JWF Mediation takes the matter of data protection and security seriously and, as a data controller of some of your personal data, recognises the need to process the data in a responsible and lawful manner. This Privacy Policy explains what personal information we collect from you, how we use it and whom we may share it with.

How we use your personal data – the categories of personal data that we may process, the purposes for which we may process such data and the legal basis for the processing are as follows:

“Enquiry data”. We may process information contained in any contact form or enquiry you submit to us regarding our services. The enquiry data may be processed for the purposes of communicating with you and record-keeping, offering, marketing and selling relevant services to you. The legal basis for this processing is consent.

“Correspondence data”. We may process information contained in or relating to any communication that you send to us to further the communication between us beyond initial enquiry. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users of our services.

“Customer relationship data”. We may process information relating to our customer relationships, including customer contact information. The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent and our legitimate interests, namely the proper management of our customer relationships.

“Transaction data”. We may process information relating to transactions, including purchases of services, that you enter into with us. The transaction data may include your contact details, your payment card details and the transaction details. The transaction data may be processed for the purpose of supplying the services to you and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

“Notification data”. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

“Usage data”. We may process data about your use of our website. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website.

Additional processing:

We may also process any of your personal data identified in this policy where necessary for:

– the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

– the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

– compliance with a legal obligation, or in order to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person’s personal data to us, unless we ask you to do so.

Embedded content from other websites:

Articles on this website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. Please see the particular websites in question regarding their own Privacy Policy.

Providing your personal data to others

We may disclose your personal data:

• to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing business risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
• to our suppliers or subcontractors insofar as reasonably necessary for the performance of a contract between you and us. 
• where such disclosure is necessary for compliance with a legal obligation, or in

  order to protect your vital interests or the vital interests of another natural person.

International transfers of your personal data

Information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA):

The hosting facilities for our website are situated in the United Kingdom.

Usage data, enquiry data, customer relationship data and correspondence data may be held and processed by Google Analytics in the United States of America. The European Commission has made an “adequacy decision” with respect to the data protection laws of the USA. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

Retaining and deleting personal data

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data as follows:

(a) enquiry data, customer relationship data and notification data will be retained for a maximum period of 12 months following enquiry date.

(b) correspondence data will be retained for a maximum period of five years following last date of correspondence.

(c) the period of retention of transaction data will be determined based on appropriate financial legislation

(d) The maximum amount of time that usage data will be retained is in line with Google’s Analytics data retention policy, which as of November 20 is 26 months.

Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Access to your personal data and other rights

JWF Mediation wishes to be as open as reasonably possible about personal data that we process.  If you would like specific information, please ask.

You have a legal right to make a “subject access request”. 

If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including giving you a description and copy of the personal data and telling you why we are processing it. If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.

You have a legal right to have your personal data rectified upon request.

You have a legal right to have your personal data erased, to object to its processing or to have its processing restricted – except for data we are obliged to keep or process for administrative, legal, or security purposes.

You have a legal right to be given data about yourself in machine readable format for transfer to another data controller. This only applies if the ground for processing is ‘consent’ or ‘contract’.

If we have relied on consent as a ground for processing, you may withdraw your consent at any time – though if you do so that will not affect the lawfulness of what we have done before you withdraw your consent.

Cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

We use Google Analytics from time to time to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/

If you block cookies, you may not be able to use all the features on our website.

Amendments

We may update this policy from time to time by publishing a new version on our website therefore you should check this page occasionally to ensure you are happy with any changes to this policy.

Any questions or complaints?

Should you have any queries about our privacy policy or how we manage your personal data, please get in touch.

If you have complaints relating to our processing of your personal data and you are not able to get satisfactory resolution with JWF Mediation, you may also raise complaints with the Information Commissioner who is the statutory regulator.  https://ico.org.uk/make-a-complaint/