In accordance with the UK General Data Protection Regulation (GDPR), Belong Limited is committed to protecting your personal information when you are communicating with us, whether using our website, as a customer of Belong Limited, an employee of Belong Limited or a job applicant.  This privacy policy describes the practices we follow in order to respect the privacy of your personal data.

Belong Limited is registered with the Information Commissioners Office (ICO) registration number Z7587537.

At Belong Limited we have focussed on implementing fair practices that are designed to protect your privacy. All personal data obtained and held by us will be processed to ensure that:

•    Processing is fair, lawful and transparent
•    Data is collected for specific, explicit and legitimate purposes
•    Data collected is adequate, relevant and limited to what is necessary for the purposes of processing.
•    Data is kept accurate and up to date.  Data which is found to be inaccurate will be rectified or deleted without delay.
•    Data is not kept for longer than is necessary for its given purpose
•    Data is processed in a manner that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisational measures.

If you have any questions or comments about this Privacy Policy please contact:

PA to the Chief Finance Officer
Belong Limited
Pepper House
Market Street
Nantwich
CW5 5DQ
Email: privacy@belong.org.uk

Websites provided by Belong Limited can collect personally identifiable information which is voluntarily provided by visitors to the Website (user data).  The user data that Belong Limited receives from site visitors is typically to:

•    Register for certain areas of the site
•    Receive requested brochures and other materials
•    Apply for jobs
•    Contact us for further information of our services
•    Enter and submit surveys
•    Register for events.

Belong Limited is committed to only collecting the minimum information to achieve the visitor’s request.

Belong Limited may also collect or receive personally identifiable information from other sources such as telephone enquiries or in person when visiting our premises, however, Belong Limited is committed to only collecting the minimum information to achieve the callers or visitor’s request.

4.1 Prospective Employees, Existing Employees, Volunteers and Members of the Society
4.1.1 Types of Data Held / Collecting Data
You provide several pieces of data to us directly during the recruitment period and subsequently upon the start of your employment.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers (when obtaining references), Disclosure and Barring Service or professional member organisations.

We keep several categories of personal data on prospective employees in order to carry out effective and efficient processes, this data would be kept within our online application and recruitment system and recruitment files.

Specifically we hold the following types of data:

• Personal details such as name, address, phone numbers and email address
• Details of gender, marital status, information of any disability you have or other medical information, together with information on your race and religion (for equality monitoring purposes)
• ‘Right to Work’ documentation
• Information gathered via the recruitment process such as that on our website which has been submitted by completion of an on-line application form, CV or information included in a cover letter
• References from former employers
• Details on your education and employment history, etc
• Driving licence
• Criminal convictions data – we only collect this data when it is appropriate for the role and the law permits us – via a DBS check.

In addition, for employees/successful applicants, we would also hold information relating to your employment with us, including:

• National insurance number
• Bank account details
• Tax codes
• Job title and job descriptions
• Details of your salary
• Name and contact details of your next of kin
• Your photograph
• Terms and conditions of your employment
• Details of formal and informal proceedings involving you such as ‘letters of concern’, disciplinary and grievance proceedings, appraisal and performance information.
• Internal and external training modules undertaken
• Information on time off from work including annual leave, sickness absence, family related leave, etc.
• Building access records
• IT equipment use including telephones and internet access

4.1.2 Lawful basis for processing your data
Our purpose for processing your information is to assess your suitability for the role. In the main we process your data in order to comply with a legal requirement or in order to effectively manage the recruitment process at your request and if successful offer an employment contract with you.

4.1.3 Failure to provide data
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment or administer contractual benefits.

4.1.4 Who we share your data with
We share your data only with Belong employees who require that information in order to carry out their relevant function, for example, those who have responsibility for recruitment, administration of payroll and contractual benefits, the carrying out of performance related/management of your contract. All employees with such responsibility have been informed about compliance with GDPR.

Data may also be shared with third parties for the following reasons – for criminal record checks, medical reports, informal/formal procedures where outsourced employment law or other legal guidance is required, administration of payroll and contractual benefits, training requirements etc.,

4.1.5 User data collected for Recruitment Purposes
Your data is stored and processed using a recruitment management system. This system is hosted on AWS (Amazon Web Services). U.S. and European Commission Model Clauses are in in place by the system provider for data transfers outside of the UK.

Your Data will be removed within 14 months of ceasing being a candidate for the vacancy applied for. However, candidates have the right to have their data removed earlier by contacting the Data Protection Department.

4.2 Enquiries and Marketing
Personal data collected for Belong Limited enquiries and marketing is used for internal business purposes and in connection with dealing with your enquiry or request. This data is not shared with others for unrelated purposes unless stated in this Privacy Policy or otherwise communicated to you.

Except for instances where the person enquiring is explicitly choosing to receive specific Belong Limited marketing or other information Belong Limited will not use your personal data to distribute marketing or information materials.

If you contact us by telephone to make an enquiry about our services, we may record and monitor your call for quality and training purposes. We also use third party service providers for telephone call routing to our Villages and offices who may from time to time monitor telephone calls for service quality and compliance.

4.3 Belong at Home Customers

4.3.1. Types of data held / collecting data

The personal data collected includes information such as customer name, address, telephone number, email address, date of birth, relevant health and medical details, details of who to contact in the event of an emergency and how to contact them, personal information to enable us to match you with an appropriate care working and your preferences relating to care services as detailed in your support plan.

This information will be used to provide the agreed services as detailed in your support plan. This will also include administering our accounts, issuing invoices and processing payments for those services. This will also assist us with dealing with any queries. The information will also allow Belong Limited to maintain its administration systems in order to comply with our contractual, statutory and legal obligations.

Customer information will be shared with the relevant members of Belong Limited’s staff which includes Support Workers and Administrative staff who need to know this information in order to provide our services to the customer. Belong Limited may use the information in a general way to analyse activities and trends within the service to ensure quality and consistency.

Belong Limited may use hosted computer systems (Cloud) to process some data. Currently Belong uses software which is partly externally hosted to schedule and administer support worker visits to customers. However customer information is NOT disclosed to third parties except for instances which we are legally required to or required to do so by statutory authorities.

Customers have the right to access the information which we hold about them. This is called a Subject Access Request. Please contact privacy@belong.org.uk to request this.

4.4 Belong Residential Customers
4.4.1 Types of data held / Collecting Data
The personal data collected includes information such as customer name, telephone number, date of birth, relevant health and medical details, medication information, details of who to contact in the event of an emergency and how to contact them, personal information to enable us to match you with appropriate care working and your preferences relating to care services as detailed in your support plan.

To provide a better service we also have access to view parts of your NHS Patient Record. This data is shared with us under strict guidelines and we can only view this information, we are not able to make any changes to this information.

4.4.2 Lawful basis for processing data
This information will be used to provide the agreed services as detailed in your support plan. This will also include administering our accounts, issuing invoices and processing payments for those services. This will also assist us with dealing with any queries. The information will also allow Belong Limited to maintain its administration systems in order to comply with our contractual, statutory and legal obligations.

4.4.3 Who we share your data with

Customer information will be shared with the relevant members of Belong Limited’s staff which includes Support Workers and Administrative staff who need to know this information in order to provide our services to the customer. Belong Limited may use the information in a general way to analyse activities and trends within the service to ensure quality and consistency.

Customer information is NOT disclosed to third parties except for instances which we are legally required to, required to do so by statutory authorities or requested to do so by the customer or their legal representative. We will however disclose personal information to the emergency services or other healthcare professionals where it is deemed in the customer’s vital interest. We also send information into the NHS National Records Locator service which allows for seamless transfer of personal information to emergency services sometimes referred to as a “Hospital Pack”. This process is in line with PRSB (Professional Records Standards Body) guidelines.

Belong Limited may use hosted computer systems (Cloud) to process some data. Currently Belong uses software which is externally hosted to store and manage care and support plans. Belong also currently uses software which is externally hosted to store and manage medication records (previously known as MAR Sheets). This information is shared with our Pharmacy supplier for the purposes of supplying medication products for our customers.

Customers have the right to access the information which we hold about them. This is called a Subject Access Request. Please contact privacy@belong.org.uk to request this.

4.5 CCTV Images
4.5.1 Types of data held / collecting data
The personal data collected on CCTV systems operated by Belong are images within public areas of the Belong Villages. This includes areas internally and externally around the premises.

4.5.2 Lawful basis for processing data
Belong Limited has vulnerable people living and visiting the Villages, therefore we record, store and process CCTV images as a legitimate business purposes.

4.5.3 Who we share your data with
These images are for the safety and security of people living at or visiting the Belong premises and are also for the protection of the village against fraud and other crime. These images may be supplied to relevant authorities should we be requested to do so for the purposes of crime prevention, crime investigation or if we are legally required to do so.
In certain circumstances we may contract with a third party specialist security organisation for the purposes of gaining their expertise for a particular part of the organisation. We may also share access to the CCTV images with this organisation.

Belong Limited will only disclose your personal data to third parties under the following circumstances:

• when explicitly requested to by you
• if it necessary to fulfil your request to deliver marketing or reference materials requested by you
• should it be necessary to fulfil any other request
• if Belong Limited is legally required to do so.

Belong Limited does not collect personally identifiable information for dissemination or sale to third parties for consumer marketing purposes, or host such services on behalf of third parties.

Cookies are tiny data files that allow a website to collect and store data onto a site visitor’s computer or laptop or mobile device.

6.2 Improve the way our websites and mobile apps work
Cookies allow the website to recognise a returning visitor on connection to the website which in turn can enable the downloading of web pages to be faster than on first visit. Cookies can also help the website to remember the visitor’s preferences from their previous visit.

6.3 Site performance and navigation data
Cookies allow us to track the performance and technical errors of a website or mobile app by collecting statistical information such as page speed and errors encountered. The site may also track the navigation route a user takes while browsing the site. This helps Belong Limited to understand the ease of use of the site. The information collected by such cookies is mostly aggregated and anonymous. However, a visitor’s IP address may also be logged by the web server.

6.4 Choosing whether to accept or reject Cookies
Site visitors can choose whether to accept or reject the use of Cookies by the use of their browser settings. However, this may mean that the visitor does not have full use of all the facilities of the website.

The procedure to choose whether to accept or reject Cookies varies for different web browsers or software. Visitors should refer to their web browsers help or software supplier to assist with this.

Belong Limited’s webserver is located in the United Kingdom and all User Data processing or storage is performed in the EU.

Belong Limited may include links on its website which are to external organisations websites which do not operate under Belong Limited’s privacy practices. When visitors follow links to other websites, Belong Limited’s privacy policy no longer applies. Visitors should review each sites own privacy policy.

Visitors are not required to register or sign in to gain access to the website, however some services such as being able to save job applications to complete later will require registration although you are not required to register to apply for jobs.

Personally identifiable data provided to Belong Limited through the website for services such as brochure requests and through contact forms is provided voluntarily. Visitors to the site can also choose whether to receive regular updates and information from Belong Limited, visitors can also choose to be removed from such mailing lists.

Any communication sent via mailing lists will provide clear instructions on how to be removed from the mailing list.

Each visitor or caller has the right of access to their personal data which Belong Limited stores as a result of submitting information through the website, supplying during a telephone enquiry or making an enquiry in person.

Customers and employees of Belong Limited also have the right of access to their personal data.

Enquiries about the data stored or the accuracy of data stored along with requests to have information removed should be sent to privacy@belong.org.uk

All Belong Limited Directors, Employees and volunteers are instructed to follow an organisation-wide security policy. Only authorised personnel are given access to personally identifiable information. Authorised personnel are required to agree to ensure confidentiality of this information and the use of this information is restricted to the purposes as defined in Belong Limited’s security policy.

12.1 For Website users
Belong Limited reserves the right to change this Privacy Policy as it may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the website and you are deemed to have accepted the terms of the policy on your first use of the website following the amendment.

Should Belong Limited make material changes to the Privacy Policy, Belong Limited will notify Website users by method of a prominent link which will be displayed on the Website home page for a minimum period of two weeks.

12.2 For Belong Customers

Belong Limited reserves the right to change this Privacy Policy as it may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the website. Material changes to the Privacy Policy will be communicated to our customers through their usual communication method with us.

12.3 For Belong Employees and Volunteers

Belong Limited reserves the right to change this Privacy Policy as it may deem necessary from time to time or as may be required by law. Any changes will be communicated to staff via email or by their Manager.

12.4 For Members of the Society
Belong Limited reserves the right to change this Privacy Policy as it may deem necessary from time to time or as may be required by law. Any changes will be communicated to Members either via letter or email.

By using the Website and by providing any personal data or information through the Website or email addresses displayed on the Website, visitors are consenting to our use of your personal information as set out in this Privacy Policy.

Please do not submit or send us any of your personal information if you do not want that information to be used in this manner.

In accordance with the Privacy and Electronic Communications Regulations 2003 Belong Limited does not send bulk unsolicited emails (popularly known as SPAM) to email addresses.