Data Protection Policy
Marram Coaching processes your personal data for the purposes discussed in detail below, but the main purposes are to enable us to provide you with services and to comply with our regulatory obligations, specifically:
- For you to engage us and for us to fulfil our services to you, we will need you to consent for your sponsoring organisation to provide us with your contact details. Alternatively, you may provide these directly to us.
- On a professional aspect, we engage with you through a sharing partnership that is based on a consensual relationship.
- When working with you we will maintain the strictest of confidentiality with all your information, and that of your sponsor, unless release of information is required by law.
- We will store, and dispose of, any of your records regarding, including electronic files and communications, in a manner that promotes confidentiality, security and privacy, and complies with all applicable laws and agreements.
- We will have a clear agreement with you and your sponsors about the conditions under which confidentiality will not be maintained (e.g. illegal activity, danger to self or others etc) and gain agreement to that limit of confidentiality where possible.
Who is the Controller?
Due to the services we provide, we are not obliged to appoint a data protection officer. However, you can contact us at any stage if you wish to exercise your rights. Please see the ‘Your Rights’ section below.
How we collect your personal data
In order to provide you with our services, you will need to provide basic information to support the services you use. This will include personal data such as your name, address, email and contact details. Given the nature of our services, you or your sponsor may also provide such information that relates to your job, for example your job title, function and the role/person to whom you report.
Where you contact us, we will process any personal data you provide in these communications.
Finally, we also use “cookies” and similar technologies which may collect certain information about you, such as your devices’ IP addresses and online activity, some of which will constitute your personal data. You can learn more about the cookies we use in the ‘Cookies’ Policy.
How will we use your personal data
In accordance with data protection laws, we will only process your personal data when we have a lawful basis for doing so in respect of your personal data. We process your personal data if: (i) it is necessary to provide services to you under the performance of the contract we have with you; (ii) you have given your consent; or, (iii) it is in our legitimate interests to process your personal data, provided that none of these interests prejudice your own rights, freedoms and interests.
With the exception of limited circumstances, we do not process special categories of personal data about you (such as personal data relating to your health, ethnicity, religion, political persuasion, trade union membership or sexuality). For the circumstances in which we process special categories of personal data, we have set out the additional lawful basis required in italics below.
The following is a list of the purposes for which we process your personal data, and the lawful basis on which it carries out such processing:
|To set-up, administer and manage your account||Necessary for the performance of a contract|
|To provide you with our services (including consensual diagnostic tools))||Necessary for the performance of a contract|
|To perform a meaningful engagement and exchange of information pertaining to the service||Consent|
|To carry out marketing campaigns||Legitimate interests of better understanding the products and services that our clients most enjoy|
|To send offers and promotions relating to our services that you may be interested in||Consent|
|Sharing: To share your personal information with any relevant partners of Marram Coaching who assist in providing the services to clients||Legitimate interests to allow us to provide services|
|Cookies: To operate our websites and mobile applications, including allowing you to interact with our websites and mobile applications and to recall selections as you move between pages||Legitimate interest of using a website with at least standard functionality to provide our services|
|Cookies: To analyse your use of our website, monitor our web audience and populate certain content on our website in line with your usage||Consent|
|Cookies: To track your journey to and from our website so we can understand how clients come to and from our website and give effect to any commercial arrangements||Consent|
|Certain conditions under which confidentiality will not be maintained (e.g. illegal activity, danger to self or others etc)||Public interest i.e. to prevent harm|
Please note that the lawful bases set out above are those which will primarily apply although it is possible that a change in circumstance may result in a change in lawful basis.
We may also disclose your personal data in the following circumstances:
- when required by applicable law or regulation (disclosure to a governmental, regulatory or enforcement authority);
- in order to defend ourselves legally and/or in relation to legal proceedings; and
- whilst negotiating a takeover, purchase or merger, and pursuant to the same.
Security of your personal data is of the utmost importance to Marram. Accordingly, we will take all appropriate security, technical and organisational measures to ensure that your personal data is kept secure and to prevent the theft, loss or unauthorized access to your personal data.
We will store, and dispose of, any records regarding clients, including electronic files and communications, in a manner that ensures confidentiality, security and privacy, and complies with all applicable laws and agreements.
We may perform marketing with organisations that contract with us. Though, we do not target market to individuals we provide our services to.
Social Media Marketing
We do not share personal information in social media articles and posts we may deliver (e.g. LinkedIn, Twitter). In limited circumstances where we request your permission to share personal information, we will only do so with your express consent. You also have the option to withdraw your consent. Please see your rights below.
You can learn more about cookies generally and how to disable them on your browser here.
Retention of your personal data
We retain your personal data for the least amount of time required for our engagement with you as a client and up to a maximum of two years from date of last engagement.
Updating your personal data
You can update your personal data at any time via email at firstname.lastname@example.org. We request that when your personal data changes you let us know as soon as possible.
You have the following rights in relation to your personal data:
- a right to access your personal data. This includes receiving confirmation on whether your personal data is being processed, why it is being processed and the personal data being processed.
- a right to rectification of inaccurate personal data or updating of incomplete personal data.
- a right to erasure (also known as the right to be forgotten) of personal data under certain circumstances, including where you (i) withdraw consent previously provided, (ii) object to Marram’s processing for its own legitimate interests or (iii) where Marram’s processing of the personal data is unlawful. In the case of unlawful processing, you may request that this processing is restricted rather than the personal data being erased.
The below rights are available to you. However, they are not applicable to the processing we perform;
- a right to data portability i.e. to receive your personal data in a portable format or, subject to it being technically feasible, have us transfer your personal data directly to a third party. This right applies where processing is taking place based on consent or for the performance of a contract.
- a right to object to the processing of personal data, where such processing is being conducted for the purpose of (a) direct marketing; (b) establishing, exercising or defending ourselves or others from legal claims; or (c) Our legitimate interests where we cannot demonstrate its interests override your interests and rights. Please note, restriction on processing may be requested while an investigation of legitimate interests takes place. You shall have the right to obtain from the controller restriction of processing in limited circumstances
- a right not to be subject to decisions taken solely on the basis of automated processing of personal data of an individual (i.e. no human involvement in the decision) which produce legal effects or have similarly significant effects unless permitted by law.
If you are unsure about your rights or are concerned about how your personal data may be processed, you should contact us on email@example.com
If you would like to exercise any of your rights then you can do so by contacting us at firstname.lastname@example.org. Please be aware that while we will try to accommodate any request you make in respect of your rights, they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.
When you make a request in respect of your rights, we will require proof of identification. We may also ask that you clarify your request. We will aim to respond to any request within one month of verifying your identity, but it may take longer (we will notify you if this is the case). If we receive repeated requests, or have reason to believe requests are being made unreasonably, we reserve the right not to respond.
If you have any complaints you have the right to contact your own national data protection supervisory authority however we do ask that you contact us in the first instance to allow us the opportunity to address your concerns.
If you have any questions regarding our use of your personal data, or you would like to exercise any of your rights, please contact Marram at email@example.com
Policy last revised: 22nd February 2022