s Disciplinary Policy and Procedure. If criminal activity is suspected or found, the Company may hand over relevant information to the police in connection with a criminal investigation.
We are committed to reviewing our policy and procedures annually. This policy was last reviewed in January 2023.