Privacy

 
 

Reichwald Mediation: privacy policy

 

Please read this document carefully. It describes how we collect, store and process the information about you, and the reasons for the processing.

In this context “processing data” does not mean that someone is intentionally moving data from one place to another. That may be the case, but the term actually includes any movement of data through any IT system. Data can become personal data when it is associated with your name or address or other data that can identify you. Our reputation is reliant on the trust of people we work with, and consequently the effective and professional use of the information you provide to us is paramount. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

This document also tells you who we share this information with, the security mechanisms we have put in place to protect your data and how to contact us in the event you need further information.

This document has been prepared carefully to be fully compliant with the Data Protection Act 2018 (Act), which also incorporates the EU General Data Protection Regulation (GDPR). Simply because we have to cover every eventuality does not mean that the data we collect about you will be different from what you would normally expect. However, please understand that in certain circumstances mediation work does involve "processing" information which is sometimes extremely personal.

I am grateful to Andrew Taylor for allowing me to use his privacy statement as a template. Note I do not have authority to allow this to be copied further.

1. Who Am I?

I am Peter Reichwald, trading as "Reichwald Mediation", the trade name for Reichwald Mediation Associates Ltd. In this document I refer to "we / our / us" meaning myself and my staff.

In the course of my business, I inevitably receive personal information about you. That makes me the "controller" of this information for the purposes of the GDPR and the Act.

This document sets out how I and my staff might use and retain your data.

If you need to contact me about your personal data please send a message to peter@reichwaldmediation.com

2. What we do

We provide services in three core areas: Mediation, CV-writing and Recruitment Solutions.

In respect of Mediation, our client is the employer and the objective is to repair relationships between the ‘participants’; usually two employees or the employer and an employee.

In CV-writing we provide a service to help a client develop their career.

In Recruitment Solutions we provide recruitment options and/or consultancy to help them solve recruitment, talent and other related challenges.

3. What information might we collect?

We will collect the minimum data needed to deliver our services. Typically, this is name, address, job title and contact details. In addition, if you are a CV-writing client or candidate being considered for a role, it is also likely to include your CV / resume as well as other details about your skills and experience.

In respect of our Recruitment Solutions services

we may also collect other personally identifiable data. For example, we may be engaged in equal opportunity monitoring or need information to complete a contract for you or our client. This data can include age, identity card number, passport number, driver license number, address, email address, user ID and passwords, gender, date of birth, marital status, occupation, income range, bank account details, financial information, contact information such as telephone, mobile, nationality, personal website or social media links or other data which may be required by local regulations.

For Sources and Referees, we collect basic contact details (for example name, title, address, email and telephone number) so that we can contact you for thoughts on potential candidates as a reference for one of our candidates.

4. Information collected from other sources

The same categories of information may also be obtained from third parties, such as other legal professionals or experts, HR professionals, clients of mediation or recruitment solution services and others introducing business.

You are responsible for the accuracy of the personal data inputted. If you use functions on the website which access data from external sources, such as LinkedIn, please be aware that we may access your personal data from these sources.

5. What we use your personal information for

We collect, store and use your name and contact details so that we can:

·        provide our services: Mediation, CV-writing and Recruitment Solutions;

·        keep accounting records and carry out office administration;

·        respond to potential complaints or make complaints;

·        perform marketing and business development activities as well as market research and statistical analysis regarding our products and/or services;

·        provide work-shadowing opportunities for other mediators but without your express permission;

·        comply with any legal or regulatory requirements and make the necessary disclosure under the requirements of any applicable law, regulation, direction, court order, guideline, circular or code which are applicable to us for the prevention of crime.

In respect of CV-writing and Recruitment Solutions additionally so we can:

·        send you the details of opportunities we become aware of;

·        promote you for a role, subject to your express permission;

·        maintain our business relationship with you;

·        place a candidate into a role as defined by our clients;

·        maintain our records of our candidates, clients and contacts;

The exchange of personal data between our candidates and client contacts is an essential part of what we do as a recruitment business and, as such, it is in our legitimate interests to process your data for such purpose.

6. Legal basis for processing your personal information

We rely on the following as the lawful bases on which we collect and use your personal information:  

·        If you have consented to the processing of your personal information, then we will do so solely for the purposes set out above to the extent to which you have consented to us doing so.

·        If you are a mediation participant, processing is necessary for the performance of a contract for mediation services or in order to take steps at your request prior to entering into a contract.

·        In relation to information in the special category, we rely on your consent for any processing for the purposes set out above. However, if you do not consent to processing for purpose of responding to potential complaints, we will be unable to serve you. This is because we need to be able to retain all the material about your case until there is no prospect of a complaint.

·        In relation to information not in the special category, we rely on our legitimate interest and / or the legitimate interests of a third party in carrying out the processing for the purposes set out above.

·        If you are a client or a candidate of our CV-writing or Recruitment Solutions business, we consider that it is necessary for our legitimate interests in providing these services to process your personal data. At different stages in delivering our Recruitment Solutions services we also have other lawful grounds for processing your data, such as compliance with our legal obligations and where it is necessary for the performance of contracts related to a recruitment process. 

·        In certain circumstances processing may be necessary in order that we can comply with a legal obligation to which we are subject.

7. Who will we share your personal information with?

In respect of our Mediation Services, some of the information you provide will be protected by legal professional privilege unless and until the information becomes public in the course of any proceedings or otherwise.

It may be necessary to share your information with the following:

·        data processors, such as IT support staff, email providers, data storage providers;

·        your conflict party – only subject to your specific instructions

·        legal professionals who act for you alone;

·        experts and other witnesses;

·        courts and tribunals - only if called upon

·        our staff;

·        trainee mediators - rare and subject to your precise consent in advance;

·        regulatory authorities.

·        if required, we may disclose your information to the police or intelligence services, where required or permitted by law

In respect of CV-writing or Recruitment Solutions we may share your personal information with clients or other contacts where we believe that you may be appropriate for a particular role or vacancy. 

8. For how long will we store your personal data?

We have no legal obligation to you to store your information for a particular period of time nor to delete such of your information as we are permitted to store within a particular timescale. However, we will normally store all your information until at least one year after the expiry of any relevant limitation period (which will usually be six years, but may be 12 years or longer where the case includes information relating to a minor), from the date of the last item of work carried out, the date of the last payment received or the date on which all outstanding payments are written off, whichever is the latest. At this point any further retention will be reviewed and the data will be marked for deletion or marked for retention for a further period.

Names and contact details held for marketing purposes will be stored indefinitely or until we become aware or are informed that you have ceased to be a potential client.

9. Consent

As explained above, we are relying on your explicit consent to process your information in the special category. You provided this consent when you supplied that information.

You have the right to withdraw this consent at any time, but this will not affect the lawfulness of any processing activity we have carried out prior to you withdrawing your consent. However, where we also rely on other bases for processing your information you may not be able to prevent processing of your data.

10. Data Protection 

We will adopt physical, technical, and organisational measures to ensure the security of Personal Data. This includes the prevention of loss or damage, unauthorised alteration, access or processing, and other risks to which it may be exposed by virtue of human action or the physical or natural environment. 
 
In summary, the Personal Data related security measures we follow are to: 

·        Prevent unauthorised persons from gaining access to data processing systems in which Personal Data are processed; 

·        Prevent persons entitled to use a data processing system from accessing Personal Data beyond their needs and authorisations; 

·        Ensure that Personal Data in the course of electronic transmission during transport cannot be read, copied, modified or removed without authorisation; 

·        Ensure that Personal Data is protected against undesired destruction or loss; 

·        Ensure that Personal Data is not kept longer than necessary. 

11. Your Rights

Under the GDPR, you have a number of rights that you can exercise in certain circumstances. These are free of charge. In summary, you may have the right to:

·        Receive a copy of the personal information you have provided to us or have this information sent to a third party. This will be provided to you or the third party in a structured, commonly used and machine-readable format, e.g. a Word file;

·        Ask for correction of mistakes in your data;

·        Ask for your personal information to be erased, in certain circumstances;

·        Object at any time to processing of your personal information for direct marketing;

·        Object in certain other situations to the continued processing of your personal information;

·        Restrict processing of your personal information in certain circumstances.

If you want more information about your rights under the GDPR please see the Guidance from the Information Commissioners Office on Individual's rights under the GDPR.

12. How to make a complaint

If you are not happy with our privacy policy or if you have any complaint then you should tell us by email. Our address is peter@reichwaldmediation.com

The GDPR also gives you the right to lodge a complaint with the Information Commissioners' Office. The Information Commissioner's Office can be contacted at http://ico.org.uk/concerns

13. Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website. They allow information gathered on one web page to be stored until it is needed for use on another web page, allowing a website to provide you with a personalised experience, and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser, others last indefinitely.

Our website uses third party cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

An example is that we use Google Analytics to measure the performance of our website.

We may use the information we obtain from your use of our cookies for the following purposes:

·        to improve the website's usability;

·        to analyse your use of our website;

·        to provide certain interactive functionality, such as remembering your answers to previous questions on a multi-page questionnaire.

Most of browsers allow you to refuse to accept cookies, and to delete ones that have been placed on your computer.

If you do not want us to use cookies, you may disable their use in your browser. However, if you do so then please note that you may not be able to use all the features on our website.

14. Data may be processed outside the European Union

Our website is hosted in the UK. We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business. Accordingly, data obtained within the UK or any other country could be processed outside the European Union.

15. Changes to this privacy notice

This privacy notice was published on 01 December 2019 and last updated on that date.

We continually review our privacy practices and may change this policy from time to time. When we do it will be placed on the website.