Terms & Conditions for Najma the Maths Tutor Platform
Introduction
Welcome to Najma the Maths Tutor! These terms and conditions (referred to as “Terms”) outline the rules and guidelines for using our platform. By using our platform, you agree to follow these Terms. We want to make sure you understand our policies, so please take a moment to read this document.
Age of Access
To use our platform, you must be at least 18 years old. If you are between 13 and 18, you need your parent or guardian’s permission. If you are under 13, we cannot allow you to use our platform.
License to Students
When you use Najma the Maths Tutor, we grant you a limited, non-exclusive license to access and use our platform for your personal development. This license is just for you and cannot be shared with others without our permission. Please do not try to mess with our platform or use it in a way that harms it.
Intellectual Property
All the content on our platform, like information, software, logos, and more (we call this “Najma the Maths Tutor Content”), belongs to us. Do not change it or use it inappropriately.
Najma the Maths Tutor’s Rights
We reserve the right to make changes to our platform, stop providing services, or remove users at any time. We can also update our refund policy if needed. If you close your account, we might keep some of your content for legal purposes.
Third-Party Communications
While using our platform, you may receive messages from third parties. We are not responsible for these messages, so be cautious and verify the source and content before trusting them.
Third-Party Offerings
Our platform may have links to third-party websites or services (“Third Party Offerings”). Use them at your own risk. We do not control or endorse them, and we are not responsible for any issues that may arise from using them.
Payments
If you use Najma the Maths Tutor Payments, you may need to agree to terms from third-party payment providers like Stripe or PayPal. Their terms will not change ours.
Refund Policy
We want you to be satisfied with our platform. If you are not happy, we offer a 30-day refund for certain content. However, please do not abuse this policy, like asking for refunds every month. We can also issue refunds at our discretion.
Cancellation and Deletion
If you cancel a paid plan, it becomes effective at the end of your billing cycle. Your account will then revert to a free account, and some features may be restricted. Inactive free accounts may be deleted after six months. Paid accounts are considered active unless you ask us to delete them.
Effect of Cancelation/Deletion
If your account is deleted, you might lose access to your content. We are not responsible for this. Upon account deletion, all licenses granted by us will end.
Errors and Corrections
We cannot guarantee our platform will always be perfect. We will do our best to fix errors and improve the platform, but occasional downtime might happen.
Limitations of Liability
We want you to understand that we are not liable for various things, including losses or damages resulting from your use of our platform or third-party content.
Remedies for Violations
If you violate these Terms, we can take legal action or block your access to the platform.
Communications
We will notify you through emails or on the platform about important information. Please check for these notices regularly.
Privacy
Your use of the platform is governed by our Privacy Policy.
Changes to the Terms and Conditions
We can update these Terms anytime. If you keep using our platform after changes are posted, it means you accept those changes. Please check for updates periodically.
Contact Us
If you have questions or concerns about these Terms and Conditions, our platform, or content, feel free to contact us at najmathemathstutor@gmail.com.
PLEASE READ THIS DOCUMENT CAREFULLY
Najma the Maths Tutor (hereafter Najma the Maths Tutor) respects your privacy and is committed to being transparent with you about how we handle personal information.
This Privacy Policy explains how Najma the Maths Tutor collects, uses, and shares information about you when you use the Najma the Maths Tutor Platform, or otherwise interact with us. It also goes over how you can exercise your privacy rights and choices.
The Najma the Maths Tutor Platform is designed to allow your daughter to learn. This Privacy Policy applies when you access or use the services and tools offered through our Platform (“Najma the Maths Tutor Services”), or otherwise interact with us. Your access to our Platform and use of Najma the Maths Tutor Services is also governed by our Terms & Conditions. Capitalized terms used but not defined in this Privacy Policy can be found in our Terms & Conditions.
Please read this Privacy Policy carefully prior to accessing our Platform and using Najma the Maths Tutor Services. If you have any questions, please contact us at: info@najmathemathstutor.co.uk.
Children
As stated in our Terms & Conditions, you must be at least 18 years old to use the Platform, or, if you are between the ages of 13 and 18, you must have your parent or guardian’s permission to use the Platform. Najma the Maths Tutor does not knowingly collect or store any personal information from or about children under the age of 13, and we will delete such information if we become aware that it has been submitted through our Platform.
Parents or guardians who believe that Najma the Maths Tutor might have any personal information from or about a child under the age of 13 may submit a request to info@najmathemathstutor.co.uk for us to remove such information.
Overview
Personal information refers to any information that relates to an identified or identifiable individual. How we handle your personal information will depend on whether we act as a “controller” or as a “processor” for the personal information. The controller is the entity that decides how and why to process personal information. The processor processes personal information on behalf of the controller at the controller’s direction.
Najma the Maths Tutor is the controller of personal information that it collects and processes in connection with the use of our marketing site and the provision of Najma the Maths Tutor Services. This includes personal information that you provide to us when you create an account on the Najma the Maths Tutor Platform, subscribe to a Najma the Maths Tutor plan, enrol in a course etc. Please refer to the “Personal Information We Collect” section of this Privacy Policy for more information about personal information that Najma the Maths Tutor collects as a controller.
Personal Information We Collect
Najma the Maths Tutor collects personal information about you in several different ways, depending on how you interact with our Platform. Please note that the types of personal information we collect differs depending on how you are using our Platform, for example, as a Student or Parent.
Personal Information you give us (or that we receive from others):
We collect personal information you directly provide to us. We may also receive personal information about you from others, e.g. from another user or our payment processors.
Personal Information from your use of our Platform:
We automatically collect certain information from your interactions with our Platform.
How We Use Personal Information We Collect
Our primary purpose for using your personal information is to provide you with a smooth, efficient, and customized experience, for customer support, advertising and marketing communications, research and service development, and to keep our Platform and users safe and secure.
How We Share Personal Information We Collect
Najma the Maths Tutor only shares your personal information with third parties under the circumstances described below. We do not sell or otherwise disclose personal information we collect about you for monetary or other valuable consideration.
Please keep in mind that all the information that you share or content that you publish in your bio, posts, comments, or other public portions of our Platform becomes public information. Because this information is publicly available, we cannot control how others treat it. We ask you to exercise care in deciding what personal information you choose to share, and refrain from sharing your sensitive personal information and those of others.
When you choose to integrate third party services with our Platform, your personal information may be shared with these third parties. We recommend that you read the Terms & Conditions and privacy policies of those third-party services to understand how they collect, use, and share your personal information.
Najma the Maths Tutor may send your personal information to a third party when you give us consent to do so or at your direction. For example, this may occur when we complete a transaction at your request.
We may share personal information with vendors, consultants, payment processors, and other service providers that provide us with certain services and process personal information on our behalf. These services may include providing customer support, performing business and sales analysis, supporting our website functionality, facilitating payment processing, and supporting contests, surveys, and other features offered on our Platform.
These service providers are not permitted to use your personal information for any other purpose, and their use of such personal information will be subject to appropriate confidentiality and security measures.
We may share usage data with third-party advertisers, advertisement networks, and analytics providers through cookies and other similar technologies. These third parties may collect information sent by your computer, browser, or mobile device in response to a request for content, such as unique identifiers, your IP address, or other information about your computer or device. For more information on our use of cookies and similar technologies, please refer to our Cookie Policy.
Legal Disclosures
Najma the Maths Tutor may be required to disclose personal information if directed by a court of law or other governmental entity. Without limiting the foregoing, we reserve the right to disclose such information where we have a good faith basis to believe that such action is necessary to:
To the extent permitted by law, we will attempt to give you prior notice before disclosing your information in response to such a request.
Your Rights and Choices
Najma the Maths Tutor gives you choices with respect to our use of your personal information. These choices include accessing, updating, or deleting your personal information, as well as choosing what communications you would like to receive from us. Depending on your location, you may have additional rights related to your personal information (see the Jurisdiction Specific Provisions section below for more information about location-specific privacy rights).
You can also choose not to provide us with certain personal information, but that may result in you being unable to use certain features of our Platform because that information may be required for you to register for an account,
purchase Najma the Maths Tutor Services, participate in our promotional offerings, get customer support, or engage in other activities on our Platform.
Please refer to the ‘Data Privacy Requests and Verification’ section below for information on how to make a data privacy request.
Accessing, Updating, and Deleting Your Personal Information
You can access and update certain personal information about you by visiting your Account Settings.
You can also submit a data privacy request to receive a copy of personal information that we hold about you, free of charge.
If you believe that any personal information, we are holding about you is incorrect or incomplete, we will work with you to make corrections deemed necessary. Note that we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you would like Najma the Maths Tutor to delete your account or delete personal information it holds about you, you can submit a deletion request. Note that when we delete your account, personal information that you have shared with others (for example, through comments or an intake form) may still be visible. Najma the Maths Tutor will also retain certain personal information about you where reasonably necessary to comply with our legal obligations or for our legitimate business purposes.
Data Privacy Requests and Verification
You can request to access, update, or delete your personal information by emailing us at info@najmathemathstutor.co.uk from the email address associated with your account.
If you would like to make a request under the privacy laws of your jurisdiction, please let us know where you reside and which rights you would like to exercise. For more information about exercising your jurisdiction-specific privacy rights, please see section ‘Jurisdiction Specific Provisions’ below.
To protect your privacy, we need to verify your identity before we process your data privacy request. As part of this process, we will need to receive the request from you via the email address associated with your account. Depending on the nature of the request, we may also need to obtain additional information necessary for us to verify your identity. You may designate an authorized agent to make a data privacy request on your behalf. To do so, we will need to receive written permission by you or a valid power of attorney, and we may also verify the validity of the request directly with you.
Controlling Promotional Communications
You can opt out of receiving some or all of our promotional communications through the unsubscribe link in the email or by emailing info@najmathemathstutor.co.uk.
If you opt out of promotional communications, we may still send you transactional communications, such as service announcements, administrative and legal notices, and information about your account, without offering you the opportunity to opt out of these communications. If you no longer wish to use our Platform or receive any communications from us (except for those that are legally required), please contact info@najmathemathstutor.co.uk to have us delete your account.
Please note that opting out of promotional email communications only affects future communications from us. If we have already provided your information to a third party (such as a credit card processing partner) before you changed your preferences or updated your information, you may have to change your preferences directly with that third party.
Controlling Cookies and Similar Technologies
Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. Note, however, that deleting cookies or directing your browser to refuse them may limit your ability to use certain portions of our Platform that require cookies to function. For more information on our use of cookies and similar technologies and how you can opt out, please refer to our Cookie Policy.
Do Not Track Signals
Your browser may give you the option to send a “Do Not Track” instruction to websites you visit. However, since there is no accepted standard for how a website should respond to this instruction, we do not currently recognize or respond to these signals.
GDPR
Users in the European Economic Area, UK, and Switzerland
Under the General Data Protection Regulation (GDPR) and other applicable laws, users in the European Economic Area (“EEA”), UK, and Switzerland have the right, under certain conditions, to request access to, rectification of, or erasure of their personal information; request restriction of processing; object to processing; withdraw consent from processing; and the right to data portability.
If you are in the EEA, UK and Switzerland and would like to exercise these rights, please email us at info@najmathemathstutor.co.uk pursuant to the ‘Data Privacy Requests and Verification’ section above. Please include the phrase “GDPR request” in the subject line and provide us with your mailing address and state of residence.
Najma the Maths Tutor only collects and processes personal information about you where it has lawful bases for doing so. The specific legal basis applied to the processing will depend on the context in which the personal information is being
processed, including the service used and the type of personal information involved.
Najma the Maths Tutor uses the following legal bases for processing:
If you’d like to withdraw your consent or object to our processing of your personal information, please contact info@najmathemathstutor.co.uk.
If you believe that we have not adequately addressed your concerns or wish to report an alleged infringement of applicable data privacy laws, you may file a complaint with your local supervisory authority.
Other Information
Information Security
Najma the Maths Tutor uses a range of physical, technical, and administrative security measures to protect your personal information. For example, only authorised
employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of financial information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information. However, no method of data transmission or storage system is absolutely secure, and we cannot guarantee that your personal information will not be accessed, disclosed, altered, or destroyed in the event of a breach of any of our security measures.
Where we have given you (or where you have chosen) a password to access certain parts of our Platform, you are responsible for protecting this password and keeping it confidential. As the safety and security of your information also depends on the precautions you take, we ask you not to share your password with anyone. If you believe your password or the security of your account has been compromised, you should change your password immediately and contact info@najmathemathstutor.co.uk with any concerns.
Data Retention
We save personal information we collect for as long as it is necessary for the purposes for which the personal information is collected and processed. Generally, we will keep your personal information until your account is deleted, or as needed to provide you with our services. We will also retain certain personal information to comply with our legal obligations or for our legitimate business purposes.
Third Parties and Other Personal Information Collectors
Except as otherwise expressly specified in this Privacy Policy, this document only addresses the use and disclosure of personal information Najma the Maths Tutor collects from you. To the extent that you disclose your personal information to other parties through our Platform, whether between Creator and Student or with other users, different rules may apply to how they use and share your personal information. Accordingly, you will need to look at the privacy policies of these third parties to understand their data privacy practices.
As further explained in our Terms & Conditions, our Platform may include links to third party websites. We are not responsible for the content of such websites or the protection and privacy of any information which you provide while visiting those sites. We recommend that you exercise caution and review the privacy policies applicable to the websites in question.
No Rights of Third Parties
This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of our Platform.
Changes to Our Privacy Policy
We encourage you to periodically review this Privacy Policy to stay informed about our privacy practices, as we may review and update our processes from time to time.
If we make a change that, in our sole discretion, is material, we will notify you through email, by posting a notification on our website, or as required by law. Unless otherwise stated, changes to this Privacy Policy will take effect immediately as of the date it is posted. By continuing to use our Platform after Privacy Policy changes go into effect, you agree to be bound by the revised Privacy Policy.
Contact Us
If you have questions or concerns regarding this Privacy Policy or Najma the Maths Tutor’ handling of your personal information, or if you would like to exercise your rights described in this Privacy Policy, please contact us at: info@najmathemathstutor.co.uk
Safeguarding Young People Policy
Najma the Maths Tutor is firmly committed to the welfare of all young people who are part of the organisation and protecting them from physical, sexual and emotional harm. Najma the Maths Tutor will aim to ensure that all young people meet in a safe environment with people they can trust. It will ensure that all risks which young people encounter are carefully assessed, and the necessary steps taken to minimise and manage them.
Throughout this document, the term young people are intended to include vulnerable adults.
The purpose of this policy statement is:
This policy applies to anyone working on behalf of Najma the Maths Tutor, including senior managers and the board of trustees, paid staff, sessional workers, agency staff and students.
This policy has been drawn up based on legislation, policy and guidance that seeks to protect children in England.
This policy has regard to the following guidance and advice:
This policy also takes account of the procedures and practice of Manchester City Council and the published safeguarding arrangements set out by the local safeguarding partners.
We believe that:
We recognise that:
We will seek to keep children and young people safe by:
All staff will supply the following information:
All staff should complete a Disclosure & Barring Service Application at enhanced level. This check will be renewed every 3 years.
All new staff must work alongside a fully vetted and trained member of staff until references have been received and the DBS process completed. In accordance with guidance from the Disclosure & Barring Service a record will be kept of the disclosure number, completion date and whether or not the check is satisfactory.
Najma the Maths Tutor adheres to the following guidelines as to how young people and adults interact with each other:
The contents of this policy (and other Najma the Maths Tutor policies) will be included in the induction process for all staff. The leadership team will insist on attendance at these sessions which will help staff understand their responsibilities and provide information on identification and appropriate response to child protection issues.
The following procedures will apply in the identification or suspicion of abuse towards a young person.
Abuse
Abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others (eg via the internet). Abuse can take place wholly online, or technology may be used to facilitate offline abuse. They may be abused by an adult or adults or by another child or children.
There are four types of abuse to which young people can be subjected:
If any of these occur, young people often display problems in the following areas:
A young person may disclose that he/she is being abused; he/she may show signs of abuse; or he/she may speak about third party abuse.
If abuse is suspected:
Observations, conversations or concerns will be recorded, signed and dated.
If abuse is reported/alleged:
The young person will be listened to and encouraged to speak without interruption, comment or judgment.
Early Help
Any child may benefit from early help, but all staff should be particularly alert to the potential need for early help for a child who:
Early help means providing support as soon as a problem emerges at any point in a child’s life, from the foundation years through to the teenage years.
Najma the Maths Tutor recognises the importance of protecting its staff from possible allegations of abuse and recommends the following guidelines:
Staff should not:
The procedures for managing concerns/ allegations against staff who are currently working in Najma the Maths Tutor follows Department for Education statutory guidance and local safeguarding partners’ arrangements and applies when staff have (or are alleged to have):
Allegations against a teacher who is no longer teaching should be referred to the Police. Historical (nonrecent) allegations of abuse should be referred to the Police and also the LADO.
If any allegation is made or suspicions emerge regarding any staff leader of the club, these should be reported to the Safeguarding Officer. If an allegation concerns either of these officers, the report should be made to Najma Mohamed.
If further action is required, the following procedure will apply during which all information relating to the allegation will remain confidential:
Since young people may be photographed while participating in events and activities, written permission from parents/guardians will be obtained which will also allow photographic material to be used in the public domain.
The ongoing implementation of the Safeguarding Young People Policy will be monitored. This policy will be reviewed at least biannually, or upon material changes in practice, or changes in regulation or legislation. Any member of staff with a concern regarding these issues should ensure that it is discussed with their supervisor or with the whole team, as appropriate. The policy will be reviewed as part of the regular cycle of reviews, unless changing circumstances require an earlier review.
Najma the Maths Tutor intends to implement this policy by:
This policy is applicable to all Trustees, staff, volunteers, management committee members, users, and the public.
Age: Where this is referred to, it refers to a person belonging to a particular age (for example 32-year olds) or range of ages (for example 18 to 30-year olds).
Disability: A person has a disability if she or he has a physical or mental impairment, which has a substantial and long-term adverse effect on that person’s ability to carry out normal day-to-day activities.
Gender reassignment: The process of transitioning from one gender to another.
Marriage and civil partnership: Marriage is no longer restricted to a union between a man and a woman but now includes a marriage between a same-sex couple. Same-sex couples can also have their relationships legally recognised as ‘civil partnerships’. Civil partners must not be treated less favourably than married couples (except where permitted by the Equality Act).
Pregnancy and maternity: Pregnancy is the condition of being pregnant or expecting a baby. Maternity refers to the period after the birth and is linked to maternity leave in the employment context. In the non-work context, protection against maternity discrimination is for 26 weeks after giving birth, and this includes treating a woman unfavourably because she is breastfeeding.
Race: Refers to the protected characteristic of Race. It refers to a group of people defined by their race, colour, and nationality (including citizenship) ethnic or national origins.
Religion and belief: Religion has the meaning usually given to it but belief includes religious and philosophical beliefs including lack of belief (such as Atheism). Generally, a belief should affect your life choices or the way you live for it to be included in the definition.
Sex: A man or a woman.
Sexual orientation: Whether a person’s sexual attraction is towards their own sex, the opposite sex or to both sexes.
Equality and diversity are central to the work of Najma the Maths Tutor.
We are committed to providing equal opportunities in employment and to avoiding unlawful discrimination. This policy is intended to assist putting this commitment into practice. Our aim is that the work environment is free of harassment and bullying and that everyone is treated with dignity and respect, which is an important aspect of ensuring equal opportunities in employment.
Najma the Maths Tutor will treat all people with dignity and respect, valuing the diversity of all. We will promote equality of opportunity and diversity. We will eliminate all forms of discrimination on grounds of race, gender, marital status, caring responsibilities, disability, gender re-assignment, age, social class, sexual orientation, religion/ belief, irrelevant offending background or any other factor irrelevant to the purpose in view.
We will tackle social exclusion, inequality, discrimination, and disadvantage.
For this policy to be successful, it is essential that everyone is committed to and involved in its delivery. Najma the Maths Tutor’ goal is to work towards a just society free from discrimination, harassment, and prejudice. Najma the Maths Tutor aims to embed this in all its policies, procedures, day-to-day practices, and external relationships.
It is unlawful to discriminate directly or indirectly in recruitment or employment because of a ‘protected characteristic’. The Equality Act defines the protected characteristics as being age, disability, sex, gender reassignment, pregnancy, maternity, race (which includes colour, nationality, caste and ethnic or national origins), sexual orientation, religion or belief, or because someone is married or in a civil partnership.
Discrimination after employment may also be unlawful, e.g. refusing to give a reference for a reason related to one of the protected characteristics.
It is also unlawful to discriminate against or harass a member of the public or service user in the provision of services or goods or to fail to make reasonable adjustments to overcome barriers to using services caused by disability.
The duty to make reasonable adjustments includes the removal, adaptation, or alteration of physical features, if the physical features make it impossible or unreasonably difficult for disabled people to make use of services. In addition, service providers have an obligation to think ahead and address any barriers that may impede disabled people from accessing a service.
Direct discrimination is where a person is treated less favourably than another because of a protected characteristic. However, discrimination may be lawful if there is an occupational requirement which is core to a job role and a proportionate means of achieving a legitimate aim.
Indirect discrimination means putting in place, a rule or policy or way of doing things that has a worse impact on someone with a protected characteristic than someone without one, when this cannot be objectively justified.
Harassment is where there is unwanted behaviour related to a protected characteristic (other than marriage and civil partnership, and pregnancy and maternity) which has the purpose or effect of violating someone’s dignity or which creates a hostile, degrading, humiliating or offensive environment. It does not matter whether this effect was intended by the person responsible for the conduct.
Associative discrimination is where the individual treated less favourably does not have a protected characteristic but is discriminated against because of their association with someone who does, e.g. the parent of a disabled child.
Perceptive discrimination is where the individual discriminated against or harassed does not have a protected characteristic, but they are perceived to have a protected characteristic.
Third-party harassment occurs where an employee is harassed by third parties such as service users, due to a protected characteristic.
Victimisation is treating someone unfavourably because they have taken some form of action relating to the Equality Act, i.e. because they have supported a complaint or raised a grievance under the Equality Act 2010, or because they are suspected of doing so. However, an employee is not protected from victimisation if they acted maliciously or made or supported an untrue complaint.
Failure to make reasonable adjustments is where a rule or policy or way of doing things has a worse impact on someone with a protected characteristic compared with someone who does not have that protected characteristic and the employer has failed to make reasonable adjustments to enable the disabled person to overcome the disadvantage.
We will avoid unlawful discrimination in all aspects of employment including recruitment, promotion, opportunities for training, pay and benefits, discipline and selection for redundancy. Job descriptions will avoid any unnecessary requirements (those unrelated to effective performance) that may otherwise have deterred applicants. We will base decisions on objective criteria. We will consider making reasonable adjustments in recruitment as well as in day-to-day employment.
We will not discriminate unlawfully against service users (including young people and volunteers) using or seeking to use the services we provide. If you are bullied or harassed by a service user, suppliers, contractor, visitor or others, or if you witness someone else being bullied of harassed, you are asked to report this to your manager who will take appropriate action.
We will provide information and guidance to those involved in recruitment or other decision making where equal opportunities issues are likely to arise to help them understand their responsibilities and to avoid the risk of discrimination.
All staff are responsible to support the organisation to meet its commitment and avoid unlawful discrimination. If you believe that you have been discriminated against you should report this to your line manager or the chief executive under the grievance procedure.
We take any complaint seriously and you will not be penalised for raising a grievance, even if your grievance is not upheld, unless your complaint is both untrue and made in bad faith.
If you witness what you believe to be discrimination you should report this to your line manager or the chief executive as soon as possible.
Employees can be held personally liable as well as, or instead of, the organisation for any act of unlawful discrimination. Employees who commit serious acts of harassment may be guilty of a criminal offence. Acts of discrimination, harassment, bullying or victimisation against employees or customers are disciplinary offences and will be dealt with under our disciplinary procedure. Discrimination, harassment, bullying or victimisation may constitute gross misconduct and could lead to dismissal without notice.
This policy will be monitored periodically to judge its effectiveness and will be updated in accordance with changes in the law. We will report to the board of trustees on any actions or activities undertaken to improve equality of opportunity.
Any information provided by job applicants and employees for monitoring purposes will be used only for these purposes and will be dealt with in accordance with the General Data Protection Regulation (GDPR).
This policy will be reviewed at least annually, or upon material changes in practice, or changes in regulation or legislation.