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Privacy Policy

Independent Migrant Services
Last Updated: November 2025
ICO Registration Number: ZB346410

1. Introduction

Independent Migrant Services ("we", "us", "our") is committed to protecting the privacy and security of your personal information. This privacy policy explains how we collect, use, and safeguard your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

We are registered with the Information Commissioner's Office (ICO) under registration number ZC051175.

Contact Details:
Independent Migrant Services
Email: info@independentmigrantservices.co.uk
Website: www.independentmigrantservices.com

If you have any questions about this privacy policy or how we handle your data, please contact us using the details above.

2. Information We Collect

We collect and process different types of personal information depending on how you interact with our services:

2.1 Website Visitors

When you visit our website, we may collect:

  • Email address and name (if you complete our contact form)

  • Payment and billing information (if you purchase templates or services)

  • Technical information collected automatically through Wix analytics, including IP address, browser type, device information, and pages visited

2.2 Training Participants

For individuals attending our training services, we collect:

  • Name and contact details

  • Professional role and organization

  • Training attendance records and completion certificates

  • Feedback and evaluation responses

2.3 Assessment Clients

When we conduct age assessments or provide consultancy services to local authorities, legal firms, or other organizations, we process:

  • Client organization contact details

  • Contractual and billing information

  • Project-specific information necessary to deliver our services

2.4 Assessment Subject Data

In the course of conducting age assessments for unaccompanied asylum-seeking children (UASC), we process special category personal data, including:

  • Biographical information and personal history

  • Information about ethnicity, national origin, and immigration status

  • Health information relevant to age assessment

  • Information about trauma, safeguarding concerns, and welfare needs

  • Photographic records and physical observations

  • Interview notes and professional assessments

  • Information from third-party sources (e.g., medical records, educational records, previous assessments)

This information is provided to us by our clients (local authorities, legal representatives) and collected during the assessment process.

3. How We Use Your Information

3.1 Website Contact Form and Purchases

Legal Basis: Legitimate interests and contractual necessity

We use your email address and contact details to:

  • Respond to your inquiries about our services

  • Process purchases of templates and resources

  • Provide customer support

  • Send you information you have requested

3.2 Training Services

Legal Basis: Contractual necessity and legitimate interests

We use training participant data to:

  • Deliver training services

  • Provide certificates of attendance and completion

  • Improve our training content and delivery

  • Maintain attendance records for professional standards

3.3 Age Assessments and Consultancy

Legal Basis: Contractual necessity, legal obligation, and legitimate interests

We process assessment data to:

  • Conduct Merton-compliant age assessments as instructed by our clients

  • Provide expert opinion and professional reports for legal proceedings

  • Fulfill our professional duties as registered social workers

  • Comply with court orders and legal requirements

  • Support safeguarding and child protection processes

Special Category Data - Additional Legal Basis: We process special category data (ethnicity, health information, etc.) under Article 9(2)(f) UK GDPR - processing necessary for legal claims - and Article 9(2)(g) - processing necessary for reasons of substantial public interest, specifically safeguarding children and individuals at risk.

3.4 Website Analytics

Legal Basis: Legitimate interests

We use Wix's built-in analytics to understand how visitors use our website, which helps us improve user experience. This involves automated collection of technical data such as IP addresses, browser types, and navigation patterns.

4. Who We Share Your Information With

We do not sell or rent your personal information to third parties. We may share your information only in the following circumstances:

4.1 Professional Service Providers

  • Wix.com - our website hosting platform (subject to their privacy policy)

  • Payment processors - for secure handling of transactions when you purchase templates

  • Professional indemnity insurers - if required in connection with a claim

4.2 Legal and Court Proceedings

Assessment reports and related data are shared with:

  • Courts and tribunals as part of legal proceedings

  • Local authorities who commissioned the assessment

  • Legal representatives acting for the young person or local authority

  • Other professionals involved in the case (with appropriate legal basis)

4.3 Legal Obligations

We may disclose your information where required by law, court order, or to comply with regulatory requirements, including:

  • Safeguarding disclosures where there is risk of harm

  • Compliance with social work professional standards

  • Responding to legitimate requests from regulatory authorities

4.4 Subcontractors

Where we engage other qualified social work professionals to conduct assessments on behalf of Independent Migrant Services, we ensure they are bound by equivalent confidentiality and data protection obligations.

5. How We Protect Your Information

We take the security of your personal information seriously and implement appropriate technical and organizational measures, including:

  • Encryption: Assessment files and sensitive documents are stored on encrypted, password-protected systems

  • Access controls: Only authorized personnel have access to personal data, limited to what is necessary for their role

  • Secure storage: Assessment records are stored on secure local systems with regular backups

  • Confidentiality: All staff and contractors are bound by professional duties of confidentiality

  • Secure transmission: When sharing assessment reports, we use secure methods such as encrypted email or secure file transfer

While we take all reasonable precautions, please be aware that no method of electronic transmission or storage is 100% secure.

6. How Long We Keep Your Information

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal and professional obligations.

6.1 Website Inquiries and Purchases

  • Contact form inquiries: 2 years from last contact

  • Purchase records: 7 years (to comply with tax and accounting requirements)

6.2 Training Records

  • Attendance records and certificates: 7 years from training date

6.3 Assessment Records

Assessment files contain information that may be relevant to ongoing legal proceedings and future safeguarding decisions. We retain assessment records in line with professional best practice and legal requirements:

  • Active case files: Retained until conclusion of legal proceedings, plus 7 years

  • Completed assessments: Minimum 7 years from completion, or until the young person reaches age 25 (whichever is longer)

  • Court-ordered assessments: Retained in accordance with court requirements and legal advice

Retention periods may be extended where:

  • Legal proceedings are ongoing or anticipated

  • The assessment is subject to review or challenge

  • Retention is required by law or court order

  • There are ongoing safeguarding concerns

After the retention period expires, records are securely destroyed.

7. Your Rights

Under UK GDPR, you have the following rights regarding your personal data:

7.1 Right of Access

You can request a copy of the personal information we hold about you.

7.2 Right to Rectification

You can request that we correct inaccurate or incomplete information.

7.3 Right to Erasure

You can request deletion of your personal data in certain circumstances. However, this right is limited where:

  • We are required to retain information for legal proceedings

  • Retention is necessary to comply with legal obligations

  • The information forms part of court records or legal files

  • Deletion would prejudice safeguarding or child protection purposes

7.4 Right to Restrict Processing

You can request that we limit how we use your data in certain circumstances.

7.5 Right to Data Portability

You can request to receive your data in a structured, commonly used format.

7.6 Right to Object

You can object to processing based on legitimate interests. We will stop processing unless we have compelling legitimate grounds that override your interests.

7.7 Rights Related to Automated Decision-Making

We do not use automated decision-making or profiling.

Important Note for Assessment Subjects: While you have rights over your personal data, these rights may be limited where:

  • The assessment was ordered by a court or tribunal

  • The data is necessary for legal proceedings or establishing legal claims

  • Modification or deletion would undermine the integrity of legal evidence

  • The information is necessary for safeguarding purposes

If you wish to exercise any of these rights, please contact us using the details in Section 1. We will respond within one month of receiving your request.

8. Children's Privacy

Our age assessment services involve processing information about children and young people. When we process data about individuals under 18, we do so:

  • On the instruction of local authorities or legal representatives with lawful authority

  • For the protection and safeguarding of the young person

  • In accordance with our professional duties under social work standards

  • With appropriate security measures for this vulnerable group

We do not collect information directly from children through our website.

9. International Transfers

We do not routinely transfer personal data outside the United Kingdom. In the rare event that international transfer is necessary (for example, if assessment evidence is required by a court in another jurisdiction), we ensure appropriate safeguards are in place in accordance with UK GDPR.

10. Third-Party Websites

Our website may contain links to other websites. This privacy policy applies only to our website and services. We are not responsible for the privacy practices of third-party websites, and we encourage you to review their privacy policies.

11. Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. We will post the updated policy on our website with a revised "Last Updated" date. Significant changes will be communicated through our website or by email where appropriate.

12. Complaints

If you are unhappy with how we have handled your personal information, you have the right to complain to the Information Commissioner's Office (ICO):

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Website: www.ico.org.uk

We would appreciate the opportunity to address your concerns directly before you contact the ICO, so please contact us first if possible.

13. Professional Standards

As a registered social work professional with Social Work England, we are bound by professional codes of conduct and ethical standards regarding confidentiality and data protection. Our handling of personal information complies with:

  • Social Work England's Professional Standards

  • British Association of Social Workers (BASW) Code of Ethics

  • Statutory guidance on age assessments and safeguarding

This privacy policy demonstrates our commitment to protecting your privacy and handling your personal information responsibly and in accordance with the law.

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