Privacy Notice

ENGITIX LIMITED (“THE COMPANY”)

PRIVACY NOTICE

September 2025

This privacy notice explains how we collect, use, store, share, and protect your personal information. It sets out your rights in relation to your data and how you can exercise them. We are committed to ensuring that your privacy is protected and that your personal information is handled in accordance with applicable data protection laws, including the UK GDPR and Data Protection Act 2018.

The Company is a “data 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.

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.

It is important that you read 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.

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
3. Relevant to the purposes we have told you about and limited only to those purposes
4. Accurate and kept up to date
5. Kept only as long as necessary for the purposes we have told you about
6. Kept securely

The Information that we may hold about you

We may collect, store, and use the following categories of personal data about you:

• Personal contact details – name, title, address (and subsequent address changes), telephone numbers, and personal email addresses, next of kin, emergency contact information
• Biographical data – date of birth, gender, marital status and dependents
• Educational data – qualifications
• Financial data – bank account details, payroll records and tax status information
• Recruitment data – CV or cover letter, application from third party sites, interview notes, right to work documents, visa documentation
• Employment records – dates of employment, job titles, work history, working hours, training records, professional memberships, location of workplace
• Compensation data – salary, benefits, bonuses, pension information, other information about your remuneration
• HR data – performance information, disciplinary and grievance information, annual leave records, family leave information, sickness absence records
• Security data – CCTV footage and other information obtained through electronic means
• ID data – driving licence, passport, photographs

We may also collect, store and use more Sensitive Personal Data, also known as “special categories of data” which require a higher level of protection.

• Information about your health, including any medical condition, health and sickness records
• Biometric data (in so far as this is contained in any ID documentation provided to us such as a passport)
• Information about criminal convictions and offences.

How we collect and use your personal data

We collect your personal data in variety of ways during the application and recruitment processes. Much of this data will come directly from you. We may sometimes collect additional data from third parties including former employers with your expressed permission. Whilst you work for us we will collect additional personal data in the course of job related activities.

Most commonly, we will use your personal data

• Where we need to perform the employment or other contract we have entered into with you (e.g. paying you)
• Where we need to comply with a legal obligation (e.g. accounting to HMRC for your tax)
• Where it is necessary for the operation of the business (our legitimate interest) for us to do so and your rights in relation to that personal data are not infringed

We will process your personal data in the following situations

• Making a decision about your recruitment, subsequent promotions or appointment and determining the terms on which you work for us
• Checking you are legally entitled to work in the UK
• Paying you and deducting tax and National Insurance contributions as appropriate
• Providing benefits to you and liaising with your pension provider
• Administration relating to the contract we have entered into with you
• Business management and planning, including accounting and auditing
• Conducting performance reviews, managing performance and determining performance requirements
• Making decisions about salary reviews and compensation.
• Assessing qualifications for a particular job or task
• Gathering evidence for possible grievance or disciplinary hearings
• Making decisions about your continued employment or engagement and for the termination of our working relationship
• Education, training and development requirements
• Dealing with legal disputes involving you, or other employees, workers and contractors
• Ascertaining your fitness to work and/or managing sickness absence
• Complying with health and safety obligations
• To prevent fraud
• To monitor your use of our information and communication systems
• To conduct data analytics studies to review and better understand employee retention and attrition rates
• Equal opportunities monitoring

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason compatible with the original purposes as detailed above. If we need to use your personal data for an unrelated purpose, we will notify you. Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

If you do not provide certain personal data when requested, we may be unable to perform some of our contractual or legal obligations to you such as to ensure the health and safety of our workers.

We may process Sensitive Personal Data in the following limited circumstances:

• Where we need to carry out our legal obligations or exercise rights in relation to your employment with us
• Where it is needed in the public interest, such as for equal opportunities monitoring
• Less commonly, we may process this type of data where it is needed in relation to legal claims, where it is needed to protect your interests or where you have already made the information public

We will use your sensitive personal data in the following ways

• We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws
• We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace, to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits
• To ensure meaningful equal opportunity monitoring and reporting
• We will use information about your trade union membership in connection with matters in the workplace which either require the involvement of the union or in which you request union involvement

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

Automated Decision Making

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.

Sharing data

We will share your personal data with third parties (including our payroll partner) where required by law, or situations where you have agreed to do so, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. For example when booking travel arrangements or attendance at conferences etc.

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

All our third-party service providers are required to take appropriate security measures to protect your personal data in line with our Data Protection Policy and Information Security Policies. We do not allow our third-party service providers to use your personal data for their own purposes. We will only permit them to process your personal data for specified purposes and in accordance with our instructions.

Transfer outside the EU

We may transfer the personal data we collect about you outside the EU in order to perform our contract with you. Only limited data will be transferred, such as to facilitate travel, meetings with clients, contacts and agents or to attend events and conferences etc.

However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measure[s] to ensure that your personal information is treated by those third parties in a way that is consistent with, and which respects the EU and UK laws on data protection.

Security

We have put in place appropriate data security measures to protect the security of your information and prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. 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.

Retaining data

We will only retain your personal data for a reasonable period and in accordance with our data retention policies in place, and to fulfil the purposes we collected it for including for the purposes of satisfying any legal, accounting, or reporting requirements. We currently retain employee personal data for a period of 7 years from the end of employment before we securely destroy it in accordance with our data retention policy.

Your rights

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact the Head of of People and Culture. Depending on the circumstances, we may need to request ID to confirm your identity before processing your request. We may also charge a reasonable fee if your request for access is excessive. Alternatively, we may refuse to comply with the request in such circumstances.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data 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 Ciara McGrath, Director of People and Culture and Operations.

Changes to this privacy notice

This notice does not form part of your contract of employment. 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 data.

If you have any questions about this privacy notice, please contact the HR and Operations teams.