South East London Family Mediation Bureau is a ‘not for profit’ charity limited by guarantee and is committed to protecting the privacy of all the personal information or data provided by those that are either members or otherwise use our services.

Personal information and data is described as “any information relating to an individual, whether it relates to his or her private, professional or public life. It can be anything from a name, a home address, a photo, an email address, bank details, or a computer’s IP address”. This policy explains how we collect, use and store the personal information provided to us.

The General Data Protection Regulations require that we process personal data in accordance with the six Data Protection principles:

• Lawfulness, fairness and transparency
• Purpose limitations
• Data minimisation
• Accuracy
• Storage limitations
• Integrity and confidentiality

South East London Family Mediation Bureau will never sell your data to other third party organisations for their marketing purposes.

Our Privacy Policy explains:​

• What information we collect and how we collect it
• Why and how we use your information
• How long we keep your information
• How we may share your information
• Your rights on the information we hold about you
• Security-How we keep your information safe
• Changes to this Privacy Policy
• How to Contact Us

Information we collect

In order to provide our services and for the other purposes set out in Use of Information below, we collect and process Personal Data from individuals. We may collect some or all of the following
information:​

• Personal information (for example, your name, email address, mailing address, phone numbers, date of birth and address)
• Sensitive Personal Data (for example ethnicity)
• Meeting information collated into session documentation.
• Safeguarding incidents

From time to time and as permitted by applicable law(s), we may collect Personal Data about you and update any existing Personal Data that we currently hold from other third-party sources.

We collect your information from:

• Self-referral forms on our websites or on paper
• Referrals from organisations e.g. Family Solicitors
• We may also collect information from telephone conversations, emails and written and verbal communications and from records of any session

How we use 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 ask you to provide feedback, 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 search warrant or court order) or to carry out professional ethics/conduct investigations
• To enable us to take payment for our services
• How to make a complaint

Consent and lawful processing of data

Our legitimate interests, which include processing such Personal Data for the purposes of:​

• providing and enhancing the provision of our services
• administration and programme delivery

How long we keep your information

We will retain information only as long as is reasonably necessary and annually, we will review our Data Retention Periods

Sharing and disclosure to Third Parties

We may disclose your Personal Data to third parties from time-to-time, but only under the following circumstances:

• You request or authorise the disclosure of your personal details to a third party, most usually for example to obtain confirmation of your entitlement to State Benefits, to receive entitlement to Legal Aid Funding, or to provide information to your solicitor. We will always ask you to confirm your request in writing and provide confirmation of your identity
• Payment information will be shared with a card processing organisation, in our case, Worldpay. Card details will not be retained in full or part by South East London Family Mediation Bureau, they will be used to process one transaction at a time and a receipt will be issued

We will only disclose your Personal Information without your permission in the following circumstances:

• If we are required by law to do so (for example, if required to do so by a court order, the government or other law enforcement agencies or for the purposes of investigation and/or prevention of fraud or other crime or where it is necessary for the purpose of, or in connection with, legal proceedings or in order to exercise or defend legal rights); The information is shared with service providers who perform functions on our behalf
• Hosting providers for the secure storage and transmission of your data
• Legal and compliance consultants, such as external counsel, external auditors
• Technology providers who assist in the development and management of our web properties

We hold Information Sharing Agreements with these 3rd parties to ensure they too comply with GDPR.

Parents and children

If the person about whom we are holding information is below 13, then we will need to seek consent from the parent or legal guardian to hold that information.

If it is directly provided by a parent or legal guardian, that will be taken as consent.

If a person is over 13 or reaches 13, we will seek consent directly from them.

Your data protection rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at enquiries@selfmb.org.uk or phone 020 8315 7460 if you wish to make a request.

Information security

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, annually to guard against unauthorised access to systems
• We restrict access to personal information to Staff and Mediators subject to strict contractual confidentiality obligations and they 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

Use of our website

In completing a form on our website, you are giving us consent to hold that personal information to provide mediation and related services.

Transmission of information via the internet will never be guaranteed 100% secure and there is a remote possibility that your personal information may still be accessed or intercepted unlawfully by third parties. Any transmission of personal information is therefore at your own risk. We will not accept any responsibility for information which is accessed or intercepted unlawfully, without permission or in a manner which is out of our control.

Linking to Third Party websites

We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from the Site and recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.

In addition, if you linked to the Site from a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

Compliance and cooperation 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.

Changes

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 complain

If you have any concerns about our use of your personal information, you can make a complaint to our Service Manager and Data Protection Officer, Ruth Bryan at:

South East London Family Mediation Bureau
The Stables
1 North St
Bromley BR1 1SB

ruth.bryan@selfmb.org.uk

020 8315 7460

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk