Privacy Promise

Who we are

We are BWL Social Care Limited (“BWL Social Care”) a company registered in England & Wales with company registration number 06552379.  Our registered office address is Concord Business Centre Nottingham Road, New Basford, Nottingham, England, NG7 7FF.

This privacy promise sets out how We collect and use personal data, in accordance with the UK’s General Data Protection Regulation (“GDPR”) and Data Protection Act 2018 (“Data Protection Legislation”).

Our promise to you

We respect your privacy and comply with data protection law whenever We process your data. The law says that the personal information We hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that We have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes We have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes We have told you about.
6. Kept securely.

How to contact us

If your query or concern relates to BWL Social Care, you can contact our Privacy Champion using the details below:

BWL Social Care

Email: privacy@bwlsocialcare.co.uk

What information we collect about you and why

The kind of information BWL Social Care collects about you will depend on who you are.  The sections below explain in detail what information is collected on each group of individuals.

Your personal information will only be used for the purposes for which it was collected, unless We reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If We need to use your personal information for an unrelated purpose, We will notify you and We will explain the legal basis which allows us to do so.

Please note that We may process your personal information without your knowledge or consent, but We will only do so where this is required or permitted by law.

It is important that you read this privacy promise together with any other privacy policy or fair processing policy We may provide on specific occasions when We are collecting or processing personal data about you so that you are fully aware of how and why We are using your data. This privacy promise supplements other notices and privacy policies and is not intended to override them.

Clients & clients’ families

Enquiries about provision of care services

Enquiry form.  If you are enquiring about the services which our network offers and complete the enquiry form on our website, BWL Social Care records the following information about you and/or the individual who may require our services:

• Name and surname;

• Contact details such as email address, telephone number; postal address including postcode;

• The nature of the relationship between the individual completing the enquiry form to the potential recipient of our services;

• Any requirements of the potential recipient of the services including any medical and/or health conditions;

BWL Social Care collects the above data for the purposes of matching you for the area where the services are to be provided.

“Save for Later” function.  This is a function which allows you to save your enquiry form without submitting it to us. If you use this feature, your partially completed form will be saved to our database, and you will receive an email with a randomly generated link which you can use to retrieve the form and continue to complete it.  If you do not retrieve your form within 8 weeks of the date when it was saved, all data will be automatically deleted from our server.

Call recording.  Please note that we may record incoming and outgoing calls for the purposes of monitoring and training.  You will be notified when recording is occurring.  We store recorded calls in accordance with our retention policy.

If you’re a client of ours

If you are a client, prospective client or former client of ours, or a family member, our office may collect and store the following categories of personal information about you:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses, date of birth, gender, marital status and any other information; and

• Medical and health information which is considered to be special category data;

Our office will collect and process your personal data for the purposes of providing the client with their services.  Please note that without collecting and processing certain personal data including any data required from you, your family or next of kin, our office will be unable to provide their services.

Our office may share some of your information with other health and/or social care professionals and emergency services where appropriate (i.e. required in order to provide you with their services, if it is in their legitimate interest to do so, or if it is in your vital interests).

GP Connect

Our offices may use a facility called GP Connect to support your direct care. GP Connect makes patient information available to all appropriate clinicians when and where they need it, to support direct patients care, leading to improvements in both care and outcomes.
GP Connect is not used for any purpose other than direct care.

Authorised Clinicians such as GPs, NHS 111 Clinicians, Care Home Nurses (if you are in a Care Home), Secondary Care Trusts, Social Care Clinicians are able to access the GP records of the patients they are treating via a secure NHS Digital service called GP connect.

The NHS 111 service (and other services determined locally e.g. Other GP practices in a Primary Care Network) will be able to book appointments for patients at GP practices and other local services.

Should you wish to know more about GP Connect, please contact your GP Surgery or visit:  https://digital.nhs.uk/services/gp-connect.

National Data Opt Out (England only).  The Office’s Privacy Champion reviews all of that office’s data processing on an annual basis and will assess if the national data opt-out applies to its processing. This is recorded in their record of processing activities. All new processing is also assessed to see if the national data opt-out applies.

You should note that the data opt-out does not apply where the office only uses your data for providing our care services. In most cases this will be the case.

Should at any time, our office’s data processing falls within scope of the national data opt-out they will use NHS Digital’s MESH system to check if any of their clients have opted out of their data being used for this purpose.

BWL Social Care.  We process your personal data for a number of reasons:

• For the purposes of monitoring the quality of the services provided by our office(s) (including for example by sharing your details with selected market research agencies)

• For the purposes of enforcing our rights and the office’s contractual obligations under their franchise agreement with us, including specifically carrying out regular audits to ensure that the office is providing the services in compliance with our high standards.

Employment and recruitment

If you are an employee of one of ours

If you are employed by us, we will collect a range of personal information about you. This will include:

• Personal contact details, such as your name, title, address and contact details, including email address and telephone number

• Date of birth

• Gender

• The terms and conditions of your employment

• Details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers

• Information about your remuneration, including entitlement to benefits such as pensions

• Details of your bank account, tax status and national insurance number

• Information about your marital status, next of kin, dependants and emergency contacts

• Information about your nationality and entitlement to work in the UK

• A copy of driving licence

• Details of periods of leave taken by you, including holiday, sickness absence, family leave and the reasons for the leave

• Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence

• Assessments of your performance, including appraisals, training you have participated in, performance improvement plans and related correspondence

• CCTV footage and other information obtained through electronic means e.g., swipe card records.

We may also collect, store and use the following special categories of more sensitive personal information:

• Information about medical or health conditions (e.g., sick notes), including whether you have a disability for which we need to make reasonable adjustments

• Information about your criminal record (where applicable)

• Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief (this information is optional and is only used to ensure that we are an equal opportunity employer).

We collect this information in a variety of ways. For example, data is collected directly from you through the application form, the recruitment process and during work-related activities throughout the period of working for them.

In some cases, we  collect personal data about you from third parties, such as references supplied by former employers.

Data is stored in a range of various places, including in your personnel file, in our HR system and in other IT systems (including the email system).

We need to process this data to form an employment contract with you and to meet its obligations under your employment contract. In addition, they may need to process data to ensure that they are complying with their legal obligations, for example, they are required to check an employee’s entitlement to work in the UK, and in some cases, it may be necessary to carry out criminal records checks to ensure that individuals are permitted to undertake a particular role.

BWL Social Care.  We process this data in order to ensure that we comply as it relates to safe and proper recruitment practices.

In other cases, we have a legitimate interest or legal obligation in processing personal data before, during and after the end of the employment relationship.  For example, we may contact employees who are leaving BWL Social Care in order to conduct an exit interview with them.  We will share the names and work email addresses of franchise owners and key players nominated for the purpose with our US parent company Honor Inc for purposes of invoicing royalties.

Applying for a job with BWL Social Care

If you apply for a position at BWL Social Car, we will collect and process the information you provide to us as part of your application. This information will be processed for the purposes of assessing your suitability for the role you have applied for.

If you are successful in your application the information you have supplied will form part of your HR record and processed as set out above in the “employee” section.

In addition, We will analyse information provided as part of the application process in order to identify trends and ensure that BWL Social Care remains an employer of choice in the market place.  We will always anonymise your data before we extract it from our systems to share with other parties.

If you are unsuccessful, unless you have given us permission to keep your application data, we will delete it once it is no longer lawful for us to retain it.

Website users

Our website is not intended for children and we do not knowingly collect data relating to children.

Using the Contact Us function

If you complete a Contact Us form on our website, We typically collect the following information:

• Your name and surname;

• Email address / Telephone number;

• Details of your enquiry.

Depending on what contact form you’re using, We may also collect additional information. It will be obvious what we’re collecting and why We need this additional information, and We will only use it for the purposes of the original contact.

If you contact Us by email and telephone, we will only collect and process the personal data which you provide to us, also, it shall only be used for the purposes for which you provide your personal data to Us.

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Our website uses cookies to distinguish you from other users of our website. This helps Us to provide you with a good experience when you browse our website and allows Us to improve our site.

We use cookies for a number of reasons on our website:

• Essential Cookies.  Cookies that are essential to the running of our website, in that the website will not function correctly without them. These are enabled by default and cannot be turned off, unless you change the cookie settings in your browser;

• Analytics cookies. For example, when someone visits our website, We make use of the Google Analytics service to collect standard information about visitors to the sites and their behaviour (e.g., what pages they viewed). The data provided by Google Analytics is anonymised and in no way enables Us to identify individual visitors, however, Google Analytics will place a cookie on your device to enable the service. For more information about how Google Analytics cookies work on websites visit: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage;

• Marketing cookies. These cookies are used for the purposes of measuring the effectiveness of our marketing campaigns and to also serve our advertising via Google’s and Teads’ advertising networks. We use these tracking technologies to help us run our business. We use cookies and tracking pixels for Google, Facebook, our Customer Relationship Management (CRM) system (see our use of UTM below) and Teads.

We also make use of specific website addresses (called “Urchin Tracking Module” or “UTM”) which allow Us to identify an individual from how they interact with our website. For example, it enables Us to track specific marketing campaigns, the source of those campaigns (e.g., on social media) and if you provide Us with contact information, we’re able to build up a profile of how you have engaged with our website and marketing activities. Such information will only be stored in our CRM if you have consented to the use of the cookies that are needed for the UTM to work.

Before We make use of these technologies via the website, where required you will be prompted to provide consent for their use. If you do not consent to their use, these cookies and pixels will not be used, and We will not be able to measure the effectiveness or provide our marketing messaging to you. However, if you do consent to the use of these cookies then certain information about you and your web activity will be shared with Facebook and Google for the purposes of their advertising services, and as such this data may be processed outside the UK and EEA. Via our cookie control settings, you may change your mind at any time.

Marketing

From time to time BWL Social Care may obtain your consent to send you educational and promotional material.  You will have the opportunity to specify how you wish to receive such material and we will only contact you by the means you have specified, i.e. email, mobile, landline or all contact options. You will have the opportunity to unsubscribe from all or some of the marketing material at any time. If you wish to unsubscribe, simply choose the Unsubscribe option or contact us and let us know that you no longer wish to be on the mailing list.

Your information is safe with us, and we will not share your personal data for marketing purposes with any third party other than as specified in this privacy promise or with your consent.

How long we keep your data

We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

BWL Social Care

Where data has been shared with us, we will retain access to that data for as long as we hold that data, in accordance with our data retention policy.

Website users

For all data submitted to us via our website, We will keep your details for a period of 6 months from the date of submission. Upon expiry of that period, your data will be automatically anonymised.

If you have used the “Save for Later” function you will have 8 weeks from the date on which you saved your form to retrieve it, complete it and submit it to us. If you do not retrieve and submit your form during this period, your data will be deleted automatically upon the expiry of 8 weeks.

Clients & clients’ families

To comply with our legal and regulatory obligations we have to retain your personal data for a period of 7 years from the date of last entry. Once this period has expired, all of your personal data will be permanently deleted.

Job Applicants

If your application is successful, the retention of your personal information will be governed by the retention timescales applicable to our employees.

If your application is unsuccessful, to comply with our legal obligations our office may retain your personal information for up to 6 months after you have been notified of the recruitment decision, unless you have given your express explicit permission to retain your information for longer.

Employees

To comply with their legal obligations our office has to retain the majority of your records for 6 years from the date your employment ends.

Where your data is stored

We do not, as a matter of course, transfer your data outside of the European Economic Area and use, as far as possible, UK or European data centres. Where We use data processors who only have overseas-based data centres, We only do so in limited circumstances and always only after completing a thorough due diligence process to ensure the continued safety and security of your data.

Third party processors

We use a number of third-party cloud-based services for the purposes of effectively running our business and providing our services to you. We also use a number of third-party organisations, e.g. accountants, HR support, CRM system etc.

In all cases where We are using a third-party service or company, We will only provide the minimal amount of information required.

We always carry out due diligence against all our third-party suppliers for the purposes of ensuring their compliance with Data Protection Legislation and specifically that they have suitably security measures in place to protect your data.  We also make sure a legally binding contract (sometimes called a Data Processing Agreement or DPA) is also in place to protect your data.

Your rights

Because the data We hold about you is your data, you have the following rights in respect of the personal data We hold about you:

1. Right to Access – this means that you can ask Us for a copy of all personal data We hold about you. This enables you to receive a copy of the personal information We hold about you and to check that We are lawfully processing it.
2. Correction Right – if you believe that any of the information We hold about you is incorrect or out of date, you have the right to correct such information by providing Us with the correct up to date information. In addition, you can ask Us to delete the incorrect or out of date information and We will be happy to do so unless We are prevented from doing so by law or regulation.
3. Right to be Forgotten – this enables you to ask Us to delete or remove personal information where there is no good reason for Us continuing to process it. Please note that where We are obliged to keep your personal data because of a regulatory or legal requirement, We will not be able to delete the data and must continue to retain it.
4. Right to Restrict Processing – in some limited circumstances you have the right to restrict the processing of your data.
5. Right of Objection to Processing – you have the right to object to Us using your data for direct marketing purposes and to profiling.
6. Right of Data Portability – you have the right to request a copy of the personal data We hold about you in a commonly used and machine-readable format. We can provide your data either to you or to such other third party as you specify in your request.
7. Automated Decision-Making Objection Right – automated decision-making is where a decision is made entirely by technological means without human intervention. We do not use or rely on automated decision-making.

If you would like to exercise any of the above rights please contact the relevant Privacy Champion using the contact details above.

Right to complain

If you have any concerns about our handling of your personal data, we’d rather you brought it to BWL Social Care in the first instance, but of course you have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) by visiting https://ico.org.uk/concerns/ or telephoning the ICO helpline on 0303 123 1113.

More information

For more information about your data rights and privacy or data protection in general visit the Information Commissioner’s Office website: https://ico.org.uk

Changes to this Privacy Promise

We keep our Privacy Promise under regular review. This Privacy Promise was last updated in January 2025.

If you have any questions about this Privacy Promise, please contact our BWL Social Care Privacy Champion via privacy@bwlsocialcare.co.uk.