Data Protection Policy

1.    Introduction

This Policy sets out the obligations of Mac Safety Signs Ltd., a company registered in Ireland under number
475358, whose registered office is at Oldfarm, Williamstown,
Waterford, Ireland.
Ireland (“the Company”) regarding data protection and the rights of customers, business contacts and website
visitors (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data
Protection Regulation (“GDPR”).
The GDPR defines “personal data” as any information relating to an
identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be
identified, directly or indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier, or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural, or social identity of that natural person.
This Policy
sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal
data. The procedures and principles set out herein must be followed at all times by the Company, its employees,
agents, contractors, or other parties working on behalf of the Company.
The Company is committed not only to
the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and
fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom
it deals.

2.    The Data Protection Principles

This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any
party handling personal data must comply. All personal data must be:

2.1    Processed lawfully, fairly, and in a transparent manner in
relation to the data subject.
2.2    Collected for specified, explicit, and legitimate
purposes and not further processed in a manner that is incompatible with those purposes. Further processing for
archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
shall not be considered to be incompatible with the initial purposes.
2.3    Adequate,
relevant, and limited to what is necessary in relation to the purposes for which it is processed.
2.4    Accurate and, where necessary, kept up to date. Every reasonable step must be taken to
ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is
erased, or rectified without delay.
2.5    Kept in a form which permits identification of
data subjects for no longer than is necessary for the purposes for which the personal data is processed.
Personal data may be stored for longer periods insofar as the personal data will be processed solely for
archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes,
subject to implementation of the appropriate technical and organisational measures required by the GDPR in order
to safeguard the rights and freedoms of the data subject.
2.6    Processed in a manner that
ensures appropriate security of the personal data, including protection against unauthorised or unlawful
processing and against accidental loss, destruction, or damage, using appropriate technical or organisational
measures.

3.    The Rights of Data Subjects

The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy
indicated for further details):

3.1    The right to be informed (Part 12).
3.2
The right of access (Part 13);
3.3    The right to rectification (Part 14);
3.4    The right to erasure (also known as the ‘right to be forgotten’) (Part 15);
3.5    The right to restrict processing (Part 16);
3.6    The right to data
portability (Part 17);
3.7    The right to object (Part 18).

4.    Lawful, Fair, and Transparent Data Processing

4.1    The GDPR seeks to ensure that personal data is processed
lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states
that processing of personal data shall be lawful if at least one of the following applies:

4.1.1    The data subject has given consent to the processing of their
personal data for one or more specific purposes;
4.1.2    The processing is necessary for the
performance of a contract to which the data subject is a party, or in order to take steps at the request of the
data subject prior to entering into a contract with them;
4.1.3    The processing is
necessary for compliance with a legal obligation to which the data controller is subject;
4.1.4
The processing is necessary to protect the vital interests of the data subject or of another natural
person;
4.1.5    The processing is necessary for the performance of a task carried out in the
public interest or in the exercise of official authority vested in the data controller; or
4.1.6
The processing is necessary for the purposes of the legitimate interests pursued by the data controller or
by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data
subject which require protection of personal data, in particular where the data subject is a child.

4.2    If the personal data in question is “special category data”
(also known as “sensitive personal data”) (for example, data concerning the data subject’s race, ethnicity,
politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or
sexual orientation), at least one of the following conditions must be met:

4.2.1    The data subject has given their explicit consent to the
processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from
doing so);
4.2.2    The processing is necessary for the purpose of carrying out the
obligations and exercising specific rights of the data controller or of the data subject in the field of
employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law
or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the
fundamental rights and interests of the data subject);
4.2.3    The processing is necessary
to protect the vital interests of the data subject or of another natural person where the data subject is
physically or legally incapable of giving consent;
4.2.4    The data controller is a
foundation, association, or other non-profit body with a political, philosophical, religious, or trade union
aim, and the processing is carried out in the course of its legitimate activities, provided that the processing
relates solely to the members or former members of that body or to persons who have regular contact with it in
connection with its purposes and that the personal data is not disclosed outside the body without the consent of
the data subjects;
4.2.5    The processing relates to personal data which is clearly made
public by the data subject;
4.2.6    The processing is necessary for the conduct of legal
claims or whenever courts are acting in their judicial capacity;
4.2.7    The processing is
necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be
proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide
for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;
4.2.8    The processing is necessary for the purposes of preventative or occupational medicine,
for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or
social care or treatment, or the management of health or social care systems or services on the basis of EU or
EU Member State law or pursuant to a contract with a health professional, subject to the conditions and
safeguards referred to in Article 9(3) of the GDPR;
4.2.9    The processing is necessary for
public interest reasons in the area of public health, for example, protecting against serious cross-border
threats to health or ensuring high standards of quality and safety of health care and of medicinal products or
medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to
safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or
4.2.10    The processing is necessary for archiving purposes in the public interest, scientific
or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on
EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to
data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the
interests of the data subject.

5.    Specified, Explicit, and Legitimate Purposes

5.1    The Company collects and processes the personal data set out in
Part 21 of this Policy. This includes:

•    Personal data collected directly from data subjects; and
•    Personal data obtained from third parties.

5.2    The Company only collects, processes, and holds personal data
for the specific purposes set out in Part 21 of this Policy (or for other purposes expressly permitted by the
GDPR).
5.3    Data subjects are kept informed at all times of the purpose or purposes for
which the Company uses their personal data. Please refer to Part 12 for more information on keeping data
subjects informed.

6.    Adequate, Relevant, and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose
or purposes of which data subjects have been informed (or will be informed) as under Part 5, above, and as set
out in Part 21, below.

7.    Accuracy of Data and Keeping Data Up-to-Date

7.1    The Company shall ensure that all personal data collected,
processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the
rectification of personal data at the request of a data subject, as set out in Part 14, below.
7.2    The accuracy of personal data shall be checked when it is collected and at regular
intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will
be taken without delay to amend or erase that data, as appropriate.

8.    Data Retention

8.1    The Company shall not keep personal data for any longer than is
necessary in light of the purpose or purposes for which that personal data was originally collected, held, and
processed.
8.2    When personal data is no longer required, all reasonable steps will be
taken to erase or otherwise dispose of it without delay.
8.3    For full details of the
Company’s approach to data retention, including retention periods for specific personal data types held by the
Company, please refer to our Data Retention Policy.

9.    Secure Processing

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected
against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details
of the technical and organisational measures which shall be taken are provided in Parts 22 to 27 of this Policy.

10.    Accountability and Record-Keeping

10.1    The Company’s Data Protection matters are dealt with the
Operations Director.
10.2    The Company shall keep written internal records of all personal
data collection, holding, and processing, which shall incorporate the following information:

10.2.1    The name and details of the Company, its Data Protection
Officer, and any applicable third-party data processors;
10.2.2    The purposes for which the
Company collects, holds, and processes personal data;
10.2.3    Details of the categories of
personal data collected, held, and processed by the Company, and the categories of data subject to which that
personal data relates;
10.2.4    Details of any transfers of personal data to non-EEA
countries including all mechanisms and security safeguards;
10.2.5    Details of how long
personal data will be retained by the Company (please refer to the Company’s Data Retention Policy); and
10.2.6    Detailed descriptions of all technical and organisational measures taken by the Company
to ensure the security of personal data.

11.    Data Protection Impact Assessments

11.1    The Company shall carry out Data Protection Impact Assessments
for any and all new projects and/or new uses of personal data which involve the use of new technologies and the
processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the
GDPR.
11.2    Data Protection Impact Assessments shall be overseen by the Data Protection
Officer and shall address the following:

11.2.1    The type(s) of personal data that will be collected, held,
and processed;
11.2.2    The purpose(s) for which personal data is to be used;
11.2.3    The Company’s objectives;
11.2.4    How personal data is to be
used;
11.2.5    The parties (internal and/or external) who are to be consulted;
11.2.6    The necessity and proportionality of the data processing with respect to the purpose(s)
for which it is being processed;
11.2.7    Risks posed to data subjects;
11.2.8    Risks posed both within and to the Company; and
11.2.9    Proposed
measures to minimise and handle identified risks.

12.    Keeping Data Subjects Informed

12.1    The Company shall provide the information set out in Part 12.2
to every data subject:

12.1.1    Where personal data is collected directly from data
subjects, those data subjects will be informed of its purpose at the time of collection; and
12.1.2    Where personal data is obtained from a third party, the relevant data subjects will be
informed of its purpose:

a)    if the personal data is used to communicate with the data
subject, when the first communication is made; or
b)    if the personal data is to be
transferred to another party, before that transfer is made; or
c)    as soon as reasonably
possible and in any event not more than one month after the personal data is obtained.

12.2    The following information shall be provided:

12.2.1    Details of the Company including, but not limited to, the
identity of its Data Protection Officer;
12.2.2    The purpose(s) for which the personal data
is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying
that collection and processing;
12.2.3    Where applicable, the legitimate interests upon
which the Company is justifying its collection and processing of the personal data;
12.2.4
Where the personal data is not obtained directly from the data subject, the categories of personal data
collected and processed;
12.2.5    Where the personal data is to be transferred to one or
more third parties, details of those parties;
12.2.6    Where the personal data is to be
transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that
transfer, including but not limited to the safeguards in place (see Part 28 of this Policy for further
details);
12.2.7    Details of data retention;
12.2.8    Details of the
data subject’s rights under the GDPR;
12.2.9    Details of the data subject’s right to
withdraw their consent to the Company’s processing of their personal data at any time;
12.2.10
Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory
authority” under the GDPR);
12.2.11    Where applicable, details of any legal or contractual
requirement or obligation necessitating the collection and processing of the personal data and details of any
consequences of failing to provide it; and

13.    Data Subject Access

13.1    Data subjects may make subject access requests (“SARs”) at any
time to find out more about the personal data which the Company holds about them, what it is doing with that
personal data, and why.
13.2    Employees wishing to make a SAR should do using a Subject
Access Request Form, sending the form to the Company’s Operations Director via email: macsafetysigns@gmail.com or by post: Oldfarm, Williamstown,
Waterford, Ireland. Ireland.
13.3    Responses to SARs shall
normally be made within one month of receipt, however this may be extended by up to two months if the SAR is
complex and/or numerous requests are made. If such additional time is required, the data subject shall be
informed.
13.4    All SARs received shall be handled by the Company’s Operations
Director.
13.5    The Company does not charge a fee for the handling of normal SARs. The
Company reserves the right to charge reasonable fees for additional copies of information that has already been
supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such
requests are repetitive.

14.    Rectification of Personal Data

14.1    Data subjects have the right to require the Company to rectify
any of their personal data that is inaccurate or incomplete.
14.2    The Company shall
rectify the personal data in question, and inform the data subject of that rectification, within one month of
the data subject informing the Company of the issue. The period can be extended by up to two months in the case
of complex requests. If such additional time is required, the data subject shall be informed.
14.3    In the event that any affected personal data has been disclosed to third parties, those
parties shall be informed of any rectification that must be made to that personal data.

15.    Erasure of Personal Data

15.1    Data subjects have the right to request that the Company
erases the personal data it holds about them in the following circumstances:

15.1.1    It is no longer necessary for the Company to hold that
personal data with respect to the purpose(s) for which it was originally collected or processed;
15.1.2    The data subject wishes to withdraw their consent to the Company holding and processing
their personal data;
15.1.3    The data subject objects to the Company holding and processing
their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so)
(see Part 18 of this Policy for further details concerning the right to object);
15.1.4
The personal data has been processed unlawfully;
15.1.5    The personal data needs to
be erased in order for the Company to comply with a particular legal obligation;

15.2    Unless the Company has reasonable grounds to refuse to erase
personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure,
within one month of receipt of the data subject’s request. The period can be extended by up to two months in the
case of complex requests. If such additional time is required, the data subject shall be informed.
15.3    In the event that any personal data that is to be erased in response to a data subject’s
request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is
impossible or would require disproportionate effort to do so).

16.    Restriction of Personal Data Processing

16.1    Data subjects may request that the Company ceases processing
the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the
amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data
in question is not processed further.
16.2    In the event that any affected personal data
has been disclosed to third parties, those parties shall be informed of the applicable restrictions on
processing it (unless it is impossible or would require disproportionate effort to do so).

17. ()
18.    Objections to Personal Data Processing

18.1    Data subjects have the right to object to the Company
processing their personal data based on legitimate interests, direct marketing (including profiling), [and
processing for scientific and/or historical research and statistics purposes].
18.2    Where
a data subject objects to the Company processing their personal data based on its legitimate interests, the
Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate
grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing
is necessary for the conduct of legal claims.
18.3    Where a data subject objects to the
Company processing their personal data for direct marketing purposes, the Company shall cease such processing
immediately.
19.  ()
20.  ()

21.    Personal Data Collected, Held, and Processed

The following personal data is collected, held, and processed by the Company (for details of data retention,
please refer to the Company’s Data Retention Policy):

Type of Data – Purpose of Data
Name See paragraphs 4.1.2, 4.1.3 and 4.1.6
Postal Address See paragraphs
4.1.2, 4.1.3 and 4.1.6
Email address See paragraphs 4.1.2, 4.1.3 and 4.1.6
Telephone Number See
paragraphs 4.1.2, 4.1.3 and 4.1.6
Voice Recording See paragraphs 4.1.2, 4.1.3 and 4.1.6
File notes See
paragraphs 4.1.2, 4.1.3 and 4.1.6
Emails See paragraphs 4.1.2, 4.1.3 and 4.1.6

22.    Data Security – Transferring Personal Data and Communications

The Company shall ensure that the following measures are taken with respect to all communications and other
transfers involving personal data:

22.1    All emails containing personal data must be marked
“confidential”;
22.2    Personal data may be transmitted over secure networks only;
transmission over unsecured networks is not permitted in any circumstances;
22.3    Personal
data may not be transmitted over a wireless network if there is a wired alternative that is reasonably
practicable;
22.4    Personal data contained in the body of an email, whether sent or
received, should be copied from the body of that email and stored securely. The email itself should be deleted.
All temporary files associated therewith should also be deleted;
22.5    Where personal data
is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and
should be waiting by the fax machine to receive the data;
22.6    Where personal data is to
be transferred in hardcopy form it should be passed directly to the recipient; and
22.7
All personal data to be transferred physically, whether in hardcopy form or on removable electronic media
shall be transferred in a suitable container marked “confidential”.

23.    Data Security – Storage

The Company shall ensure that the following measures are taken with respect to the storage of personal data:

23.1    All electronic copies of personal data should be stored
securely using passwords;
23.2    All hardcopies of personal data, along with any electronic
copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or
similar;
23.3    All personal data stored electronically should be backed up daily with
backups stored onsite and offsite. All backups should be encrypted;
23.4    No personal data
should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones),
whether such device belongs to the Company or otherwise and, in the event of such approval, strictly in
accordance with all instructions and limitations described at the time the approval is given, and for no longer
than is absolutely necessary; and
23.5    No personal data should be transferred to any
device personally belonging to an employee and personal data may only be transferred to devices belonging to
agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to
comply fully with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to the
Company that all suitable technical and organisational measures have been taken).

24.    Data Security – Disposal

When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been
made and are no longer needed), it should be securely deleted and disposed of. For further information on the
deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.

25.    Data Security – Use of Personal Data

The Company shall ensure that the following measures are taken with respect to the use of personal data:

25.1    No personal data may be shared informally and if an employee,
agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that
they do not already have access to, such access should be formally requested from the Operations Director;
25.2    No personal data may be transferred to any employees, agents, contractors, or other
parties, whether such parties are working on behalf of the Company or not, without the authorisation of the
Operations Director;
25.3    Personal data must be handled with care at all times and should
not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any
time;
25.4    If personal data is being viewed on a computer screen and the computer in
question is to be left unattended for any period of time, the user must lock the computer and screen before
leaving it; and
25.5    Where personal data held by the Company is used for marketing
purposes, it shall be the responsibility of the Operations Director to ensure that the appropriate consent is
obtained and that no data subjects have opted out, whether directly or via a third-party service such as the
TPS.

26.    Data Security – IT Security

The Company shall ensure that the following measures are taken with respect to IT and information security:

26.1    All passwords used to protect personal data should be changed
regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords
must contain a combination of uppercase and lowercase letters, numbers, and symbols. All software used by the
Company is designed to require such passwords;
26.2    Under no circumstances should any
passwords be written down or shared between any employees, agents, contractors, or other parties working on
behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset
using the applicable method. IT staff do not have access to passwords;
26.3    All software
(including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT
staff shall be responsible for installing any and all security-related updates as soon as reasonably and
practically possible, unless there are valid technical reasons not to do so; and
26.4    No
software may be installed on any Company-owned computer or device without the prior approval of the Operations
Director.

27.    Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding, and
processing of personal data:

27.1    All employees, agents, contractors, or other parties working
on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s
responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy;
27.2    Only employees, agents, sub-contractors, or other parties working on behalf of the
Company that need access to, and use of, personal data in order to carry out their assigned duties correctly
shall have access to personal data held by the Company;
27.3    All employees, agents,
contractors, or other parties working on behalf of the Company handling personal data will be appropriately
trained to do so;
27.4    All employees, agents, contractors, or other parties working on
behalf of the Company handling personal data will be appropriately supervised;
27.5    All
employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall
be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that
relate to personal data, whether in the workplace or otherwise;
27.6    Methods of
collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
27.7    All personal data held by the Company shall be reviewed periodically, as set out in the
Company’s Data Retention Policy;
27.8    The performance of those employees, agents,
contractors, or other parties working on behalf of the Company handling personal data shall be regularly
evaluated and reviewed;
27.9    All employees, agents, contractors, or other parties working
on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the
GDPR and this Policy by contract;
27.10    All agents, contractors, or other parties working
on behalf of the Company handling personal data must ensure that any and all of their employees who are involved
in the processing of personal data are held to the same conditions as those relevant employees of the Company
arising out of this Policy and the GDPR; and
27.11    Where any agent, contractor or other
party working on behalf of the Company handling personal data fails in their obligations under this Policy that
party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or
proceedings which may arise out of that failure.

28.    Transferring Personal Data to a Country Outside the EEA

28.1    The Company may from time to time transfer (‘transfer’
includes making available remotely) personal data to countries outside of the EEA.
28.2
The transfer of personal data to a country outside of the EEA shall take place only if one or more of the
following applies:

28.2.1    The transfer is to a country, territory, or one or more
specific sectors in that country (or an international organisation), that the European Commission has determined
ensures an adequate level of protection for personal data;
28.2.2    The transfer is to a
country (or international organisation) which provides appropriate safeguards in the form of a legally binding
agreement between public authorities or bodies; binding corporate rules; standard data protection clauses
adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory
authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism
(as provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory authority;
or provisions inserted into administrative arrangements between public authorities or bodies authorised by the
competent supervisory authority;
28.2.3    The transfer is made with the informed consent of
the relevant data subject(s);
28.2.4    The transfer is necessary for the performance of a
contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data
subject);
28.2.5    The transfer is necessary for important public interest reasons;
28.2.6    The transfer is necessary for the conduct of legal claims;
28.2.7
The transfer is necessary to protect the vital interests of the data subject or other individuals where
the data subject is physically or legally unable to give their consent; or
28.2.8    The
transfer is made from a register that, under UK or EU law, is intended to provide information to the public and
which is open for access by the public in general or otherwise to those who are able to show a legitimate
interest in accessing the register.

29.    Data Breach Notification

29.1    All personal data breaches must be reported immediately to the
Company’s Operations Director.
29.2    If a personal data breach occurs and that breach is
likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of
confidentiality, discrimination, reputational damage, or other significant social or economic damage), the
Operations Director must ensure that the Information Commissioner’s Office is informed of the breach without
delay, and in any event, within 72 hours after having become aware of it.
29.3    In the
event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described
under Part 29.2) to the rights and freedoms of data subjects, the Operations Director must ensure that all
affected data subjects are informed of the breach directly and without undue delay.
29.4
Data breach notifications shall include the following information:

29.4.1    The categories and approximate number of data subjects
concerned;
29.4.2    The categories and approximate number of personal data records
concerned;
29.4.3    The name and contact details of the Company’s Operations Director (or
other contact point where more information can be obtained);
29.4.4    The likely
consequences of the breach;
29.4.5    Details of the measures taken, or proposed to be taken,
by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse
effects.

30.    Implementation of Policy

This Policy shall be deemed effective as of 15/05/2018. No part of this Policy shall have retroactive effect and
shall thus apply only to matters occurring on or after this date.

1) Your personal data – what is it?

“Personal data” is any information about a living individual which allows them to be identified from that
data (for example a name, photograph, video, email address, or address). Identification can be directly
using the data itself or by combining it with other information which helps to identify a living
individual (e.g. a list of staff may contain personnel ID numbers rather than names but if you use a
separate list of the ID numbers which give the corresponding names to identify the staff in the first
list then the first list will also be treated as personal data). The processing of personal data is
governed by legislation relating to personal data which applies in Ireland including the General Data
Protection Regulation (the “GDPR”) and other legislation relating to personal data and rights.

2) Who are we?

This Privacy Notice is provided to you by Mac Safety Signs Ltd. which is the Data Controller and
the Data Processor for your data. Mac Safety Signs works together with:

  • Other data controllers, e.g. local authorities, public authorities, central government and agencies
    such as Revenue
  • Staff pension providers
  • Former and prospective employers
  • Payroll services providers
  • Recruitment Agencies
  • Credit reference agencies

We may need to share personal data we hold with them so that they can carry out their responsibilities to
the Company. The organisations referred to above will sometimes be “joint data controllers”. This means
we are all responsible to you for how we process your data where for example two or more data
controllers are working together for a joint purpose. If there is no joint purpose or collaboration then
the data controllers will be independent and will be individually responsible to you.

3) Mac Safety Signs will comply with data protection law. This says that the personal data we
hold about you must be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that
    is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept and destroyed securely including ensuring that appropriate technical and security measures are
    in place to protect your personal data to protect personal data from loss, misuse, unauthorised
    access and disclosure.

4) What data do we process?

  • Names, titles, and aliases, photographs.
  • Start date / leaving date
  • Contact details such as telephone numbers, addresses, and email addresses.
  • Where they are relevant to our legal obligations, or where you provide them to us, we may process
    information such as gender, age, date of birth, marital status, nationality, education/work history,
    academic/professional qualifications, employment details, hobbies, family composition, and
    dependants.
  • Non-financial identifiers such as passport numbers, driving licence numbers, vehicle registration
    numbers, taxpayer identification numbers, staff identification numbers, tax reference codes, and
    national insurance numbers.
  • Financial identifiers such as bank account numbers, payment card numbers, payment/transaction
    identifiers, policy numbers, and claim numbers.
  • Financial information such as National Insurance number, pay and pay records, tax code, tax and
    benefits contributions, expenses claimed.
  • Other operational personal data created, obtained, or otherwise processed in the course of carrying
    out our activities, including but not limited to, CCTV footage, vehicle tracking, recordings of
    telephone conversations, IP addresses and website visit histories, logs of visitors, and logs of
    accidents, injuries and insurance claims.
  • Next of kin and emergency contact information
  • 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 and referral
    source (e.g. agency, staff referral))
  • Location of employment or workplace.
  • Other staff data (not covered above) including; level, performance management information, languages
    and proficiency; licences/certificates, immigration status; employment status; information for
    disciplinary and grievance proceedings; and personal biographies.
  • CCTV footage and other information obtained through electronic means such as swipecard records.
  • Information about your use of our information and communications systems.

5) We use your personal data for some or all of the following purposes: –

Please note: We need all the categories of personal data in the list above primarily to allow us to
perform our contract with you and to enable us to comply with legal obligations.

  • Making a decision about your recruitment or appointment.
  • Determining the terms on which you work for us.
  • Checking that you are legally entitled to work in Ireland.
  • Paying you and deducting tax and other contributions.
  • Providing any contractual benefits to you
  • Liaising with your pension provider.
  • Administering the contract we have entered into with you.
  • 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, including decisions about promotions.
  • Conducting grievance or disciplinary proceedings.
  • Making decisions about your continued employment or engagement.
  • Making arrangements for the termination of our working relationship.
  • Education, training and development requirements.
  • Dealing with legal disputes involving you, including accidents at work.
  • Ascertaining your fitness to work.
  • Managing sickness absence.
  • Complying with health and safety obligations.
  • To prevent fraud.
  • To monitor your use of our information and communication systems to ensure compliance with our IT
    policies.
  • To ensure network and information security, including preventing unauthorised access to our computer
    and electronic communications systems and preventing malicious software distribution.
  • To conduct data analytics studies to review and better understand employee retention and attrition
    rates.
  • Equal opportunities monitoring.
  • To undertake activity consistent with our statutory functions and powers including any delegated
    functions.
  • To maintain our own accounts and records;
  • To seek your views or comments;
  • To process a job application;
  • To provide a reference.

Our processing may also include the use of CCTV systems for monitoring purposes.

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

We will only use your personal data when the law allows us to. Most commonly, we will use your personal
data in the following circumstances:

  • Where we need to perform the contract we have entered into with you.
  • Where we need to comply with a legal obligation.

We may also use your personal data in the following situations, which are likely to be rare:

  • Where we need to protect your interests (or someone else’s interests).
  • Where it is needed in the public interest [or for official purposes].

6) How we use sensitive personal data

We may process sensitive personal data relating to staff including, as appropriate:

  • Information about your physical or mental health or condition in order to monitor sick leave and
    take decisions on your fitness for work;
  • Your racial or ethnic origin or religious or similar information in order to monitor compliance with
    equal opportunities legislation;
  • In order to comply with legal requirements and obligations to third parties.

These types of data are described in the GDPR as “Special categories of data” and require higher levels
of protection. We need to have further justification for collecting, storing and using this type of
personal data. We may process special categories of personal data in the following circumstances:

  • In limited circumstances, with your explicit written consent.
  • Where we need to carry out our legal obligations.
  • Where it is needed in the public interest, such as for equal opportunities monitoring or in relation
    to our pension scheme.
  • Where it is needed to assess your working capacity on health grounds, subject to appropriate
    confidentiality safeguards.

Less commonly, we may process this type of personal data where it is needed in relation to legal claims
or where it is needed to protect your interests (or someone else’s interests) and you are not capable of
giving your consent, or where you have already made the information public.

7) Do we need your consent to process your sensitive personal data?

  • We do not need your consent if we use your sensitive personal data in accordance with our rights and
    obligations in the field of employment and social security law.
  • In limited circumstances, we may approach you for your written consent to allow us to process
    certain sensitive personal data. If we do so, we will provide you with full details of the personal
    data 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.

8) Information about criminal convictions

  • We may only use personal data relating to criminal convictions where the law allows us to do so.
    This will usually be where such processing is necessary to carry out our obligations and provided we
    do so in line with our data protection policy.
  • Less commonly, we may use personal data relating to criminal convictions where it is necessary in
    relation to legal claims, where it is necessary to protect your interests (or someone else’s
    interests) and you are not capable of giving your consent, or where you have already made the
    information public.
  • We will only collect personal data about criminal convictions if it is appropriate given the nature
    of the role and where we are legally able to do so. Where appropriate, we will collect personal data
    about criminal convictions as part of the recruitment process or we may be notified of such personal
    data directly by you in the course of you working for us.

9) What is the legal basis for processing your personal data?

Some of our processing is necessary for compliance with a legal obligation. We may also process data if
it is necessary for the performance of a contract with you, or to take steps to enter into a contract.
We will also process your data in order to assist you in fulfilling your role in the council including
administrative support or if processing is necessary for compliance with a legal obligation.

10) Sharing your personal data

Your personal data will only be shared with third parties including other data controllers where it is
necessary for the performance of the data controllers’ tasks or where you first give us your prior
consent. It is likely that we will need to share your data with:

  • Our agents, suppliers and contractors. For example, we may ask a commercial provider to manage our
    HR/ payroll functions , or to maintain our database software;
  • Other data controllers, such as local authorities, public authorities, central government and
    agencies such as Revenue
  • Staff pension providers
  • Former and prospective employers
  • Payroll services providers
  • Recruitment Agencies
  • Credit reference agencies
  • Professional advisors
  • Trade unions or employee representatives

11) How long do we keep your personal data?

We will keep some records permanently if we are legally required to do so. We may keep some other records
for an extended period of time. For example, it is currently best practice to keep financial records for
a minimum period of 6 years to support Revenue audits or provide tax information. We may have legal
obligations to retain some data in connection with our statutory obligations or to defend or pursue
claims. In some cases the law imposes a time limit for such claims (for example 10 years from date of an
accident – The Safety health and Welfare at Work (General Applications Regulation 1993, section 60)). We
will retain some personal data for this purpose as long as we believe it is necessary to be able to
defend or pursue a claim. In general, we will endeavour to keep data only for as long as we need it.
This means that we will delete it when it is no longer needed.

12) Your responsibilities

It is important that the personal data we hold about you is accurate and current. Please keep us informed
if your personal data changes during your working relationship with us.

13) Your rights in connection with personal data

You have the following rights with respect to your personal data:

  1. The right to access personal data we hold on you

At any point you can contact us to request the personal data we hold on you as well as why we have that
personal data, who has access to the personal data and where we obtained the personal data from. Once we
have received your request we will respond within one month.

There are no fees or charges for the first request but additional requests for the same personal data or
requests which are manifestly unfounded or excessive may be subject to an administrative fee.

  1. The right to correct and update the personal data we hold on you

If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will
be updated.

  1. The right to have your personal data erased

If you feel that we should no longer be using your personal data or that we are unlawfully using your
personal data, you can request that we erase the personal data we hold.

When we receive your request we will confirm whether the personal data has been deleted or the reason why
it cannot be deleted (for example because we need it for to comply with a legal obligation).

  1. The right to object to processing of your personal data or to restrict it to certain
    purposes only

You have the right to request that we stop processing your personal data or ask us to restrict
processing. Upon receiving the request we will contact you and let you know if we are able to comply or
if we have a legal obligation to continue to process your data.

  1. The right to data portability

You have the right to request that we transfer some of your data to another controller. We will comply
with your request, where it is feasible to do so, within one month of receiving your request.

  1. The right to withdraw your consent to the processing at any time for any processing of
    data to which consent was obtained

You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).

  1. The right to lodge a complaint

You can lodge a complaint with the appropriate data-protection authority if you have concerns about how
we process your personal data.

14) Transfer of Data Abroad

Any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will
only be placed on systems complying with measures giving equivalent protection of personal rights either
through international agreements or contracts approved by the European Union. Our website is also
accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed
from overseas.

15) Further processing

If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will
provide you with a new notice explaining this new use prior to commencing the processing and setting out
the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior
consent to the new processing, if we start to use your personal data for a purpose not mentioned in this
notice.

16) Changes to this notice

We keep this Privacy Notice For Employees under regular review and we will place any updates on this web
page: https://macsafetysigns.com/data-protection/

All questions, concerns, and other feedback relating to this Policy should be communicated to the
Operations Director.