1. Who this notice is from

This notice is given by Sen Works LLC, formed in the United States [state of formation and registered agent: TBC], with delivery through our company in Vietnam [name and enterprise registration number: TBC].

2. What this notice covers, and what it does not

This notice covers personal data we decide the use of ourselves: enquiries from this website, business contacts at clients and prospects, people who apply to work with us, and contacts at our suppliers.

It does not cover the data we handle when working for a client. In that work we act on the client's instructions and the client remains responsible for it. Where that data is protected health information under HIPAA, we act as a business associate. Those arrangements are governed by the services agreement, the data processing agreement and the business associate agreement signed with that client, and not by this notice. If you are a patient or a client's employee and want to know how your data is handled, the organisation that holds your record is the right place to ask.

3. What we collect

• Enquiries. Your name, employer, email address and anything you choose to put in your message.
• Candidates. Your application, CV, interview notes, right-to-work and, where a role requires it, the results of background and exclusion screening. See the separate candidate privacy notice [to be written].
• Business contacts. Name, role, work contact details and our record of dealings with you.
• Technical data. When you load this page, our hosting provider receives your IP address and browser details in the ordinary course of serving it. We do not use analytics or advertising tools. See the cookie notice.

4. Why we use it, and on what basis

Responding to you

To answer an enquiry and take a conversation forward. Legitimate interests, or steps taken at your request before a contract.

Recruitment

To assess an application and meet our checking obligations. Legitimate interests, and legal obligation where screening is required by a client contract or by law.

Running the business

Contract administration, invoicing, insurance and professional advice. Contract and legitimate interests.

Legal and regulatory

Tax, accounting, sanctions and anti-bribery obligations in the United States and Vietnam. Legal obligation.

5. Who we share it with

Our cloud, email and document providers; our accountants, insurers and legal advisers; and any authority we are legally required to tell. We do not sell personal data, and we do not share it for anyone else's marketing.

6. Sending data across borders

Our people are in the United States and Vietnam, and some of our directors are in the United Kingdom, so ordinary business contact data moves between those places. For personal data leaving the UK or the European Economic Area we rely on the UK International Data Transfer Agreement or Addendum, or the European Commission's standard contractual clauses, supported by a transfer risk assessment.

7. How long we keep it

Enquiries that do not become business, two years. Unsuccessful applications, twelve months, unless you ask us to keep you on file. Contract and financial records, six years after the relationship ends, or longer where tax law in a relevant country requires it. A full retention schedule sits in our internal document set.

8. Your rights

If UK or EU data protection law applies to you, you can ask for a copy of your data, ask us to correct or delete it, object to or restrict our use of it, and ask for it in portable form. Where we rely on legitimate interests you can object, and we will stop unless we can show compelling grounds. Write to [privacy@senworks.com: mailbox not yet created]. We will answer within one month.

You can complain to the Information Commissioner's Office in the United Kingdom, or to your local supervisory authority in the European Economic Area. We would rather you came to us first.

9. Security

How we protect client data is described in the security section of this site. Sen Works does not hold its own security certifications or attestations today. Each resource is contracted to work within the client's information security management system, in addition to Sen Works' own baseline controls and training, so our people meet the third-party requirements of our clients' HITRUST r2, SOC 2, ISO 27001 and other compliance programmes.

10. Changes and contact

We will post any change here with a new revision date. Questions to [privacy@senworks.com], or by post to [registered office: TBC].

The short version

This site sets no cookies. It carries no analytics, no advertising tags, no session tracking and no consent banner, because there is nothing to consent to.

The one thing worth telling you

The page loads its two typefaces from Google Fonts. That request goes to Google's servers and discloses your IP address and browser details to Google in the process. No cookie is set by it, but it is a disclosure to a third party and we would rather say so than not.

Server logs

Our hosting provider keeps ordinary access logs, including IP addresses, to serve the site and protect it from abuse. These are not cookies and are not used to build a profile of you.

If this changes

If we later add analytics, a chat widget, a contact form or anything that embeds a third-party player, this notice changes and a consent mechanism becomes necessary before those load.

These terms govern your use of senworks.com. They are not our master services agreement, and they do not govern any engagement. Services are provided only under a separate signed agreement.

1. Who operates this site

senworks.com is operated by Sen Works LLC. By using the site you accept these terms. If you do not accept them, please leave the site.

2. What the site is

The site describes our services in general terms. It is information, not an offer, and nothing on it forms a contract or a binding quotation. Descriptions of capability, timescales and security controls describe how we intend to work and are subject to the terms actually agreed in an engagement.

3. Not advice

Nothing on this site is legal, tax, clinical, regulatory or compliance advice, and it must not be relied on as such. Our summaries of United States healthcare rules, state requirements and data protection obligations are written for orientation and are not a substitute for your own advisers. Sending us an enquiry does not create a client relationship.

4. Our material

The text, diagrams, imagery, the Sen Works name and the lotus mark are ours or licensed to us. You may read, print and share the pages for the purpose of evaluating us as a supplier. Any other copying, republication or commercial use needs our written permission.

5. Acceptable use

Do not attempt to gain unauthorised access to the site or its hosting, probe or scan it, introduce anything malicious, scrape it at a volume that degrades it, or misrepresent your identity when contacting us. Security researchers acting in good faith are welcome to write to us first.

6. Links out

Where we link to another organisation, we do not control or endorse what is on the other end.

7. Availability

The site is provided as it stands. We do not promise it will be uninterrupted or error-free, and we may change or withdraw any part of it.

8. Liability

We do not exclude liability for death or personal injury caused by our negligence, for fraud or fraudulent misrepresentation, or for anything else that cannot lawfully be excluded. Subject to that, we are not liable for loss of profit, business, goodwill or data, or for indirect or consequential loss, arising from use of this site.

9. Governing law

These terms are governed by the law of [the state in which Sen Works LLC is formed: TBC], and the courts of that place have exclusive jurisdiction.

10. Changes

We may revise these terms. The version on this page at the time you use the site is the one that applies.

Our aim

We want this site to be usable by as many people as possible, including anyone using a screen reader, navigating by keyboard, or needing larger text or higher contrast. We build to the Web Content Accessibility Guidelines version 2.2 at level AA.

Where we actually are

We are partially conformant with WCAG 2.2 AA. No independent accessibility audit has been carried out, and we will not describe the site as conformant until one has. The assessment below is our own.

What we have done

• Semantic headings and landmarks, so the page can be navigated by structure.
• Visible keyboard focus on every link and control.
• Light and dark themes, both meeting the AA contrast ratio for body text.
• Text reflows and stays readable when zoomed to 200 per cent, and down to a 320 pixel viewport.
• The data-flow diagram carries a text description, and everything it shows is also written out in the surrounding copy.
• Motion is suppressed for anyone whose system asks for reduced motion.

Known limitations

• Our secondary green reaches roughly 4.4:1 against the page background, marginally below the 4.5:1 required for small text. We use it only for large text, headings, rules and fills, never for body copy. It is a constraint we work around rather than a defect we have fixed.
• Section headings and some display type use a colour gradient. Every stop in it clears the AA contrast ratio at the size used, but the gradient is decorative and carries no meaning on its own.
• The data-flow diagram scrolls sideways on a narrow screen. The text description is the accessible route to the same information.
• The policy sections above use expandable panels. They are keyboard operable and announce their state, but a very long policy inside one panel is harder to skim than a page of its own would be. The production build gives each policy its own page.
• We have tested with keyboard navigation and the browser accessibility inspector. We have not yet tested with JAWS, NVDA or VoiceOver end to end.

Telling us about a problem

Write to [hello@senworks.com: mailbox not yet created] and tell us the page and what went wrong. We will reply within five working days, and if we cannot fix something quickly we will tell you how to get the same information another way.

If you are a buyer asking about this

We do not hold a VPAT or Accessibility Conformance Report today. If your procurement process requires one, or requires conformance with Section 508 or EN 301 549, say so early: it means a paid independent audit, and it is better priced into the engagement than discovered during it.

This statement is made voluntarily. We are not a UK company and our turnover is in any case well below the £36 million threshold at which section 54 of the Modern Slavery Act 2015 requires a statement. We publish it because we supply offshore labour, and a buyer is entitled to ask how the people doing their work are treated before they are asked to sign anything.

Our structure and our supply chain

A contracting entity in the United States, Sen Works LLC, and a delivery company operating a single floor in Ho Chi Minh City. Our supply chain is short: the people we employ in Vietnam, the building and the services that run it, our IT hardware and our cloud providers.

Where the risk actually is

It is not the engineers. Software engineers and revenue cycle specialists in Ho Chi Minh City are educated, mobile and in demand, and the labour market protects them better than any policy of ours could. The risk sits in three places, and we would rather name them than produce a statement that implies there are none.

• Recruitment fees. Charging a worker to get a job is the most common route into debt bondage in South East Asia, and it usually happens through an agent rather than the employer.
• Facilities labour. Cleaning, security, catering and maintenance at the building are contracted, lower paid and less visible to us than our own staff.
• Hardware. The manufacture of the equipment on the floor sits in a supply chain we do not control and cannot see to the bottom of.

What we commit to

We have not yet hired. These are undertakings for our first hire onwards, not a description of a record we do not have.

• The employer pays. No worker pays any fee, to us or to anyone else, to be recruited or placed. Where an agency is used, the contract says so and we check it.
• Direct employment. Our delivery staff are employed by our Vietnamese company on written contracts in Vietnamese, not supplied as agency labour.
• No document retention. We do not hold anyone's passport, identity card or qualification certificates.
• Paid properly, traceably. Wages above the statutory regional minimum, paid on time into a bank account in the worker's own name. Overtime voluntary and paid at the statutory rate.
• Freedom to leave. Contractual notice only, no penalty for resigning, no bond tying anyone to a training cost.
• Facilities suppliers. Modern slavery terms in the building and facilities contracts, with the right to ask how those workers are paid.
• A way to speak up. A reporting route in Vietnamese that does not go through a line manager, with no retaliation. Shared with our whistleblowing policy.

Training

Managers with hiring responsibility will be trained on recruitment-fee risk and on the indicators of forced labour. Everyone else receives it as part of induction.

How we will know it is working

From the first full year we will report: the proportion of hires made directly, the number of workers who reported paying any fee to a third party, the number of facilities suppliers with modern slavery terms in their contract, and the number of concerns raised and how they were resolved. Publishing zero against a measure we have not taken would be worse than publishing nothing.

Approval

This statement covers the financial year [period: TBC] and was approved by Sen Works LLC on [date], and signed by [name and role].

A public summary of our internal anti-bribery and corruption policy. The full policy, the gifts register and the due diligence procedure are internal documents, available to a client under a security review.

Our position

We do not offer, give, request or accept a bribe, in any country, in any amount, for any reason, including where it would cost us the work. This applies to everyone who works for us and to anyone acting on our behalf.

The laws we operate under

Three regimes can reach us at once. The United States Foreign Corrupt Practices Act, which reaches Sen Works LLC and its dealings abroad. Vietnamese anti-corruption and criminal law, which applies to our delivery company and its staff. And the UK Bribery Act 2010, which reaches an organisation carrying on business in the UK and makes it liable for failing to prevent bribery by anyone performing services for it. We have no UK company, but we have UK-resident people, so we hold ourselves to it.

Where the three differ, we follow the strictest. The clearest example is facilitation payments.

Facilitation payments

Small unofficial payments to speed up a routine official act are prohibited outright. They are criminal under the UK Bribery Act with no exception, whatever the local custom and whatever a narrow exception elsewhere might appear to permit. Anyone asked for one refuses, pays nothing, and reports it the same day. Nobody will be penalised for a delay caused by refusing.

Gifts and hospitality

Modest, infrequent, openly given, proportionate to the occasion, and never around a live tender or decision. Anything above [threshold: TBC] needs approval in advance and goes in the register. Cash and cash equivalents are never acceptable in either direction.

Selling into United States healthcare

Our clients bill federal healthcare programmes, which brings the Anti-Kickback Statute and the Stark law into scope. We do not pay or accept anything of value in return for a referral of business, and we do not price an engagement in a way that turns on the volume or value of referrals.

Intermediaries

Agents, introducers, resellers and local advisers are the most common route by which a company acquires a bribery problem it did not intend. Anyone acting for us is checked before appointment, contracted with anti-bribery terms and a right to terminate, and paid a fee that is recorded, proportionate and traceable to real work.

Political and charitable giving

No political donations in any jurisdiction. Charitable donations only to a verified organisation, approved in advance, and never where they have been suggested by a client or an official.

Speaking up

Anyone can report a concern, including anonymously, through a route that does not pass through their line manager. Reports are investigated and nobody suffers for making one in good faith, even if they turn out to be mistaken. Contact [speakup route: TBC].