Privacy Policy

WHO IS “RESOLVED ONLINE”?

For the purposes of data protection law, the “controller” and Data Protection Officer is Dominic Bright.

He is responsible for, and controls the processing of, your personal data.

If you would like to contact him in relation to this Privacy Notice, please send an email to dominicbright@resolvedonline.com.

PURPOSES OF THIS PRIVACY NOTICE

This Privacy Notice contains information about the information that is collected, stored and otherwise processed about you, and the reasons for the processing.

It tells you who Resolved Online shares this information with, the security mechanisms that Resolved Online has put in place to protect your information, and how to contact Resolved Online in the event you need further information.

It provides information on the correct body to contact in the unlikely event that you have a complaint that Resolved Online cannot address.

COOKIES

Resolved Online uses cookies.

These are small files that a website or service provider transfers to your computer’s hard drive through your website browser, if you allow it to, enabling the website or service provider’s systems to recognise your browser, capture and remember certain information.

Cookies help Resolved Online to remember and save your preferences for future visits.

They also held Resolved Online to compile aggregate data about website traffic and interaction, so that Resolved Online can offer better site experiences.

Resolved Online may contact third-party service providers, so as to assist in understanding the visitors to the website.  These service providers are not permitted to use the information collected on behalf of Resolved Online, expect to assist the website to conduct and improve the service that is offered.

You can choose to receive a warning each time a cookie is being sent.  You can also choose to turn off all cookies, via browser settings.

Like many website, if you turn cookies off, some of the services offered may not function properly.

PERSONAL INFORMATION

Resolved Online collects, uses, and is responsible for, personal information about you.

“Personal information” is any information relating to an identified, or an identifiable individual, including:

  • Name, address, and telephone numbers;
  • Information to enable Resolved Online to check, and to verify your identity, for example, your date of birth, or passport details;
  • Electronic contact details, for example, your email address;
  • Information relating to the matter in which you are seeking our mediation services, or mediation advocacy representation;
  • Financial details, so far as relevant to your matter; and
  • Information about your use of the IT, communication and other systems, and other monitoring information of Resolved Online.

When Resolved Online does this, Dominic Bright is the “controller” of this information for the purposes of the General Data Protection Regulation (“GDPR”), and for the purposes of the Data Protection Act 2018.

Resolved Online won’t disclose your information to anyone, other than as set out in this Privacy Notice, and any applicable terms and conditions.

If you need to contact Resolved Online about your information, or about the processing carried out, please send an email to dominicbright@resolvedonline.com.

WHAT DOES RESOLVED ONLINE DO WITH YOUR INFORMATION?

INFORMATION COLLECTED

Resolved Online collects some, or all of the following personal information that you provide:

  • Personal details;
  • Financial details;
  • Criminal proceedings, outcomes and sentences, or related security measures;
  • Physical, and mental health details;
  • Education, training, and employment details; and
  • Other personal information, relevant to instructions to provide mediation services, including information specific to the instructions in question.

INFORMATION COLLECTED FROM OTHER SOURCES

Resolved Online collects most of this information from you.

The same categories of information may also be obtained from third parties, however, such as:

  • Experts;
  • Members of the public;
  • Your family, and friends;
  • Witnesses;
  • Courts, and other tribunals;
  • Suppliers of goods and services;
  • Investigators;
  • Government departments;
  • Regulators; and
  • Public records, and registers.

HOW RESOLVED ONLINE USES YOUR PERSONAL INFORMATION

Under data protection law, Resolved Online can only use your personal data if there is a proper reason for doing so, or a legitimate interest.

A legitimate interest is when Resolved Online have a business, or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

This includes use of your personal information for the following purposes, including to:

  • Provide mediation services to you;
  • Administer Resolved Online in accordance with Civil Mediation Council (and other) regulatory regulations and guidance;
  • Arrange payment of mediators’ fees and expenses;
  • Fulfil regulatory requirements;
  • Carry out anti-money laundering and terrorist financing checks; and
  • As otherwise required, or as permitted by law.

WHETHER INFORMATION HAS TO BE PROVIDED BY YOU & WHY

If you are offering or providing Resolved Online with goods or services, your information may be processed in relation to such offers or contracts.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

Resolved Online relies on the following lawful bases, so as to collect, and to use your personal information:

  • If you have consented to the processing of your personal information, then Resolved Online may process your information for the purposes set out above, to the extent to which you have consented to Resolved Online doing so;
  • In relation to categories which are considered to include particularly sensitive information (which include information about criminal convictions or proceedings), Resolved Online is entitled by law to process the information where the processing is necessary for mediation services, legal proceedings, legal advice, or otherwise for the establishment, exercise or defence of legal rights;
  • In relation to information that is not particularly sensitive, Resolved Online relies on its legitimate interests and / or the legitimate interests of a third party in carrying out the processing for the purposes set out above;
  • In relation to information which is particularly sensitive, and which include information about criminal convictions or proceedings, Resolved Online relies on your consent for any processing for the purposes set out above.
  • The processing is necessary for the purposes of performing, or of exercising obligations, or of rights which are imposed, or are conferred by law on Resolved Online, or you, in connection with employment, social security or social protection.
  • The processing is necessary to prevent, or to detect unlawful acts, where there is substantial public interest, and it must be carried out without consent, so as not to prejudice those purposes.
  • In certain circumstances, processing may be necessary in order for Resolved Online to comply with a legal obligation to which it is subject (including carrying out anti-money laundering, or terrorist financing checks).

WHO WILL RESOLVED ONLINE SHARE YOUR PERSONAL INFORMATION WITH?

 It may be necessary to share your information with the following:

  • Information processors, such as IT support staff, email providers, and information storage providers;
  • In the event of complaints, the Civil Mediation Council, the Bar Standards Board, and the Legal Ombudsman;
  • Other regulatory authorities;
  • Legal professionals;
  • Experts, and other witnesses;
  • Prosecution authorities;
  • Courts, and tribunals;
  • Business associates, professional advisers and trade bodies, for example, the Civil Mediation Council;
  • Resolved Online may be required to provide your information to regulators, such as the Civil Mediation Council, Bar Standards Board, the Financial Conduct Authority or the Information Commissioner’s Office. In the case of the latter, there is a risk that your information may lawfully be disclosed by them for the purpose of any other civil, or criminal proceedings, without the consent of Resolved Online, or your consent, which includes privileged information; and
  • Resolved Online may also be required to disclose your information to the police, or the intelligence services, where required, or permitted by law.

SOURCES OF INFORMATION

Personal information that Resolved Online obtains may include information obtained from:

  • Legal professionals;
  • Experts, and other witnesses;
  • Prosecution authorities;
  • Courts and tribunals
  • Lay, and professional clients of Resolved Online;
  • Family and associates of the person whose personal information Resolved Online is processing;
  • In the event of complaints, Dominic Bright, the Civil Mediation Council, the Bar Standards Board, and the Legal Ombudsman;
  • Other regulatory authorities;
  • Business associates, professional advisers and trade bodies, for example, the Civil Mediation Council;
  • Data processors, such as IT support staff, email providers, and data storage providers; and
  • Public sources, such as the press, public registers, and law reports.

TRANSFER OF YOUR INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA (“EEA”)

This Privacy Notice is of general application, and, as such, it is not possible to state whether it will be necessary to transfer your information out of the EEA in any particular case.

If you are in a country outside the EEA, or, if the instructions that you provide come from outside the EEA, then, it is inevitable that information will be transferred to those countries.

If this applies to you, and you wish additional precautions to be taken in respect of your information, please indicate this when providing initial instructions.

Some countries and organisations outside the EEA have been assessed by the European Commission, and their information protection laws and procedures found to show adequate protection.

Most do not.

If your information has to be transferred outside the EEA, then it may not have the same protections.  You may not have the same rights as you would within the EEA.

Resolved Online will not transfer personal information outside the EEA, except as necessary for the conduct of any mediation.

If you would like any further information, please use the contact details at the bottom of this page.

HOW LONG WILL RESOLVED ONLINE STORE YOUR PERSONAL INFORMATION?

Resolved Online will normally store all your information until at least one year after the expiry of any relevant limitation period.

For example, the date of the last provision of service or goods, the date of the last payment made or received, or the date on which all outstanding payments are written off, whichever is the latest.

This is because it may be needed for potential legal proceedings.

At this point, any further retention will be reviewed, and the information will be marked for deletion, or marked for retention for a further period.

The latter is likely to occur only where the information is needed for legal proceedings, regulatory matters, or active complaints.

Deletion will be carried out as soon as reasonably practicable after the information is marked for deletion.

CONSENT

As explained above, Resolved Online is relying on your explicit consent to process your information that is particularly sensitive.

You have the right to withdraw this consent at any time, but this will not affect the lawfulness of any processing activity carried out prior to you withdrawing your consent.

Where Resolved Online also relies on other bases for processing your information, however, you may not be able to prevent processing of your information.

If there is an issue with the processing of your information, please contact Dominic Bright at dominicbright@resolvedonline.com.

YOUR RIGHTS

Under the GDPR, you have a number of rights that you can exercise in certain circumstances.

These are free of charge.

In summary, you may have the right to:

  • Ask for access to your personal information, and other supplementary information;
  • Ask for correction of mistakes in your information, or to complete missing information that Resolved Online holds on you;
  • Ask for your personal information to be erased, in certain circumstances;
  • Receive a copy of the personal information that you have provided to Resolved Online, or have this information sent to a third party. This will be provided to you, or the third party in a structured, commonly used, and machine-readable format, for example, a Microsoft Word file;
  • Object in certain other situations to the continued processing of your personal information; and
  • Restrict the processing of your personal information in certain circumstances.

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, Resolved Online may need to ask you to provide other information, so that you can be identified.

To exercise any of these rights, please:

  • Contact at dominicbright@resolvedonline.com;
  • Provide a contact address, so that you can be contacted to request further information to verify your identity;
  • Provide proof of your identity, and proof of your address; and
  • State the right, or the rights that you wish to exercise.

Resolved Online will respond to you within one month from the date that your request is received.

HOW TO MAKE A COMPLAINT?

If you are in the UK, the GDPR also gives you the right to lodge a complaint with the Information Commissioners’ Office, or with the supervisory authority of the European Union Member State where you work, normally live, or where the alleged infringement of information protection laws occurred.

The Information Commissioner’s Office can be contacted at http://ico.org.uk/concerns/.

FUTURE PROCESSING

Resolved Online does not intend to process your personal information, except for the reasons stated within this Privacy Notice.

If this changes, this Privacy Notice will be amended, and placed on the website of Resolved Online at https://www.resolvedonline.com.

IN THE CASE OF A BREACH

If a personal data breach occurs, Resolved Online will record this, and consider both the likelihood, and the severity of the resulting risk to your rights and freedoms.

If it’s likely that there will be a risk, then, Resolved Online will report the following to you and the Information Commissioner’s Office within 72 hours:

  • Nature of the data concerned, approximately how many people are affected, and the consequences of this for them; and
  • What measures Resolved Online has taken, or plan to take in response.

CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice was published, and last updated on 30 March 2020.

Resolved Online continually reviews its privacy practices, and it may change this policy from time to time.

When it does, an amended privacy notice will be substituted on the website of Resolved Online at https://www.resolvedonline.com.

CONTACT DETAILS

If you have any questions about this Privacy Notice, or the information that Resolved Online holds about you, please contact Dominic Bright at dominicbright@resolvedonline.com.