Healing Process policy suite

Equality, Diversity, Inclusion and Human Rights Policy

1. Purpose

To ensure that Healing Process is designed, supplied and operated in a way that respects dignity, advances fair access, identifies avoidable disadvantage and does not introduce unlawful discrimination into a digital care pathway.

2. Scope and status

This policy applies to directors, workers, contractors, product design, research, marketing, procurement, support and every customer deployment. NHS and care providers retain their own statutory and organisational duties and must complete a local equality impact assessment for the configured service.

Core supplier and product policy

3. Policy principles

• People will be treated fairly and with dignity irrespective of protected characteristic, health status, communication need, socioeconomic circumstance, digital access or any other irrelevant factor.
• Equality is an active design and governance task. A technically identical service can produce unequal access or outcomes, so the company will examine barriers, completion rates, model performance, support use and clinical workflow effects.
• No person will be required to use a digital route where an appropriate reasonable adjustment or non-digital alternative is needed for access to care.
• Inclusive language must remain accurate for clinical, legal and safeguarding purposes. Respect and data accuracy are complementary obligations.

4. Mandatory requirements

• Complete and maintain a product equality impact assessment covering enrolment, identity, photography, image quality, skin-tone representation, messaging, clinician review, accessibility, language and support.
• Require each live provider to identify the local population, exclusion risk, alternative route, reasonable adjustments, protected-characteristic monitoring and accountable equality lead.
• Recruit diverse participants for user research and evaluation, provide accessible participation methods and record where important groups are under-represented.
• Test image capture and any analytical function across relevant skin tones, body sites, conditions, devices, age groups and environments; do not publish parity claims without evidence.
• Review public content, training and support material for stereotypes, unnecessary assumptions, inaccessible formats and wording that could discourage a person from seeking help.
• Provide a route for equality concerns and ensure that complaints, incidents and adverse trends are investigated without retaliation.
• Use suppliers and partners whose conduct is compatible with this policy and include relevant equality, accessibility and ethical requirements in contracts.

5. Procedure and escalation

• At discovery and before each material release, the product owner records affected groups, foreseeable barriers and planned mitigations.
• Before deployment, the provider and supplier agree the alternative pathway, supported-use arrangements, accessibility contacts, language services and equality measures.
• During operation, dashboards should support proportionate equality monitoring using lawful, minimised data. Small-number suppression and privacy safeguards apply.
• Where a disparity or discriminatory effect is suspected, the responsible owner pauses or limits the feature where necessary, investigates causes, consults affected users and records corrective action.

6. Roles and responsibilities

Board

sets the tone, approves this policy and receives material equality risks and outcome trends.

Product and design teams

apply inclusive research, design and test criteria and document trade-offs.

Clinical and safety leads

consider differential clinical risk and ensure mitigations do not create false reassurance or delayed care.

People managers

maintain fair recruitment, work allocation, development and workplace adjustments.

Providers

own local legal duties, reasonable adjustments, service access, clinical pathway and local equality impact assessment.

7. Records, confidentiality and retention

Retain approved impact assessments, user-research demographics where lawfully collected, accessibility/equality test evidence, decisions, complaints, incidents, corrective actions and review minutes under the applicable records schedule.

Records created under this policy must be accurate, attributable, access-controlled and linked to the applicable retention schedule. Where a provider is the controller or authoritative record holder, its documented instructions and legal duties apply.

8. Monitoring, assurance and review

Review at least annually and after a major product, legal, clinical or population change. Report access, completion, support, safety and outcome measures by relevant groups where sample size and lawful processing permit. The policy owner records actions and completion dates.

Material non-compliance is reported through the relevant clinical-safety, patient-safety, data, security, safeguarding, HR, contractual or whistleblowing route. Corrective actions receive an owner, target date and effectiveness check.

9. Training and communication

The policy owner identifies which roles require awareness, operational or specialist training. Training is accessible, version-controlled, role-specific and refreshed after material change or evidence that understanding is inadequate. Providers communicate local procedures and contact routes before users are granted access.

10. Related documents

• Sex, Gender Reassignment and Gender Identity Policy
• Religion, Belief and Cultural Inclusion Policy
• Accessibility and Accessible Information Policy
• English as an Additional Language Policy

11. Approval record