Privacy Policy

This privacy notice explains how Belong Limited collects and uses personal data about website visitors, prospective customers and other people who enquire about or receive our services, job applicants and candidates, customers, relatives, representatives, visitors and other individuals who interact with us. It includes the processing of personal data throughout recruitment and when responding to enquiries, discussing our services and managing prospective customer relationships. It explains why we use personal data, the lawful bases we rely on, who we share it with, how long we keep it, whether it may be transferred outside the United Kingdom and the rights available to you. Individuals who join Belong Limited will receive a separate Colleague Privacy Notice during induction covering the processing of their personal data as colleagues and members of our workforce.

Belong Limited is the data controller for the personal data covered by this notice and is registered with the Information Commissioner’s Office under 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 questions about this notice, wish to exercise a data protection right or want to raise a concern about how your personal data has been used, please contact the Data Protection Team using the details below:

Data Protection Team

Belong Limited

Pepper House

Market Street

Nantwich

CW5 5DQ

Email: privacy@belong.org.uk

Belong Limited’s websites may collect personal data that visitors provide voluntarily. We typically collect this information so that visitors can:

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.

2.1 Lawful bases and consent

We use personal data only where we have an appropriate lawful basis and for the purposes explained in this notice or in privacy information provided when the data is collected. Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

Before submitting personal data, please read the relevant privacy information provided on the website or at the point of collection. If you have questions about how we will use the information, contact the Data Protection Team before submitting it.

Belong Limited may collect personal data when you contact us by telephone or speak to us in person at one of our premises. We collect only the information needed to respond to your enquiry, provide requested information or services, record relevant actions and meet any applicable legal, regulatory or safeguarding obligations. Information about the recording and monitoring of telephone calls is provided in Section 4.2.

4.1 Recruitment and candidates

4.1.1 Types of data collected, processed and stored

You provide personal data to us directly during the recruitment process and, if your application is successful, when completing pre-employment checks and onboarding arrangements. Once you join Belong Limited, further information about how we process your personal data as a colleague will be provided in the Colleague Privacy Notice during induction.

In some cases, we collect personal data about you from third parties, such as employment agencies, former employers or referees, the Disclosure and Barring Service and professional membership organisations. We also use an approved third-party pre-employment screening provider to carry out checks relevant to the role, which may include employment referencing, Disclosure and Barring Service checks, right-to-work verification, identity and address checks and other appropriate background checks. This may involve providing the organisation with information supplied during your application and receiving information or verification results from it.

We keep the categories of personal data needed to administer applications, assess suitability, complete relevant checks and communicate with candidates. This information is held in our online application and recruitment system and, where necessary, in 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.

If your application is successful, we may collect additional information needed to complete pre-employment checks, prepare an offer and establish your employment record. Once you join Belong Limited, the collection and use of payroll, benefits, performance, attendance, training, building-access and IT-use information is covered by the separate Colleague Privacy Notice provided during induction.

4.1.2 Lawful basis for processing your data

We process recruitment information to assess your suitability for a role, administer the recruitment process, take steps at your request before entering into an employment contract, comply with our legal obligations and, where appropriate, pursue our legitimate interests in recruiting and selecting suitable candidates. Where we process special category personal data or criminal offence data, we also identify and document an additional condition required by data protection law. The lawful basis and any additional condition depend on the particular information and purpose; we do not normally rely on consent where it would not be freely given.

Where an approved recruitment system uses artificial intelligence or automated processing to support initial candidate pre-screening, it may analyse information in an application, CV, answers to screening questions, qualifications, skills or work history against criteria relevant to the role. The system may produce a score, ranking, recommendation or indication that an application meets specified criteria. Belong Limited remains responsible for the recruitment process and applies appropriate human oversight. AI-generated outputs are not treated as conclusive or used as the sole basis for a recruitment decision without the safeguards required by data protection law. Before introducing or materially changing such a tool, we assess its purpose, necessity, accuracy, fairness, accessibility, security and potential effect on candidates, complete a Data Protection Impact Assessment where required, undertake supplier assurance and monitor for unjustified bias or discriminatory outcomes. If a decision with a legal or similarly significant effect is made solely by automated processing, you may make representations, challenge the decision and request human intervention by contacting the Data Protection Team.

4.1.3 Failure to provide data

If you do not provide information that is necessary for the recruitment process, we may be unable to assess your application, complete required checks or offer you employment. Where information is optional, we will make this clear.

4.1.4 Who we share your data with

We share candidate information internally only with colleagues who need it to administer recruitment, assess applications, arrange interviews, complete pre-employment checks or prepare an offer. If a candidate joins Belong Limited, subsequent payroll, benefits, performance-management and employment processing is covered by the Colleague Privacy Notice. Colleagues with access to recruitment information must comply with Belong Limited’s data protection and confidentiality requirements.

Candidate information may also be shared where necessary and lawful with recruitment agencies, former employers or referees, the Disclosure and Barring Service, occupational health or medical advisers, professional membership bodies, immigration or right-to-work checking services, recruitment-system providers, and legal or professional advisers. Each recipient receives only the information needed for its role, and suppliers processing personal data on our behalf must follow our instructions and meet appropriate contractual and security requirements.

4.1.5 User data collected for Recruitment Purposes

Your recruitment information is stored and processed through an externally hosted application tracking system (ATS). Where pre-employment or background checks are required, candidate information and supporting documents may also be submitted to, stored in and processed through a secure portal operated by an approved third-party screening provider. The providers and any authorised sub-processors act under contractual and security requirements appropriate to their roles. If personal data is processed outside the United Kingdom, Belong Limited ensures that the transfer is permitted by data protection law and protected by an adequacy regulation, approved contractual safeguards or another lawful transfer mechanism. Further information about relevant safeguards is available from the Data Protection Team.

We normally delete or anonymise recruitment information within 14 months after you cease to be a candidate for the vacancy concerned, unless we need to retain it for longer to meet a legal or regulatory obligation or to establish, exercise or defend a legal claim. You may ask us to delete your information sooner by contacting the Data Protection Team, although the right to erasure is not absolute.

4.2 Enquiries and Marketing

When you contact Belong Limited about our services, request information, attend an event, ask for a brochure or otherwise express an interest in becoming a customer, we may collect and use your name, contact details, enquiry details, service interests, communication preferences and a record of our communications. We use this information to respond to your request, provide relevant information, arrange visits or follow-up contact, manage prospective customer relationships and enquiry leads and understand demand for our services. We process this information where necessary to take steps at your request before entering into a contract and, where appropriate, for our legitimate interests in responding to enquiries, developing our services and managing prospective customer relationships. We do not use or share this information for unrelated purposes unless we have another lawful basis and have provided appropriate privacy information.

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.

When you telephone Belong Limited, including to make a customer enquiry or discuss our services, the call may be recorded and monitored. Where recording applies, we will provide an appropriate notification at or before the start of the call. Recordings may include the caller’s telephone number, the date, time and duration of the call, the voices of participants and information discussed during the call. We use recordings where necessary for our legitimate interests in maintaining service quality, training colleagues, confirming information provided or agreed, handling complaints, supporting safeguarding, preventing or detecting misuse, and establishing, exercising or defending legal claims. We balance these interests against the rights and freedoms of callers and restrict access to these recording to authorised personnel with a business need. Our telephone and call-routing service providers may process recordings on our behalf under appropriate contractual and security requirements. Recordings are kept only for as long as necessary for the stated purpose and in accordance with Belong Limited’s retention arrangements, after which they are securely deleted unless they must be retained for an ongoing complaint, safeguarding matter, investigation or legal claim. You may contact the Data Protection Team at privacy@belong.org.uk about a recording or to exercise your data protection rights.

Belong Limited may use an approved AI-enabled receptionist service for some enquiry calls. The service may transcribe the call and use the caller’s details and enquiry information to support initial call handling, routing and follow-up. Its function is intended to help the enquiry team to understand the enquiry and make contact. A member of the enquiry team will review the information, consider the caller’s circumstances and apply appropriate judgement before deciding what follow-up or action is required. AI-generated information is subject to restricted access and appropriate data protection and security controls.

4.3 Belong at Home Customers

4.3.1 Types of data collected, processed and stored

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 worker and your preferences relating to care services as detailed in your support plan.

To provide a better service we also use the GP Connect Service, facilitated by NHS Digital which allows 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.

Your personal 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 you. 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 use externally hosted computer systems (Cloud) to process data:

schedule and administer support worker visits to customers
store and manage care and support plans
store and manage medication records

We share Belong at Home customer information only where this is necessary and lawful, including where disclosure is required by law or by a statutory authority, where it is needed to provide or support the customer’s care, or where it is necessary to protect someone’s vital interests. Where a supplier processes personal data on our behalf, it must act only for authorised purposes and under appropriate contractual and security safeguards.

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 collected, processed and stored

The personal data 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, daily care notes and observations, care related assessments and monitoring including nutrition, hydration and mobility information, risk assessments and other risk information, including incidents and safeguarding concerns, wellbeing and daily activity information, clinical information including wound-care photographs and personal information to enable us to match you with appropriate care workers and record your preferences relating to care services as detailed in your support plan.

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.

We share customer information only where this is necessary and lawful. This may include sharing information with authorised Belong Limited colleagues, emergency services, healthcare professionals, statutory authorities and other organisations involved in providing or supporting a customer’s care. We may also share information where the customer or their legal representative asks us to do so, where disclosure is required by law, or where it is necessary to protect the customer’s vital interests. We also send information into the NHS National Records Locator service, which allows for the seamless transfer of relevant personal information to emergency services in a package sometimes referred to as a “Hospital Pack”. This process is in line with Professional Records Standards Body (PRSB) guidelines.

Belong Limited use hosted computer systems (Cloud) to process some data. 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 AI-assisted care planning and reporting

Belong Limited may use an approved artificial intelligence tool to support with care planning, care plan auditing and to analyse relevant care information to produce reports that help authorised colleagues identify patterns, changes or trends that may indicate a potential concern and support informed decision-making. The tool may process relevant personal data from the categories described in section 4.4.1 where this is necessary for these purposes. The tool provides indicators only: its outputs are not treated as conclusions or used as the sole basis for action. An appropriately trained colleague reviews the underlying information, considers the individual circumstances and applies professional judgement before any decision or action is taken. Access is restricted to authorised users, and the processing is subject to appropriate data protection, confidentiality, security, accuracy, supplier-assurance and human-oversight controls.

4.6 AI-supported room monitoring and falls alerts

Where appropriate, Belong Limited may use approved AI-enabled room sensors to support customers’ safety and care. The personal data processed may include movement and activity information, the customer’s identity and location, alerts and short event recordings relating to a possible fall. The system does not provide staff with conventional live video.

We use this information to identify possible falls or an increased risk of falling, alert authorised colleagues, support an appropriate response, review incidents and inform care planning. The lawful basis and any additional condition for processing health-related information will depend on the purpose and circumstances.

Any event recording is stored securely, accessed only by authorised users and retained only for as long as necessary for the authorised purpose. Suppliers processing information on our behalf must follow our instructions and meet appropriate contractual, confidentiality and security requirements.

Alerts, recordings and identified patterns are indicators only and are not used as the sole basis for a care decision or intervention. An appropriately trained colleague reviews the available information and the customer’s individual circumstances before deciding what action is appropriate. The processing is subject to accuracy, fairness, data protection and human-oversight controls, and individuals may exercise the rights described in Section 10.

4.7 CCTV Images

4.7.1 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.

4.7.2 Lawful basis for processing data

Belong Limited uses CCTV where necessary for its legitimate interests in maintaining safety and security, preventing and detecting crime, supporting safeguarding and investigating incidents. Before relying on legitimate interests, we consider whether the processing is necessary and balance those interests against the rights and freedoms of the people recorded. CCTV is operated proportionately and in accordance with Belong Limited’s CCTV Security Policy and applicable data protection law.

4.7.3 Who we share your data with

CCTV images are used to support the safety and security of people living at or visiting Belong premises, protect premises and property, prevent and detect crime, support safeguarding and investigate incidents. We may disclose relevant images to the police, emergency services, regulators or other authorised bodies where this is necessary and lawful, including where disclosure is required by law or supports the prevention, detection or investigation of crime.

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 shares personal data only where this is necessary and lawful, including where you or your authorised representative ask us to do so; where sharing is needed to respond to your request, provide a service, protect someone’s vital interests or comply with a legal or regulatory obligation; and where an authorised supplier processes information on our behalf. We limit disclosures to information relevant to the purpose and require processors to follow our instructions and appropriate contractual and security safeguards.

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.

Belong Limited uses cookies and similar technologies to operate its websites, remember visitor preferences, understand website performance and, where applicable, support analytics or marketing. Cookies that are strictly necessary may be used without consent. Non-essential cookies will be used only where the required consent has been obtained through our website cookie controls.

6.1 What are Cookies?

Cookies are small text files that a website places on, or reads from, a visitor’s computer, mobile phone or other device. They can enable the website to recognise the device and remember information about the visitor’s choices or previous activity. Similar technologies, such as pixels, scripts, tags, local storage and device identifiers, may perform comparable functions and are covered by this section.

6.2 Improve the way our websites and mobile apps work

We may use cookies or similar technologies to recognise a returning visitor’s device, maintain website functions and remember choices such as language, display or accessibility preferences. Where an applicable legal exception permits their use without consent, we will provide a simple means of objecting where required. Otherwise, these technologies will be used only after the visitor has provided the required consent.

6.3 Site performance and navigation data

We may use cookies and similar technologies to measure website or mobile-app performance, identify technical errors and understand how visitors navigate our services. The information collected may include page loading times, error reports, pages viewed, navigation paths, device or browser information and IP addresses. Where these technologies qualify for the statistical-purpose exception, we will provide a simple, free means of objecting. Where the exception does not apply, we will obtain consent before using them. Information is aggregated or anonymised where appropriate, but it may still constitute personal data until that process is complete.

6.4 Choosing whether to accept or reject cookies

When you first visit our website, you can use the cookie controls to accept or reject non-essential cookies and select any available categories. Rejecting non-essential cookies will not prevent access to the website’s core functions, although features that depend on your chosen cookie settings may be unavailable. You can change or withdraw your choices at any time using the cookie settings available on the website.

You can also manage cookies through your browser or device settings. The steps vary between browsers and devices, so consult the relevant help information for instructions. Blocking all cookies, including those that are strictly necessary, may prevent parts of the website from operating correctly. Browser settings do not replace the website controls for giving, refusing or withdrawing consent to non-essential cookies.

Belong Limited and its authorised service providers may process personal data in the United Kingdom and, where necessary, in other countries. Where personal data is transferred outside the United Kingdom, we ensure that the transfer is permitted by data protection law and protected by an adequacy regulation, approved contractual safeguards or another lawful transfer mechanism. Further information about applicable safeguards is available from the Data Protection Team.

Our website may contain links to websites operated by other organisations. Belong Limited is not responsible for how those organisations collect or use personal data after you follow an external link. You should review the privacy information provided on each external website before submitting personal data.

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.

Personal data submitted through brochure requests, contact forms and similar website services is provided voluntarily, although some information may be necessary for us to respond to a request. Where you can choose to receive updates or marketing from Belong Limited, we will explain the available choices and provide a clear way to opt out.

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.

Depending on the circumstances and the lawful basis used, you may have the right to be informed about how your personal data is used; request access to your personal data; ask for inaccurate or incomplete information to be corrected; ask for information to be erased; ask for processing to be restricted; object to processing; receive certain information in a portable format; and challenge certain automated decisions or request human intervention. You may also withdraw consent where consent is the lawful basis. These rights are not absolute, and we may need to verify your identity or restrict a request where permitted by law. Requests should be sent to privacy@belong.org.uk. We will respond within the timescales required by law.

10.1 How long we keep personal data

We keep personal data only for as long as it is needed for the purpose for which it was collected, to meet legal or regulatory obligations, or to establish, exercise or defend legal claims. Retention periods are set through Belong Limited’s records retention arrangements and take account of the nature and sensitivity of the information and the risks associated with keeping it. At the end of the applicable retention period, information is securely deleted or anonymised, or archived where there is a lawful reason to retain it. Specific retention information may also be provided when personal data is collected.

10.2 Complaints about how we use personal data

You may make a complaint about how Belong Limited has used your personal data by contacting the Data Protection Team at privacy@belong.org.uk. We will acknowledge and respond to the complaint within the timescales required by data protection law. You also have the right to complain to the Information Commissioner’s Office. We welcome the opportunity to consider your concern first, but this does not affect your right to contact the Information Commissioner’s Office.

Belong Limited uses appropriate technical and organisational measures to protect personal data against accidental or unlawful loss, alteration, disclosure, destruction or access. Access is restricted according to role and business need, and colleagues, volunteers and suppliers with authorised access are subject to confidentiality, security and data protection requirements. Our controls include proportionate arrangements for access management, supplier assurance, incident handling, business continuity, records management and staff awareness. If you become aware of a suspected loss, unauthorised disclosure, access, alteration or misuse of personal data, please contact privacy@belong.org.uk.

12.1 For Website users

Belong Limited may update this privacy notice where legislation, regulatory guidance, our activities, systems, suppliers or the ways in which we use personal data change. The current version will be published on our website. Where a change materially affects how we use personal data, we will take reasonable steps to bring it to the attention of affected individuals before the new use begins.

For material changes affecting website users, we may also display a prominent notice on the website home page for an appropriate period.

12.2 For Belong Customers

The current version of this privacy notice will be published on our website. Where a change materially affects how we use customers’ personal data, we will take reasonable steps to communicate it through the usual contact method or another appropriate channel before the new use begins.

12.3 For Belong Employees and Volunteers

Changes affecting the processing of personal data about colleagues and volunteers will be communicated in accordance with the separate Colleague Privacy Notice and through an appropriate internal channel, such as email, the intranet or a manager briefing.

12.4 For Members of the Society

Where a change materially affects how we use the personal data of Society members, we will take reasonable steps to communicate it by email or another appropriate contact method before the new use begins.

Belong Limited sends electronic marketing only where permitted by the Privacy and Electronic Communications Regulations 2003 and data protection law. Where consent is required, we obtain it before sending marketing communications. Where the law permits us to rely on an existing customer relationship, we provide the opportunity to opt out. You may withdraw consent or opt out of marketing at any time.

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.