We are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
By engaging the services of NHMC you consent to NHMC as Data Processors processing the personal and or sensitive data you provide together with that of your children whether such data is supplied in preparation for or in performance of a contract for a Mediation Assessment Meeting (MIAM) pursuant to s10 Children and Families Act 2014 and FPR Part 3A s 32 and s33 and/or a contract for mediation. We will ask you to complete a Consent Form when you first engage our services.
You generally have the right to withdraw your consent to the holding of your personal and or sensitive information at any point during the provision of services to you by NHMC and the following information sets out your rights in relation to this data.
For the purposes of the Data Protection Act 1998 (“Act”), the Data Controller is NHMC Westbourne Grove, London W2 5BZ
Information we may collect from you
We may collect and process the following data about you:
· Information that you provide by filling in forms which we give to you or information that you have provided to us by e mail, texts or on the telephone, or which you provide in meetings with us.
· Information about you that is provided to us by others acting for you or representing you. For example, your solicitor may provide us with some information about you including completing our Referral Form.
· Information provided to us about you by another person to enable us to contact you because they have made a referral to us and have asked us to contact you. Typically, this information will include your name, address, date of birth and telephone number(s).
· We process your Personal Data e.g. your name, address, e mail, telephone number, date of birth and we will also process sensitive classes of information that may include physical health details, racial/ethnic origin details and/or details of your sex life and/or sexual orientation.
· If you contact us, we may keep a record of that correspondence.
· We may also ask you to complete questionnaires that we use for research purposes, although you do not have to respond to them.
Parents and Children
If we are holding information about someone under 14 then we will need to seek consent from their parent or legal guardian if consent is required. Once the person reaches 14 we will seek consent from them.
Where we store your personal data
We store your data in both electronic and hardcopy form. The electronic data is stored in our own IT system, including PCs used by individuals who work for us. All PCs are encrypted and password protected and the passwords are known only to those people who work for us. That data may be stored both on and off our premises. Data stored in hardcopy documents will ordinarily be kept securely at our business premises.
We maintain and review strict security standards and procedures with a view to preventing unauthorised access to your data by anyone. We have an Information Security 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 re-coverable.
All our third parties whenever we hire them to provide a service are required to observe our privacy standards and to comply with this policy
We are working to protect your personal information : its confidentiality, integrity and availability.
Use made of the information
We use information held about you in the following ways:
· To provide you with information and services that you request from us or which we feel may be helpful to you, where you have consented to be contacted for such purposes, or we have been asked to contact you.
· To carry out our obligations arising under any contracts entered into between you and us
· To administer your relationship with us, provide you with services and respond to enquiries
· To ensure the billing of any procured services and obtain payment
· To process and respond to complaints
· To enable us to meet our legal and statutory obligations
We will collect data from you because it is necessary for our legitimate interests in providing a mediation service to you and to others, and to enable us to fulfil our contractual obligations to you. We are satisfied that there is no less intrusive way of achieving this goal. We would not be able to provide mediation services to you and to others effectively without having this data about you.
Disclosure of your information
We will not share your personal information with outside entities unless:
· Authorised by you to do so, or in order to enable us to fulfil our contractual obligations.
· In order for us to comply with any legal obligation on us, or to protect the safety of our clients, or others. For example to provide billing information to HMRC, to safeguard individuals.
· The information is provided to the service providers who perform functions on our behalf:
vHosting providers for the secure storage and transmission of your data
vLegal and compliance consultants such as PPCs, Actuaries, IFAs Accountants
vTechnology providers who assist in the development and management of our web properties.
include the right:
to be informed of the use of your Personal Data.
to access and to require the correction, completion or erasure of your Personal Data
to block and/or object to the processing of your Personal Data in certain circumstances including any processing for the purposes of direct marketing.
Our website may, from time to time, contain links to and from the websites of other organisations (“Third-Party Sites”). If you follow a link to any of these Third-Party Sites, please note that these Third-Party Sites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these Third-Party Sites.
You may seek to exercise any of these rights by e mailing firstname.lastname@example.org
Access to information
The Act gives you the right to access information held by us about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information which we hold about you. We will ask you for proof of identity and upon this being successfully verified you are entitled to obtain the information.
Retention of information
We will retain your personal information during the period that we are working with you and, after that work is finished, we will retain it for a further period of 6 years in our archive system. We retain it for this length of time in case you need to have access to it and also to enable us to carry out statistical analysis from time to time. After 6 years has elapsed, we will commence a process of deleting your information although the information may not be deleted until a further 12 months has elapsed. The deletion process will involve the mechanical confidential disposal of all hardcopies of your information and deleting the information electronically from our IT system. Once that process has been completed, we will not retain any information about you.
Please note that pursuant to any applicable data protection laws in each jurisdiction (including, without limitation, the European Data Protection Directive 1995 (the “Directive”) and any national laws implementing the Directive), we are obliged to inform you that any personal information (for the purposes of the Directive this shall mean “Personal Data” as that term is defined in the Directive) (hereinafter “Personal Data”) may be disclosed, processed and transferred by us for the purposes of providing services to our clients and for servicing our relationship with them or you.
We will not disclose or transfer Personal Data to third parties for the purposes of marketing.