1.1 Purpose

The purpose of this Personnel Privacy Notice is to ensure an appropriate and consistent approach to protecting personal data used within Ppac. This notice further aims to ensure compliance with the principles of the General Data Protection Regulation 2016 (GDPR) and Data Protection Act 2018 (DPA) with regards to the collection, use, handling, storage and disposal of personal data within Ppac.

1.2 Scope

The privacy notice has been designed to provide an external facing framework for the handling of personal data by Ppac.

1.3 Responsibilities

Within Ppac, Andi Magona, the accountable and responsible member of staff for data protection matters (DPM – Data Protection Manager), has been appointed as being responsible for the implementation and maintenance of Ppac’s Personnel Privacy Notice.

1. External Privacy Notice

Ppac (“Ppac ”, “CLIENT”, “We”, “Us” or “Our”) is a service provider registered at Highland House, 165 The Broadway, Wimbledon, SW19 1NE. This privacy notice explains what we do with your personal data, whether this is in relation to one of our services, using our website or our app on IOS or Android. Specifically, this notice describes how we collect, use and process your personal data in line with our regulatory requirements and personal commitments to safeguarding your privacy rights. This notice applies to website users, Ppac’s suppliers and other individuals whom we may contact during the normal course of business.

2. What Kind of Data Do We Collect?

2.1 Workforce

When you register your data with Ppac for the purposes of ID verification, we process your personal data which may include (but not limited to) your name, contact details and information from your registration. If you interact with our website, use links provided to you, open or forward emails, download applications from the app store or other information from us, we will also collect personal information from those interactions. We may also obtain personal information about you from third parties, including information from government agencies for the purpose of verifying your identity and right to work in the UK,industry trade associations for qualification checks.

2.2 Website Users

If you use our website, we collect personal data such as your IP address and other data about your device in order for you to use our online content. As part of this interaction, we also collect data about your use of our website or apps, such as the pages you view and the duration. In order to effectively run our website, we use cookies to collect this information.

2.3 Clients and Suppliers of Ppac

During the normal course of business with our clients, we collect personal data such as names, job titles and contact details. Through our correspondence with our clients, we also process personal data about the communications we have had with you in relation to the services we are providing, which may include email monitoring.

3. How we use your personal data

3.1 Workforce

We collect your personal data in order to: • Provide you with services; and • Communicate with you. We may use the skilled card registration and the right to work in the UK details you have provided to inform you when your skilled worker card / right to work status is due to expire and will need renewing. This communication is included as part of the service we provide to you and you consent to us obtaining expiration dates on your skilled card / right-to-work status as part of this service. You also consent to reminder email communication being sent when you agree to use our services.

3.2 Website Users

We may use your personal data in order to: • Improve and personalise your user experience when you use our website or applications; and • Provide you with personalised advertising that you receive from us.

3.3 Clients and Suppliers of Ppac

We may use your personal data in order to: • Communicate with you; • Maintain our business relationship and conduct our course of business together; • Fulfil our contractual obligations; and • Establish, exercise or defend legal claims against Ppac.

4. Lawful Basis for Processing your Personal Data

Under the GDPR, we rely on the following lawful basis for processing your personal data. Performance of a contract: In order to perform our obligations under our contractual agreement with you or in order to take steps at your request to enter into a contract with us, it is necessary for Ppac to process your personal data. Meeting our legal obligations: In order to comply with legal or regulatory obligations, we need to process your personal data. Pursuing our Legitimate Interests or those of a third party (client/ contractor, government organisation, industry trade association, client access control/ CRM software,document verification provider) : We may process your data under this lawful basis for a number of reasons, including: • Providing you with our services; • In order to respond to your requests and enquiries; • The optimisation of our user experience and performance of our website; and • Informing you about our services. Consent: In specific circumstances, we may ask for your consent to process your data in scenarios where this is required. This may include where you use our service to move construction sites. Where consent is required for lawful processing, you have the right to withdraw your consent at any time, details on how to do this are outlined below.

5. Sharing your data

In certain circumstances, we will share your personal data with third parties (client/ contractor, government organisation, industry trade association, client access control/ CRM software, document verification provider) in relation to our normal business conduct. If you are a member of the workforce, we may share your personal data with our clients to enable you to work on the site. We may also share your personal data with third parties, who perform services on Ppac’s behalf such as: • Conducting employment reference/background checks; • Undertaking criminal conviction checks (where required); • Verifying your details with third parties (client/ contractor, government organisation, industry trade association, client access control/ CRM software,document verification provider) ; • Development of the service offering; • Providing professional services (e.g. Legal) to us; and • Communicating with you. Where your personal data is shared with third parties, we ensure that there are clear contracts in place that require set standards of confidentiality and data protection. In some instances where our right to work & identify checking service has been used by a worker to move from site to site, we will share the data between the sites to enable the service to work.

6. Retaining your Personal Data

Ppac will only keep your personal data for as long as it is required to fulfil the purpose in which we collected it for, which may be medium or long term, depending on your relationship with us. To determine the appropriate retention period for keeping your personal data, we consider a number of factors including our legal, regulatory, accounting and reporting obligations, as well as the nature of personal data and the potential risk of harm that may result from unauthorised access or use of your personal data.

7. Individual’s Rights

Under European and UK Data Protection Laws you have several rights with respect to the personal data that we process about you. These individuals rights include: • To ask for a copy of your personal information; • To ask for your data to be rectified, restricted or deleted; • To object to the processing of your personal data (where we don’t process your personal data to meet a contractual or other legal requirement); and • The right for us to share (port) this data to another controller. Although where possible we will look to comply with your request, there are scenarios where these rights are limited where they would infringe the rights of a third party (including our rights) or if you ask us to delete information that we are required to keep by law, or have a clear compelling legitimate interest for keeping. We will inform you of any relevant exemptions we are relying upon when we respond to your request.

8. Exercising your rights

To exercise your rights under European and UK law, withdraw your consent, unsubscribe from receiving marketing communications or raise a complaint, you can contact us through: Email: andi.magona@ppac.co.uk Write to us at: PPAC, Highland House, 165 The Broadway, Wimbledon, SW19 1NE If we are unable to resolve your concerns, you have the right to complain to the UK Information Commissioner’s Office who can be contacted through at: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telephone: 0303 123 1113

9. Changes to our Privacy Notice

From time to time, we may make changes to our privacy notice to ensure that it accurately reflects our processing activity. When this occurs, our latest privacy notice will be placed here and updates published on our website to notify you of this. THIS PRIVACY NOTICE WAS LAST UPDATED ON 22 JUNE 2021.