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Privacy Notice

1. What is the purpose of this document?

1.1. This Privacy Notice explains how companies within Dawsongroup PLC’s group of companies  (together, “the Group”, “we”, “our” or “us”) use any personal information that we may collect about  you. The Group includes (inter alia) each of the following direct and indirect subsidiaries of  Dawsongroup PLC: Alexena Limited, Dawsongroup International BV, Dawsongroup International  Limited, Dawsongroup Bus and Coach Limited, Dawsonrentals Iberica,S.L, Dawsongroup  (Ireland), Dawsongroup UK Limited, Dawsongroup Material Handling Limited, Dawsonrentals  (Nederland) BV, Dawsonrentals Polska Sp. Zoo, Dawsongroup Portable Cold Rooms Limited,  Dawsongroup Temperature Control Solutions Limited, Dawsongroup Temporary Kitchens Limited,  Dawsongroup Truck and Trailer Limited, Dawsongroup Vans Limited, Dawsongroup Finance  Limited, Modulfroid Service SARL, Thermobil Mobile Kuhllager GmbH and Ventura Rental Limited.

1.2. The Group is committed to protecting the privacy and security of your personal information. This  privacy notice describes how we collect and use personal information about you during and after  your working relationship with us, in accordance with the General Data Protection Regulation  (“GDPR”). It applies to all current or former employees, workers and contractors.

1.3. The Group company which is named as your employer on your contract of employment is a “data  controller” which means they are responsible for deciding how they 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.

1.4. 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.

2. Data protection principles

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

2.1.1. Used lawfully, fairly and in a transparent way.

2.1.2. Collected only for valid purposes that we have clearly explained to you and not used in any  way that is incompatible with those purposes.

2.1.3. Relevant to the purposes we have told you about and limited only to those purposes. 2.1.4. Accurate and kept up to date.

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2.1.5. Kept only as long as necessary for the purposes we have told you about. 2.1.6. Kept securely.

3. The kind of information we hold about you

3.1. Personal data, or personal information, means any information about an individual from which that  person can be identified. It does not include data where the identity has been removed  (anonymous data). There are “special categories” of more sensitive personal data which require  a higher level of protection.

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

3.2.1. Personal contact details such as name, title, addresses, telephone numbers, and personal  email addresses.

3.2.2. Date of birth.

3.2.3. Gender.

3.2.4. Marital status and dependants.

3.2.5. Next of kin and emergency contact information.

3.2.6. National Insurance number.

3.2.7. Bank account details, payroll records and tax status information.

3.2.8. Salary, annual leave, pension and benefits information.

3.2.9. Start date.

3.2.10. Location of employment or workplace.

3.2.11. Copy of driving licence, if relevant to your job role, or if used for ID purposes.

3.2.12. 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).

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

3.2.14. Compensation history.

3.2.15. Performance information.

3.2.16. Disciplinary and grievance information.

3.2.17. CCTV footage and other information obtained through electronic means. 3.2.18. Information about your use of our information and communications systems. 3.2.19. Photographs.

3.3. We may also collect, store and use the following special categories of more sensitive personal  data about you:

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3.3.1. Information about your race or ethnicity, religious beliefs, sexual orientation and political  opinions.

3.3.2. Trade union membership.

3.3.3. Information about your health, including any medical condition, health and sickness  records.

3.3.4. Genetic information and biometric data.

3.3.5. Information about criminal convictions and offences.

4. How is your personal information collected?

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. 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

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

5.1.1. Where we need to perform the contract we have entered into with you;

5.1.2. Where we need to comply with a legal obligation;

5.1.3. Where it is necessary for our legitimate interests (or those of a third party) and your  interests and fundamental rights do not override those interests.

5.2. The Group will monitor, record, store and use all telephone (including conversations), email or other  communications with you, in order to check any instructions given to us, for training purposes, for the  prevention of crime and/or to improve the quality of our customer service.

6. How we use particularly sensitive personal information

6.1. “Special categories” of particularly sensitive personal information require higher levels of  protection. This information includes the following information: racial or ethnic origin, political  opinions, religious or philosophical beliefs, trade union membership, genetic/biometric data, health,  sex life or sexual orientation.

6.2. In so far as your personal information amounts to special categories of personal data, in addition  to the above, we will most likely use your personal information in the following additional  circumstances:

6.2.1. In limited circumstances, with your explicit written consent.

6.2.2. Where it is necessary for the purposes of carrying out obligations and exercising rights  under employment, social security and social protection law and in line with our data  protection policy.

6.2.3. Where it is necessary to protect your vital interests (in emergency situations).

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6.2.4. Where the processing is necessary for reasons of substantial public interest (such as equal  opportunities monitoring) and in line with our data protection policy.

6.2.5. Where the processing is necessary for the purposes of occupational medicine, medical  diagnosis or for the assessment of your working capacity on health grounds etc. pursuant  to a contract with a health professional.

6.2.6. Where the processing is necessary for the establishment, exercise or defence of legal  claims.

7. Situations in which we will use your personal information

7.1. 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 of our own or those of third  parties***, provided your interests and fundamental rights do not override those interests. We  have indicated by asterisks the purpose or purposes for which we are processing or will process  your personal information, as well as indicating which categories of data are involved.

7.2. The situations in which we will process your personal information are listed below:

7.2.1. Making a decision about your recruitment or appointment which will include obtaining  references from your referees (* and ***).

7.2.2. Determining the terms on which you work for us (* and ** and ***).

7.2.3. Checking you are legally entitled to work in the UK (**).

7.2.4. Paying you and, if you are an employee, deducting tax and National Insurance  contributions (which will include obtaining bank account details from you) (* and **).

7.2.5. Providing the following benefits to you: live cover (*).

7.2.6. Liaising with your pension provider (*).

7.2.7. Administering the contract we have entered into with you (* and ** and ***). 7.2.8. Business management and planning, including accounting and auditing (***).

7.2.9. Conducting performance reviews, managing performance and determining performance  requirements (***).

7.2.10. Making decisions about salary reviews and compensation (* and ** and ***).

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

7.2.12. Gathering evidence for possible grievance or disciplinary hearings (** and ***). 7.2.13. Making decisions about your continued employment or engagement (** and ***). 7.2.14. Making arrangements for the termination of our working relationship (** and ***). 7.2.15. Education, training and development requirements (** and ***).

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

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7.2.17. Ascertaining your fitness to work and considerations of reasonable adjustments (** and *** and we will in addition rely on special category additional conditions 2 and 5 above).

7.2.18. Managing sickness absence (* and ** and *** and we will in addition rely on special  category additional conditions 2 and 5 above).

7.2.19. Complying with health and safety obligations (** and special category additional condition  2 above).

7.2.20. To prevent fraud (** and ***).

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

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

7.2.23. Equal opportunities monitoring (** and *** and special category additional conditions 2 and  4 above).

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

7.4. We will use your particularly sensitive personal information in the following ways:

7.4.1. 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.

7.4.2. 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.

7.4.3. 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.

7.4.4. We will use trade union membership information to pay trade union premiums, register the  status of a protected employee and to comply with employment law obligations.

8. If you fail to provide personal information

8.1. 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).

9. Change of purpose

9.1. 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.

9.2. 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.

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10. Do we need your consent?

10.1. 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.

11. Information about criminal convictions

11.1. We may only use information 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.

11.2. Less commonly, we may use information 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.

11.3. We will only collect information about criminal convictions if it is appropriate given the nature of the  role and where we are legally able to do so.

12. Automated decision-making

12.1. Automated decision-making takes place when an electronic system uses personal information to  make a decision without human intervention. We are allowed to use automated decision-making  in the following circumstances:

12.1.1. Where we have notified you of the decision and given you 21 days to request a re consideration.

12.1.2. Where it is necessary to perform the contract with you and appropriate measures are in  place to safeguard your rights.

12.2. 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.

13. Data sharing

13.1. We may have to share your data with third parties, including third-party service providers and other  entities in the group. We require third parties to respect the security of your data and to treat it in  accordance with the law. We may transfer your personal information outside the EU. If we do,  you can expect a similar degree of protection in respect of your personal information.

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

14.1. 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.

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

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15.1. “Third parties” includes third-party service providers (including contractors and designated  agents) and other entities within our group. The following third-party service providers process  personal information about you for the following purposes:

15.1.1. Advanced Processing Solutions – HR

15.1.2. Wealden – Payroll

15.1.3. Mimecast – email backup

15.1.4. Acronis – IT storage and backup.

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

16.1. 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.

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

17.1. 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.

18. What about other third parties?

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

19. Transferring information outside the EU

19.1. We will not transfer your personal information outside the EU.

20. Data security

20.1. We have put in place measures to protect the security of your information. Details of these  measures are available upon request.

20.2. Third parties will only process your personal information on our instructions and where they have  agreed to treat the information confidentially and to keep it secure.

20.3. 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.

20.4. 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 – how long will you use my information for?

21.1. 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

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whether we can achieve those purposes through other means, and the applicable legal  requirements. We also take into account the limitation periods applicable for making any claims  against us which features in our decision-making on retention.

21.2. 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 our policies.

22. Your duty to inform us of changes

22.1. 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.

23. Your rights in connection with personal information

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

23.1.1. 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.

23.1.2. 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.

23.1.3. 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).

23.1.4. 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.

23.1.5. 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.

23.1.6. Request the transfer of your personal information to another party.

23.2. 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 Richard Bulmer (Group Legal Manager) in writing.

23.3. 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.

23.4. 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.

24. Right to withdraw consent

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24.1. In the limited circumstances where we have relied on your consent for the collection, processing  and transfer of your personal information for a specific purpose (which will be rare), you have the  right to withdraw your consent for that specific processing at any time. To withdraw your consent,  please contact Richard Bulmer (Group Legal Manager). 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.

25. Data protection manager

25.1. We have appointed Richard Bulmer (Group Legal Manager) 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 him. You have the right to make a complaint at any time to the  Information Commissioner’s Office (the “ICO”), the UK supervisory authority for data protection  issues.

26. Changes to this privacy notice

26.1. 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 Richard Bulmer (Group Legal  Manager).