Privacy Policy Statement

The A Project is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified then you can be assured that it will only be used in accordance with this privacy policy.





































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

The Data Controller is The A Project Ltd.  We are registered with the ICO under the Data Protection Register, our registration number is: ZA112045

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 our service users.  The A Project provides a range of services, so we have given examples of the types of information we require based on the service we are providing.

Mediation

We may collect any or all of the following information, but the data we collect will be related to the service we are providing to you:

Personal information (for example, your name, email address, mailing address, phone numbers, date of birth and address)
Sensitive Personal Data (for example your financial situation, your accommodation arrangements, details of



child contact arrangements, court orders that affect you, the involvement of other agencies for example police or social services)
Attendance information (such as dates you used our service)
Safeguarding (such as details of concerns about the safety of a child or vulnerable adult)

Training

We may collect any or all of the following information, but the data we collect will be related to the service we are providing to you:

Personal information (for example, your name, email address, mailing address, phone numbers, date of birth and address, your qualifications and work experience)
Attendance information (such as training courses, events and dates attended)
Assessments and submitted information (including videos)

Supervision

Personal information (for example, your name, email address, mailing address, phone numbers, date of birth and address, your qualifications and work experience)
Attendance information (such as Supervision dates attended)
Assessments and submitted information related to your performance (e.g. accreditation, complaints, professional development and training etc.)
Details of membership bodies to which you belong
Details of your clients for the purpose of supervising your practice (such as signing MIAMs forms and dealing with complaints)

Employees and Associates

These are people who work for us as employees, contractors, volunteers or trainees.

Personal information (for example, your name, email address, mailing address, phone numbers, date of birth and address, your qualifications and work experience)
Attendance information (such as dates you worked for our service)
Assessments and submitted information related to your performance (e.g. accreditation, complaints, professional development, training etc.)
Details of membership bodies to which you belong
Details of your practice for supervision purposes
Information provided by your referees
Where appropriate, the outcome of a DBS check

How we collect information

We collect your information from

Telephone conversations and emails
Written and verbal material (collected during meetings, documents submitted to us, etc)
Self-Referral Forms on our websites
Referrals from organisations e.g. Referring Solicitors
Other communications and from records of any sessions

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

Parents and Children

If the person about whom we are holding information is below 16 then we will need to seek consent from the parent or legal guardian if consent is required.  Once the person reaches 16, we will seek consent from them.

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 inquiries,
To improve our services, for example creating statistics
To request your participation in surveys, academic research or other initiatives, which help us to gather information, used to develop and enhance our services and inform professional development.
To comply with applicable law(s) or to ensure the quality and professional practice of our Associates.
To enable us to provide, to maintain our own accounts and records and to support and manage our employees and our Associates.

What is the legal basis for processing your personal data?

Consent – Where we have asked you for written permission to hold and process your data
Contractual Necessity – Where we have a contract to provide services to you (for example; an agreement to mediate, an acceptance onto a course, a PPC agreement)
Compliance with Legal Obligations – Where for example, processing is necessary for carrying out obligations under the law
Vital Interests – Where processing is necessary to protect your vital interests or those of another person (for example; where we may have an obligation to report concerns for the safety of a child or vulnerable person)
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
Where processing relates to personal data manifestly made public by the data subject
Reporting safeguarding concerns

Data relating to criminal offences and civil law enforcement

 How long will we keep your information?

We will keep your information no longer than we are required to for administration, by our professional body or our insurers (whichever is the longer). We are currently required to hold data on you and details of the services we supplied to you for seven years.

For mediation clients, all supporting documentation provided by you as part of your negotiations (e.g. bank statements, pension values etc.) will be destroyed or returned to you at the end of the mediation process.

Sharing and Disclosure to Third Parties

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

You request or authorise the disclosure of your personal details to a third party.
The 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 search warrant or court order).
The information is provided to service providers who perform functions on our behalf, for example:

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

Subject Access/User Rights

As a user, you have the following rights with respect to your personal data:

The right to be informed of the use of your Personal Data
The right to access and/or to require the correction or erasure of your Personal Data
The right to block and/or object to the processing of your Personal Data
The right to not be subject to any decision based solely on automated processing of your Personal Data

If you have a complaint in relation to the processing of your data carried out under this Privacy Policy, you have the right to lodge a complaint with the Information Commissioner Office.

You may seek to exercise any of these rights by updating your information online (where possible) or by sending a written request to the Administrator, at the address below.

Information security

We always work 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 unauthorized access to systems.
We restrict access to personal information to Staff, Associates and Volunteers subject to strict contractual confidentiality obligations and who may be disciplined or have their contract 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.

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 Contact Us

If you wish to contact us in relation to any aspect of this document please write to:

The Data Protection Officer
The A Project
Garden Studios, 71-75 Shelton Street
London WC2H 9JQ