Our policies

At TTB CircularIT, we operate to high standards of security, ethics, environmental responsibility and professionalism. This page brings together all of our organisational policies in one place to ensure transparency for our customers, partners, suppliers and the wider community. Each policy explains our commitments and the standards we follow across our operations, supply chain and service delivery:

Information Security Policy
How TTB CircularIT protects customer data and maintains compliance with industry standards.

Environmental Policy
Our commitments to reducing e‑waste, lowering emissions, responsible recycling, ethical sourcing and continuous environmental improvement.

Safeguarding Policy
Protecting children, adults at risk, staff, volunteers and members of the public during CircularIT activities.

Equality, Diversity & Inclusion (EDI) Policy
Our commitment to fairness, dignity, anti‑bullying, anti‑harassment and an inclusive environment for all.

Modern Slavery Policy
Our zero‑tolerance stance on modern slavery and human trafficking, including supply chain due diligence and ethical procurement.

Ethical Donations & Corporate Partnerships Policy
Our principles for accepting donated devices and working transparently with corporate partners while protecting independence and values.

Returns & Warranty Policy
Your rights and protections when purchasing a refurbished device from TTB CircularIT, including DOA coverage, returns and a 90‑day warranty.

Information Security Policy

1. Purpose and Scope

This Information Security Policy sets out the controls, responsibilities and procedures TTB CircularIT uses to protect all data-bearing assets handled throughout the lifecycle of our services — including secure collection, transport, refurbishment, certified data erasure, reuse-first processing and responsible recycling. Our objective is to safeguard client information, ensure regulatory compliance, and maintain the highest standards of data security.

This policy applies to:

• All TTB CircularIT employees, contractors and authorised partners

• All operational environments, including warehouse, logistics, digital systems and remote-working arrangements

• All data-bearing devices processed by TTB CircularIT

2. Information Classification

TTB CircularIT recognises three data classifications during the data-erasure process:

• Personal Data: One-pass overwrite, non-certified

• Business Data: One-pass overwrite, certified

• Business Confidential Data: Three-pass overwrite, certified
  All categories receive the same high operational safeguards. Classifications are recorded within our secure asset inventory system during processing. Client identifiers are restricted to the inventory system, and physical records are digitised and securely shredded after entry.

3. Roles and Responsibilities

• Managing Director: Oversees crisis management and escalated incidents.

• Technical Director: Leads IT security, system oversight, and data‑erasure processes.

• Chief Operating Officer: Owns this policy and ensures day‑to‑day operational compliance.

• Warehouse Manager: Implements physical and procedural controls and performs quality assurance checks.

• All Staff: Must follow all security protocols and report concerns immediately.

4. Access Control

TTB CircularIT enforces strict access controls across physical and digital environments:

• All warehouse access is digitally logged and restricted to authorised personnel only.

• Visitors must sign in/out and remain supervised at all times.

• IT systems require strong, regularly updated credentials.

• Data‑bearing devices are stored in a secure red zone.

5. Asset Management & Tracking

We maintain end‑to‑end audit trails for every device we handle:

• Real‑time digital tracking from collection to processing and final outcome.

• Barcoded asset management ensuring accuracy and traceability.

• Status updates recorded in our secure logging system at each stage.

6. Data Protection & Certified Erasure

TTB CircularIT complies with NCSC standards. Our certified erasure process includes:

• Immediate processing on arrival using industry-standard erasure software.

• Issuing detailed erasure audit reports for certified erasures.

• On‑site certified destruction for unsuccessful erasures, followed by licensed recycling.

• Complete audit trails stored securely.

7. Physical & Environmental Security

Our secure premises include:

• Access-controlled warehouse with robust physical security

• CCTV and locked storage for all devices

• Sealed, unmarked vehicles for device transport

• Verified driver identity and pre‑authorised routing

• Red-zone device storage until erasure is complete

8. Technical Security Measures

TTB CircularIT maintains high cybersecurity standards, including:

• Secure cloud storage

• Firewalls, antivirus, and cybersecurity hygiene across all systems

• Controlled access to critical erasure software stored on encrypted USBs
  

9. Incident Response & Management

We maintain clear, immediate procedures for security incidents, including:

• Physical security breaches

• Cybersecurity threats

• Operational disruptions
  Incidents are logged, investigated promptly, and escalated to the ICO where required. All actions are captured in full audit trails.

10. Business Continuity & Disaster Recovery

TTB CircularIT maintains resilience planning to minimise disruption in the event of: fire, theft, system failures, supply-chain interruption, or emergencies.
Recovery objectives include:

• IT systems restored within 24 hours

• Warehouse operations restored within 48–72 hours
  Alternate location plans are in place if needed.

11. Human Resources Security

All operational staff are vetted (ID verification, employment checks, DBS where relevant).
Ongoing training includes:

• Data protection

• Cybersecurity

• Secure handling of data-bearing devices
  We support knowledge sharing and operational resilience.

12. Compliance & Audits

We carry out regular internal quality assurance checks and random audits of erasure procedures. Issues are escalated and addressed promptly.
We are committed to full legal compliance and continual improvement.

13. Remote Working & BYOD

Remote or hybrid working must be authorised by line managers and follow strict security requirements:

• Secure home working environment

• Company-issued devices used exclusively for work and protected with strong passwords and encryption

• Approved VPNs for access to systems

• No downloading sensitive data to personal devices

• Immediate reporting of any suspected breach
  Personal devices (BYOD) may only be used with IT approval and must meet security standards; CircularIT reserves the right to remotely wipe company data if necessary.

14. Review

This policy is reviewed annually or following significant operational changes.

Reviewed: March 2026

Environmental Policy

1. Introduction

TTB CircularIT is committed to promoting environmental sustainability through secure, circular IT services. Our mission is to reduce e‑waste, extend the life of technology and minimise environmental impact through reuse‑first processing, repair, responsible recycling and transparent reporting. This policy outlines our approach to delivering environmentally responsible operations while complying with UK environmental regulations and best practice.

2. Scope

This policy applies to all CircularIT activities, including:

• Procurement of equipment and consumables

• Secure collections and logistics

• Refurbishment, repair and reuse-first processing

• Parts harvesting and responsible recycling

• Customer and stakeholder engagement

• Environmental reporting and impact measurement

3. Our Environmental Commitments

3.1 Reducing Environmental Impact

TTB CircularIT will:

• Prioritise refurbishment and reuse to extend device lifespan and reduce waste

• Minimise resource use and energy consumption in our facilities

• Use environmentally responsible packaging and logistics where practical
  

3.2 Responsible Recycling

Where reuse is not possible, we will:

• Partner with certified recycling facilities only

• Ensure maximum material recovery

• Reduce contributions to landfill

• Comply with WEEE and all relevant UK regulations
  

3.3 Promoting Awareness

We will:

• Educate customers, partners and communities about the benefits of reuse and repair

• Promote responsible disposal of electronic items

• Advocate for sustainable consumption and circular IT practices
  

3.4 Ethical Sourcing and Partnerships

TTB CircularIT is committed to:

• Working with suppliers that share our environmental values

• Ensuring all equipment handled is safe, ethically sourced and compliant with UK standards
  

3.5 Continuous Improvement

We will:

• Monitor and evaluate environmental impacts through audits and assessment

• Set measurable targets for reducing emissions, waste and energy use

• Adopt innovative practices and technologies supporting sustainability
  

3.6 Stakeholder Engagement

We aim to:

• Encourage customers and partners to participate in circular initiatives

• Provide clear information on responsible reuse and recycling

• Communicate progress, challenges and successes openly
  

4. Environmental Performance Targets & Monitoring

We will systematically collect and analyse data to inform improvements, including:

• Carbon emissions: Reduce carbon impact through reuse and recycling by at least 10% year‑on‑year

• Waste reduction: Increase reuse/refurbishment rates by 5% annually

• Energy consumption: Reduce operational energy use by 5% each year

• Logistics & transport: Lower transport emissions through route optimisation, behaviour change and use of low‑emission vehicles
  

5. Implementation & Accountability

TTB CircularIT will:

• Ensure all staff and partners understand their environmental responsibilities

• Allocate resources to support environmental initiatives

• Encourage feedback from staff, partners and stakeholders

• Conduct annual reviews of environmental performance to ensure transparency and continual improvement
  

6. Review

This policy will be reviewed annually to ensure ongoing relevance and compliance with evolving environmental legislation and best practice.

Reviewed: March 2026

Safeguarding Policy

1. Purpose

This policy sets out how TTB CircularIT safeguards and promotes the welfare of children and adults at risk. Our commitment is to prevent abuse wherever possible, act promptly where concerns arise, and ensure that everyone who interacts with our services is protected from harm. Safeguarding is essential to how we operate across collections, community events, site visits, and any activity where employees or volunteers interact with the public.

2. Principles

TTB CircularIT believes that:

• Anyone can be vulnerable given certain situations or circumstances

• Everyone has the right to feel safe, respected and free from harm

• Safeguarding is a shared responsibility across the organisation

• We must take proactive steps to minimise risk, including safe recruitment, training, supervision and clear reporting routes
  

We uphold a duty of care to staff, volunteers, visitors, contractors, customers and participants in any of our activities, whether onsite, in the community or in partner environments.

3. Definitions

Children and Young People
Anyone under the age of 18.

Adults at Risk
A person aged 18 or over who has care or support needs and/or is experiencing, or is at risk of, abuse or neglect.

Allegation
A concern relating to someone working with children or adults at risk who has:

• behaved in a way that caused or may cause harm, or

• potentially committed a criminal offence, or

• may pose a future risk of harm.
  

4. Safeguarding Responsibilities

Safeguarding is everyone’s responsibility. All CircularIT employees and volunteers must familiarise themselves with this policy and follow it at all times.

Managers

• Ensure their teams understand safeguarding responsibilities

• Discuss safeguarding in team meetings and supervision

• Manage or escalate safeguarding concerns and seek advice where needed
  

Designated Safeguarding Leads
The Managing Directors act as TTB CircularIT’s Designated Safeguarding Leads (DSLs). They are responsible for:

• Leading safeguarding procedures

• Overseeing safeguarding decisions

• Ensuring appropriate training and guidance is in place
  

5. Partnership Working

We work in partnership with statutory bodies, regulatory authorities and other relevant organisations to ensure safeguarding concerns are escalated and managed appropriately.

6. Prevention & Response

TTB CircularIT will:

• Use safe recruitment practices and checks

• Promote safe working environments and behaviours

• Raise awareness and provide ongoing safeguarding training

• Follow clear reporting procedures for suspicions or allegations of abuse

• Ensure all allegations are handled swiftly, proportionately and appropriately

• Uphold person‑centred, rights‑based safeguarding practice
  

Responses to risk will always be reasonable, proportionate, and focused on the least intrusive action appropriate to the circumstances.

7. Breaches of Policy

Failure to comply with this policy may result in:

• An internal safeguarding investigation

• A police investigation

• Referral to the Disclosure and Barring Service (DBS)

• Disciplinary action under our HR processes

• Internal or external review

The necessary route will depend on the nature and seriousness of the incident.

8. Accountability & Review

TTB CircularIT is committed to transparency, continuous learning and improving our safeguarding practices. The Managing Directors monitor this policy and ensure compliance.
This policy will be reviewed annually.

Reviewed: March 2026

Equality, Diversity & Inclusion (EDI) and Anti‑Bullying Policy

1. Introduction

TTB CircularIT is committed to maintaining a workplace and service environment in which everyone is treated fairly, with dignity and respect. We actively promote equality, celebrate diversity, and foster an inclusive culture where staff, volunteers, customers and partners can thrive. We operate a zero‑tolerance approach to bullying, harassment and discrimination of any kind.

This policy sets out our principles and responsibilities for ensuring an inclusive, respectful and safe environment for all.

2. Scope

This policy applies to:

• All employees and volunteers

• Contractors and partners

• Visitors and anyone engaged in TTB CircularIT activities, whether onsite, at events, or working remotely
  

3. Our Commitments

3.1 Equality, Diversity & Inclusion (EDI)

Promoting Equality
TTB CircularIT ensures fair treatment regardless of:

• Age

• Gender or gender identity

• Race or ethnicity

• Disability

• Sexual orientation

• Religion or belief

• Socioeconomic background

• Any protected characteristic under the Equality Act 2010
  We commit to ensuring equal access to opportunities, support and resources.
  

Celebrating Diversity
We value the unique perspectives and contributions of individuals from diverse backgrounds, and we actively encourage participation from underrepresented groups across our organisation and activities.

Inclusion & Accessibility
We aim to create an environment where everyone feels welcome, respected and empowered. We continually work to improve accessibility across our communications, facilities and services.

Education & Awareness
We provide training and resources to strengthen understanding of diversity, inclusion, unconscious bias and respectful behaviour.

3.2 Anti‑Bullying & Harassment

Zero Tolerance

We maintain a zero‑tolerance approach to bullying, harassment, victimisation, or abusive behaviour in any form — verbal, physical, written or digital. All allegations will be taken seriously and acted upon swiftly.

Unacceptable Behaviour
Bullying includes repeated or unreasonable actions that demean or intimidate.
Harassment includes unwanted conduct that violates an individual’s dignity or creates a hostile or offensive environment.

Reporting & Resolution
We provide clear, confidential processes for reporting concerns.
Reports will be investigated promptly, fairly and sensitively, with appropriate action taken.
Individuals raising concerns will be protected from retaliation.

Support for All Parties
We offer appropriate support for anyone affected by bullying or harassment, including access to guidance, mediation or other measures to restore a safe environment.

4. Responsibilities

Management

• Lead by example in promoting EDI and respectful behaviour

• Ensure appropriate responses to unacceptable behaviour

• Support implementation of this policy across teams
  

Employees & Volunteers

• Treat colleagues, partners and customers with respect

• Uphold the principles of this policy

• Report concerns or incidents promptly
  

Partners & Stakeholders

• Operate in line with TTB CircularIT’s standards

• Contribute to a positive, inclusive environment
  

5. Implementation & Monitoring

TTB CircularIT commits to embedding EDI values into all policies, practices and day‑to‑day activities.
We monitor progress through regular assessment and review diversity and inclusion across the organisation.

6. Review

This policy is reviewed annually to ensure alignment with best practice and legal requirements.

Reviewed: March 2026

Modern Slavery Policy

1. Introduction

TTB CircularIT is committed to preventing modern slavery, human trafficking and all forms of exploitation within our operations and supply chains. As a provider of secure, circular IT services, we recognise our responsibility to uphold human rights, ensure ethical labour practices, and promote full transparency throughout the lifecycle of our services—from collection and data erasure to reuse-first processing and responsible recycling.

This policy sets out our approach to identifying, preventing and addressing risks of modern slavery in all areas of our business.

2. Scope

This policy applies to:

• All TTB CircularIT employees

• Contractors, agency workers and consultants

• Suppliers, logistics partners and downstream recycling partners

• Any organisation or individual working on our behalf or engaging with our supply chain
  

3. Our Commitments

Zero Tolerance for Modern Slavery
We operate a strict zero‑tolerance approach to modern slavery and human trafficking.
TTB CircularIT will not engage with suppliers or partners who cannot demonstrate compliance with ethical labour standards.

Supply Chain Due Diligence
We carry out proportionate risk assessments and due diligence across our supply chain, particularly relating to:

• Device sourcing and collections

• Logistics and transport

• Recycling and materials processing

We expect all suppliers to comply with the Modern Slavery Act 2015 and to provide evidence of robust labour practices upon request.

Ethical Procurement Practices
TTB CircularIT sources equipment, components and consumables only from reputable suppliers that can demonstrate ethical working practices.
We avoid partnerships where labour standards cannot be verified or where unacceptable working conditions are suspected.

Awareness and Training
We provide training and guidance so employees and relevant partners can:

• Recognise indicators of modern slavery

• Understand how to escalate concerns

• Support ethical decision‑making across operations

Reporting and Accountability
We maintain a confidential process for reporting concerns about potential modern slavery or exploitation. All concerns will be investigated promptly, and appropriate action will be taken, including supplier termination or reporting to authorities when necessary.

Continuous Improvement
We review and strengthen our procedures regularly to reflect evolving risks, legislation and best practice. This includes ongoing review of supply chain transparency, training, and procurement processes.

4. Responsibilities

• Management: Ensures implementation of this policy and oversight of supply chain risk.

• Employees: Must remain vigilant, report concerns and adhere to this policy.

• Suppliers & Partners: Must comply with TTB CircularIT’s standards and provide evidence of ethical practice when requested.

5. Review

This policy will be reviewed annually to ensure continued effectiveness and alignment with the Modern Slavery Act 2015 and other relevant legislation.

Reviewed: March 2026

Ethical Donations & Corporate Partnerships Policy

1. Purpose

This policy sets out how TTB CircularIT accepts, evaluates and manages donated devices, corporate contributions, in‑kind support, and partnership activity.
It exists to ensure that all contributions:

• Align with our values

• Support our mission of secure, circular IT services

• Do not create conflicts of interest

• Are safe, lawful and compliant

• Maintain our independence and integrity

Although CircularIT is a commercial organisation, donated devices and partnership support form an important part of how we deliver environmental and social impact. This policy ensures an ethical and transparent approach.

2. Principles

We follow these principles when assessing donated devices or partnership offers:

• Integrity & transparency: We operate openly and honestly, and we respect donor/partner intent. [3 TTB Equa...ity Policy | Word]

• Safety & compliance: Only lawful, safe and legitimate devices or support will be accepted.

• Independence: Contributions must not influence our operational decisions or compromise our independence. [3 TTB Equa...ity Policy | Word]

• Value for purpose: Device donations must be useful, processable and aligned with our circularity objectives.

3. What We Accept

3.1 Donated Devices (Gifts‑in‑Kind)

We may accept donated equipment where:

• Devices are legally owned by the donor

• Items are safe, lawful and practical to process

• Devices align with our reuse-first approach
  

This includes laptops, PCs, mobile devices, tablets, peripherals and accessories.

3.2 Corporate Support

CircularIT may accept:

• Sponsored collections, Tech Amnesty Days or events

• In‑kind support such as logistics or equipment

• Partnership projects that align with our mission
  

We do not run public fundraising or charity appeals — all community benefit resulting from CircularIT activity is delivered through our operational impact and our relationship with TechTakeback Foundation (an independent charity).

4. Conditions for Acceptance

We will accept support only when it:

1. Aligns with our values and mission

2. Does not impose inappropriate influence over operations, research or decision‑making

3. Is lawful, safe and suitably risk‑assessed

4. Does not present significant reputational, ethical or compliance risks

5. Comes from a source whose identity is known and legitimate (no anonymous sources other than public anonymity with known identity internally)
   

5. Due Diligence (Risk‑Based)

All significant device donations or partnership offers undergo basic due diligence checks, including:

• Identity and legitimacy of donor/partner

• Device ownership verification

• Risk considerations (e.g., sanctions, criminality, ESG concerns)
  

Additional checks may be carried out for:

• Large volumes of devices

• Corporate partnerships

• Higher‑risk sectors or international sources
  

Outcomes include: accept / accept with conditions / decline.

6. Conditions on Support

If conditions are attached to a donation or partnership, they must be:

• Reasonable and deliverable

• Fully aligned with our operational model

• Free from undue influence or attempts to control CircularIT operations
  

If conditions cannot be met, the contribution may be declined.

7. Refusing or Returning Donations

TTB CircularIT may refuse or return donations or partnership support if they:

• Present significant reputational or ethical risk

• Are suspected to be linked to illegal activity

• Are unsafe or not processable

• Impose inappropriate restrictions
  

Concerns may be escalated internally and, if necessary, to relevant authorities.

8. Corporate Partnerships & Sponsorship

Corporate partnership activity must:

• Be transparent and documented

• Not imply endorsement of a company’s products or services

• Include clear terms around brand use, recognition, deliverables and termination
  

Where partnerships involve Tech‑Takeback Foundation, independence is preserved and conflicts of interest are managed accordingly.

9. Gifts‑in‑Kind (including Donated Tech)

We accept donated devices or equipment where the items are:

• Safe and lawful

• Useful for repair, refurbishment or parts harvesting

• Suitable for our processing capabilities
  

Corporate donors may receive documentation they require for internal reporting (not tax advice).

10. Recognition & Anonymity

Donors or partners may request public anonymity.
We maintain internal records for compliance and due diligence.
Recognition will always be proportionate and will not overstate levels of influence.

11. Working Responsibly With People

We ensure:

• No high‑pressure engagement

• No targeted outreach to vulnerable individuals

• All personal data is handled lawfully under UK GDPR
  

12. Records & Data Protection

Records relating to device donations or partnerships are retained in line with our Data Retention Policy. We comply with UK GDPR, and any data sharing with authorised processors follows strict security standards.

13. Roles & Responsibilities

• COO: Implements this policy and documents due diligence decisions

• Senior Leadership: Approves higher‑risk decisions

• Staff: Must follow this policy and escalate concerns promptly

14. Complaints & Reporting Concerns

Concerns about donations, partnerships or ethical issues can be raised via CircularIT’s complaints or whistleblowing channels.

15. Review

This policy will be reviewed annually or following any material change in operations or legislation.

Reviewed: March 2026

Returns & Warranty Policy

1. Purpose

This policy explains how TTB CircularIT manages returns, warranty claims and “dead‑on‑arrival” (DOA) issues for refurbished devices purchased through our online shop or via offline agreements. It applies to both consumer and business customers and is designed to be clear, fair and transparent, reflecting our commitment to quality, trustworthiness and responsible circular IT practices.

2. Scope

This policy applies to all refurbished devices sold by TTB CircularIT, including laptops, desktops, tablets, monitors and peripherals.

3. 30‑Day Returns Policy

3.1 Eligibility

Customers may return a purchased item within 30 days of receiving it if:

• The device is not as described

• You change your mind (unused items)

• You identify a fault that does not fall under the DOA procedure

• You are otherwise dissatisfied with the device

3.2 Conditions

To qualify for a return:

• The device should be in the same condition as received (reasonable handling expected)

• All accessories, chargers and included items must be returned

• Any passwords, accounts or security locks must be removed before return

3.3 Refunds

Refunds will be processed once the returned item has been received and inspected.

• Refunds are made to the original payment method

• Collection or return shipping will be arranged with you where appropriate

4. 7‑Day Dead‑On‑Arrival (DOA) Protection

If your device arrives faulty or becomes unusable within 7 days of receipt, it qualifies as DOA.

4.1 What DOA covers

• Hardware failures

• Boot issues

• Functional defects present at arrival

• Items that materially differ from the listing description

4.2 DOA resolution

For confirmed DOA cases, TTB CircularIT will:

• Arrange free collection

• Offer a replacement device (where available)

• If no replacement is available, offer a full refund

5. 90‑Day Warranty

TTB CircularIT provides a 90‑day hardware warranty on all refurbished devices.

5.1 What the warranty covers

• Hardware faults arising from normal use

• Component failures

• Defects not caused by misuse, accidental damage or unauthorised modification

5.2 What the warranty does NOT cover

• Accidental damage (drops, spills, breakage)

• Software issues (malware, corrupted OS, user-installed software conflicts)

• Battery degradation beyond the guaranteed baseline

• Consumables (e.g., batteries past the initial 7‑day guarantee)
  

5.3 Battery guarantee

• Batteries are guaranteed to last at least 1 hour on first inspection

• Batteries not meeting this standard must be reported within 7 days for replacement

• After this point, batteries are considered consumables and not covered
  

6. Warranty Process

To request a warranty repair or replacement:

1. Contact hello@ttbcircular.co.uk with your order number and issue description

2. We will run remote troubleshooting to confirm the nature of the issue

3. If a return is required, we will arrange collection or provide return instructions

4. Devices will be repaired or replaced within a reasonable timeframe

5. If repair or replacement is not possible, a refund or partial refund may be offered depending on usage and age

7. Important Customer Responsibilities

Before returning or sending any device for warranty assessment, customers must:

• Remove all accounts, passwords and security locks

• Back up personal data (we cannot guarantee data retention during repair)

• Acknowledge that TTB CircularIT may need to perform data erasure as part of the diagnostics
  (This aligns with CircularIT’s secure data handling standards.)

8. Data Handling on Returned Devices

Because TTB CircularIT processes data-bearing devices securely, any returned data-bearing device will undergo certified data erasure. This ensures your personal data is protected and aligns with our Information Security Policy.

9. Right to Decline Warranty Claims

We may decline warranty or return claims if:

• The device shows signs of accidental or deliberate damage

• Software has been altered or corrupted

• Repairs have been attempted by third parties

• Serial numbers or asset labels have been tampered with

10. Review

This policy will be reviewed annually to ensure alignment with consumer law, industry standards, and operational best practice.

Reviewed: March 2026