Privacy Policy

  1. Purpose of this Policy

The Wells Group has developed this privacy policy to demonstrate our commitment to safeguarding the privacy of your data whilst providing a personal and valuable service.  This privacy policy applies to all personal data as defined in the General Data Protection Regulation 2018.

  1. Collection of Information

We collect personal information as volunteered by you through telephone calls to us, emails, referral forms, meetings in the office, online and via our Website.

The information we collect will vary depending on the service you request but could include name, address, phone number, email address, gender, date of birth, reasons for using our service, financial history, relationship and marriage background, names and ages of children. We may also ask for additional information depending on the nature of the service to be provided.

We will not collect personal information about you without your knowledge or permission unless provided to us by your ex-partner as part of The Wells Process.

This information will be kept securely on file for up to 3 years in the event that you return to use the services of The Wells Group.

  1. Use of Information

We are ‘processors’ of personal data for the purposes of the General Data Protection Regulation (‘GDPR’) or such UK legislation as may replace GDPR. You consent to us processing your personal data for the purposes of this agreement (this is part of your contract with us and our legal basis for processing your data is contract) and to passing to other professionals who are part of the service provided by the Wells Process, or other professionals whom you may instruct, such of your personal data as they may reasonably require. This includes our retaining and storing your personal data for as long as is necessary in connection with this agreement, to include a period of 36 months after the mediation concludes, in case of query. We may retain data for research and statistical purposes on the understanding that, if used for this purpose, all identifying details will have been removed.

We will use your personal information to provide our services, produce summary documentation and where necessary provide forms for court.

The personal information we obtain will be disclosed only to the partners The Wells Group and only as much as is reasonably necessary for the purposes as set out in this privacy policy.

Our quality assurance standards require that we monitor our mediation files. Periodically, our practice supervisors may have sight of files, but access is strictly controlled and on a similarly confidential basis.

  1. Sharing Information

Unless required to do so by law, we will not pass your information to any third party other than a data processor acting on our instructions pursuant to the General Data Protection Act 2018.

The Wells Group will not share personal data with third parties for marketing purposes.

Where specifically you consent or request us to send your information to solicitors, legal draftsperson, financial advisor or other professional we will do so.

  1. Data Transfers

IONOS is a managed services provider who provides The Wells Group with a Hosted Exchange.

The Wells Group uses Hosted Exchange accounts for transmitting confidential and sensitive data via email. We have ensured that our supplier is GDPR compliant. Most of our Hosted Exchange data is stored within the EU, however some is processed within the US and is certified under the Privacy Shield Framework Agreement, which means under EU law the supplier is eligible to hold EU citizen data under the GDPR.

  1. Your Rights

As the Data Subject, you have certain rights to the personal information we process about you. You have the:

  1. Right to be informed
  2. Right of access
  3. Right to rectification
  4. Right to erasure
  5. Right to restrict processing
  6. Right to data portability
  7. Right to object to having your personal data processed

If you would like to remove, check or amend any of the information held about you, or exercise any of your data subject rights, please send an email to info@wellsgroupdivorce.co.uk and we will take the necessary action within a reasonable time.

Requests must be made in writing and there is a £10 fee for each request. Proof of identification is required in order to protect your information.

The rights detailed above do not relate to any session records of the mediator, which are a memory aid and belong to the mediator.  Our session records will not be shared with others, and are subject to this privacy policy.

  1. Lawful Basis for Processing

The Wells Group has legitimate grounds for collecting and using your personal data, namely we need to have such information for the purposes of a) inviting people to engage in The Wells Process and b) conducting the services that individual clients ask us to provide.

The “General Data Protection Regulation” (GDPR) is the primary piece of legislation defining your rights over our processing of your personal information. The GDPR requires us to declare which of six “lawful reasons” we are relying on when we are processing your personal data:

Before the Service Agreement is signed, we operate on the basis of “legitimate interest”. In order to facilitate the mediation process, we will process your data in a targeted and proportionate way. Once the Service Agreement is signed, we operate on the basis of “contract”.

  1. Security

To prevent unauthorised access, maintain data accuracy and ensure the correct use of information, we have put in place appropriate physical and electronic procedures to safeguard and secure the information we collect from you.

  1. Changes to our Privacy Policy

We reserve the right to change our Privacy Policy and all changes will be posted on the The Wells Group website where they will take immediate effect.  Where the changes are significant, we may also choose to email all our current clients with the new Privacy Policy.

  1. Contact Us

If you have any questions or comments about this Privacy Policy or if you would like to exercise your rights please contact us at info@wellsgroupdivorce.co.uk or write to The Wells Group, Pantiles Chambers, 85 High Street, Tunbridge Wells Kent TN1 1XP.