This Privacy Notice tells you how we, Marlin Training Ltd, will collect and use your personal data to provide our courses for you.
What’s covered by this Privacy Notice?
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
All data subjects whose personal data is collected, in line with the requirements of the GDPR, have a right to know what data is being collected about them and also have a right to have the information deleted.
Why does Marlin Training Ltd need to collect and store personal data?
In order for Marlin Training Ltd to provide you with training courses we need to collect personal data for correspondence purposes and/or to allow us to provide you our service(s). We are committed to ensuring that the information we collect and use is appropriate for this purpose. Marlin Training Ltd is a company which values its users’ data protection and privacy rights and we have no interest in collecting data beyond what we need to make our service(s) work for you.
If you are going to be contacted by us for marketing purposes, we will not rely solely on this notice, but will always seek an additional confirmation from you that it’s ok to do that.
In general we collect personal data relating to you for specific purposes, with the nature of the data collected depending on your interaction with Marlin Training Ltd.
Our legal basis for the processing of personal data are:
- Article 6.1(a), GDPR, Consent
- Article 6.1(b), GDPR, Contract
- Article 6.1(f), GDPR, Legitimate Interest
Any legitimate interests pursued by us, or third parties we use, are as follows:
- recruitment and Induction of new Candidates
- emergency Contacts for people who work with us, such as employees and contractors for health and safety purposes.
- business Development
- providing accounts on our system to allow you to complete a training course
The special categories of personal data concerned are:
- biometric Data in the form of facial images
- health Data in respect of employees, contractors and other people who work with us
- any special categories of special personal data which any user volunteers while using our systems (for example in a forum or submission)
Will Marlin Training Ltd share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to Marlin Training Ltd in the course of dealing with you. We do this because there are some services, such as our video conferencing facility, which will not work unless we are able to make these transfers. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to deliver the service they provide on our- and of course, your-behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Marlin Training Ltd’s procedures.
If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, or if it is necessary to comply with an employment contract, unless we are legally required to do otherwise.
How will Marlin Training Ltd use the personal data it collects about me?
Marlin Training Ltd will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Marlin Training Ltd maintains a register of its data processes which includes a record of the data retention policy for each type of data collected and is committed to only ever trying to process the minimum amount of data needed. Marlin Training Ltd is required to retain certain information in accordance with the Law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Can I find out the personal data that the organisation holds about me?
Marlin Training Ltd at your request, can confirm what information we hold about you and how it is processed. If Marlin Training Ltd does hold personal data about you, you can request the following information:
- Identity and the contact details of the person or organisation that has determined how and why to process your data.
- Contact details of our data protection officer in the EU, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Marlin Training Ltd or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information. These will rely on measures approved by the EU Commission.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this?
Marlin Training Ltd accepts a request made through our system account while the person making the request is logged in. In certain circumstances Marlin Training Ltd could ask for additional information and the following forms of ID when information on your personal data is requested:
- A colour copy of a Passport, driving licence or National ID Card
Agreeing to these terms is your Consent
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Where consent is required for Marlin Training Ltd to process both standard and sensitive types of personal data, it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used. Agreement with this Privacy Notice and its accompanying terms and conditions (as applicable) (and any Data Processing Agreements, if they apply to you) will be considered to be explicit consent and we will keep a copy of the records of that consent for audit purposes.
You may withdraw consent at any time by contacting the Data Protection Officer.
Please identify your role in relation to Marlin and the data you wish to withdraw consent to be processed.
Marlin Training Ltd will process different forms of personal data for as long as is necessary and proportionate for the purpose for which it has been supplied and will store the personal data for the shortest amount of time possible, taking into account legal and service requirements. For further details on the retention period for any particular type of data, please contact our privacy officer.
Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- right of access – you have the right to request a copy of the information that we hold about you.
- right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- right of portability – you have the right to have the data we hold about you transferred to another organisation.
- right to object – you have the right to object to certain types of processing such as direct marketing.
- right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- right to judicial review: in the event that Marlin Training Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the section named “Complaints” below.
You may make a request directly to the Data Protection Officer using the contact form.
In the event that you wish to make a complaint about how your personal data is being processed by Marlin Training Ltd (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Marlin Training Ltd’s data protection Officer.