Privacy Policy

25th February 2025
Integrity Conflict Solutions is committed to respecting and protecting your privacy. This is our privacy notice and explains how we do so. Please read the following information carefully. This privacy notice contains information about the information collected, stored and otherwise processed about you and the reasons for the processing. It also tells you who we share this information with, the security mechanisms we have put in place to protect your data and how to contact us in the event you need further information.

Data Controller

Integrity Conflict Solutions uses and is responsible for personal information about you and is the ‘controller’ of this information for the purposes of the General Data Protection Regulation and other applicable data protection laws.

What information we collect

When carrying out the following activities:

The management and administration of Integrity Conflict Solutions – We may obtain your personal data, including special categories of personal data as defined in the General Data Protection Regulation (“GDPR”), when you make an enquiry about using us as mediators. This could include contact via telephone, email, or other electronic correspondence, for example, if you seek an estimate of costs for a mediation or appoint us as mediators.
Otherwise in the normal course of business – you may have provided us with your personal business details in relation to appointing a mediator or for the purposes of communicating regarding potential mediations or marketing/business development opportunities. This could include contact via telephone, email, or other electronic correspondence.
Other marketing – We may have obtained limited personal data at an event or through an introduction by a third party or through mutual networking activity in person or via social media, email or other digital communications.

In addition, if you visit integrityconflictsolutions.co.uk some limited personal data may also be collected. Web usage information such as IP address, time, and duration of visits.

We collect the following personal information that you provide:

your name and title
contact information, including telephone number, postal address and email address
information relating to your location, preferences and / or interests
in certain circumstances, your and others’ signature(s), financial details such as bank account details
in certain circumstances, data relating to health (including disabilities), ethnicity, race, religious beliefs, trade union membership and other ‘special category personal data’ • the content of any enquiry submitted over the Website
any other personal data we collect (such as the reference number which may be assigned to you) in the context of our work or in the course of operating our business.
other personal information relevant to instructions to provide mediation services, including information specific to the instructions in question.
any other information relating to you which you may provide to us.

Information collected from other sources.

We collect the following information from other sources:

your name and title
contact information, including telephone number, postal address and email address
information relating to your location, preferences and / or interests
in certain circumstances, your and others’ signature(s), financial details such as bank account details
in certain circumstances, data relating to health (including disabilities), ethnicity, race, religious beliefs, trade union membership and other ‘special category personal data’
any other personal data we collect (such as the reference number which may be assigned to you) in the course of operating our business.
other personal information relevant to instructions to provide mediation services, including information specific to the instructions in question.

If you give us personal information about another person, you should ensure that:

(a) you are legally entitled to give us that information.

(b) the disclosure is in accordance with any applicable data protection or privacy law; and

How we may use this information

We may use your personal information for the following purposes:

to provide the requested service to you
to respond to any query that you may submit to us
to manage our relationship with you (and/or your business), including by maintaining our database of contacts and other third parties for administration, and accounting and relationship management purposes
to complete our contractual obligations to you, or otherwise taking steps as described in our Mediation Agreement (including any associated administration)
to carry out any relevant conflict checks
to keep accounting records
to promote and market our practice
to provide work shadowing opportunities
to respond to requests for references
to respond to potential complaints or make complaints
to comply with any other professional, legal and regulatory obligations which apply to us or policies that we have in place
to establish, exercise or defend our legal rights or for the purpose of legal proceedings
for our legitimate business interests, such as undertaking conflict searches, business research and analysis, managing the operation of our practice
to prevent and respond to actual or potential fraud or illegal activities.
for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey responses 16. as we feel is necessary to prevent illegal activity or to protect interests. We do not use automated decision-making in the processing of your personal data. Please bear in mind that if you choose not to provide personal data requested by us, or if you object to our processing your personal data, we may not be able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the personal data.

Our legal basis for processing (using and storing) your personal information

The GDPR requires all those that process personal data to have a legal basis for doing so.

The lawful bases identified in the GDPR, and which provide our legal bases for processing your personal data, are:

Performance of a contract with the data subject or to take steps to enter into a contract.
Compliance with a legal obligation.
The legitimate interests of ourselves , or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.
Where we are otherwise required or authorised by law.
Where processing of ‘special category data’ is necessary in the context of the establishment, exercise or defence of legal claims.
In certain circumstances, where we need to process ‘special category data’ in the context of our legal work but outside the scope of the point above, where we have obtained your express consent to do so. As we will explain at the time we collect your consent, you may withdraw it at any time in accordance with the information I provide to you at that time.

Legitimate interest as follows:

The legitimate interests and purposes for which we process personal data are as follows:

To administer and perform our mediation services.
To make, investigate, respond to or address complaints or concerns, including any legal or regulatory action.
To ensure network and information security, including preventing unauthorised access to personal data.
To assess and improve our services.
For marketing purposes.
Our interests in managing our relationship with our contacts and ascertaining achievement of proper standards/compliance with policies, practices or procedures.
Running conflict checks.
To report possible criminal acts or threats to public security.

As mediators we have an obligation to keep your information confidential, save as may be required by law, whether under the Proceeds of Crime Act 2002 and/or any Regulations relating thereto or otherwise.

Our obligations in relation to mediation matters are governed by the terms of the mediation agreement executed in relation to each matter.

Information collected from or otherwise arising from the provision of our mediation services may be shared internally with the administration team of Integrity Conflict Solutions.

Third-party IT staff may have access to the data if it is necessary in the performance of their supporting role for the Controller.

We also share limited information with third parties who process data on our behalf, including IT service and business administration service providers, insurers and in connection with bank transfers and accountancy requirements.

We will not rent or sell contacts details to any other organisation or individual.

We may be required to provide your information to regulators or the Information Commissioner’s Office. In the case of the Information Commissioner’s Office, there is a risk that your information may lawfully be disclosed by them for the purpose of any other civil or criminal proceedings, without our consent or yours, which includes privileged information.

We may also be required to disclose your information to the police or intelligence services, where required or permitted by law.

Storage and retention of your personal information

Personal data will be retained for as short a period as possible and the retention period may vary from one piece of information to another. It will also take into account our need to meet any legal, statutory and regulatory obligations, good practice and business purposes. In all cases the need to use your personal information will be reassessed on a regular basis and information which can be destroyed because it is no longer required will be disposed of effectively and securely.

Security of personal data

We are committed to ensuring that your information is secure. To help protect your personal information from unauthorised access or disclosure, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we hold. Once we have received your information, we will use standard procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure and although we do our best to protect your personal data, we cannot absolutely guarantee the security of your data.

Sending your personal data outside the EEA

It may be necessary to transfer your personal information outside the EEA or to an international organisation in order to operate email systems and email marketing. A list of third countries that your personal data may be transferred to can be found below:

We use Microsoft Office 365 for email. Whilst servers are based in the EU it is replicated to other servers. Microsoft Office 365 complies with the EU-U.S. Privacy Shield. The EU-U.S. Privacy Shield has been recognised by the European Commission as providing adequate protection. To obtain further details of that protection see https://ec.europa.eu/info/law/law-topic/data-protection/data- transfers-outside-eu/eu-us-privacy-shield_en. Privacy Policy for Microsoft Office 365 located here: https://products.office.com/en-gb/business/office-365-trust-center-privacy
cloud data storage services based in the USA who have agreed to comply with the EU-U.S. Privacy Shield, in order to enable me to store your data and/or backup copies of your data so that we may access your data when they need to. The USA does not have the same data protection laws as the EU but the EU-U.S. Privacy Shield has been recognised by the European Commission as providing adequate protection. To obtain further details of that protection see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us- privacy-shield_en.
cloud data storage services based in Switzerland, in order to enable me to store your data and/or backup copies of your data so that I may access your data when we need to. Switzerland does not have the same data protection laws as the EU but has been recognised by the European Commission as providing adequate protection; see https://ec.europa.eu/info/law/law-topic/data- protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

Your Rights

Under the General Data Protection Regulation, you have several important rights that you can exercise free of charge. In summary, these rights are to:

transparency over how we use your personal data and fair processing of your information;
access to your personal information and other supplementary information;
require us to correct any mistakes or complete missing information we hold on you;
require us to erase your personal information in certain circumstances;
receive a copy of the personal information you have provided to me or have this information be sent to a third party, this will be provided to you or the third party in a structured, commonly used and machine readable format;
object at any time to processing of your personal information for direct marketing;
object in certain other situations to the continued processing of your personal information;
restrict our processing of your personal information in certain circumstances;
Request not to be subject to automated decision making which produce legal effects that concern you or affect you in a significantly similar way;

If you want more information about your rights under the GDPR please see the Guidance from the Information Commissioners Office on Individual’s rights under the GDPR. If you want to exercise any of these rights, please:

Email us direct on info@integrityconflictsolutions.co.uk
provide information so that we can identify you such as a copy of your passport. We may need to contact you to request further information to verify your identity;
let us have proof of your identity and address;
state the right or rights that you wish to exercise; We will respond to you within one month from when I receive your request. If a data subject believes that the Controller has not complied with their data protection rights, they can complain to the Information Commissioner’s Office We do not intend to process your personal information for any reason other than stated within this privacy notice. If this changes, the privacy notice will be amended and placed on our website. Changes to this privacy notice This privacy notice was published on 25th February 2025. Any changes to it will be shown on the revised version of it on our website. How to contact us about data protection matters

If you have any questions about this privacy notice or the information we hold about you, please contact helen.grimberg@integrityconflictsolutions.co.uk or Madeleine.Kelly@integrityconflictsolutions.co.uk