Privacy Policy

This privacy notice tells you how Crunch Mediation (‘Crunch Mediation’, ‘we, ‘our’) uses and protects your personal information when you contact us or use one of our services.

You can contact us by emailing: support@crunchmediation.co.uk

We keep our privacy notice under regular review to make sure it is up to date and accurate.

This policy was last updated on: 1st Jan 2024

Who we are

Crunch Mediation provides mediation services. We specialise in civil, commercial and workplace mediation.

Crunch Mediation 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. Refer to ‘Protecting your information’ section below for more details.

Our role as data controller

Business Loss Prevention trading as Crunch Mediation is defined as a Data Controller for most of our processing. We are registered with the Information Commissioner’s Office (ICO) (Registration No. ZA007351.)

Processing purposes

Crunch Mediation processes personal information for the following purposes:

Providing mediation services to clients

Where clients engage Crunch Mediation’s services, we may collect and process personal data in order to satisfy a contractual obligation. Where individuals make use of our services this personal data will usually be provided to us by the individual directly, or by the person or organisation with whom they are in dispute. The personal information may include, for example, contact details, financial, and employment data. Typically, we receive information from solicitors dealing with your case, and occasionally directly from you. We pass this information on to your mediator so that they can provide you with the service.

Providing training services to clients

Enquiries and client management

When dealing with enquiries from existing and prospective clients, we collect only necessary information for assessment and communication.

Promotion and marketing

We may contact organisations, via business contact details, to provide information about Crunch Mediation services and events. These communications offer a marketing opt-out option to prevent undesired contact. Crunch Mediation will not contact non-commercial clients without their specific permission.

Administration

As part of our normal day-to-day operations in administering mediations, processing client enquiries, marketing and promotional event management.

Website monitoring

Information gathered through cookies and similar technologies are used to measure and analyse information on visits to our websites, to tailor the websites to make them better for visitors and to improve technical performance. We will not use the data to identify you personally or to make any decisions about you.

The personal data we process may include sensitive (or special category) data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, health, sex life or criminal record.

Grounds for processing

We must have a lawful basis for processing personal information. This varies according to the type of processing, this includes:

· as part of a contract to which you are party or prior to you entering into a contract e.g. because you wish to engage us to provide mediation services.

· you have given consent for us to process your information e.g. when making an enquiry about mediation.

· you have consented, or we are within our legitimate interests, to our activities seeking to engage with and provide services to prospective and current clients.

We may rely on legitimate interest when contacting organisations, via business contact details, to provide information about Crunch Mediation services and events. These communications offer a marketing opt-out option to prevent undesired contact. Crunch Mediation will not contact non-commercial clients without their specific permission.

If we process any special categories of information, we must have a further lawful basis for the processing.

Special category information includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, processing of biometric data for the purpose of uniquely identifying individuals, health data, or data concerning your sex life or sexual orientation.

This may include where:

· the processing being necessary for the establishment, exercise or defence of legal claims.

· we have your explicit consent e.g. to cater for your dietary needs whilst at events.

· the processing is necessary to protect your vital interests or someone else’s vital interests.

· you have made the information public.

· the processing is necessary for reasons of substantial public interest e.g. in relation to the prevention or detection of fraud or other unlawful or dishonest activities.

Protecting your data

Crunch Mediation has a strong data protection culture.

We have in place technical and organisational measures to guard against and to minimise the risk of loss, misuse or unauthorised processing or disclosure of the personal information that we hold.

Crunch Mediation mediators are trained, and have been provided specific guidance, on data protection and confidentiality. We have appropriate governance to ensure compliance with our data protection policies and procedures.

Data is stored securely and access is carefully controlled. All third parties are subject to confidentiality obligations which form part of our contractual relationship with them and only process personal data according to our instructions.

In most circumstances, personal data is held within the EEA. Any special category or sensitive data we process is held within the EEA. In rare situations information may be transferred to a country or international organisation outside of the EEA, we rely on the basis of an adequacy decision as allowed by the GDPR.

We have taken comprehensive steps to protect personal data. However, should a data breach occur, we have in procedures to comply with legal requirements to inform individuals and the relevant regulator.

Data retention

We only keep your personal information for as long as necessary for the purpose for which it was collected unless there are any legal or compliance reasons that apply.

When deciding the appropriate retention period, we consider a number of factors such as the nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which it is processed and if those purposes can be achieved by alternative means and any relevant legal requirements.

You can contact us for further by emailing: support@crunchmediation.co.uk

Sharing your information

We will only share personal information about individuals as part of our contracted service with you or where we have your permission or required by law to do so.

In all circumstances where data is shared, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

We use trusted data processors who are third parties who provide elements of services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct, unless legal or compliance reasons apply.

Information is shared with your allocated mediator, parties attending the mediation, and our administrators. Other third parties may include third party IT platforms (including cloud‐based platforms) and suppliers of IT support or other specialist services.

On rare occasions, we may be obliged to disclose data, for example:

· under certain laws or by order of court or other competent regulatory body or may be permitted to disclose it under applicable data protection laws.

· if Crunch Mediation merges with another business entity or divests a part of its business or carries out internal restructuring, your information may be disclosed to Crunch Mediation’s new business partners or owners or the new corporate entities.

· When hosting events, delegate information may be shared with other delegates and partner organisations.

Your rights

Data protection laws in the UK give people a number of rights concerning their personal data, although those rights may not apply in all cases or to all information that we hold about you. For example, we may need to continue to hold and process information to establish, exercise or defend our legal rights.

Each link below will take you to the Information Commissioner’s Office’s website where further detail is provided in section ‘When does the right apply’. These rights are:

· Right to be informed – this privacy policy aims to be transparent about what data we process and for what purposes.

· Right of access – you have the right to request a copy of the information that we hold about you and so details of how to make a subject access request are below.

· Right to rectification – If you believe that any information we are holding on you is incorrect or incomplete, please contact us as soon as possible by emailing support@crunchmediation.co.uk We will promptly correct any information found to be incorrect.

· Right to erasure – under some circumstances you can ask for the data we hold about you to be erased from our records. There may be circumstances where this is not possible, for example, where we are obliged to retain records of the service that we have provided to you.

· Right to restrict processing – where certain conditions apply to have a right to restrict the processing of the data that we have about you. · Right to data portability – you have the right to have the data we hold about you transferred to another organisation.

· Right to object – you have the right to object to certain types of processing such as direct marketing. Where you have consented to us processing your personal data, you may withdraw your consent at any time.

· Rights in relation to automated decision making and profiling– you also have the right not to be subject to the legal effects of automated processing or profiling.

If you have a query or wish to exercise any of your rights, please contact us by emailing: support@crunchmediation.co.uk.We will respond to your request as soon as we can.

Generally, this will be within one calendar month from when we receive your request but on occasions it may take longer to deal with your request and in such circumstances, we will inform you.

If we are not sure of your identity, we may require you to provide further information in order for us to confirm who you are.

Requesting a copy of your information

Typically, we receive information from solicitors dealing with your case, your employer and occasionally directly from you. We pass this information on to your mediator so that they can provide you with the service.

You may wish to consider directly contacting the organisation that you provided the information to in the first place (your solicitor or your employer) for a more complete record of your data.

If you would like to request a copy of your personal data that Crunch Mediation is processing then you will need to complete a Subject Access Request Form.

We will respond to your request (including providing information on whether the rights apply in the particular circumstances) within the applicable statutory time period.

If we are not sure of your identity, we may require you to provide further information in order for us to confirm who you are.

Please complete the form as fully as possible. Incorrect information or incomplete forms may cause delay in processing your request as we may need to request further information from you.

Complaints

If you consider we are using your information in a way which breaches UK Data Protection law, you have the right to complain to us and, if you remain unhappy following our response to your complaint, you have the right to raise a further complaint with The Information Commissioners Office (ICO).

If you have a query, complaint or wish to exercise any of your rights, please contact us by emailing: support@crunchmediation.co.uk.

We will respond to your request as soon as we can. Generally, this will be within one calendar month from when we receive your request but on occasions it may take longer to deal with your request and in such circumstances, we will inform you.

The ICO can be contacted via their website www.ico.org.uk or postal address: Customer Contact, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow. SK9 5AF.

Our website

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

We use the following cookies:

We use Google analytics cookies for tracking purposes. to help us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Please note that you cannot opt-out of these cookies being used as they are necessary for website performance or services to visitors.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.