CLIENT POLICIES · 5 NOVEMBER 2026
Information sharing, data protection and confidentiality
In this document, “Bina”, “the Company”, “we”, “us” and “our” mean Bina Pathways Ltd (company number 16667031).
Operational guidance for clients and Bina Pathways Ltd staff. Applicable statutory duties and the organisation’s signed terms remain in force.
1. What to share
Share only the necessary information required for the specific staffing assignment: relevant duties, health and safety risks, care/support instructions and emergency escalation. Do not upload complete service-user records to general registration forms.
2. Roles and lawful basis
The client and Bina may each be independent controllers for different purposes; where one party processes information solely on the other's instructions, a processor agreement may be necessary. Responsibilities must be assessed by actual processing activities rather than assumed.
3. Sensitive information
Health, disability and safeguarding details may be special-category data and require a lawful basis and additional condition. Clients should assess necessity, accuracy, access and secure transfer, and Bina should give access only to appropriately authorised staff.
4. Location and department permissions
Separate company and site access. Company administrators should invite individuals using their own verified accounts; disable access when staff leave and periodically review finance and service roles. Do not share passwords.
5. Breaches and security incidents
A lost device, misdirected email or unauthorised record access must be reported promptly to the appropriate privacy lead; preserve facts, investigate containment and assess whether ICO and affected-person notification is required.
6. Retention and rights
Document the retention schedule for agreements, invoices, booking records, employment evidence and safeguarding materials. Respect applicable data-subject rights and avoid retaining personal data indefinitely simply because storage is available.
7. Further information
ICO right to be informed: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/the-right-to-be-informed/ . This policy must be reconciled with Bina's actual suppliers, transfer mechanisms and storage practices before final data-protection sign-off.
Verified official reference material
These links provide external regulatory guidance. Review dates and legal requirements are subject to change.
Chat records and the purposes of access
Bina records verified account identity, company and department details, conversation membership, messages and attachments, booking actions, delivery/read events, security events and investigation access records. These support work communication, staffing administration, service security, fair complaint handling and necessary safeguarding investigations. Client–staff, client–management and management–staff work conversations retain existing Bina management and department oversight. Access must be used for an authorised work purpose; a role or technical capability is not permission to browse out of curiosity. Staff-only conversations require the separate director-authorised control described above.
Lawful basis and proportionate investigation
Bina records the applicable lawful basis for each purpose. Routine staffing administration and proportionate security or complaint handling may rely on legitimate interests after a documented necessity and balancing assessment; legal obligation is used only where a specific duty applies. A client supply contract is not automatically a contract basis for processing a worker’s information. Before investigation access is enabled, the director must record the concern, why access is necessary, the selected conversation, investigators and duration, and consider a less intrusive route. Complete a DPIA where required and identify any Article 9 condition, Article 10 authority and associated UK-law requirements before processing the relevant sensitive information. Staff acknowledgement is not consent to surveillance and does not replace these assessments.
Limits on access and retained evidence
Investigation access exposes the selected conversation history and available attachments during the authorised period, including new messages while access remains active. The current control does not restrict access to selected dates within a conversation. The director must consider this scope before granting it. Switching access off ends further application access; it cannot withdraw a lawful copy or information already seen. Necessary retained evidence must be placed in the restricted case record, limited to the purpose and reviewed under the applicable retention schedule. No personal app, private device content or unrelated conversation is included. Do not use this control for covert monitoring.
Acknowledgement and optional choices
Staff acknowledge receipt and understanding of the current handbook and chat policy. Clients acknowledge the operational and privacy information, and an authorised company administrator separately accepts revised contractual terms where required. Nobody may accept or sign for another user. Earlier signed versions and receipts remain historical evidence. Optional marketing, device notification permission and any genuinely optional consent remain separate, may be declined without preventing ordinary account access, and can be changed through the relevant control. Essential service and policy notices are operational communications rather than marketing.
Retention and privacy rights
Chat participants cannot delete sent messages, attachments or conversations through the app. Own-message text editing ends two minutes after original sending; edits retain their audit history. This user-interface restriction does not remove data protection rights or authorise indefinite retention. Routine closed support conversations follow the published review schedule; operational chat and necessary investigation evidence follow their applicable justified category, with a specific legal hold where required. Contact admin@binapathways.co.uk for access, correction, objection, restriction, deletion or other applicable rights. Bina will assess the legal conditions and any necessary protection of another person’s information and explain any limitation. You may complain to the ICO.
Client work chat boundaries
Clients and eligible staff may communicate for staffing and assignment purposes. Bina management and departments retain oversight of client–staff and client–management work conversations for authorised operational, service, security and safeguarding purposes. Clients cannot see another company’s conversations or staff-only conversations. Staff-only investigation controls apply solely to staff-to-staff conversations and do not switch off oversight of client work conversations. Bina must use access proportionately and follow the privacy notice, confidentiality obligations and applicable law.
Staff identity, attendance and communications — 9 November 2026
Verify the live digital staff ID
Ask the worker to open My staff ID in their own signed-in Bina staff app. Compare the photograph, name, role and BPW number with the booking and use the QR code to open the official Bina verification page. Check the current status and expiry; verify the assignment separately. Screenshots, saved images, a printed card or a caller's name alone are not proof of current clearance. Contact Bina before duties if identity, release, role, card status or booking does not match. Do not ask the worker to email passports or unrestricted recruitment files to solve an ID query. A printed Bina card or local visitor badge can be arranged where your site requires it.
Arrival and attendance verification
Your site must welcome the worker, check the named assignment and identity, provide local induction and confirm the actual start and finish. Bina's staff app uses the signed-in worker's fresh device location at clock-in and clock-out as supporting attendance evidence. Clock-in is checked against the service's configured arrival radius; the present clock-out boundary is less than 10 miles from the service address. That boundary does not authorise an early departure or attendance away from the agreed service. An app sign-in or a location result alone does not prove identity, all hours worked or satisfactory handover.
Accurate hours and fallback checks
Review the actual start, finish and unpaid break, and confirm the hours or explain a discrepancy through the authorised timesheet process. Do not approve hours merely because they match the scheduled booking, or alter original evidence to conceal an error. Report an incorrect site address, location failure or disputed attendance to Bina promptly. Verify actual attendance with the named site lead; Bina records any authorised override or correction and retains the audit trail. Do not use a worker's account, clock on their behalf or direct them to fabricate location. A technical failure is investigated fairly; confirmed undisputed hours are not simply treated as unpaid.
Bina Chat calls and voice notes
Authorised clients, staff and Bina management may use Bina Chat for appropriate work communication. Confirm the conversation and recipient before sending a voice note or starting or answering a call. Sent voice notes are stored audio attachments; do not include unnecessary sensitive information or play them where others can overhear. Current live Bina Chat calls are not audio-recorded or transcribed by the service, although call-event messages and connection metadata may be retained. Do not assume that management can listen to a previous live call. A separate recording needs the appropriate approved process, lawful basis and clear notice.
Privacy and existing agreements
Use only necessary identity and attendance information for the assignment and keep it within authorised access. Do not demand continuous location sharing or access to a worker's private device, personal messages or unrelated records. Existing authorised Bina oversight of client work conversations, and the separate director-authorised process for staff-only investigations, remain governed by the privacy notice. Required notices and acknowledgement are separate from optional device permissions and any recording arrangement. This operational update does not silently change signed rates, liability, cancellation, payment or employment terms. Any contractual variation requiring agreement follows the existing authorised process.
Additional information used for staff identity and attendance
For the staff digital ID, Bina uses the approved staff photograph, name, role, BPW number, ID issue and expiry dates, verification token and status. A limited verification page enables the host to check the worker presented for an assignment; it does not disclose the underlying recruitment, health, payroll or reference file. The signed-in staff account controls access to the worker's own digital card. Identity and current assignment checks must be completed separately from simply displaying the card.
Location at clocking actions
When the worker deliberately clocks in or out, the app requests fresh device coordinates and accuracy information and uses them with the time, account and booking to check the recorded service address and permitted boundary. Bina and authorised reviewers use relevant attendance evidence for accurate hours, safety, timesheet queries and necessary investigations. This is not conclusive proof of identity or all hours worked. Ordinary sign-in and reading documents do not require location, and this update does not authorise continuous tracking. Device permission is a technical permission; it is not blanket UK GDPR consent. If location is unavailable or inaccurate, use the named verification and correction route described in the attendance policy.
Voice notes and live call information
Bina Chat stores sent voice notes as audio attachments available to the conversation's authorised participants and to authorised reviewers under the established oversight or investigation controls. Current live voice calls are not recorded or transcribed as audio by Bina Chat. Call-event and connection information can include account and conversation identifiers, participants, ringing/connection/end times, outcome and duration where recorded, and signalling information needed to establish the connection. Live media may be relayed through the enabled calling provider, currently Cloudflare, where required. Use of suppliers and any international transfer must follow Bina's assessed safeguards; do not assume that a product label alone establishes a particular encryption or transfer guarantee.
Purpose limits and rights
Bina identifies and documents the lawful basis for each purpose, the necessity and balancing assessment where legitimate interests is used, any additional condition required for sensitive information, and the applicable retention category. Access is restricted to relevant employment, assignment, security, complaint or safeguarding purposes. A discrepancy must be reviewed with the worker and host; there is no automatic adverse decision based only on location failure. Necessary records and legal holds are retained under the documented schedule and reviewed when no longer needed; inability to delete a sent item in the app does not remove data-protection rights. Staff and clients are informed of material changes and can request clarification, correction, access or other applicable rights through admin@binapathways.co.uk. Acknowledgement of this notice is not agreement to unspecified future monitoring or to the recording of calls.
Updated 9 November 2026 · BP-DIGITAL-OPERATIONS-2026-11-09-v1. Read the current staff identity, attendance and calls guide.
