Stobbs General Data Protection and Privacy Policy

Schedule 1 Data Protection Policy

1. INTERPRETATION

1.1 Definitions:

Automated Decision-Making (ADM): when a decision is made which is based solely on Automated Processing (including profiling) which produces legal effects or significantly affects an individual. The UK GDPR prohibits Automated Decision-Making (unless certain conditions are met) but not Automated Processing.

Automated Processing: any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.

Company name: Stobbs (IP) Ltd.
Company Personnel: all employees, workers, contractors, agency workers, consultants, directors, members and others.

Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject's wishes by which they, by a statement or by a clear positive action, signify agreement to the Processing of Personal Data relating to them.

Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the UK GDPR. We are the Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.

Criminal Convictions Data: means personal data relating to criminal convictions and offences and includes personal data relating to criminal allegations and proceedings.

Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.

Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programmes involving the Processing of Personal Data.

Data Protection Officer (DPO): the person required to be appointed in specific circumstances under the UK GDPR. Where a mandatory DPO has not been appointed, this term means a data privacy manager or other voluntary appointment of a DPO or refers to the Company data privacy team with responsibility for data protection compliance.

Explicit Consent: consent which requires a very clear and specific statement (that is, not just action).

UK GDPR: the retained EU law version of the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the UK GDPR.

Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person's actions or behaviour.

Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.

Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the UK GDPR.

Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies: separate notices setting out information that may be provided to Data Subjects when the Company collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, employee privacy notices or the website privacy policy) or they may be stand-alone, one-time privacy statements covering Processing related to a specific purpose.

Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.

Related Policies: the Company's policies, operating procedures or processes related to this Data Protection Policy and designed to protect Personal Data.

Special Categories of Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.

2. Introduction

1. 2.1  This Data Protection Policy sets out how Stobbs (IP) Ltd ("we", "our", "us", "the Company") handle the Personal Data of our customers, suppliers, employees, workers and other third parties.

2. 2.2  This Data Protection Policy applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject.

3. 2.3  This Data Protection Policy applies to all Company Personnel ("you", "your"). You must read, understand and comply with this Data Protection Policy when Processing Personal Data on

our behalf and attend training on its requirements. This Data Protection Policy sets out what we expect from you for the Company to comply with applicable law. Your compliance with this Data Protection Policy is mandatory. Related Policies and Privacy Guidelines are available to help you interpret and act in accordance with this Data Protection Policy. You must also comply with all such Related Policies and Privacy Guidelines. Any breach of this Data Protection Policy may result in disciplinary action.

4. 2.4  Where you have a specific responsibility in connection with Processing such as capturing Consent, reporting a Personal Data Breach, conducting a DPIA as referenced in this Data Protection Policy or otherwise then you must comply with the Related Policies and Privacy Guidelines.

5. 2.5  This Data Protection Policy (together with Related Policies and Privacy Guidelines) is an internal document and cannot be shared with third parties, clients or regulators without prior authorisation from the DPO.

3. Scope

1. 3.1  We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times. The Company is exposed to potential fines of up to £17.5 million or 4% of total worldwide annual turnover, whichever is higher and depending on the breach, for failure to comply with the provisions of the UK GDPR.

2. 3.2  All line managers are responsible for ensuring all Company Personnel comply with this Data Protection Policy and need to implement appropriate practices, processes, controls and training to ensure that compliance.

3. 3.3  The DPO is responsible for overseeing this Data Protection Policy and, as applicable, developing Related Policies and Privacy Guidelines. That post is held by Julius Stobbs, and they can be reached at julius.stobbs@iamstobbs.com .

4. 3.4  Please contact the DPO with any questions about the operation of this Data Protection Policy or the UK GDPR or if you have any concerns that this Data Protection Policy is not being or has not been followed. In particular, you must always contact the DPO in the following circumstances:

   1. (a)  if you are unsure of the lawful basis which you are relying on to process Personal Data (including the legitimate interests used by the Company) (see paragraph 5.1);

   2. (b)  if you need to rely on Consent and/or need to capture Explicit Consent (see paragraph 6);

   3. (c)  if you need to draft Privacy Notices (see paragraph 7);

   4. (d)  if you are unsure about the retention period for the Personal Data being Processed (see paragraph 11);

   5. (e)  if you are unsure about what security or other measures you need to implement to protect Personal Data (see paragraph 12.1);

   6. (f)  if there has been a Personal Data Breach (paragraph 13)

7. (g)  if you are unsure on what basis to transfer Personal Data outside the UK (see paragraph 14);

8. (h)  if you need any assistance dealing with any rights invoked by a Data Subject (see paragraph 15);

9. (i)  whenever you are engaging in a significant new, or change in, Processing activity which is likely to require a DPIA (see paragraph 19) or plan to use Personal Data for purposes other than what it was collected for;

10. (j)  if you plan to undertake any activities involving Automated Processing including profiling or Automated Decision-Making (see paragraph 20);

11. (k)  if you need help complying with applicable law when carrying out direct marketing activities (see paragraph 21); or

12. (l)  if you need help with any contracts or other areas in relation to sharing Personal Data with third parties (including our vendors) (see paragraph 22).

4. Personal data protection principles

4.1 We adhere to the principles relating to Processing of Personal Data set out in the UK GDPR which require Personal Data to be:

1. (a)  Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency);

2. (b)  collected only for specified, explicit and legitimate purposes (Purpose Limitation);

3. (c)  adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation);

4. (d)  accurate and where necessary kept up to date (Accuracy);

5. (e)  not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation);

6. (f)  Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality);

7. (g)  not transferred to another country without appropriate safeguards being in place (Transfer Limitation); and

8. (h)  made available to Data Subjects and allow Data Subjects to exercise certain rights in relation to their Personal Data (Data Subject's Rights and Requests).

4.2 We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).

5. Lawfulness, fairness, transparency 5.1 Lawfulness and fairness

2. 5.2  Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject.

3. 5.3  You may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The UK GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.

4. 5.4  The UK GDPR allows Processing for specific purposes, some of which are set out below:

   1. (a)  the Data Subject has given his or her Consent;

   2. (b)  the Processing is necessary for the performance of a contract with the Data Subject;

   3. (c)  to meet our legal compliance obligations;

   4. (d)  to protect the Data Subject's vital interests;

   5. (e)  to pursue our legitimate interests (or those of a third party) for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices.

5. 5.5  You must identify and document the legal ground being relied on for each Processing activity.

6. Consent

1. 6.1  A Controller must only process Personal Data on the basis of one or more of the lawful bases set out in the UK GDPR, which include Consent.

2. 6.2  A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters.

3. 6.3  Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured. Consent may need to be refreshed if you intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented.

4. 6.4  When processing Special Category Data or Criminal Convictions Data, we will usually rely on a legal basis for processing other than Explicit Consent or Consent if possible. Where Explicit Consent is relied on, you must issue a Privacy Notice to the Data Subject to capture Explicit Consent.

5. 6.5  You will need to evidence Consent captured and keep records of all Consents in accordance with Related Policies and Privacy Guidelines so that the Company can demonstrate compliance with Consent requirements.

7. Transparency (notifying Data Subjects)

1. 7.1  The UK GDPR requires Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. The information must be provided through appropriate Privacy Notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them.

2. 7.2  Whenever we collect Personal Data directly from Data Subjects, including for HR or employment purposes, we must provide the Data Subject with all the information required by the UK GDPR including the identity of the Controller and DPO, how and why we will use, Process, disclose, protect and retain that Personal Data through a Privacy Notice which must be presented when the Data Subject first provides the Personal Data.

3. 7.3  When Personal Data is collected indirectly (for example, from a third party or publicly available source), we must provide the Data Subject with all the information required by the UK GDPR as soon as possible after collecting or receiving the data. We must also check that the Personal Data was collected by the third party in accordance with the UK GDPR and on a basis which contemplates our proposed Processing of that Personal Data.

4. 7.4  If you are collecting Personal Data from Data Subjects, directly or indirectly, then you must provide Data Subjects with a Privacy Notice in accordance with our Related Policies and Privacy Guidelines.

8. Purpose limitation

1. 8.1  Personal Data must be collected only for specified, explicit and legitimate purposes. It must not be further Processed in any manner incompatible with those purposes.

2. 8.2  You cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes and they have Consented where necessary.

9. Data minimisation

1. 9.1  Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.

2. 9.2  You may only Process Personal Data when performing your job duties requires it. You cannot Process Personal Data for any reason unrelated to your job duties.

3. 9.3  You may only collect Personal Data that you require for your job duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes.

4. 9.4  You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company's data retention guidelines.

10. Accuracy

1. 10.1  Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.

2. 10.2  You will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any

Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

11. Storage limitation

1. 11.1  Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.

2. 11.2  The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires that data to be kept for a minimum time.

3. 11.3  You must not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.

4. 11.4  You will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all the Company's applicable records retention schedules and policies. This includes requiring third parties to delete that data where applicable.

5. 11.5  You will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice.

12. Security integrity and confidentiality

1. 12.1  Protecting Personal Data

2. 12.2  Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

3. 12.3  We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. You are responsible for protecting the Personal Data we hold. You must implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data. You must exercise particular care in protecting Special Categories of Personal Data and Criminal Convictions Data from loss and unauthorised access, use or disclosure.

4. 12.4  You must follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.

5. 12.5  You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

(a) Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it;

2. (b)  Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed; and

3. (c)  Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.

13. Reporting a Personal Data Breach

1. 13.1  The UK GDPR requires Controllers to notify any Personal Data Breach to the Information Commissioner and, in certain instances, the Data Subject.

2. 13.2  We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.

3. 13.3  If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the person or team designated as the key point of contact for Personal Data Breaches. You should preserve all evidence relating to the potential Personal Data Breach.

14. Transfer limitation

1. 14.1  The UK GDPR restricts data transfers to countries outside the UK to ensure that the level of data protection afforded to individuals by the UK GDPR is not undermined. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country.

2. 14.2  You may only transfer Personal Data outside the UK if one of the following conditions applies:

   1. (a)  the UK has issued regulations confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subject's rights and freedoms;

   2. (b)  appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved for use in the UK, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the DPO;

   3. (c)  the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or

   4. (d)  the transfer is necessary for one of the other reasons set out in the UK GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest.

15. Data Subject's rights and requests

15.1 Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:

1. (a)  withdraw Consent to Processing at any time;

2. (b)  receive certain information about the Controller's Processing activities;

(c) request access to their Personal Data that we hold;

4. (d)  prevent our use of their Personal Data for direct marketing purposes;

5. (e)  ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;

6. (f)  restrict Processing in specific circumstances;

7. (g)  challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;

8. (h)  request a copy of an agreement under which Personal Data is transferred outside of the UK;

9. (i)  object to decisions based solely on Automated Processing, including profiling (ADM);

10. (j)  prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;

11. (k)  be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;

12. (l)  make a complaint to the supervisory authority;

13. (m)  in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine-readable format.

2. 15.2  You must verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade you into disclosing Personal Data without proper authorisation).

3. 15.3  You must immediately forward any Data Subject request you receive to your line manager, the People Team and the DPO.

16. Accountability

1. 16.1  The Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.

2. 16.2  The Company must have adequate resources and controls in place to ensure and to document UK GDPR compliance including:

   1. (a)  appointing a suitably qualified DPO (where necessary) and an executive accountable for data privacy;

   2. (b)  implementing Privacy by Design when Processing Personal Data and completing DPIAs where Processing presents a high risk to rights and freedoms of Data Subjects;

   3. (c)  integrating data protection into internal documents including this Data Protection Policy, Related Policies, Privacy Guidelines or Privacy Notices;

4. (d)  regularly training Company Personnel on the UK GDPR, this Data Protection Policy, Related Policies and Privacy Guidelines and data protection matters including, for example, Data Subject's rights, Consent, legal basis, DPIA and Personal Data Breaches. The Company must maintain a record of training attendance by Company Personnel; and

5. (e)  regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort.

17. Record keeping

1. 17.1  The UK GDPR requires us to keep full and accurate records of all our data Processing activities.

2. 17.2  You must keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects' Consents and procedures for obtaining Consents.

3. 17.3  These records should include, at a minimum, the name and contact details of the Controller and the DPO, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data's retention period and a description of the security measures in place. To create the records, data maps should be created which should include the detail set out above together with appropriate data flows.

18. Training and audit

1. 18.1  We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.

2. 18.2  You must undergo all mandatory data privacy related training and ensure your team undergo similar mandatory training.

3. 18.3  You must regularly review all the systems and processes under your control to ensure they comply with this Data Protection Policy and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.

19. Privacy by Design and Data Protection Impact Assessment (DPIA)

1. 19.1  We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles.

2. 19.2  You must assess what Privacy by Design measures can be implemented on all programmes, systems or processes that Process Personal Data by taking into account the following:

   1. (a)  the state of the art;

   2. (b)  the cost of implementation;

   3. (c)  the nature, scope, context and purposes of Processing; and

   4. (d)  the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing.

19.3 Controllers must also conduct DPIAs in respect to high-risk Processing.

4. 19.4  You should conduct a DPIA (and discuss your findings with the DPO) when implementing major system or business change programs involving the Processing of Personal Data including:

   1. (a)  use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes);

   2. (b)  Automated Processing including profiling and ADM;

   3. (c)  large-scale Processing of Special Categories of Personal Data or Criminal Convictions Data; and

   4. (d)  large-scale, systematic monitoring of a publicly accessible area.

5. 19.5  A DPIA must include:

   1. (a)  a description of the Processing, its purposes and the Controller's legitimate interests if appropriate;

   2. (b)  an assessment of the necessity and proportionality of the Processing in relation to its purpose;

   3. (c)  an assessment of the risk to individuals; and

   4. (d)  the risk mitigation measures in place and demonstration of compliance.

20. Automated Processing (including profiling) and Automated Decision-Making

1. 20.1  Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:

   1. (a)  a Data Subject has Explicitly Consented;

   2. (b)  the Processing is authorised by law; or

   3. (c)  the Processing is necessary for the performance of or entering into a contract.

2. 20.2  If certain types of Special Categories of Personal Data or Criminal Convictions Data are being processed, then grounds (b) or (c) will not be allowed but the Special Categories of Personal Data and Criminal Convictions Data can be Processed where it is necessary (unless less intrusive means can be used) for substantial public interest like fraud prevention.

3. 20.3  If a decision is to be based solely on Automated Processing (including profiling), then Data Subjects must be informed when you first communicate with them of their right to object. This right must be explicitly brought to their attention and presented clearly and separately from other information. Further, suitable measures must be put in place to safeguard the Data Subject's rights and freedoms and legitimate interests.

4. 20.4  We must also inform the Data Subject of the logic involved in the decision making or profiling, the significance and envisaged consequences and give the Data Subject the right to request human intervention, express their point of view or challenge the decision.

5. 20.5  A DPIA must be carried out before any Automated Processing (including profiling) or ADM activities are undertaken.

21. Direct marketing

1. 21.1  We are subject to certain rules and privacy laws when marketing to our customers.

2. 21.2  For example, a Data Subject's prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as "soft opt-in" allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.

3. 21.3  The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information.

4. 21.4  A Data Subject's objection to direct marketing must be promptly honoured. If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.

22. Sharing Personal Data

1. 22.1  Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.

2. 22.2  You may only share the Personal Data we hold with another employee, agent or representative of our group (which includes our subsidiaries and our ultimate holding company along with its subsidiaries) if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions.

3. 22.3  You may only share the Personal Data we hold with third parties, such as our service providers, if:

   1. (a)  they have a need to know the information for the purposes of providing the contracted services;

   2. (b)  sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject's Consent has been obtained;

   3. (c)  the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;

   4. (d)  the transfer complies with any applicable cross-border transfer restrictions; and

   5. (e)  a fully executed written contract that contains UK GDPR-approved third party clauses has been obtained.

23. Changes to this Data Protection Policy

1. 23.1  We keep this Data Protection Policy under regular review.

2. 23.2  This Data Protection Policy does not override any applicable national data privacy laws and regulations in countries where the Company operates.

Schedule 2 Privacy notice for employees, workers and contractors 1. What is the purpose of this document?

1. 1.1  Stobbs is a "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.

2. 1.2  This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

3. 1.3  It is important that you read and retain 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 and what your rights are under the data protection legislation.

2. Data protection principles

3. The kind of information we hold about you

3.1 We will collect, store, and use the following categories of personal information about you:

1. (a)  Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

2. (b)  Date of birth.

3. (c)  Gender.

4. (d)  Marital status and dependants.

5. (e)  Next of kin and emergency contact information.

6. (f)  National Insurance number.

7. (g)  Bank account details, payroll records and tax status information.

8. (h)  Salary, annual leave, pension and benefits information.

9. (i)  Start date and, if different, the date of your continuous employment.

10. (j)  Leaving date and your reason for leaving.

11. (k)  Location of employment or workplace.

12. (l)  Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).

13. (m)  Employment records (including job titles, work history, working hours, holidays, training records and professional memberships).

14. (n)  Compensation history.

15. (o)  Performance information.

16. (p)  Disciplinary and grievance information.

17. (q)  CCTV footage and other information obtained through electronic means such as swipe card records.

18. (r)  Information about your use of our information and communications systems.

19. (s)  Photographs.

20. (t)  Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied.

3.2 We may also collect, store and use the following more sensitive types of personal information:

1. (a)  Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.

2. (b)  Information about your health, including any medical condition, health and sickness records, including:

(i) details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and

(ii) where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.

4. How is your personal information collected?

1. 4.1  We collect personal information about employees, workers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.

2. 4.2  We may also collect personal information from the trustees or managers of pension arrangements operated by a group company.

3. 4.3  We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

5. How we will use information about you

6. Situations in which we will use your personal information

6.1 We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below

1. (a)  Making a decision about your recruitment or appointment.

2. (b)  Determining the terms on which you work for us.

3. (c)  Checking you are legally entitled to work in the UK.

4. (d)  Paying you and, if you are an employee or deemed employee for tax purposes, deducting tax and National Insurance contributions (NICs).

5. (e)  Providing the following benefits to you: private medical, pension, life assurance, cyclescheme, charitable giving, electric car scheme.

6. (f)  Enrolling you in a pension arrangement in accordance with our statutory automatic enrolment duties.

7. (g)  Liaising with the trustees or managers of a pension arrangement operated by a group company, your pension provider and any other provider of employee benefits.

8. (h)  Administering the contract we have entered into with you.

9. (i)  Business management and planning, including accounting and auditing.

10. (j)  Conducting performance reviews, managing performance and determining performance requirements.

11. (k)  Making decisions about salary reviews and compensation.

12. (l)  Assessing qualifications for a particular job or task, including decisions about promotions.

13. (m)  Gathering evidence for possible grievance or disciplinary hearings.

14. (n)  Making decisions about your continued employment or engagement.

15. (o)  Making arrangements for the termination of our working relationship.

16. (p)  Education, training and development requirements.

17. (q)  Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.

18. (r)  Ascertaining your fitness to work.

19. (s)  Managing sickness absence.

20. (t)  Complying with health and safety obligations.

21. (u)  To prevent fraud.

22. (v)  To monitor your use of our information and communication systems to ensure compliance with our IT policies.

23. (w)  To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

24. (x)  To conduct data analytics studies to review and better understand employee retention and attrition rates.

25. (y)  Equal opportunities monitoring.

6.2 Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

7. If you fail to provide personal information

7.1 If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we

may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

8. Change of purpose

1. 8.1  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.

2. 8.2  Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9. How we use particularly sensitive personal information

10. Situations in which we will use your sensitive personal information

10.1 In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process your particularly sensitive personal information are listed below.

1. (a)  We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits including statutory maternity pay, statutory sick pay, pensions and any health insurance.

2. (b)  We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

11. Do we need your consent?

11.1 We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

12. Information about criminal convictions

12.1 We do not envisage that we will hold information about criminal convictions.

13. Automated decision-making

1. 13.1  You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

2. 13.2  We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

14. Data sharing

15. Why might you share my personal information with third parties?

15.1 We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

16. Which third-party service providers process my personal information?

16.1 "Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities may be carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT services.

17. How secure is my information with third-party service providers and other entities in our group?

17.1 All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

18. When might you share my personal information with other entities in the group?

18.1 We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

19. What about other third parties?

1. 19.1  We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

2. 19.2  We may also need to share your personal information with a regulator or to otherwise comply with the law.

20. Data security

20.1 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 will only process your personal information on our instructions and they are subject to a duty of confidentiality.

20.2 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.

21. Data retention

22. How long will you use my information for?

1. 22.1  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.

2. 22.2  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. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

23. Rights of access, correction, erasure, and restriction

24. Your duty to inform us of changes

24.1 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.

25. Your rights in connection with personal information

25.1 Under certain circumstances, by law you have the right to:

1. (a)  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.

2. (b)  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.

3. (c)  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).

4. (d)  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.

5. (e)  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.

6. (f)  Request the transfer of your personal information to another party.

25.2 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 contact the DPO in writing.

26. No fee usually required

26.1 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.

27. What we may need from you

27.1 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

27.2 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 contact the DPO. 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 officer

27.3 We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO).

28. Changes to this privacy notice

28.1 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 privacy notice, please contact the DPO.