Abingdon Family Mediation (which is the trading name of Polly Gavins Limited) is committed to ensuring your privacy is protected.
Personal data we collect and hold:
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.
When a mediation referral is received, we store sufficient information to communicate with prospective mediation participants, and to check that there is no conflict of interest. This includes the names and contact details, together with details of solicitors acting for potential mediation participants. We also ask for dates of marriage and separation, and names and dates of birth of any children. This additional information is not required at this stage and potential clients do not have to provide it. However, if they choose to do so, it helps us to prepare for a Mediation Information and Assessment Meeting (MIAM) and can save time later.
During a MIAM or mediation, we may gather and store additional information to help the process. This may include, where relevant, health matters, learning difficulties within the family, domestic violence incidents, financial data, other professionals who are supporting the family, safeguarding issues, attendance information and notes taken during meetings.
We collect your information from:
- Self-Referral Forms on our websites or Google Forms
- Referrals from organisations e.g. Family Solicitors
We may also collect information from telephone conversations, emails and written and verbal communications and from face-to-face meetings.
The legal basis for our storing your personal data
When a mediation referral is received, it is in the public interest to give all potential mediation participants access to the mediation information and assessment process introduced by the Children and Families Act 2014, s10. We store your information to enable us to communicate with potential mediation participants and to check that there is no conflict of interest.
Any additional information provided at this stage is voluntary and given with your consent.
If you decide to enter into family mediation you will sign an Agreement to Mediate and the legal basis for our storing your data will be contractual.
How long your information is kept by us
Our standard period of retention is seven years, as required by our professional indemnity insurers.
We do not keep all information for this period of time. Full details of our procedure for disposing of information is as follows (although these timescales should be seen as guides only);
- Your paper file is closed one month after final meeting or final contact.
- Information archived at this point is referral form, confidentiality form, agreement to mediate, summary letters/statements, most recent/final Memorandum of Understanding and Open Financial Statement.
- All kept electronically. No paper copies kept.
- All other notes and flip charts burnt.
- Statements/financial documents – originals returned to clients, copies burnt or deleted.
- Telephone number remains in mediator’s phone and email contact in contacts book and basic case details in casebook.
- Email correspondence archived in case clients return to mediation (which sometimes happens).
- Invoice details (name and address and invoices) remains in accounts records.
This information is held electronically for seven years as required by our insurers. It is then deleted.
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 disclosed under the terms of our Agreement to Mediate or Consent and Confidentiality Form.
- 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. We only use third party service providers where we are satisfied that they provide adequate security for your personal data.
How we protect your data
We work to protect your personal information that we hold, its confidentially, integrity and availability.
Paper files are stored in the mediator’s home office in a locked drawer. If the files are being worked on out of the mediator’s home office, they remain in the physical possession of the mediator or they are locked away securely.
All client electronic files are held by Dropbox, a cloud based storage app. Dropbox are ISO 27001 compliant. This is one of the highest information security standards. The mediator has a two-factor authentication to log into the client Dropbox files.
The mediator uses Google Forms to gather client information. Google Forms are also ISO 27001 compliant and the mediator uses a two-factor authentication to log into their Google account.
Abingdon Family Mediation has a WordPress website hosted by Gum Cloud. No client information is held on the website. Gum Cloud is Cyber Essentials certified. This is a standard that certifies compliance with fundamental technical security controls. Gum Cloud also hosts our emails. Emails are accessed online only and not downloaded to our computer.
Polly Gavins Limited uses FreeAgent software for its accounting software. FreeAgent are Cyber Essentials Certified.
Polly Gavins Limited uses Worldpayzinc for card payments. Abingdon Family Mediation holds no client card details.
Subject Access/User Rights
If you would like a copy of the information that we hold, we can provide this on request for free.
If you discover an error in any personal data that we hold, please let us know as soon as possible and we will rectify it.
In some circumstances, you may have a right to ask us to erase data or to restrict the use to which data is put.
If we receive formal written complaints regarding the transfer of personal data, we will contact the person who made the complaint to follow up. We will work with the Information Commissioners Office (ICO) to resolve any complaints that we cannot resolve with our users directly.
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How to contact us:
Company Name Polly Gavins Limited T/A Abingdon Family Mediation
Registered in England and Wales Number 06540847
Registered Address Merchant House, 5 East St Helen Street, Abingdon, Oxfordshire OX14 5EG