Brackenwood Windows Limited recognises that some customers we come into contact with will be vulnerable in the context of how we interact with them by virtue of their personal circumstances which may include, but are not limited to, mental or physical infirmity, age, credulity, learning difficulties, illiteracy or if their first language is not English. Brackenwood has a duty and obligation to ensure that where a vulnerable person is identified, reasonable adjustments are put in place and appropriate steps considered. If it becomes obvious that information we provide to the customer is not being understood, we will seek the involvement of a trusted friend or relative. In the event a vulnerable person is identified we will withdraw from an appointment until such time as it can be re-arranged with a trusted friend or relative present. Adjustments will be made in the way in which we communicate with vulnerable individuals. Brackenwood recognises that there is a sliding scale of vulnerability and that people are different, meaning that some customers may become vulnerable in circumstances where others may not. Brackenwood believes that the welfare of any vulnerable person is paramount; those who are vulnerable without exception have the right to protection from abuse regardless of gender, ethnicity, disability, sexuality or beliefs. Brackenwood works on the basis that every individual is different, with different circumstances which means that, as far as possible, we will treat individuals in a way that is appropriate to their needs. Brackenwood expects its own and its subcontractor’s staff who come into direct contact with members of the public as part of their job to carry out appropriate selection and vetting procedures, including where appropriate basic criminal record checks. Brackenwood takes any complaint about treatment of customers, whether identified as vulnerable or not, very seriously and any such complaint will be investigated fully. Any information gathered will be processed in line with GDPR and the Data Protection Act 2018.  Where necessary, explicit consent will be obtained from a customer to enable us to process the details of their vulnerability accordingly.  Customers will also be fully informed of how we will process this information. We will always:

• Ask for a customer’s explicit consent in order to record, store or process the details of their vulnerability, where it is necessary and appropriate to do so
• Clearly explain to the customer why we need to record, store or process the details of their vulnerability
• Clearly explain to the customer who the details of their vulnerability will be shared with

Typically, we would only look to process the details of a customer’s vulnerability where we may need to tailor our approach during our communications with them, or when we are entering their home for the purposes of a sales consultation or installation. We would therefore only share the details of the vulnerability with the relevant staff and representatives.