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Privacy Policy

Updated May 2018

We understand that the privacy of your information is important to you, and we are committed to being transparent about how we use, share, and protect your information. To help further our commitment, we have developed this Privacy Policy to help you better understand the types of information we collect, why we collect it, how we will use it, and the various options you have to manage the privacy of your personal information.

At SFMS we take our role seriously when obtaining, storing and the security of your personal information. We abide by the requirements of the Data Protection Act 1998 and the General Data Protection Regulation (GDPR) 2018.  We are registered with the Information Commissioner’s office (ICO) Reference Z2166971 and subject to their oversight and regulation.

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Policy or for purposes we provide at the time we collect your personal information. However, we may also use your personal information for other purposes permitted by applicable law. We will provide you with further information on any such additional processing when this happens, in accordance with applicable data protection laws. We do not use your information for general marketing purposes.

This Privacy Policy includes some important information; please take the time to read the entire document and associated agreements you may receive when using our services.

 

What information do you collect?

We receive information from you when you use our Services, such as:

 

  • Personal information (for example, your name, email address, mailing address, phone numbers, and date of birth)
  • Sensitive Personal Data such as physical health condition, court proceedings, details of your children and other information as may be required for assessing eligibility for Legal Aid
  • Attendance information (such as appointment dates and fees paid)
  • Reporting on any safeguarding incidents as may be necessary in the carrying out of our services.

We may also obtain information about you from other third parties where permitted by applicable law.

 

Where do you collect our information from?

We collect the information you provide to us when you acces our services by:

Self-Referral Forms on our website (this is sent only with your consent and with a view to providing you with our service as indicated by your agreement when submitting the referral form).

  • Self-Referral Forms sent by post or emailed, again with your consent.
  • Referrals from other organisations such as family solicitors that you may have requested to act on your behalf.
  • We may also collect information from telephone conversations, emails and written and verbal communications when you contact us.

How do you use our Information?

Your Personal Data may be used in the following ways:

  • To provide our services to you,
  • To respond to your requests and enquiries,
  • To improve our services, for example, to request your participation in surveys, or other initiatives which help us to gather information used to develop and enhance our services,
  • To comply with applicable law(s) for example, to comply with a court order
  • To enable us to provide, to maintain our own accounts and records and to support and manage our employees.

What is the law on processing our data?

The GDPR is the primary piece of legislation defining your rights over our processing of your personal information. We operation on the basis of ‘legitimate interest’ when communicating with you and which include processing your personal data for the purposes of:

Providing a service to you and enhancing the provision of our services.

  • administration and service delivery
  • Statutory and legal reasons such as required by the Family Mediation Council or Legal Aid

How long will you keep our information?
Unless you specifically ask us to delete your personal information as explained under “What are your rights”, we retain your information as long as is necessary to provide you with our services, contractual or legal responsibilities as outlined below:

Situation Retention period
Clients self-referral or third party referrals to the service but unable to contact or who declined support Records deleted within 6 months after the last referral.
Clients referred who accept support and attend a Mediation Information Assessment Meeting (MIAM) but who do not proceed to mediation Deleted 3 years after MIAM appointment date.
Private clients following assessment who go on to mediation Deleted 6 years after the last contact.
All Legal Aided clients whether having attended just a MIAM or who proceed to mediation Deleted 6 years after the contract end date

 

What do you share or disclosure to Third Parties?

We do not share your personal data with any third parties except where information is disclosed as permitted by applicable law(s) and/or in order to comply with applicable law(s) for example, to comply with a court order.

Other circumstances may include:

    • We have a duty, should we believe there is a risk or issue, to alert relevant authorities as part of our overall responsibility to safeguard children
    • If you have been provided with free government funded family mediation the Legal Aid Agency will have access to your data for audit purposes for the duration of our contract with them
    • You request or authorise us to disclose your personal details to a third party such as a solicitor or someone acting on your behalf.

The information is provided to service providers who perform functions on our behalf such as:

  • Hosting providers for the secure storage and transmission of your data
  • Legal and compliance consultants, such as external examiners or auditors
  • Technology providers who assist in the development and management of our web properties

 

What about the information relating to our children?

If we mediate on child matters or carry out child inclusive mediation then we may hold sensitive personal information such as dates of both. If the person we are holding information about is below 14 then we will need to seek consent from their parent or legal guardian. Once the person reaches 14, we will seek consent directly from them.

What are our rights?

Under the terms of GDPR and as a user, you have the following rights:

  • The right to be informed. This Privacy Policy tells you about the ways in which we use your information and personal data.
  • You have the right to request any personal data that we hold about you.       Except for exceptional circumstances you can obtain this information at no cost and we will send you a copy of the information within 30 days of your written request.
  • You have the right to have any inaccuracies in your personal data corrected or can request for your data to be deleted.

You may seek to exercise any of these rights by sending a written request to Helen Bennett, CEO.

If you have any questions or a complaint in relation to the processing of your data carried out under this Privacy Policy please address this to our Data Protection Officer at admin@surreymediation.co.uk or alternatively write to us in the contact details shown below.  You also have the right to lodge a complaint directly with the Information Commissioner Office.

 

How do you protect and secure our Information?

We understand that the security of your information is important to you. We provide appropriate technical and organisational security controls to protect your information. We are working to protect your personal information that we hold, its confidentially, integrity and availability.

  • We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
  • We restrict access to personal information to Staff and Volunteers subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
  • We have a Security Information Policy in place which defines the measures we take to protect your personal information. We use a combination of technology and procedures to ensure that our paper and computer systems are protected, monitored and are recoverable.
  • We only use third party service providers where we are satisfied that they provide adequate security for your personal data.

But, even with the above controls and our best efforts, as transmission of information is sometimes sent via the internet or post we cannot ensure or warrant the security of your information when it is outside of our control.

 

Changes to our policy and compliance with regulatory authorities

 

We regularly review our compliance with our Privacy Policy. If we receive formal written complaints, we will contact the person who made the complaint to follow up. We will work with the ICO to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

 

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent.

 

How to Contact Us

 

Email:            admin@surreymediation.co,uk

Telephone:     01737 919675

Post:               44c church Street, Reigate, Surrey. RH2 0AJ

 

  • Family disputes that are resolved through mediation are cheaper, quicker and according to academic research, less acrimonious than those that are settled through the courts."

    National Audit Office 2/3/07