Changelog
- v2.1 — 13 June 2026. Appropriate Policy Document referenced for special-category data processed through Baton. Information Security Policy (BTN-WAC-IS-2026) referenced for security controls. Central Retention Schedule referenced for data held in Baton. Forward commitment on AI tokenisation added to Section 04 — pseudonymisation with re-identification keys never leaving our infrastructure, and AI-vendor-agnostic stance. Operational hosting position added to Section 05 — UK where possible, EU as fallback. Anchor block expanded with “Governed by” row. Changelog discipline initiated. Connect / Baton Ltd entity restructure pending confirmation by Ashley — will be captured in v2.2 once the data processing relationship between We Are Care Ltd and Baton Ltd is formalised.
Section 01
What this covers
We Are Care uses Baton, our care operating platform, to support how we run workforce operations. This statement explains where Baton helps and where our people stay accountable, across onboarding, compliance, worker communication, policy review and operational records.
Section 02
How we use it
Baton supports our team with evidence, reminders, review cycles and workflow consistency. In practice that means organising onboarding documents and tracking expiry of DBS, right-to-work, training and certificates; holding compliance evidence and audit trails in one place; prompting policy review dates and flagging regulatory changes for a person to review; and supporting worker reminders and availability. It helps us work more consistently and respond faster. It does not replace human review.
Section 03
People make the decisions
Baton works at four levels, and the level sets the control.
- Assist. It flags, summarises or organises information, and a person reviews anything material.
- Prepare. It drafts an action or message, and a person approves before it is used or sent.
- Automate. It runs a small number of low-risk, pre-approved tasks such as expiry reminders, each with an opt-out and an audit log.
- Block or escalate. Where a risk is detected, it stops or routes the workflow to a named person.
Baton supports decisions. People make them.
Section 04
What Baton does not do, and will not do
What Baton does not do today. It does not make safeguarding, medication or clinical decisions. It does not submit statutory notifications. It does not make solely automated significant decisions about workers or applicants, and anyone affected has a route to human review and correction. It does not replace a registered manager, a provider’s governance, or a client’s own policies, care plans and escalation routes.
What Baton will not do. We are agnostic on AI services — we are not locked to any single vendor. We do not send personal data to AI services. Where AI features are used today or added in future, the data presented to those services is pseudonymised, with re-identification keys held by We Are Care and never leaving our infrastructure. We will not adopt AI features that depend on transferring identifiable personal data outside this pattern.
Section 05
Worker data, hosting and review
Where Baton supports onboarding or compliance checks, it helps us organise documents, evidence, expiry dates and reminders. Decisions about suitability, placement, safeguarding or escalation remain subject to human review.
Governing framework. Special category personal data and personal data relating to criminal allegations or convictions — including DBS metadata, safeguarding logs and incident records held in Baton — is governed by our Appropriate Policy Document (BTN-WAC-APD-2026). Information security controls on data held in Baton are governed by our Information Security Policy (BTN-WAC-IS-2026), security lead Joel Dawson. Retention of all data held in Baton aligns to the central Retention Schedule (RoPA companion sheet); we do not invent per-system retention periods.
Hosting and data residency. Operational data hosting is UK where possible, EU as fallback. We do not host operational personal data outside the UK or EU.
Section 06
Provider duties remain clear
Baton gives us and our clients better visibility of tasks, evidence and workflows. It does not replace a provider’s own policies, care plans, medication procedures, safeguarding duties, regulatory responsibilities or statutory notifications.
Section 07
Ownership and review
Owner: Joel Dawson. Reviewed at least annually, and sooner if Baton’s role materially changes or if national guidance on AI in adult social care is updated.
Each change to this policy is captured as a version bump with a one-line changelog entry.
Published at wearecare.co.uk/policies/how-we-use-baton.