Modality Partnership Modern Slavery Statement 2023/2024
Modern Slavery Statement 2023/2024
The Modern Slavery Act 2015 is designed to consolidate various offences relating to
human trafficking and slavery. The provisions in the Act create a requirement for an annual
statement to be prepared that demonstrates transparency in supply chains pertaining to
goods or services. In line with all businesses with a turnover greater than £36 million per
annum, and as a provider of services, the Modality Partnership provides the following
statement in compliance with the Act.

Our Business
We are a primary care Super Partnership that was established in June 2009. There are
currently over 40 practices as part of the group that form nine divisions (areas) across the
country in Birmingham, Walsall, Hull, Airedale, Wharfedale and Craven, East Surrey,
Wokingham, Lewisham, Mid-Sussex, and St Helens. Our vision is to become a leading
primary care provider locally nationally.

Assurance and our approach to Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our
supply chains or in any part of our business. Rigour in our recruiting processes and staff
welfare is our priority. Our Anti-Slavery approach reflects our commitment to acting
ethically and with integrity in all our business relationships, and to implementing and
enforcing effective systems and controls to ensure this is not taking place anywhere in our
business or within our supply chains.
This statement is published on our partnership website and contained within our staff
handbook.

Due Diligence and Processes
As part of our initiative to identify risk and mitigate against such risks, our National Board
and the Chief Executive Officer take responsibility through our management teams for
ensuring that our practices identify pertinent risks.

We have in place systems and approaches across our business, our trading partners and
our supply chains to:-
• Identify inappropriate employment practices including a robust approach to recruiting staff
into Modality Partnership that includes identity, DBS and qualification/reference checks,
and checks to ensure our people we recruit are legally entitled to work in the UK.
• Setting strict standards for conduct within the workplace, referencing this within our
contracting documentation and staff handbook for all staff as well as mirroring the NHS
code of conduct in respect of the expected standards for managers.
• Policies to guide staff on routes for whistleblowing, grievance, disciplinary and bullying
and harassment, providing them with assurance on our management role and providing
support with relevant workforce to support such policies, such as centralised HR
professionals, Wellbeing Champions and Guardians and Freedom to Speak Guardians.
• Through our mandatory training for all staff to raise awareness and responsibilities in
relation to the Act, and in particular towards our patients.
• Additional management training and wellbeing support awareness has been undertaken
and which will form part of mandatory management training to ensure all employees with
line management responsibility are consistent in their approach to staff recruitment,
employment rights and awareness and support to ensure the correct management of
employee welfare.
• Additionally, in acknowledgment of pressures which create extra demand on our services,
for example the COVID 19 Pandemic, and the increased seasonal demands on General
Practice, the recruitment of additional workers is a necessity to ensure safe service
delivery. Some of the additional required workers included voluntary workers, all of which
were recruited in line with the Modality Partnership recruitment policy. All volunteers that
provide support to our service provision are background checked in the same way as paid
employees who have pre-employment checks carried out.
Volunteers are issued with honorary contracts following their clearance checks, which also
includes rights to working in the UK and a DBS check. All volunteers are given the same
onboarding, induction, and site orientation as paid employees. Volunteers support the
service on a ad hoc basis and hours are monitored in line with working time directives to
ensure adequate rest breaks are provided.

Supplier and Procurement adherence to our values and ethics
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply
chain and contractors comply with our values, we operate in line with principles of
responsible sourcing. All members of staff have a personal responsibility for the successful
prevention of such practices taking place with our procurement department taking the lead
for compliance with our suppliers and those we contract with. The organisation is
committed to training our Procurement and Supplies Team on the implications of the Act
in order that they can support the wider organisation on its implementation.

The prevention, detection and reporting of modern slavery in any part of our organisation
or supply chain is the responsibility of all those working for us or on our behalf. Workers
must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a
breach in this area.

We are committed to engaging with our stakeholders and suppliers to address the risk of
modern slavery in our operations and supply chain. If we find that other individuals or
organisations working on our behalf have breached this policy, we will ensure that we take
appropriate action. This may range from considering the possibility of breaches being
remediated and whether that might represent the best outcome for those individuals
impacted by the breach to terminating such relationships.

The National Board of Directors has considered and approved this statement and will
continue to support the requirements of the legislation.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and
constitutes our slavery and human trafficking statement for the financial year ended 31
March 2024.

Vincent Sai
Modality Group Chief Executive
March 2024

MOD Gender Pay Reporting 2023 Final 28.03.24

This is the privacy notice of Modality Partnership. In this notice, “we”, “our”, or “us” refer to Modality Partnership.
Our registered office is at Orsborn House, 55 Terrace Road, Birmingham, B19 1BP
Data Protection Officer Umar Sabat
Our data protection officer’s contact details are:
modality.dpo@nhs.net

Introduction

1. This is a notice to inform you of our policy about all information that we record about
you. It sets out the conditions under which we may process any information that we
collect from you, or that you provide to us. It covers information that could identify you
(“personal information”) and information that could not. In the context of the law and this
notice, “process” means collect, store, transfer, use or otherwise act on information.

2. We regret that if there are one or more points below with which you are not happy, your
only recourse is to leave our website immediately.

3. We take seriously the protection of your privacy and confidentiality. We understand that
all visitors to our website are entitled to know that their personal data will not be used for
any purpose unintended by them and will not accidentally fall into the hands of a third
party.

4. We undertake to preserve the confidentiality of all information you provide to us, and
hope that you reciprocate.

5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).

6. The law requires us to tell you about your rights and our obligations to you in regards to
the processing and control of your personal data. We do this now, by requesting that
you read the information provided at www.knowyourprivacyrights.org

7. Except as set out below, we do not share, or sell, or disclose to a third party, any
information collected through our website.

The bases on which we process information about you The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall
immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever you process personal data:
(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us info@modalitypartnership.com.However, if you do so, you may not be able to use our website or our services further.

Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:
• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round,
consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
• record-keeping for the proper and necessary administration of our
• responding to unsolicited communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage risk
• protecting your interests where we believe we have a duty to do so

Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.

Complaints regarding content on our website
If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we have to make a judgment as to whose right will be
obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

Job application and employment
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our organisation.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

Complaints
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is. We may also compile statistics showing information obtained from this source to assess the level of
service we provide, but not in a way that could identify you or any other person.

Use of information we collect through automated systems when you visit our website
Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use. Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose. If you choose not to use cookies or you prevent their use through your browser settings, you will not
be able to use all the functionality of our website.
We use cookies in the following ways:
1. to track how you use our website
2. to record whether you have seen specific messages we display on our website
3. to keep you signed in our site
4. to record your answers to surveys and questionnaires on our site while you complete them Personal identifiers from your browsing activity Requests by your web browser to our servers for web pages and other content on our website are
recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed into our website.

Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website. We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

Disclosure and sharing of your information
Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you. Third party advertising on our website Third parties may advertise on our website. In doing so, those parties, their agents or other
companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.
We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties. Data may be processed outside the European Union
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly, data obtained within the UK or any other country could be processed outside the
European Union.
For example, some of the software our website uses may have been developed in the United States
of America or in Australia.
Access to your own information
1. Access to your personal information
2. To obtain a copy of any information that is not provided on our website you may send us a
request at info@modalitypartnership.com
3. After receiving the request, we will tell you when we expect to provide you with the
information, and whether we require any fee for providing it to you.
Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us
at info@modalitypartnership.com
This may limit the service we can provide to you.
Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first
take reasonable steps to verify your identity before granting you access or otherwise taking any
action. This is important to safeguard your information.
Other matters
Use of site by children
1. If you are under 18, you may use our website only with consent from a parent or guardian
WEBSITE PRIVACY POLICY
Privacy Notice
2. We collect data about all users of and visitors to these areas regardless of age, and we
anticipate that some of those users and visitors will be children.
3. Such child users and visitors will inevitably visit other parts of the site and will be subject to
whatever on-site marketing they find, wherever they visit.
Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt
any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by
looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
How you can complain
1. If you are not happy with our privacy policy or if have any complaint then you should tell us by
email. Our address is info@modalitypartnership.com.
2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in
good faith with us in a process of mediation or arbitration.
3. If you are in any way dissatisfied about how we process your personal information, you have
a right to lodge a complaint with the Information Commissioner’s Office. This can be done
at https://ico.org.uk/concerns
Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as
long as required by us:
1. to provide you with the services you have requested;
2. to comply with other law, including for the period demanded by our tax authorities;
3. to support a claim or defence in court.
Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or legal
jurisdiction in which we operate. If you think it fails to satisfy the law of your jurisdiction, we should like
to hear from you.
However, ultimately it is your choice as to whether you wish to use our website.
Review of this privacy notice
We may update this privacy notice from time to time as necessary. The terms that apply to you are
those posted here on our website on the day you use our website. We advise you to print a copy for
your records.
If you have any question regarding our privacy policy, please contact us

This page contains details of the Privacy Policy and Terms of Use of the website.

1. Accuracy
Our internet site is intended primarily to provide information about our Modality Partnership. We have taken care to ensure that all information is provided is accurate and valid.
However, Modality accepts no responsibility for use of the information provided. The advice for
patients is as comprehensive and accurate as possible, but it can only be of a general nature and should not be used as a substitute for a consultation with a medical professional.

2. Medical Information on the Web
The Internet can be a useful resource for researching medical conditions. It also has inherent weaknesses that you should be aware of. If you use the Internet for medical research or information, please be aware of the following points:
• Always look for a balanced view – do not rely on advice from one site and seek a
balanced viewpoint
• Remember that anyone can publish anything on the Internet. Make sure that the authors’
names and their qualifications are included – anonymous information may not be sourced
accurately
• Be aware that advertising might influence the site contents – check for commercial
sponsorship or for advertising which might influence the information on the site
• Check that the website is updated regularly
• Be cautious of online diagnoses or consultations
• Check the website’s Privacy and Confidentiality Policy
• Beware that website information or advice sourced from outside the UK might describe
treatments not available in the UK.

3. Suitability and Availability
We cannot guarantee that this website will meet your requirements, or that it will be of
satisfactory quality, or that it will be fit for your particular purpose, or that it will not infringe the rights of third parties, or that it will be secure.
Further, we cannot guarantee uninterrupted access to our website, or the sites to which it links. We accept no responsibility for any damages arising from the loss of use of this information.

4. Links to Other Websites
All links from our Modality Partnership website to any other websites are provided for information
and convenience only. We cannot accept responsibility for sites linked to, or the information found there. A link does not imply an endorsement of a site; likewise, not linking to a particular site does not imply lack of endorsement.

5. Data Collection
Please be aware that we collect contact details of those who wish to communicate with us via email, collect aggregated (non-personal) information about which pages visitors to our website chose to access, and collect information volunteered by visitors to our website (such as survey information and/or site registrations). The information we collect is used to improve the content of our Web pages and the quality of our service.

6. Hosting, Networks and Data Storage
Please be aware that our website uses Third Party Service Providers, Vendors and Hosting
Partners to provide the necessary hardware, software, networking, storage, and related
technology required to support our website