Data Protection & Privacy Policy
At the Centre for Dispute Avoidance (CDA) we respect your privacy, and we are committed to protecting your personal data. This privacy notice is to inform you as to how we look after your personal data and inform you of your rights.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice supplements any other notices.
If you are an individual, you will need to provide us with personal data about you (and possibly others) for the purposes of being a member of the CDA. Such data may include the your name, address, date of birth, passport or other identification documentation, qualifications, experience, expertise, contact numbers and email, bank account details, assets, family details. We may also obtain from you and public resources the names, ages, addresses and other details of anyone involved with your matter.
Any such personal data may be used by us for the provision of our dispute avoidance management services, billing and other administrative purposes (including the processing of any such data as part of those services or so as to improve the delivery of similar services in the future). It may also be used by us from time to time to provide you (and where appropriate anyone for whom you act) with information about the CDA and our service (including contacting you or them by email or telephone or sending you a newsletter by email).
If you are the representative of a legal entity member, we will use any personal data you provide to us for the purposes of acting, on the same basis as set out above. It is your responsibility to ensure that the client has appropriate procedures in place (including adequate privacy notices) when you ask us to collect and process personal data for the purposes of the client matter. If you have any concerns about the status of such data you must let us know before any such data is shared with us.
If you do not wish to receive information about us and our services, wish to receive only certain kinds of information, or wish to receive information only by a particular method, please use the unsubscribe function on our communications or inform us at membership@disputeavoidance.net.
None of the information we hold about you will be disclosed to third parties except in accordance with paragraph 7 (confidentiality) of our Terms of Business or for the purpose of managing our database or improving our business.
If, as part of our services, we collect personal data about other people on your behalf, we will hold and process that data in accordance with the prevailing data protection legislation. If in our view, certain of that personal data should not be held or processed by us we will return or delete it as appropriate (and technologically practicable).
If you are an individual and wish to make a subject access request at any time, please email us on membership@disputeavoidance.net and your request will be dealt with expeditiously.
CONTROLLER
The CDA is the controller and responsible for your personal data (collectively referred to as ”the Company”, “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
CONTACT DETAILS
The Centre for Dispute Avoidance Ltd, 5 Chancery Lane, London EC4A 1BL, UK.
INFORMATION COMMISSIONER'S OFFICE
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 8 October 2018.
The data protection law in the UK changed on 25 May 2018. It is essential that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party sites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party sites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every site you visit.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
Contact Data includes a billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Marketing and Communications Data includes your preferences in receiving marketing from us and third parties and your communication preferences.
Professional Data includes your academic and professional qualifications, experience and expertise.
Business Data includes your areas of business practice.
Background Data includes background checks, including criminal records checks and compliance with anti-corruption legislation.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, on our website or otherwise. This includes personal data you provide when you:
Enquire about our services;
Engage us to provide services to you;
request marketing to be sent to you;
or give us some feedback.
Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below:analytics providers;
search information providers based inside the EU.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than for sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by sending us an e-mail on the above e-mail address.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of the ways we plan to use your personal data. We will collect, store and use your identiy and contact details for:
Registering you as a new member.
Processing your requests.
Managing our relationship.
Administering our business.
Making suggestions to you about services that may be of interest to you.
Delivering website content and advertisements to you and understanding the effectiveness of the advertising we serve to you.
Ensuring you are compliant with your obligations as a member of the CDA.
For processing instructions and managing our business, we may also use your financial information and information relating to a transaction.
Please contact us if you need details about the legal ground we are relying on to process your personal data.
MARKETING
We aim to provide you with choices regarding certain personal data uses, particularly in marketing and advertising. We have established the following personal data control mechanisms:
NEWSLETTERS AND MAILSHOTS
We may use your Identity and Contact to send you information which we consider may be of interest to you.
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
OPTING OUT
You can ask us to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with certain third parties for the purposes set out above. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we have to keep basic information about our clients (including Contact, Identity and Financial Data) for six years after they cease being clients.
In some circumstances, you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, details of which we set out below, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.