Data Privacy Notice
This privacy notice tells you what to expect when Marl Partners LLP (Marlborough) collects personal information. It applies to information we collect about:
- Visitors to our websites;
- Clients & other Persons who use our Services,
- Job applicants and our current and former employees.
Visitors to our Website
When someone visits www.marlborough.com we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site.
This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. Our website will only collect personal data when you fill in a contact form; we will only use such personal data to fulfil your request and either call you or write back to you. We will make it clear when we collect personal information and will explain what we intend to do with it, should our existing arrangements change.
We may collect information about your computer, including your IP address, operating system and browser type, for system administration. This is anonymous statistical data about users’ browsing habits.
You do not need to allow your browser to accept cookies in order to browse much of the website or to access many of our services. Most browsers allow you to turn off the cookie function. If you want to know how to do this please look at the help menu on your browser.
There are also cookies that store basic data on your interactions with WordPress, the CMS running this website.
Our website is powered by TWK. Our website does not operate a search or decision facility, thus no user-specific data is collected by either Marlborough or any third party.
Any information you provide will be held securely and in accordance with the Data Protection Act 1998 and EU Regulation 2016/679 General Data Protection Regulation (“GDPR”). Your personal details will not be disclosed to third parties.
If you provide feedback about the website through a contact form or email address we will only use this information for the purposes intended. You will not receive any subsequent unsolicited communication.
Clients and other Persons who use our Services
Marlborough provides debt advisory services to private equity firms and public and corporate clients across Europe. Information on our services can be found at http://www.marlborough.com
We have gather and hold the details of those who have requested our services in order to abide with a long list of statutory and regulatory provisions, including financial crime prevention.
However, we only use these details to provide the service the person has requested and for other closely related purposes.
We also use third party providers of technology who host cloud and provide IT infrastructure support to us. In some cases, they may store personal data for us. Similarly, third party providers may support our business by providing external support.
When clients agree to use our services, they can cancel or stop using our services as per the applicable product Terms and Conditions.
When you call Marlborough we collect Calling Line Identification (CLI) information. We use this information to help improve its efficiency and effectiveness.
People who Email us
We use Transport Layer Security (TLS) to encrypt and protect email traffic. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.
We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the limits of the law.
Job Applicants, Current and Former Employees
Marlborough is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at email@example.com.
What will we do with the information you provide to us?
All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.
We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
Information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.
The information we ask for is used to assess your suitability for employment. You do not have to provide what we ask for but it might affect your application if you do not.
We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.
You will also be asked to provide equal opportunities information. This is not mandatory information and will not affect your application if you choose not to provide it. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.
We might ask you to participate in assessments; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by Marlborough.
If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of six months. If you say yes, we would proactively contact you should any further suitable vacancies arise.
Conditional Offer of Employment
If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.
You may be required to provide:
Proof of your identity – you will be asked to attend our office with original documents, we will take copies.
Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.
You may be asked to complete a criminal records declaration to declare any unspent convictions.
We may require you to complete an application for a Basic Criminal Record check via the Disclosure and Barring Service, or Access NI, which will verify your declaration of unspent convictions.
We will contact your referees, using the details you provide in your application, directly to obtain references
If we make a final offer, we will also ask you for the following:
Bank details – to process salary payments
Emergency contact details – so we know who to contact in case you have an emergency at work
Membership of a Pension scheme – so we can determine whether you are eligible to join the scheme.
Some roles require a higher level of due diligence and regulatory approval by the Financial Conduct Authority or other regulators may be required. If this is the case, then you will be asked to submit information via the FCA Connect System. The Financial Conduct Authority or relevant regulator/law enforcement agency will be the data controller for this information.
Members of staff must declare if they have any potential conflicts of interest that may exist or arise in the conduct of their employment, the information will be held on your personnel file.
Use of Data Processors
Data processors are third parties who provide elements of our recruitment service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Medical Insurance and other Insurance
???? provides life insurance to our employees in the form of a standard employee benefit. In some situations, your death in service insurance, may require you to disclose personal data of family members, in some cases minors, which you may want to include as beneficiaries of the policies.
The information will be included in your Employee file and made available to the relevant insurance providers.
How long is the information retained for?
If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.
If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.
Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the recruitment process.
Equal opportunities information is retained for 6 months following the closure of the recruitment process whether you are successful or not.
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint if applicable.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide and determine whether a legal or regulatory obligation we may owe to our clients may have been breached. In some cases, we may need to share such data with third parties such as law firms, arbitrators, accountancy and forensic service providers, law enforcement and government agencies such as the Financial Ombudsman Service.
We usually have to disclose the complainant’s identity to the third parties mentioned above. This is inevitable where, for example, the accuracy of a person’s record is in dispute or where an arbitrator, law firm or government agency may be engaged as part of the process of dealing with the Complaint. Generally, is difficult if not impossible, to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure or subject to minimal requirements under financial crime prevention requirements if and when applicable. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
Under the Data Protection Act 1998 and EU Regulation 2016/679 General Data Protection Regulation (“GDPR”); you have rights as an individual which you can exercise in relation to the information we hold about you.
You can read more about these rights here – https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
Marlborough tries to meet the highest standards when collecting and using personal information. We are open to considering suggestions for improving our procedures.
This privacy notice was drafted using simple language to provide a general understanding of Marlborough’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
If you want to make a complaint about the way we have processed your personal information, you can contact us as per contact details below.
Access to Personal Information
Marlborough tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 1998. If we do hold information about you we will:
- give you a description of it;
- tell you why we are holding it;
- tell you who it could be disclosed to; and
- let you have a copy of the information in a durable form.
To make a request to us for any personal information we may hold you need to put the request in writing addressing it to the Data Protection Officer, or writing to the address provided below.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting the Data Protection Officer.
Disclosure of personal information
In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint or make a disclosure to law enforcement agencies, for example, we will need to share personal information with the organisation concerned and with other relevant bodies.
You can also get further information on:
- agreements we have with other organisations for sharing information;
- circumstances where we can pass on personal data without consent for example, to prevent and detect crime;
- our instructions to staff on how to collect, use and delete personal data; and
- how we check that the information we hold is accurate and up to date.
Links to other websites
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 14 May 2018.
How to contact us
Data Protection Officer
21 Sackville Street
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