Privacy Policy


You will be aware that data protection law is changing on 25 May 2018. To make sure that you fully understand how we use your company data, we have updated our Privacy Notice. Please read this or view it online at

This update doesn’t change anything, and you do not need to take any action. We are sending this to keep you informed.


Data Protection Law in the UK and EU will change on 25 May 2018. This notice sets out your rights as a client of Happy Raspberry Ltd, or as a visitor to our website, under the new law.

This privacy notice tells clients and potential clients what to expect when Happy Raspberry Ltd collects, uses, retains and discloses personal information. Personal information is information that (on its own or together with other information) identifies you and is about you. This includes what you tell us about your company and what we learn by having you as a client.

To ensure that we process your personal information fairly and lawfully, this notice informs you:

  • Why we need your personal information;
  • How it will be used;
  • With whom it will be shared; and
  • What rights you have in relation to the personal information we collect.

Within this notice we describe instances where Happy Raspberry Ltd is the “data controller” (the company who decides what personal information is collected and how it is used), and where we direct or commission the processing of personal information by third parties on our behalf to provide or improve our services to you.

There may be situations where Happy Raspberry Ltd processes data on the instruction of another organisation (known as acting as a “data processor”), but in those circumstances our use of data would be governed by that organisation.


Happy Raspberry Ltd recognises the importance of protecting personal and confidential information in all that we do and takes care to meet our legal duties. Happy Raspberry Ltd puts in place all reasonable technical, security and procedural controls required to protect your personal information for the whole of its life, in whatever format we hold that information in.


Your privacy is protected by law, which says that we can use your personal information only if we have a proper reason to do so. This includes sharing it outside Happy Raspberry Ltd. The reasons why Happy Raspberry Ltd may process your personal information are:

  • To fulfil a contract that we have with you;
  • When it is our legal duty;
  • When it is in our legitimate interest;
  • When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information, but this must not unfairly against your rights or freedoms. If we rely on our legitimate interest, we will tell you what that is.

Below is the list of the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are. For further information in relation to the marketing that we undertake, please see the “Marketing” section below.

• To manage our relationship with you.
• To communicate with you about your retainer or services you may have purchased.
• To develop and carry out marketing activities.
• To conduct analysis and develop our services.
• To analyse your reaction to our advertising activity.
• create anonymised look alike audiences for marketing purposes.
• Fulfilling contracts.
• Our legal duty.
• Your consent.
• Our legitimate interests.
• Keeping our records up to date.
• Working out which of our services may interest you and telling you about them.
• Seeking your consent when we need it to contact you.
• Being efficient about how we fulfil our legal and contractual duties.
• To provide you with the services we can offer when clients request assistance.
• To manage how we work with other companies that provide services to us and our clients.
• Fulfilling contracts.
• Our legal duty.
• Our legitimate interests.
• Being efficient about how we fulfil our legal and contractual duties.
• To administer payments relating to client retainers.
• To administer payments relating to specific service(s) provided.
• To administer payments relating to services that we can offer when clients require assistance.
• Fulfilling contracts.
• Our legal duty.
• Our legitimate interests.
• Being efficient about how we fulfil our legal and contractual duties.
• To manage risk for us and for our clients.
• To comply with regulations that apply to us.
• To respond to complaints and seek to resolve them.
• Fulfilling contracts.
• Our legal duty.
• Our legitimate interests.
• Complying with regulations that apply to us.
• Being efficient about how we fulfil our legal and contractual duties.
• To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance and audit.• Our legal duty.
• Our legitimate interests.
• To exercise our rights as set out in agreements or contracts.• Fulfilling contracts


We process personal information to enable us to run Happy Raspberry Ltd, to support the provision of services to clients, to maintain our own accounts and to promote our services.

The types of personal information we use include:

  • Personal dates such as names, addresses, telephone numbers, dates of birth;
  • Your relationship to other individuals e.g. next of kin;
  • Employment details, work or profession details for individuals.
  • Financial details, including payments made to Happy Raspberry Ltd by clients and payments made by Happy Raspberry Ltd to suppliers and employees.
  • Details of how you use our website, and where you have accessed it from;
  • Details of how you interact with us on social media;
  • Details of when you contact us and when we contact you (including voice recordings of telephone calls and copies of written communications such as emails or letters;
  • CCTV images, which are used for building security;
  • Details of which Happy Raspberry Ltd services that you have purchased.
  • Any consents that you have provided in relation to the processing of your information;
  • Details of your use of services offered by Happy Raspberry Ltd.


We may collect your personal information from the following sources:

Personal information you give to us:

  • When you contact Happy Raspberry Ltd (for example by phone, email or letter);
  • In client surveys or any other research activity we may conduct with you;
  • When you use our services;
  • When you update your client information.

Personal Information gathered from our website

  • When you use or access our website.
  • Details obtained from social media;
  • Identifying and contact information from employers (if Happy Raspberry Ltd is contracted to provide all or part of an HRD service with the employer);



We may need to collect personal information by law, or under the terms of a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot provide you with services under your contract or other services that which you may have purchased from us. We will notify you if your choice not to give personal information to us would result in a delay or prevent us from meeting our obligations.

Any personal information that is optional will be clearly marked at the point of collection.


We may share your personal information for some or all of the reasons outlined below:

  • Assisting in verifying your identity;
  • Assessing risks
  • Understanding your requirements;
  • Developing, researching and improving our range of services;
  • Marketing services we believe may be appropriate for you;
  • Training and business analysis;
  • Legal and regulatory requirements;
  • Complaints handling; or
  • Improving customer service.

It some circumstances certain services are provided by third party organisations who collect and use personal information in order to provide those services to you. They are known as “joint data controllers” under data protection law. This means that they have a separate responsibility to protect your personal information and will keep you informed about how your personal information will be used.

Your personal information will only be shared with third party organisations when required (for example for legal obligations or regulatory requirements, in respect of products/services you request as a client of Happy Raspberry Ltd.

These types of organisation are:

  • HM Revenue & Customs, our regulators or other authorities e.g. Equality Commission for NI, Legal Services and or other statutory bodies.

In the usual course of our business, we may use other third party organisations known as “data processors” under data protection law to support the essential delivery of our services. These organisations process your personal information on our behalf.

These types of organisations include:

  • Mailing, SMS messaging, email, and/or print fulfilment organisations (to enable us to communicate with you efficiently);
  • Providers of business services such as auditors, consultants, solicitors, and/or insurers (to enable us to run the company efficiently);
  • Providers of records management services such as secure disposal suppliers, and IT storage providers (to enable us to secure data efficiently);
  • Providers of IT systems or services (to enable us to run Happy Raspberry Ltd efficiently);
  • Market researchers (to help us improve the services we offer);
  • Providers of information management services (to help us learn about our customers);
  • Companies that you ask us to share your personal information with (upon request).

When we share your information with our approved third party providers, our contractual relationship with them prevents them from using your information for any other purpose other than the instructions given to them by us. They may also use their own third party data processors, but they are always required to meet the same legal requirements as Happy Raspberry Ltd does.

Happy Raspberry Ltd will never share or sell your information to external companies/organisations for our own marketing purposes.


We may use your personal information to tell you about relevant products offered by Happy Raspberry Ltd. This is what we mean when we talk about marketing.

We can only use your personal information to send you marketing messages if we have either your consent or a “legitimate interest”. Legitimate interest is defined as when we have a business reason to use your information for marketing purposes (which will not unfairly go against your rights and/or freedoms). We will not market to you based on legitimate interest if you have not told us that you do not want to receive such marketing or are registered on your preference services list.

We have a legitimate interest to:

  • Send you marketing messages about services offered by Happy Raspberry Ltd by post, by email (if you have provided us with an email address;
  • Contact you via telephone to discuss services that you have enquired about or to discuss your current/renewal/extension/termination of contract.

We will seek explicit consent before sending you any other marketing messages.

You can withdraw your consent to send you any other marketing messages.

You can withdraw your consent or ask to stop sending you through any marketing messages at any time. If you want to do so, please contact us by;

  • Write to us at: Happy Raspberry Ltd, 16 Mandeville Street, Portadown, Craigavon, Co Armagh, BT62 3NZ;
  • Emailing mcdowell@happyraspberry.comor telephoning +44 (0) 7802604130.

Please note that if you tell us that you no longer wish to receive marketing from us, you will still receive essential service information such as details to the service(s) currently provided invitations to events and updates to our privacy notice.


We will keep your personal information as long as you remain a client of Happy Raspberry Ltd.

After you stop being a client:

  • We may contact you for a period of up to3 years, unless you have asked us not to send marketing messages to you (see “Marketing” above).
  • We may keep your personal information for up to 8 years for one or more of the following reasons:
  • To respond to questions or complaints;
  • To show that we treated you fairly;
  • To maintain records according to legal requirements and documented business need.
  • We may keep personal information for longer than 8 years if we cannot delete it for legal, regulatory or technical reasons. In such circumstances we will make sure that your privacy is protected and only use it for legal or regulatory purposes.


In order to exercise your rights under data protection law, we will need to verify your identify for your security.

You can contact us by emailing


You can request a copy of your personal information, as well as why we have that personal information, who has access to that personal information and where we got that personal information from at any time. Once we have received your request we will respond within 30 days.


You have the right to question any information that we hold on you that you think is wrong, out of date or incomplete. If you do, we will take reasonable steps to check its accuracy and correct it.

If you need to update your details, you can do so by contacting on the details given above.


You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using your personal information if there is no need for us to keep it. This is known as the “right to object” and the “right to erasure” (or “right to be forgotten”).

We may be able to restrict the use of your personal information so that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it was restricted.

You can ask us to restrict the use of your personal information if:

  • It is not accurate;
  • It has been used unlawfully but you don’t want us to delete it;
  • It is not relevant any more, but you want us to keep it for use in legal claims; or
  • You have already asked us to stop using your personal information, but you are waiting for us to assess your request and confirm whether or not we are permitted to continue using the personal information under the data protection law.

If you want to object to how we use your personal information, or to restrict how we use it, please contact us using the details above.


If you feel that we should no longer be using your personal information, or that we are illegally using your data, you can request that we erase the personal information that we hold on you. When we receive your request, we will confirm whether the personal information has been deleted or we will tell you the reason why it cannot be deleted. There may be legal reasons why we need to keep your personal information.

If you want to request that we erase your personal information, please contact us using the details above.


You have a right to get copies of your personal information from us in a format that can be easily re-used. You can also ask us to pass on your personal information to other organisations. To request this, please contact us using the details above.


If you are not satisfied with our response or believe that we are not processing your personal information in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).


We will regularly review our privacy notice. We will publish any updates on our website and will inform clients by other means of communication e.g. email or letter.



When you contact us, we will need to verify your identity for your security, we may need to ask you to provide further evidence so that we can access your information.

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If you have any questions about this privacy notice or our processing of information, if you wish to raise a complaint on how we have handled your personal information, or you wish to exercise any of the rights set out in this privacy notice, please contact Gillian McDowell or in writing to Happy Raspberry Ltd, 16 Mandeville Street, Portadown, Craigavon, Co Armagh, BT62 3NZ.