Introduction

This Privacy Notice has been produced to better serve those who are concerned with how their ‘Personal Information’ is being used by Global Commissioning. Personal information and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy Notice carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

Our Contact Details

Global has appointed an internal data protection officer for you to contact if you have any questions or concerns about Global’s personal data policies or practices. Global’s data protection officer’s details are below.

Connor Nash

Data Protection Officer

Global Commissioning Limited

Radio House

John Wilson Business Park

Whitstable

Kent

CT5 3QP

cnash@global-cxm.com

+44 (0) 1227 649087

The type of personal information we collect:

We currently collect and process the following information

– Personal Identifiers, contacts and characteristics (for example, name and contact details)

– Images and video recordings captured on-site for site progress monitoring and reporting.

How we collect your data:

We collect personal data in the following ways:

• When you complete a “Contact Us” form on our website, providing name, email address, and phone number to assist with your query.

• When you provide us with feedback on our products or services.

• When images and video footage are captured on-site as part of our routine site progress documentation and health and safety compliance.

When do we collect information:

Global receives personal data from the individual directly. We collect information from you when you fill out a form or enter information on our website. Or provide us with feedback on our products or services.

How do we use your information:

We may use the information we collect from you in the following ways:

• To follow up after correspondence (email or phone enquiries).

• To monitor and document project progress through on-site photography and video recording.

• To ensure health and safety compliance and security.

Site Photography & Video Recording:

How We Use Images and Videos

As part of our site progress monitoring, Global Commissioning Limited may capture photographs and video footage using Insta360 cameras and other recording devices. These images may include individuals who are present on-site at the time of recording.

Legal Basis for Processing:

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing images and video recordings is:

• Legitimate Interest – We capture site progress images to monitor and document project

development, ensure health and safety compliance, and report on site conditions.

How We Inform Individuals:

To ensure transparency, we:

• Display clear signage at site entrances and in recording areas to inform individuals that

photography and video recording are in progress.

• Provide access to this Privacy Notice for further details on how images are used.

How We Store and Protect Images

Captured images and videos are stored securely on restricted-access cloud storage solutions. We implement security measures to prevent unauthorised access, including encryption and access controls.

Processing and Storage of Images:

• When a photo is taken, it is uploaded to the Insta360 software, where faces are blurred automatically to protect identities.

• The original image is then deleted from the recording device to ensure no personal data remains unnecessarily stored.

• Site progress reports containing these images are normally retained for 12 months, after which they are securely deleted unless required for legal or compliance purposes.

Retention Period:

We retain images and videos only as long as necessary for site progress monitoring and compliance purposes. Typically, images are kept for no longer than 14 days unless required for legal or contractual obligations.

Legal Basis for collecting and using your data:

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information are:

– Legitimate Interest

How we store your personal information:

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. However, please note that no data transmission over the Internet is completely secure. Therefore, we cannot guarantee or warrant the security of any information that you provide to us, and you transmit such information to us at your own risk.

Retention of Data:

The Company will retain personal data securely and only in line with how long it is necessary to keep for a legitimate reason. We will then dispose your information by securely removing it from our SharePoint.

If you have any specific queries about how this policy is applied or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact the DPO.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. You can read more about these rights at:

https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

The Data Protection Act gives you the right to access information held about you. You can find out what information we hold about you by making a Subject Access Request under the Act. If we hold personal information about you, we will give you a description of it, tell you why we are holding it and let you have a copy of it.

Your data protection rights:

Under the GDPR data subjects have the following rights:

• The right of access – You have the right to ask us for copies of your personal information.

• The right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

• The right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

• The right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

• The right to object to processing – You have the right to object to the processing of your personal information in certain circumstances

• The right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

If any of the personal information that we hold about you is incorrect or needs updating, or if you want us to delete any personal information, please contact us. We may request that you provide further information and identification to enable us to comply with this request.

Please contact the DPO at:

Connor Nash cnash@global-cxm.com

+44 (0) 1227 649087

Global Commissioning Limited

Radio House

John Wilson Business Park

Whitstable

Kent

CT5 3QP

Third-party disclosure:

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information.

Third-party links:

Our website may contain links to other websites of interest such as Facebook and LinkedIn.

However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Data Breaches:

To be in line with ICO we will take the following responsive action, should a data breach occur, we will notify the ICO and make them aware of the breach within 72 hours. If the breach is likely to result in a high risk of adversely affecting individuals’ rights and freedoms, you must also inform those individuals without undue delay. We will also keep a record of any personal data breaches, regardless of whether you are required to notify.

How to complain:

If you have any concerns about our use of your personal information, you can make a complaint to us at:

Global Commissioning Limited

Radio House

John Wilson Business Park

Whitstable

Kent

CT53QP

Alternatively, you can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s Address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

ICO Helpline Number: 0303 123 1113

Website: https://ico.org.uk/

Changes To This Notice:

If we change our notice, we will post the changes on our website.