General Data Protection Regulation

• 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
• Complaints 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 type of information we require based on the services we are providing.

Mediation/Facilitation/Advocacy

We may collect any or all of the following information, but the data we collect will be related to the service we are providing 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 accomodation arrangements, details of child contact arrangments, court orders that affect you, the involvement of other agencies for example the 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 purpse 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 supervison purposes
• Information provided by your referees
• When 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
• Our 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 sek 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 folowing ways:

• To provide 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 helps us to gather information, used to develop and enhance 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 for your 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, ab 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 warrent or court order).
• The information is provided to service providers who perform functions on our behalf, foe 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 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 Commissioners 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, or at the address below. 

Information Security                                                                                                                                                                                                 

We always work to protect your personal information that we hold, its confidentiality, 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 the 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 nd 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 mde 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

Complaints Policy

If you are dissatisfied with any part of our process, we suggest you discuss your concerns with the Mediator/Facilitator responsible, to give them an opportunity to resolve the issue informally. If it is not possible to resolve the matter informally, please contact the Director at the A Project via info@theaproject.co.uk. Our complaints process is; 

• All complaints will be acknowledged in writing within 5 working days of receipt
• All complaints will be investigated and responded to within 21 working days of receipt. The procedure may specify that on occasions further time may be required, in which case the complainant should be notified of this in writing.
• The investigation will be carried out by the Director, or the Chair of the Trustees if the complaint is about the Director.
• You will receive a written reply from the Director or Chair. If the response from the Director is not satisfactory, the matter can be referred to the Chair of Trustees for appeal. The Chair will have 21 working days to respond to you in writing.
• If the response is not accepted the complainant can appeal to the Governing Body on certain grounds,  contact details of governing bodies;                                                           restorativejustice.org.uk collegeofmediators.co.uk familymediationcouncil.org.uk/fmsb

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

HQ 18 Soho Square

London W1D 3QL