1. Introduction
Communicourt Ltd (“Communicourt”, “we”, “our”, “us”) is committed to protecting and respecting your privacy and ensuring that personal information is handled lawfully, fairly and transparently.
This Privacy Notice explains how we collect, use, store, share and protect personal information when providing our communication support, intermediary, assessment and related services.
This notice has been prepared in accordance with:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- Privacy and Electronic Communications Regulations (PECR)
- Applicable court, safeguarding and regulatory requirements
2. Who We Are
Communicourt Ltd is the data controller responsible for the personal information described within this notice.
Communicourt Ltd
Unit 110, Fort Dunlop
Fort Parkway
Birmingham
B24 9FD
Telephone: 0121 663 0931
Email: admin@communicourt.co.uk
Data Protection Officer
If you have any concerns or questions about how your information is handled, please contact our Data Protection Officer:
Email: dpo@rcigroup.co.uk
3. The Information We Collect
Depending upon the services being provided, we may process the following categories of information.
Personal Information
- Name
- Date of birth
- Address
- Email address
- Telephone number
- Job title
- Organisation details
- Professional registration information
- Case references
- Court references
Special Category Information
Where necessary, we may process information relating to:
- Physical health
- Mental health
- Learning disabilities
- Neurodiversity
- Speech and language needs
- Psychological reports
- Psychiatric reports
- Cognitive functioning
- Ethnicity
- Other information necessary to assess communication needs
We only process special category information where a lawful basis and an appropriate Article 9 condition applies.
Criminal Offence Data
In the course of providing services within the justice system we may process information relating to:
- Criminal allegations
- Investigations
- Charges
- Offences
- Convictions
- Court proceedings
- Sentencing information
- Witness evidence
Such information is processed in accordance with Article 10 UK GDPR and Schedule 1 of the Data Protection Act 2018.
4. How We Obtain Information
We may obtain information from:
- Individuals receiving our services
- Solicitors
- Barristers
- Courts and tribunals
- HMCTS
- Family members
- Appropriate adults
- Healthcare professionals
- Experts instructed by legal representatives
- Commissioners and contracting organisations
- Public authorities
- Recruitment applicants
- Website users
Information may be collected:
- Directly from you
- Through referral forms
- Through assessments
- During meetings or interviews
- Through correspondence
- Via telephone calls
- Through our website
- Through surveys and feedback forms
5. Why We Process Personal Information
We process personal information to:
- Deliver intermediary and communication support services
- Conduct assessments
- Produce reports and recommendations
- Arrange appointments and service delivery
- Communicate with service users and referrers
- Manage contracts
- Recruit and manage employees
- Comply with legal obligations
- Maintain business records
- Protect vulnerable individuals
- Safeguard children and adults at risk
- Prevent fraud and misuse of services
- Defend or establish legal claims
- Improve our services and quality assurance processes
6. Our Lawful Bases for Processing
The lawful basis used will depend upon the service being provided. We may rely upon:
Contract
Where processing is necessary to enter into or perform a contract.
Legal Obligation
Where processing is necessary to comply with legal requirements.
Legitimate Interests
Where processing is necessary for our legitimate interests or those of our clients and service users, provided those interests do not override your rights and freedoms.
Examples include:
- Service administration
- Information security
- Quality assurance
- Business continuity
- Complaints handling
- Record keeping
Vital Interests
Where processing is necessary to protect someone’s life or prevent serious harm.
Consent
Where consent is required by law or appropriate for the activity being undertaken.
Where consent is relied upon, you have the right to withdraw it at any time.
7. Special Category and Criminal Offence Information
Where we process special category information, we may rely on one or more of the following conditions:
- Explicit consent
- Safeguarding of children and adults at risk
- Establishment, exercise or defence of legal claims
- Administration of justice
- Substantial public interest
- Provision of health or social care-related services
- Protection of vital interests
Where criminal offence information is processed, appropriate safeguards are applied in accordance with Schedule 1 of the Data Protection Act 2018.
8. Vulnerable Adults and Children
Many individuals who receive our services may be:
- Children
- Young people
- Vulnerable adults
- People with communication difficulties
- Individuals with cognitive impairments
We are committed to ensuring that personal information relating to vulnerable individuals is handled with additional care and protection.
Where safeguarding concerns arise, we may share information with appropriate organisations if required to protect an individual from harm or where required by law.
9. Who We Share Information With
We only share personal information where necessary and lawful.
Recipients may include:
- Courts and tribunals
- HM Courts & Tribunals Service (HMCTS)
- Solicitors
- Barristers
- Legal representatives
- Commissioners of our services
- Healthcare professionals
- Expert witnesses
- Regulatory bodies
- Law enforcement agencies
- Local authorities
- Safeguarding organisations
- Auditors
- Professional advisers
- IT and software providers
- Cloud hosting providers
We do not sell personal information to third parties.
10. International Transfers
We primarily store and process information within the United Kingdom.
Where personal information is transferred outside the UK, we will ensure that appropriate safeguards are in place, including:
- UK adequacy regulations
- International Data Transfer Agreements (IDTAs)
- Approved contractual safeguards
You may request further details by contacting us.
11. How Long We Keep Information
We retain personal information only for as long as necessary to fulfil the purposes for which it was collected.
Retention periods may vary according to:
- Legal requirements
- Regulatory obligations
- Limitation periods
- Safeguarding requirements
- Contractual commitments
- Operational needs
In many cases service-user records are retained for six years following the conclusion of services. However, different retention periods may apply to particular record categories.
Further information can be requested from us.
12. Security of Your Information
We implement appropriate technical and organisational measures designed to protect personal information against:
- Unauthorised access
- Accidental loss
- Destruction
- Alteration
- Disclosure
- Cybersecurity threats
Measures include:
- Access controls
- Staff confidentiality obligations
- Encryption where appropriate
- Secure hosting
- Monitoring and auditing
- Information governance training
13. Your Rights
Under UK GDPR you may have the right to:
- Be informed
- Access your personal information
- Request correction of inaccurate information
- Request erasure in certain circumstances
- Restrict processing
- Object to processing
- Data portability
- Withdraw consent where applicable
- Object to direct marketing
- Not be subject to solely automated decision-making
Requests can be submitted using the contact details provided in this notice.
14. Direct Marketing
Where we send information about our services, we will do so in accordance with UK GDPR and PECR requirements.
You may opt out of marketing communications at any time by:
- Using the unsubscribe facility provided
- Contacting us directly
We will not use health information, criminal offence information or other special category information for marketing purposes.
15. Cookies and Website Data
Our website uses cookies and similar technologies to:
- Operate the website
- Improve user experience
- Analyse website usage
- Maintain security
Further information is available in our Cookie Policy, including:
- The cookies used
- The purposes of each cookie
- How to manage cookie preferences
Where required by law, we will obtain your consent before placing non-essential cookies on your device.
16. Complaints
If you are unhappy with the way we have handled your information, we would encourage you to contact us in the first instance so we can attempt to resolve your concerns.
You also have the right to complain directly to the Information Commission (IC).
Information Commission
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: Information Commissioner’s Office
Communicourt’s ICO Registration Number is Z3265724.
