Our Privacy Policy

This privacy policy aims to give you information on how Ciarb collects and processes your personal data when you become a member, or when you use or apply to our services, including any job applications, as well as through your use of this website.

The privacy policy should be read in conjunction with any privacy policy or fair processing policy we may provide on specific occasions. This privacy policy supplements the other policies and is not intended to override them. This privacy policy, together with our cookies policy tells you how we collect, use and protect your personal information.

 If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Our full details are:

Full name of legal entity:  The Chartered Institute of Arbitrators (Incorporated by Royal Charter 1979 (RC000099) and is a Registered Charity in England and Wales (number 803725).

ICO registration reference:      Z7576947

Contact person:                        General Counsel

Email address:                          legal@ciarb.org

Postal address:                         The Chartered Institute of Arbitrators, 12 Bloomsbury Square, London, WC1A 2LP, England, United Kingdom

Telephone number:                  +44 207 421 7444

Website:                                      https://ciarb.org   

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. 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 policy

This privacy policy was last updated on 30^th May 2024. We may change or update the terms of this privacy policy from time to time, by publishing an updated version on our website. You will be notified of any significant changes to this privacy policy.

This website may include links to third-party websites, 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 websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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 as follows:

• Identity Data includes first name, middle name, last name or similar identifier, title, pre and post nominal data, date of birth, photo, and any identity documents to prove identity.
• Contact Data includes home address, country of residence and/or domicile, billing address, delivery address, email address, social media details/handles/links, and telephone numbers.
• Work Data includes occupation, employer details, job titles, education details, course details (including transcript, letter or examination documentation), qualification details, CVs detailing education and work history, referee details and letters, right to work, and/or any information we receive from you through your interview or recruitment processes, and/or membership applications.
• 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 from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses. You can object to such use of your personal information for profiling at any time by contacting us. 
• Usage Data includes information about how you use our website, products and services.
• Recording Data includes any recordings (including but not limited to videos, audio and/or images or photographs) that are made of you as part of a formal assessment, part of our courses, the delivery of a service and/or published online collaborations, events or webinars (or equivalent) with us.
• CCTV Data includes any recordings at our offices at number 12 and 14 Bloomsbury Square, London in the communal areas.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• User Contribution Data includes information about you and which is posted on or through Ciarb’s off-line and online channels, for example, Ciarb’s social media handles and website, and/or Ciarb virtual learning platforms.

We also collect, use and share Aggregated Data such as statistical or demographic data to enable us to meet our charitable objectives. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Data protection laws categorises certain types of personal data as more sensitive, which is commonly known as Special Category personal data. This covers, for example, information relating to racial or ethnic origin, religious or philosophical beliefs and political opinions, trade union membership, genetic or biometric data, information concerning health or data concerning a person's sex life or sexual orientation.

We will only collect Special Category personal data where necessary.

We may collect Special Categories of Personal Data about you, such as:

Information relating to your health and any disability, if, for example, we have to make reasonable arrangements or adjustments for your interview, course assessment, access to:

• an event, or obtain your dietary requirements. At the time we collect this information, we will explain what information is needed and why.
• As a Disability Confident Committed Employer, we may collect optional information on disability, as part of our recruitment process.
• Equal Opportunities Monitoring form, we may collect optional information on disability, social mobility, race, religion, gender, sexual orientation, on recruitment to support us in delivering our equality programme.
• Information relating to gender and disability, which is anonymised, for the purposes of statistical analysis to meet our equality and diversity reporting and/or objectives.

In addition, we may collect other sensitive personal data about you in connection with your entry, appointments, and annual declaration on criminal convictions, prior conduct, and character suitability which we may take into account when deciding to grant or renew membership, such as:

• any investigation(s), finding(s), sanction(s) or action(s) by a regulatory body, professional body, appointing authority or nominating body;
• if you (or a company, partnership or other entity which you are in a position of authority or control over) have threatened to suspend payment of debts, been unable to pay debts as they fall due or have admitted an inability to pay your debts, in any jurisdiction;
• any outstanding judgments against you;
• any outstanding complaints about your professional conduct;
• bankruptcy orders against you or a company of which you were a director or there has been compulsory or voluntary liquidation on grounds of insolvency;
• any criminal investigation(s), caution(s), charge(s) or conviction(s) of any criminal offences, (other than: (i) motoring offences that haven’t resulted in disqualification (in any jurisdiction) or (ii) where there is legislation in the jurisdiction of the conviction, which allows the criminal record to be removed after a certain period of time and that period of time has passed; and
• any non-compliance with our Code of Professional and Ethical Conduct for Members.

(collectively together “Special Category 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.

You may give us your Identity Data, Contact Data, Work Data, and/or Financial Data (these are categories as defined earlier in Section 2 of this Privacy Policy) by filling in forms or by corresponding with us by post, phone, email or in person. This includes personal data you provide when you:

• apply to become a member (including any renewals);
• apply for any member grade/status;
• apply to any aspect of the Dispute Appointment Services (including but not limited to any panel appointments);
• apply to us for a job;
• submit any items to us;
• create an account on our website;
• edit your professional profile on our Membership Directory;
• subscribe to our services or publications;
• request marketing materials to be sent to you;
• use our products and services;
• register for, enroll, and/or attend our any of our courses, workshops, training, programmes, assessments and events;
• attendance at and/or use of our offices;
• visitors Record Book: we also have sign-in registers for guests and/or visitors who attend our office;
• free guest WiFi access;
• enter a competition, promotion or survey;
• submit an enquiry and/or make any requests;
• give us some feedback and/or make a complaint;
• enter into a contract with us;
• interact with our recruitment platform/chat facility;
• collaborate in any way with us; and
• publish, draft, or write anything for us and/or on behalf of us.

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

We use CCTV systems at our offices at number 12 and 14 Bloomsbury Square, London in the communal areas.

Includes any recordings (including but not limited to videos, audio and/or images or photographs) that are made of you as part of a formal assessment, part of our courses, the delivery of a service and/or published online collaborations, events or webinars (or equivalent) with us.

We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

• analytics providers based inside and outside the UK and the EU;
• advertising networks based inside and outside the UK and the EU; and
• search information providers based inside and outside the UK and the EU.

This data is collected from providers of technical, payment and delivery services based inside or outside the UK and the EU.

This data is collected from publicly availably sources to verify pre-submitted information to us, which may include but not limited to Companies House, social media and/or the Charity Commission.

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 you have asked us for information or to contact you or have otherwise explicitly consented.
• 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.
• Where it is necessary to protect someone’s life.

See the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this direct marketing).

You will receive direct marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that direct marketing.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

We strive to provide you with choices regarding certain personal data uses, particularly where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. For clarity, we will still send non-marketing messages that are required as part of our business operations.

Cookies

When you visit our website, you will be invited to choose which cookies you are willing to accept. In addition to using the tools made available on our site, you can also set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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.

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Regulators and/or Law Enforcement Agencies or the equivalent bodies (statutory and non-statutory) in or outside of the UK, who investigate matters, including but not limited to matters of misconduct and/or crime.

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.

Please note that some of your details such as your name, contact details, social media links, your discipline, active in ADR over the past 12 months, and personal biography will be listed our public Membership Directory on our website.

We share your personal data with our Global Network. This will involve transferring your data outside the European Economic Area (EEA) and the UK. The personal data is shared in accordance with our Global and UK Data Protection Standard which requires all Branches to follow the same standard when processing your personal data.

Many of our external third parties are based outside the EEA and the UK so their processing of your personal data will involve a transfer of data outside the EEA and the UK.

Whenever we transfer your personal data out of the EEA and the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and the UK Information Commissioner. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries and the UK Data Protection and the ICO - International Data Transfers.
• Where we share your data with our Global Network or use certain service providers that are located in a jurisdiction which do not have the equivalent level of protection provided in the UK and the EEA, we will put suitable safeguards in place to protect your personal data, for example, by using specific contracts and standards data protection clauses approved by the European Commission and the UK Information Commissioner which are designed to give personal data the same protection it has in its country of origin.
• Please contact us if you want further information on the specific mechanism used by us at legal@ciarb.org when transferring your personal data out of the EEA and the UK.

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.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of 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.

Typically, we will process your personal data for as long as your account is active with us or as needed to provide you with access to our products and services or otherwise in accordance with our Retention procedure.

By law we have to keep basic information about our members and customers (including Contact Data, Identity Data, Financial Data and Transaction Data) and this will be retained in line with our Retention procedure.

In some circumstances you can ask us to delete your data: see Requests erasure 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 reference to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  These include the rights to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

Further detail on each of these rights is set out in the Glossary below. If you wish to exercise any of these rights, please contact us.

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.

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.

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.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering in to such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

• Service providers acting as processors who provide services, including but not limited to telemarketing/IT/market research and system administration/direct marketing services on our
• Service providers and/or third-party platforms acting as processors who provide recruitment services, educational services, and/or software solutions on our behalf.
• Software solutions acting as processors that provide customer relationship management and/or case management on our behalf.  
• Payment providers acting as processors who provide payment services on our behalf.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting
• HM Revenue & Customs, regulators, law enforcement and other authorities who may request or require personal data in certain circumstances.
• Suppliers acting as processors for the purposes of delivering events, including but not limited to hotels, travel agencies, event agencies and event venues.
• Contractual partnerships that include both us and the other party to act as processors and/or joint controllers for the delivery of projects or activities.  

These third parties may be based in or outside the UK and EU.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.