What is the purpose of this document?
Marra Ltd is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
It applies to all individuals at clients or potential clients of ours and users of this website and our services in respect of whom we hold personal data. This notice does not form part of any contract to provide services or any other contract. We may update this notice at any time.
Marra Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
The kind of information we may hold 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).
Depending on the circumstances, we may collect, store, and use the following categories of personal information about you:
Next of kin details
Details of visitors to premises for Health and Safety purposes
The above are not exhaustive lists but provide examples of information which we may collect legally.
How may your personal information be collected?
We may collect personal information about potential employees, employees’ clients, individuals at clients or potential clients of ours in a number of different ways such as sales exhibitions, customer orders, sales agreements, via the contact us section on this website, via our website or use of our services, telephone enquiries. We also collect visitor details to our premises for health and safety purposes. Individuals at clients may provide us with their contact details as part of a discussion about our services.
We may also collect personal data which is publicly available on websites. We may use third-party applications which source their data from publicly-available websites.
How we may use information about you
We will only use your personal information when the law allows us to. Most commonly, we may use your personal information in the following circumstances:
1. Where we are taking steps at your request prior to entering into a contract.
2. Where we need to perform a contract which we have entered into with you.
3. Where we need to comply with a legal obligation.
4. Where it is necessary for our legitimate interests to provide services to you (or your employer or a company related to you or those of a third party) and your interests and fundamental rights do not override those interests.
5. To assess your suitability for a role.
We may also use your personal information in the following situations, which are likely to be rare:
Where it is necessary to protect the vital interests of you or another person.
Where it is needed in the public interest or for official purposes.
Situations in which we may use your personal information
We may need the categories of information (in the section ‘The kind of information we hold about you’) for the reasons set out above (‘How we may use information about you’). Primarily this will be where we are taking steps at your request prior to entering into a contract and to perform a contract we have entered into with you (or your employer or a company related to you), and in some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
The situations in which we may process your personal information are listed below. The list below indicates the categories of data which may be involved in processing your personal information (depending on the circumstances).
• Determining or agreeing with you (or your employer or a company related to you) the terms on which we work together
• Administering the contract we have entered into with you ( or your employer or a company related to you)
• Conducting performance reviews, managing performance and determining performance requirements
• Gathering evidence for possible grievance or disciplinary hearings
• Making arrangements for termination of the working relationship
Education, training and development requirements
• For health and safety purposes and complying with health and safety obligations
• To monitor and manage your use of our information, communication and software systems to ensure compliance with our IT policies
• Business management, planning including accounting and auditing
• Management of client accounts
• Management of website traffic and behaviours
• To ensure network and information security
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (or your employer or a company related to you), or we may be prevented from complying with our legal obligations.
Change of purpose
We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may process your personal information without your knowledge or consent where this is required or permitted by law.
We do not use automated decision-making which means we do not make decisions based solely on automated processing.
Disclosure of your personal data
We may have to share your personal data with third parties set out below for the purposes set out under the heading “Situations in which we may use your personal information” above.
• Internal Third Parties,
• External Third Parties,
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
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 notice.
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.
We may transfer your personal data outside the European Economic Area (EEA) depending on your relationship with us.
We may transfer your personal data to Canada who have been deemed adequate in the way they treat personal data status by the European Union, details can be found here
We may also transfer your personal data to the US, however where we do so we transfer to companies that are signed up to the Privacy Shield framework so are deemed to be adequate, details can be found here.
Privacy Shield is not a compulsory registration and if the Company in the US is not signed up to it we ensure there are in place appropriate clauses within contracts to ensure you receive the same level of data protection we provide. Should you require any further information on international transfers specific to your situation please email firstname.lastname@example.org.
There may be occasion where we have to transfer your personal data to a different country that has not been awarded adequacy status, are not signed up to Privacy Shield in the US or we do not have appropriate contracts in place. On these occasions we will only do so if one of the derogations under Article 49 of the General Data Protection Regulation apply.
We have put in place measures to protect the security of your information, for example to backup and protect the integrity of our electronic communications and data storage systems. Details of these measures are available upon request.
Third parties may only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They may only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will only retain your personal information 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.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
In some circumstances you can ask us to delete your data.
Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please write to us at the address below.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please write to us at the address below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Data Protection Administrator
Marilyn Harding has been nominated by the Company to oversee compliance with data protection laws and this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact by email email@example.com 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.
Address for Exercising Your Rights
If you wish to exercise any of your rights listed above please write to
6 James Street,
Newcastle upon Tyne,
Tyne And Wear
and mark it for the attention of the Data Protection Administrator.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. If you have any questions about this data protection / privacy notice, please contact us at firstname.lastname@example.org